Agenda packet, first session — East Palo Alto City Council, March 3, 2026 (part 1 of 4)

EAST PALO ALTO CITY COUNCIL

REGULAR SESSION AMENDED AGENDA
Tuesday, March 3, 2026, 6:00 PM
EPA Government Center
2415 University Avenue, First Floor
East Palo Alto, CA 94303
NOTICE
This meeting will be held virtually and in- person at the Council Chambers located on 2415 University Ave, First Floor East Palo Alto, CA 94303. The virtual portion of this City Council meeting will be conducted in accordance with City of East Palo Alto Resolution adopted pursuant to Assembly Bill 361.

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International numbers available: https://zoom.us/u/aMWYF4KT East Palo Alto City Council March 3, 2026 Agenda
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1. CALL TO ORDER AND ROLL CALL

2. APPROVAL OF THE AGENDA

3. APPROVAL OF CONSENT CALENDAR

3.1 Authorize the Salary Adjustment of the Community and Economic Development Director
Recommendation: Adopt a resolution approving the Publicly Available Compensation Schedule for FY 2025-26.

4. CLOSED SESSION

5. PUBLIC COMMENT

6. INFORMATIONAL REPORTS

6.1 City Council Strategic Priorities Fiscal Years (FY) 2025-27 Work Plan - Second Quarter Status Update
Recommendation: Receive a second quarter update on the City Council Strategic Priorities FY 2025-27 Work Plan.

6.2 Informational report regarding February 23, 2026, Almanac News Article Concerning Former On-Call Temporary Employee Rafael Prado Caballero Recommendation: Receive an informational report from staff regarding February 23, 2026 Almanac News Article Concerning Former On-Call Temporary Employee Rafael Prado Caballero

7. SPECIAL PRESENTATIONS

8. PUBLIC HEARINGS

8.1 Appeal of a Decision by the Planning Commission to Not Approve Two Separate Applications to Develop 1675 Bay Road (Townhome and Mixed Use)
Recommendation:

1. By motion, approve the appeal, and adopt two resolutions:
a. Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners Townhomes Residential Project (Design Review Permit: DR25-004)
and Finding that the University and Bay at 4 Corners Townhomes Residential Project is exempt from the California Environmental Quality Act (CEQA) pursuant to Public Resources Code
Section 21080.66.

East Palo Alto City Council March 3, 2026 Agenda
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b. Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007) and Finding that the University and Bay at 4 Corners – Mixed-Use Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66.

2. Or alternatively, by motion, deny the appeal, and direct staff to return with a resolution for adoption supporting the denial

8.2 Ordinance Adopting 2026 California Building Standards Code, Adopting Reach Codes for Existing Buildings, and Ratifying Ordinance No. 59- 2025 of the 2025 District Fire Prevention Code
Recommendation:

1. Waive the first reading and introduce an ordinance to amend various sections and provisions of the East Palo Alto Municipal Code, including:

15. Chapters 15.04, 15.08, 15.10, 15.11, 15.12, 15.15, 15.16, 15.20,

15.25, 15.32, 15.58 to adopt by reference the 2025 California Building Standards Code, including the following 2025 California Codes and specified appendices: Administrative Code; Building Code volumes 1 and 11; Residential Code; Electrical Code; Mechanical Code; Plumbing Code; Energy Code; Historical Building Code; Existing Building Code; Green Building Standards Code; and Fire Code;

16. Chapter 15.58 to adopt and ratify local amendments set forth in Menlo Park Fire Protection District Ordinance No. 59-2025;

17. Chapter 15.32 pertaining to dangerous buildings;

18. Chapter 15.25 (Energy Code) of the East Palo Alto Municipal Code to incorporate local amendments herein referred to as Reach Codes, which mandate cost-effective building
requirements, including increasing building efficiency and requiring electric readiness, with findings demonstrating local amendments are reasonably necessary; and

19. Make any necessary conforming amendments, as the
Council deems necessary.

2. Find that the proposed action is exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines sections 15061(b)(3), 15308, and 15183.

9. POLICY AND ACTION

9.1 University Avenue Grand Corridor Project Corridor Vision Recommendation: Receive a presentation on the University Avenue Grand Corridor Project and provide feedback on a preferred University Avenue Grand Corridor concept.

East Palo Alto City Council March 3, 2026 Agenda
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9.2 Discuss Ordering the Submission of a Measure on Term Limits for a Future Municipal Election
Recommendation:

Discuss and consider the following regarding term limits:

1. Adopt a Resolution Ordering the Submission of a Measure on Term Limits at the June 2, 2026, Statewide Election and Setting Priorities for Filing Arguments For or Against the Ballot Measure; and

2. Appoint two members to write the argument for and rebuttal against the ballot measure.

10. COUNCIL REPORTS

10.1 Bay Area Urban Eagles 2026 Anniversary & Gala
Recommendation: Receive the report and provide direction regarding Council interest in attendance, recognition, or sponsorship.

11. ADJOURNMENT
Upcoming meetings:

Regular Meeting March 17, 2026 6:00 PM
Council Team Building Session March 14, 2026 9:00 AM
Study Session March 24, 2026 6:00 PM
Regular Session April 7, 2026 6:00 PM
East Palo Alto City Council March 3, 2026 Agenda
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This AGENDA is posted in accordance with Government Code Section 54954.2(a) This Notice of Availability of Public Records: All public records relating to an open session item which are not exempt from disclosure pursuant to the Public Records Act, that are distributed to the majority of the City Council will be available for public inspection at the City Clerk’s Office, 2415 University Avenue, East Palo Alto, CA at the same time that the public records are distributed or made available to the City Council. Such documents may also be available on the East Palo Alto website www.cityofepa.org subject to staff’s ability to post the documents prior to the meeting. Information may be obtained by calling (650) 853-3100.

The City Council meeting packet may be reviewed by the public in the Library or the City Clerk's Office. Any writings or documents pertaining to an open session item provided to a majority of the City Council less than 72 hours prior to the meeting, shall be made available for public inspection at the front counter at the City Clerk's Office, 2ND Floor, City Hall, 2415 University Avenue, East Palo Alto, California 94303 during normal business hours. Information distributed to the Council at the Council meeting becomes part of the public record. A copy of written material, pictures, etc. should be provided for this purpose.

East Palo Alto City Council Chambers is ADA compliant. Requests for disability related modifications or accommodations, aids or services may be made by a person with a disability to the City Clerk's office at (650) 853-3127 no less than 72 hours prior to the meeting as required by Section 202 of the Americans with Disabilities Act of 1990 and the federal rules and regulations adopted in implementation thereof.

DECLARATION OF POSTING
This Notice is posted in accordance with Government Code §54954.2(a) or §54956. Members of the public can view electronic agendas and staff reports by accessing the City website. Under penalty of perjury, this Agenda was posted to the public at least 72 hours prior to the meeting.

POSTED: February 20, 2026
AMENDED: February 27, 2026
ATTEST:

James Colin
City Clerk
East Palo Alto City Council March 3, 2026 Agenda
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CONSENT ITEM 3.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: March 3, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Regina Rubier, Interim Human Resources Manager
SUBJECT: Authorize the Salary Adjustment of the Community and Economic Development Director Recommendation
Adopt a resolution approving the Publicly Available Compensation Schedule for FY 2025-26.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:

Priority: Ensure Our Financial and Organizational Health Background
Compensation consisting of salary and benefits paid to employees of the City of East Palo Alto is governed by the City’s Municipal Code, Personnel Policies and Procedures, negotiated and authorized memoranda of understanding authorized compensation for unrepresented employees. As a member of the California Public Employees’ Retirement System (CalPERS), the City also is subject to applicable provisions of the Public Employee Retirement Law (PERL) referenced in the California Government Code and the California Code of Regulations.

In accordance with East Palo Alto Municipal Code section 2.8.110, and as further codified in the City’s Personnel Policies and Procedures approved by the City Council on August 28, 1985 (Resolution No. 00210), Rule 3.9.01 states that “annually, the City Council shall establish the pay range and steps assigned to each classification in the City service.” The City maintains a Classification and Compensation Schedule inclusive of all authorized employee classifications.

This includes the salary ranges that depict salary steps associated with such authorized classifications.
6 CONSENT ITEM 3.1
In addition to local policy requirements, Title 2 of the California Code of Regulations (C.C.R.) section 570.5 requires the City adopt a publicly available pay schedule for purposes of determining the amount of “compensation earnable” pursuant to California Government Code sections 20630, 20636, and 20636.1. Generally, compensation earnable is calculated using employee payrate and special compensation earned while working for the contracting agency (the City). It is paramount to have a properly adopted and administered pay schedule to assure both transparency and the accuracy of employee retirement benefits.

The City’s Compensation Schedule is required to meet eight criteria contained in 2 C.C.R. section 570.5, including that the schedule must be approved by the governing body (City Council). The schedule must be publicly accessible, and available for auditing purposes for at least five years. The schedule also requires the following: position titles; payrates for each position (ranges or steps); the time bases for how pay is calculated (i.e., hourly, bi-weekly); payrates’ effective dates; and any applicable revision dates. The schedule may not reference another document in lieu of disclosing the payrates.

Analysis
Staff recommends adopting a resolution to adjust the salary range and classification details for the Community and Economic Development Director position. Following the incumbent’s resignation, Human Resources conducted a market compensation analysis. The survey reflects increased competition for qualified candidates in this discipline.

Market findings indicate that comparable agencies offer an annual maximum of approximately $262,641 for similar executive-level classifications. Considering the City’s compensation for other positions in relation to the market, staff recommends establishing a salary range of $197,397 to $249,509 annually.

After establishing the market average and mean for the classification, staff evaluated internal alignment by comparing the recommended salary range to classifications of comparable authority, complexity, and organizational impact within the City’s compensation plan. This internal equity review indicated that the recommended range is appropriately aligned with existing director-level classifications. Pay scale steps for the Community and Economic Development Director position are as follows:

This recommendation maintains internal alignment with other director-level classifications and supports the City Council’s priority of Governance, Organizational Strength, and Fiscal Sustainability.

To remain in compliance with the City compensation ordinance, personnel policies, and CCR section 570.5, staff is presenting the revised FY 2025-26 Annual Compensation Schedule.

A B C D E
197,397 210,425 223,453 236,481 249,509 7
CONSENT ITEM 3.1
Fiscal Impact
No fiscal impact is associated with approval of the schedule.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Environmental
The action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (CEQA), pursuant to CEQA Guideline section 15378 (b)(5), in that it is a government administrative activity that will not result in direct or indirect changes in the environment.

Government Code § 84308
Applicability of Levine Act: No, as the entitlement involves a personnel contract, the Levine Act is not applicable.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Resolution

2. Amended FY 2025-26 Citywide Compensation Schedule
8 RESOLUTION NO. XX– 2026

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

ADOPTING THE AMENDMENT FOR A REVISED COMPENSATION SCHEDULE FOR FISCAL YEAR (FY) 2025-26
WHEREAS, in accordance with East Palo Alto Municipal Code Section 2.80.110 (Compensation plan), the City’s Personnel Policies and Procedures approved by the City Council on August 28, 1985 (Resolution #00210) Rule 3.9.01 states that “annually, the City Council shall establish the pay range and steps assigned to each classification in the City service”; and
WHEREAS, the City maintains a Compensation Schedule inclusive of all authorized employee classifications, which includes the salary ranges that depict salary steps associated with such authorized classifications; and
WHEREAS, as a member of the California Public Employees’ Retirement System (CalPERS), the City also is subject to applicable provisions of the Public Employee Retirement Law (PERL) referenced in the California Government Code and the California Code of Regulations; and
WHEREAS, the City’s Compensation Schedule is required to meet eight criteria contained in 2 C.C.R. §570.5: it must be approved by the governing body (City Council);the schedule must be publicly accessible and available for auditing purposes for at least five years; the schedule is required to include position titles, payrates for each position (ranges or steps), the time bases for how pay is calculated (i.e., hourly, bi-weekly, etc.), payrates’ effective
WHEREAS, to remain in compliance with City compensation ordinance, personnel policies, and 2 CCR §570.5, staff is presenting the amended FY 2025-26 Revised Annual Compensation Schedule.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of East Palo Alto hereby:

1. Finds the foregoing recitals are true and correct, and are incorporated by this action: and

2. Adopts the amended Fiscal Year (FY) 2024-25 Compensation Schedules, which are attached hereto as Attachments A and B and incorporated herein by this reference; and

3. 3. The proposed action is not a “project” within the meaning of the California Environmental Quality Act (CEQA), pursuant to CEQA Guideline section 9 15378(b)(2), in that it is government administrative activity that will not result in direct or indirect changes in the environment.

PASSED AND ADOPTED this 3rd day of March 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Webster Lincoln, Mayor
ATTEST: APPROVED AS TO FORM:

James Colin, City Clerk John D. Lê, City Attorney
10 Accountant I (SEIU)
Step A Step B Step C Step D Step E
Hourly 38.0462 39.9485 41.9459 44.0432 46.2454
Bi-Weekly 3,043.70 3,195.88 3,355.68 3,523.46 3,699.63
Monthly 6,594.68 6,924.41 7,270.63 7,634.16 8,015.87
Annual 79,136.11 83,092.92 87,247.56 91,609.94 96,190.44 Accountant II (SEIU)
Step A Step B Step C Step D Step E
Hourly 42.036 44.1377 46.3446 48.6619 51.095
Bi-Weekly 3,362.88 3,531.02 3,707.57 3,892.95 4,087.60
Monthly 7,286.23 7,650.54 8,033.07 8,434.72 8,856.46
Annual 87,434.78 91,806.52 96,396.84 101,216.69 106,277.52 Accountant Senior (MEA)
Step A Step B Step C Step D Step E
Hourly 51.335 53.9017 56.5968 59.4267 62.398
Bi-Weekly 4,106.80 4,312.14 4,527.75 4,754.13 4,991.84
Monthly 8,898.07 9,342.97 9,810.12 10,300.62 10,815.65
Annual 106,776.79 112,115.63 117,721.41 123,607.48 129,787.85 Account Technician I (SEIU)
Step A Step B Step C Step D Step E
Hourly 31.7903 33.3798 35.0488 36.8012 38.6413
Bi-Weekly 2,543.22 2,670.38 2,803.90 2,944.10 3,091.30
Monthly 5,510.32 5,785.83 6,075.12 6,378.88 6,697.82
Annual 66,123.80 69,429.99 72,901.49 76,546.56 80,373.89

CITY OF EAST PALO ALTO
COMPENSATION SCHEDULE - FY 2025-26
Rates Effective 3/4/2026
11 Account Technician II (SEIU)
Step A Step B Step C Step D Step E
Hourly 34.1746 35.8833 37.6775 39.5613 41.5394
Bi-Weekly 2,733.96 2,870.66 3,014.20 3,164.91 3,323.15
Monthly 5,923.59 6,219.77 6,530.76 6,857.30 7,200.16
Annual 71,083.08 74,637.24 78,369.10 82,287.55 86,401.93 Administrative Assistant (SEIU)
Step A Step B Step C Step D Step E
Hourly 38.1329 40.0395 42.0415 44.1436 46.3507
Bi-Weekly 3,050.63 3,203.16 3,363.32 3,531.48 3,708.06
Monthly 6,609.70 6,940.18 7,287.19 7,651.55 8,034.13
Annual 79,316.36 83,282.17 87,446.28 91,818.60 96,409.53 Assistant City Manager / Assistant General Manager (Executive ) Step A Step B Step C Step D Step E
Hourly 103.5157 108.6915 114.1261 119.8324 125.824
Bi-Weekly 8,281.26 8,695.32 9,130.09 9,586.59 10,065.92 Monthly 17,942.72 18,839.86 19,781.85 20,770.94 21,809.49 Annual 215,312.68 226,078.31 237,382.23 249,251.34 261,713.90 Assistant to the City Manager (Non Bargaining- MEA)
Step A Step B Step C Step D Step E
Hourly 68.685 72.1192 75.7252 79.5115 83.487
Bi-Weekly 5,494.80 5,769.54 6,058.02 6,360.92 6,678.96
Monthly 11,905.40 12,500.67 13,125.70 13,781.99 14,471.09 Annual 142,864.80 150,008.04 157,508.44 165,383.86 173,653.06 12 Assistant Engineer (SEIU)
Step A Step B Step C Step D Step E
Hourly 45.664 47.9472 50.3446 52.8618 55.5049
Bi-Weekly 3,653.12 3,835.78 4,027.57 4,228.94 4,440.39
Monthly 7,915.09 8,310.85 8,726.39 9,162.71 9,620.85
Annual 94,981.13 99,730.19 104,716.70 109,952.53 115,450.16 Assistant Planner (SEIU)
Step A Step B Step C Step D Step E
Hourly 44.8717 47.1153 49.471 51.9446 54.5418
Bi-Weekly 3,589.74 3,769.22 3,957.68 4,155.57 4,363.35
Monthly 7,777.76 8,166.65 8,574.98 9,003.73 9,453.92
Annual 93,333.14 97,999.79 102,899.78 108,044.77 113,447.01 Associate Engineer (SEIU)
Step A Step B Step C Step D Step E
Hourly 52.8619 55.505 58.2802 61.1942 64.2539
Bi-Weekly 4,228.95 4,440.40 4,662.42 4,895.54 5,140.31
Monthly 9,162.72 9,620.86 10,101.90 10,607.00 11,137.35 Annual 109,952.67 115,450.31 121,222.82 127,283.96 133,648.16 Associate Planner (SEIU)
Step A Step B Step C Step D Step E
Hourly 49.0607 51.5137 54.0894 56.7939 59.6336
Bi-Weekly 3,924.86 4,121.10 4,327.15 4,543.51 4,770.69
Monthly 8,503.85 8,929.05 9,375.50 9,844.27 10,336.49
Annual 102,046.25 107,148.56 112,505.99 118,131.29 124,037.85 13 Building Inspector I (SEIU)
Step A Step B Step C Step D Step E
Hourly 44.0603 46.2633 48.5765 51.0053 53.5556
Bi-Weekly 3,524.83 3,701.07 3,886.12 4,080.43 4,284.45
Monthly 7,637.12 8,018.98 8,419.93 8,840.92 9,282.97
Annual 91,645.46 96,227.73 101,039.12 106,091.08 111,395.63 Building Inspector II (SEIU)
Step A Step B Step C Step D Step E
Hourly 49.3413 51.8084 54.3988 57.1187 59.9747
Bi-Weekly 3,947.30 4,144.67 4,351.90 4,569.50 4,797.97
Monthly 8,552.49 8,980.12 9,429.12 9,900.58 10,395.61
Annual 102,629.92 107,761.41 113,149.48 118,806.96 124,747.31 Building Inspector / Neighborhood Preservation Officer I (SEIU) Step A Step B Step C Step D Step E
Hourly 50.6693 53.2028 55.8629 58.6561 61.5889
Bi-Weekly 4,053.55 4,256.22 4,469.03 4,692.49 4,927.11
Monthly 8,782.68 9,221.82 9,682.91 10,167.05 10,675.41
Annual 105,392.20 110,661.81 116,194.90 122,004.64 128,104.88 Building Inspector / Neighborhood Preservation Officer II (SEIU) Step A Step B Step C Step D Step E
Hourly 56.7424 59.5796 62.5585 65.6865 68.9708
Bi-Weekly 4,539.40 4,766.37 5,004.68 5,254.92 5,517.66
Monthly 9,835.36 10,327.13 10,843.48 11,385.66 11,954.94 Annual 118,024.29 123,925.51 130,121.78 136,627.87 143,459.27 14 Building Permit Technician (SEIU)
Step A Step B Step C Step D Step E
Hourly 33.0329 34.6846 36.4188 38.2397 40.1517
Bi-Weekly 2,642.63 2,774.77 2,913.50 3,059.18 3,212.14
Monthly 5,725.71 6,011.99 6,312.59 6,628.22 6,959.63
Annual 68,708.49 72,143.92 75,751.11 79,538.67 83,515.60 Chief Building Official (MEA)
Step A Step B Step C Step D Step E
Hourly 75.5534 79.3311 83.2976 87.4625 91.8356
Bi-Weekly 6,044.27 6,346.48 6,663.81 6,997.00 7,346.85
Monthly 13,095.92 13,750.72 14,438.25 15,160.16 15,918.17 Annual 157,151.04 165,008.59 173,259.02 181,921.97 191,018.07 City Clerk- Public Information Officer (Non Bargaining- MEA) Step A Step B Step C Step D Step E
Hourly 58.5174 61.4433 64.5155 67.7413 71.1283
Bi-Weekly 4,681.40 4,915.46 5,161.24 5,419.30 5,690.27
Monthly 10,143.02 10,650.17 11,182.68 11,741.82 12,328.91 Annual 121,716.28 127,802.09 134,192.19 140,901.80 147,946.89 City Engineer (MEA)
Step A Step B Step C Step D Step E
Hourly 79.3554 83.3232 87.4893 91.8638 96.457
Bi-Weekly 6,348.43 6,665.86 6,999.15 7,349.11 7,716.56
Monthly 13,754.94 14,442.69 15,164.82 15,923.06 16,719.21 Annual 165,059.27 173,312.23 181,977.85 191,076.74 200,630.57 15 Community & Economic Development Director (Executive) Step A Step B Step C Step D Step E
Hourly 94.902404 101.165865 107.42933 113.69279 119.95625 Bi-Weekly 7,592.19 8,093.27 8,594.35 9,095.42 9,596.50 ` Monthly 16,449.75 17,535.42 18,621.08 19,706.75 20,792.42 Annual 197,397.00 210,425.00 223,453.00 236,481.00 249,509.00 Community Services Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 58.0515 60.9541 64.0018 67.2019 70.562
Bi-Weekly 4,644.12 4,876.33 5,120.14 5,376.15 5,644.96
Monthly 10,062.26 10,565.38 11,093.64 11,648.33 12,230.74 Annual 120,747.15 126,784.51 133,123.74 139,779.92 146,768.92 Community Services Officer (PT) (Non Bargaining- SEIU)
Step A Step B Step C Step D Step E
Hourly 32.6157 34.2465 35.9588 37.7567 39.6446
Bi-Weekly 1,174.16 1,232.87 1,294.52 1,359.24 1,427.20
Monthly 2,544.02 2,671.23 2,804.79 2,945.03 3,092.28
Annual 30,528.29 32,054.70 33,657.44 35,340.31 37,107.32 Community Services Officer (SEIU)
Step A Step B Step C Step D Step E
Hourly 32.6157 34.2465 35.9588 37.7567 39.6446
Bi-Weekly 2,609.26 2,739.72 2,876.70 3,020.54 3,171.57
Monthly 5,653.39 5,936.06 6,232.86 6,544.50 6,871.73
Annual 67,840.64 71,232.67 74,794.30 78,534.02 82,460.72 Deputy City Attorney I (Non Bargaining- MEA)
Step A Step B Step C Step D Step E
Hourly 57.2152 60.0759 63.0797 66.2337 69.5454
Bi-Weekly 4,577.21 4,806.08 5,046.38 5,298.70 5,563.63
Monthly 9,917.30 10,413.16 10,933.82 11,480.51 12,054.54 Annual 119,007.59 124,957.97 131,205.86 137,766.16 144,654.46 16 Deputy City Attorney II (Non Bargaining- MEA)
Step A Step B Step C Step D Step E
Hourly 71.2417 74.8037 78.5439 82.4711 86.5947
Bi-Weekly 5,699.33 5,984.30 6,283.51 6,597.69 6,927.57
Monthly 12,348.55 12,965.98 13,614.28 14,295.00 15,009.75 Annual 148,182.66 155,591.79 163,371.38 171,539.95 180,116.95 Deputy City Clerk (MEA)
Step A Step B Step C Step D Step E
Hourly 40.6291 42.6606 44.7936 47.0333 49.385
Bi-Weekly 3,250.33 3,412.85 3,583.49 3,762.66 3,950.80
Monthly 7,042.38 7,394.50 7,764.23 8,152.44 8,560.06
Annual 84,508.62 88,734.05 93,170.75 97,829.29 102,720.75 Director of Finance / District Treasurer (Executive )
Step A Step B Step C Step D Step E
Hourly 94.9072 99.6525 104.6352 109.8669 115.3603
Bi-Weekly 7,592.57 7,972.20 8,370.81 8,789.35 9,228.82
Monthly 16,450.58 17,273.11 18,136.76 19,043.60 19,995.78 Annual 197,406.95 207,277.30 217,641.16 228,523.22 239,949.38 Electrician - Apprentice (SEIU)
Step A Step B Step C Step D Step E
Hourly 44.0002 46.2002 48.5102 50.9357 53.4825
Bi-Weekly 3,520.01 3,696.01 3,880.81 4,074.86 4,278.60
Monthly 7,626.70 8,008.03 8,408.43 8,828.85 9,270.30
Annual 91,520.35 96,096.36 100,901.18 105,946.24 111,243.55 Electrician - Journeyman (SEIU)
Step A Step B Step C Step D Step E
Hourly 46.495 48.8198 51.2608 53.8238 56.515
Bi-Weekly 3,719.60 3,905.58 4,100.86 4,305.90 4,521.20
Monthly 8,059.14 8,462.09 8,885.20 9,329.46 9,795.93
Annual 96,709.64 101,545.13 106,622.38 111,953.50 117,551.18 17 Electrician - Lead (SEIU)
Step A Step B Step C Step D Step E
Hourly 49.7695 52.258 54.8709 57.6144 60.4952
Bi-Weekly 3,981.56 4,180.64 4,389.67 4,609.16 4,839.61
Monthly 8,626.72 9,058.05 9,510.95 9,986.50 10,485.83
Annual 103,520.60 108,696.63 114,131.46 119,838.03 125,829.93 Environmental Services Aide FT (SEIU)
Step A Step B Step C Step D Step E
Hourly 27.3863 28.7556 30.1934 31.7031 33.2883
Bi-Weekly 2,190.91 2,300.45 2,415.47 2,536.25 2,663.06
Monthly 4,746.96 4,984.31 5,233.53 5,495.20 5,769.96
Annual 56,963.57 59,811.75 62,802.34 65,942.45 69,239.58 Environmental Services Aide PT (0.45 FTE, 936 Hrs) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 27.3863 28.7556 30.1934 31.7031 33.2883
Bi-Weekly 985.91 1,035.20 1,086.96 1,141.31 1,198.38
Monthly 2,136.13 2,242.94 2,355.09 2,472.84 2,596.48
Annual 25,633.61 26,915.29 28,261.05 29,674.10 31,157.81 Executive Assistant to the City Manager (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 43.5229 45.699 47.984 50.3832 52.9023
Bi-Weekly 3,481.83 3,655.92 3,838.72 4,030.66 4,232.19
Monthly 7,543.97 7,921.17 8,317.22 8,733.09 9,169.74
Annual 90,527.62 95,054.00 99,806.70 104,797.03 110,036.88 Financial Service Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 65.9617 69.2598 72.7228 76.3589 80.1768
Bi-Weekly 5,276.93 5,540.78 5,817.82 6,108.71 6,414.15
Monthly 11,433.36 12,005.03 12,605.28 13,235.54 13,897.32 Annual 137,200.29 144,060.31 151,263.32 158,826.49 166,767.81 18 Fiscal Analyst (MEA)
Step A Step B Step C Step D Step E
Hourly 55.5222 58.2983 61.2132 64.2739 67.4876
Bi-Weekly 4,441.77 4,663.86 4,897.06 5,141.91 5,399.00
Monthly 9,623.84 10,105.04 10,610.29 11,140.80 11,697.84 Annual 115,486.13 121,260.44 127,323.46 133,689.63 140,374.11 Grants Coordinator (SEIU)
Step A Step B Step C Step D Step E
Hourly 41.6347 43.7164 45.9022 48.1973 50.6072
Bi-Weekly 3,330.77 3,497.31 3,672.18 3,855.79 4,048.57
Monthly 7,216.67 7,577.51 7,956.38 8,354.20 8,771.91
Annual 86,600.09 90,930.09 95,476.60 100,250.43 105,262.95 Housing Project Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 56.106 58.9113 61.8569 64.9497 68.1972
Bi-Weekly 4,488.48 4,712.90 4,948.55 5,195.98 5,455.77
Monthly 9,725.04 10,211.29 10,721.86 11,257.95 11,820.85 Annual 116,700.47 122,535.49 128,662.27 135,095.38 141,850.15 Housing Specialist I (SEIU)
Step A Step B Step C Step D Step E
Hourly 36.6678 38.5012 40.4263 42.4476 44.5699
Bi-Weekly 2,933.42 3,080.10 3,234.10 3,395.81 3,565.60
Monthly 6,355.75 6,673.54 7,007.22 7,357.58 7,725.46
Annual 76,269.04 80,082.49 84,086.62 88,290.95 92,705.50 Housing Specialist II (SEIU)
Step A Step B Step C Step D Step E
Hourly 45.8075 48.0979 50.5028 53.0279 55.6793
Bi-Weekly 3,664.60 3,847.83 4,040.22 4,242.23 4,454.35
Monthly 7,939.97 8,336.97 8,753.82 9,191.51 9,651.08
Annual 95,279.63 100,043.61 105,045.79 110,298.08 115,812.98 19 Housing & Economic Development Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 68.6849 72.1192 75.7251 79.5114 83.487
Bi-Weekly 5,494.79 5,769.53 6,058.01 6,360.91 6,678.96
Monthly 11,905.39 12,500.66 13,125.69 13,781.98 14,471.07 Annual 142,864.66 150,007.89 157,508.29 165,383.70 173,652.89 Human Resource Manager (Non Bargaining- MEA)
Step A Step B Step C Step D Step E
Hourly 68.0071 71.4074 74.9778 78.7267 82.663
Bi-Weekly 5,440.57 5,712.60 5,998.22 6,298.14 6,613.04
Monthly 11,787.89 12,377.29 12,996.15 13,645.96 14,328.26 Annual 141,454.74 148,527.47 155,953.85 163,751.54 171,939.12 Human Resources Technician I (Non Bargaining- SEIU)
Step A Step B Step C Step D Step E
Hourly 41.4192 43.4902 45.6647 47.9479 50.3453
Bi-Weekly 3,313.54 3,479.22 3,653.18 3,835.84 4,027.63
Monthly 7,179.33 7,538.30 7,915.22 8,310.98 8,726.53
Annual 86,152.01 90,459.61 94,982.59 99,731.72 104,718.30 Human Resources Technician II (Non Bargaining- SEIU)
Step A Step B Step C Step D Step E
Hourly 45.5612 47.8393 50.2312 52.7428 55.3799
Bi-Weekly 3,644.90 3,827.14 4,018.50 4,219.42 4,430.39
Monthly 7,897.27 8,292.14 8,706.75 9,142.08 9,599.19
Annual 94,767.29 99,505.66 104,480.94 109,704.99 115,190.24 Information Technology Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 75.0204 78.7715 82.71 86.8455 91.1878
Bi-Weekly 6,001.63 6,301.72 6,616.80 6,947.64 7,295.02
Monthly 13,003.54 13,653.72 14,336.40 15,053.22 15,805.89 Annual 156,042.50 163,844.62 172,036.85 180,638.70 189,670.63 20 Information Technology Specialist I (SEIU)
Step A Step B Step C Step D Step E
Hourly 36.6678 38.5012 40.4262 42.4476 44.5699
Bi-Weekly 2,933.42 3,080.09 3,234.10 3,395.80 3,565.59
Monthly 6,355.75 6,673.54 7,007.22 7,357.58 7,725.46
Annual 76,269.01 80,082.46 84,086.59 88,290.91 92,705.46 Information Technology Specialist II (SEIU)
Step A Step B Step C Step D Step E
Hourly 45.8075 48.0979 50.5028 53.0279 55.6793
Bi-Weekly 3,664.60 3,847.83 4,040.22 4,242.23 4,454.34
Monthly 7,939.97 8,336.96 8,753.81 9,191.50 9,651.08
Annual 95,279.60 100,043.58 105,045.76 110,298.04 115,812.95 Kitchen Aide - (0.5 FTE, 1040 Hrs) (SEIU)
Step A Step B Step C Step D Step E
Hourly 18.8601 19.8031 20.7933 21.833 22.9246
Bi-Weekly 754.41 792.13 831.73 873.32 916.98
Monthly 1,634.55 1,716.27 1,802.09 1,892.19 1,986.80
Annual 19,614.54 20,595.27 21,625.03 22,706.28 23,841.60 Maintenance Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 66.8105 70.151 73.6585 77.3415 81.2085
Bi-Weekly 5,344.84 5,612.08 5,892.68 6,187.32 6,496.68
Monthly 11,580.48 12,159.51 12,767.48 13,405.85 14,076.15 Annual 138,965.78 145,914.07 153,209.77 160,870.26 168,913.77 Maintenance Worker I (SEIU)
Step A Step B Step C Step D Step E
Hourly 29.9452 31.4424 33.0146 34.6653 36.3985
Bi-Weekly 2,395.61 2,515.39 2,641.16 2,773.22 2,911.88
Monthly 5,190.50 5,450.02 5,722.52 6,008.65 6,309.08
Annual 62,285.96 65,400.26 68,670.27 72,103.78 75,708.97 21 Maintenance Worker II (SEIU)
Step A Step B Step C Step D Step E
Hourly 33.2834 34.9476 36.695 38.5297 40.4562
Bi-Weekly 2,662.67 2,795.81 2,935.60 3,082.38 3,236.50
Monthly 5,769.12 6,057.58 6,360.46 6,678.48 7,012.41
Annual 69,229.48 72,690.96 76,325.51 80,141.78 84,148.87 Maintenance Worker III (SEIU)
Step A Step B Step C Step D Step E
Hourly 37.0756 38.9294 40.8758 42.9196 45.0656
Bi-Weekly 2,966.05 3,114.35 3,270.07 3,433.57 3,605.25
Monthly 6,426.43 6,747.76 7,085.14 7,439.40 7,811.37
Annual 77,117.20 80,973.06 85,021.72 89,272.80 93,736.44 Management Analyst I (MEA)
Step A Step B Step C Step D Step E
Hourly 46.2317 48.5433 50.9704 53.519 56.1949
Bi-Weekly 3,698.54 3,883.46 4,077.63 4,281.52 4,495.59
Monthly 8,013.49 8,414.17 8,834.88 9,276.62 9,740.45
Annual 96,161.91 100,970.01 106,018.51 111,319.43 116,885.40 Management Analyst II (MEA)
Step A Step B Step C Step D Step E
Hourly 55.5221 58.2982 61.2132 64.2738 67.4875
Bi-Weekly 4,441.77 4,663.86 4,897.05 5,141.91 5,399.00
Monthly 9,623.84 10,105.03 10,610.28 11,140.79 11,697.83 Annual 115,486.05 121,260.35 127,323.37 133,689.54 140,374.01 Neighborhood Preservation Officer I (SEIU)
Step A Step B Step C Step D Step E
Hourly 37.0805 38.9345 40.8812 42.9253 45.0715
Bi-Weekly 2,966.44 3,114.76 3,270.50 3,434.02 3,605.72
Monthly 6,427.28 6,748.65 7,086.08 7,440.38 7,812.40
Annual 77,127.38 80,983.75 85,032.94 89,284.58 93,748.81 22 Neighborhood Preservation Officer II (SEIU)
Step A Step B Step C Step D Step E
Hourly 42.4903 44.6148 46.8456 49.1879 51.6472
Bi-Weekly 3,399.23 3,569.19 3,747.65 3,935.03 4,131.78
Monthly 7,364.99 7,733.24 8,119.90 8,525.89 8,952.19
Annual 88,379.86 92,798.85 97,438.80 102,310.74 107,426.27 Nutrition Site Supervisor (0.75 FTE, 1560 Hrs) (SEIU)
Step A Step B Step C Step D Step E
Hourly 23.0283 24.1797 25.3887 26.6582 27.9911
Bi-Weekly 1,381.70 1,450.78 1,523.32 1,599.49 1,679.46
Monthly 2,993.68 3,143.37 3,300.53 3,465.56 3,638.84
Annual 35,924.18 37,720.38 39,606.40 41,586.72 43,666.06 Office Assistant (SEIU)
Step A Step B Step C Step D Step E
Hourly 28.734 30.1707 31.6792 33.2632 34.9264
Bi-Weekly 2,298.72 2,413.66 2,534.34 2,661.06 2,794.11
Monthly 4,980.56 5,229.59 5,491.07 5,765.62 6,053.90
Annual 59,766.73 62,755.06 65,892.81 69,187.46 72,646.83 Paralegal (Non Bargaining- SEIU)
Step A Step B Step C Step D Step E
Hourly 43.7484 45.9358 48.2326 50.6443 53.1765
Bi-Weekly 3,499.87 3,674.87 3,858.61 4,051.54 4,254.12
Monthly 7,583.06 7,962.21 8,360.32 8,778.34 9,217.26
Annual 90,996.73 95,546.56 100,323.89 105,340.09 110,607.09 Planning Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 70.0878 73.5922 77.2718 81.1354 85.1921
Bi-Weekly 5,607.02 5,887.37 6,181.74 6,490.83 6,815.37
Monthly 12,148.55 12,755.97 13,393.77 14,063.46 14,766.63 Annual 145,782.56 153,071.69 160,725.27 168,761.54 177,199.61 23 Planning Permit Technician (SEIU)
Step A Step B Step C Step D Step E
Hourly 33.0329 34.6846 36.4188 38.2397 40.1517
Bi-Weekly 2,642.63 2,774.77 2,913.50 3,059.18 3,212.14
Monthly 5,725.71 6,011.99 6,312.59 6,628.22 6,959.63
Annual 68,708.49 72,143.92 75,751.11 79,538.67 83,515.60 Police Captain (Non Bargaining- MEA)
Step A Step B Step C Step D Step E
Hourly 90.1947 94.7045 99.4397 104.4117 109.6323
Bi-Weekly 7,215.58 7,576.36 7,955.18 8,352.93 8,770.58
Monthly 15,633.75 16,415.44 17,236.21 18,098.02 19,002.92 Annual 187,605.03 196,985.29 206,834.55 217,176.28 228,035.09 Police Chief (Executive )
Step A Step B Step C Step D Step E
Hourly 99.863 104.8562 110.099 115.604 121.3842
Bi-Weekly 7,989.04 8,388.50 8,807.92 9,248.32 9,710.73
Monthly 17,309.59 18,175.07 19,083.83 20,038.02 21,039.92 Annual 207,715.13 218,100.88 229,005.93 240,456.22 252,479.03 Police Officer - Academy Graduate/ Basic (POA)
Step A Step B Step C Step D Step E Step F Step G
Hourly 49.5661 52.0444 54.6466 57.379 60.2479 63.2603 65.4744 Bi-Weekly 4,163.55 4,371.73 4,590.32 4,819.83 5,060.83 5,313.87 5499.85 Monthly 9,021.03 9,472.08 9,945.69 10,442.97 10,965.12 11,513.38 11916.35 Annual 108252.39 113665.01 119348.26 125315.68 131581.46 138160.5 142996.2 Police Records Clerk I (SEIU)
Step A Step B Step C Step D Step E
Hourly 30.5421 32.0692 33.6727 35.3563 37.1241
Bi-Weekly 2,443.37 2,565.54 2,693.81 2,828.51 2,969.93
Monthly 5,293.97 5,558.66 5,836.60 6,128.43 6,434.85
Annual 63,527.60 66,703.98 70,039.18 73,541.13 77,218.19 24 Police Records Clerk II (SEIU)
Step A Step B Step C Step D Step E
Hourly 33.9227 35.6188 37.3998 39.2698 41.2333
Bi-Weekly 2,713.82 2,849.51 2,991.98 3,141.58 3,298.66
Monthly 5,879.93 6,173.93 6,482.63 6,806.76 7,147.10
Annual 70,559.21 74,087.17 77,791.53 81,681.11 85,765.16 Police Records Supervisor (MEA)
Step A Step B Step C Step D Step E
Hourly 42.5684 44.6968 46.9317 49.2782 51.7422
Bi-Weekly 3,405.47 3,575.75 3,754.53 3,942.26 4,139.37
Monthly 7,378.52 7,747.45 8,134.82 8,541.56 8,968.64
Annual 88,542.28 92,969.39 97,617.86 102,498.76 107,623.70 Police Sergeant - Basic (POA)
Step A Step B Step C Step D Step E Step F Step G
Hourly 59.5196 62.4956 65.6203 68.9013 72.3464 75.9637 78.6225 Bi-Weekly 4,999.64 5,249.63 5,512.11 5,787.71 6,077.10 6,380.95 6604.29 Monthly 10,832.56 11,374.19 11,942.90 12,540.05 13,167.05 13,825.40 14309.29 Annual 129990.75 136490.29 143314.8 150480.54 158004.57 165904.8 171711.5 Property and Evidence Technician (SEIU)
Step A Step B Step C Step D Step E
Hourly 37.3838 39.253 41.2157 43.2765 45.4403
Bi-Weekly 2,990.71 3,140.24 3,297.26 3,462.12 3,635.22
Monthly 6,479.87 6,803.86 7,144.05 7,501.26 7,876.32
Annual 77,758.40 81,646.32 85,728.64 90,015.07 94,515.82 Public Works Director / District Engineer (Executive )
Step A Step B Step C Step D Step E
Hourly 97.2033 102.0634 107.1666 112.5249 118.1512
Bi-Weekly 7,776.26 8,165.07 8,573.33 9,001.99 9,452.09
Monthly 16,848.57 17,690.99 18,575.54 19,504.32 20,479.54 Annual 202,182.79 212,291.93 222,906.52 234,051.85 245,754.44 25 Public Works Supervisor (MEA)
Step A Step B Step C Step D Step E
Hourly 53.8156 56.5064 59.3317 62.2983 65.4132
Bi-Weekly 4,305.25 4,520.51 4,746.54 4,983.87 5,233.06
Monthly 9,328.04 9,794.45 10,284.17 10,798.38 11,338.30 Annual 111,936.53 117,533.35 123,410.02 129,580.52 136,059.55 Recreation Leader I FT (SEIU)
Step A Step B Step C Step D Step E
Hourly 17.9735 18.8722 19.8158 20.8066 21.8469
Bi-Weekly 1,437.88 1,509.77 1,585.26 1,664.53 1,747.75
Monthly 3,115.41 3,271.18 3,434.74 3,606.47 3,786.80
Annual 37,384.88 39,254.12 41,216.83 43,277.67 45,441.56 Recreation Leader I (0.45 FTE, 936 Hrs) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 17.9735 18.8722 19.8158 20.8066 21.8469
Bi-Weekly 647.05 679.4 713.37 749.04 786.49
Monthly 1,401.93 1,472.03 1,545.63 1,622.91 1,704.06
Annual 16,823.20 17,664.36 18,547.57 19,474.95 20,448.70 Recreation Leader II FT (SEIU)
Step A Step B Step C Step D Step E
Hourly 19.1788 20.1378 21.1447 22.2019 23.312
Bi-Weekly 1,534.31 1,611.02 1,691.57 1,776.15 1,864.96
Monthly 3,324.33 3,490.55 3,665.08 3,848.33 4,040.75
Annual 39,892.00 41,886.60 43,980.93 46,179.97 48,488.97 Recreation Leader II (0.45 FTE, 936 Hrs) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 19.1788 20.1378 21.1447 22.2019 23.312
Bi-Weekly 690.44 724.96 761.21 799.27 839.23
Monthly 1,495.95 1,570.75 1,649.28 1,731.75 1,818.34
Annual 17,951.40 18,848.97 19,791.42 20,780.99 21,820.04 26 Recreation Program Coordinator (SEIU)
Step A Step B Step C Step D Step E
Hourly 37.0222 38.8733 40.8169 42.8578 45.0007
Bi-Weekly 2,961.77 3,109.86 3,265.36 3,428.62 3,600.05
Monthly 6,417.18 6,738.03 7,074.94 7,428.68 7,800.12
Annual 77,006.11 80,856.41 84,899.23 89,144.19 93,601.40 Rent Stabilization Administrator (MEA)
Step A Step B Step C Step D Step E
Hourly 67.8723 71.2659 74.8292 78.5707 82.4992
Bi-Weekly 5,429.78 5,701.27 5,986.34 6,285.65 6,599.94
Monthly 11,764.53 12,352.76 12,970.40 13,618.92 14,299.86 Annual 141,174.41 148,233.13 155,644.78 163,427.02 171,598.37 Rent Stabilization Program Coordinator I (SEIU)
Step A Step B Step C Step D Step E
Hourly 38.1328 40.0395 42.0414 44.1435 46.3507
Bi-Weekly 3,050.63 3,203.16 3,363.32 3,531.48 3,708.06
Monthly 6,609.69 6,940.18 7,287.18 7,651.54 8,034.12
Annual 79,316.29 83,282.11 87,446.21 91,818.52 96,409.45 Rent Stabilization Program Coordinator II (SEIU)
Step A Step B Step C Step D Step E
Hourly 45.8075 48.0978 50.5027 53.0279 55.6792
Bi-Weekly 3,664.60 3,847.83 4,040.22 4,242.23 4,454.34
Monthly 7,939.96 8,336.96 8,753.80 9,191.49 9,651.07
Annual 95,279.51 100,043.48 105,045.66 110,297.94 115,812.84 Secretary I (SEIU)
Step A Step B Step C Step D Step E
Hourly 29.2663 30.7296 32.2661 33.8794 35.5734
Bi-Weekly 2,341.30 2,458.37 2,581.29 2,710.35 2,845.87
Monthly 5,072.83 5,326.47 5,592.79 5,872.43 6,166.05
Annual 60,873.91 63,917.61 67,113.49 70,469.16 73,992.62 27 Secretary II (SEIU)
Step A Step B Step C Step D Step E
Hourly 32.6021 34.2322 35.9438 37.741 39.628
Bi-Weekly 2,608.17 2,738.57 2,875.50 3,019.28 3,170.24
Monthly 5,651.02 5,933.58 6,230.25 6,541.77 6,868.86
Annual 67,812.30 71,202.91 74,763.06 78,501.21 82,426.27 Senior Accounting Technician (SEIU)
Step A Step B Step C Step D Step E
Hourly 36.7377 38.5745 40.5033 42.5284 44.6548
Bi-Weekly 2,939.01 3,085.96 3,240.26 3,402.27 3,572.39
Monthly 6,367.86 6,686.25 7,020.57 7,371.59 7,740.17
Annual 76,414.32 80,235.03 84,246.78 88,459.12 92,882.08 Senior Engineer (MEA)
Step A Step B Step C Step D Step E
Hourly 66.8104 70.1509 73.6585 77.3414 81.2085
Bi-Weekly 5,344.83 5,612.08 5,892.68 6,187.31 6,496.68
Monthly 11,580.47 12,159.50 12,767.47 13,405.85 14,076.14 Annual 138,965.68 145,913.96 153,209.66 160,870.14 168,913.65 Senior Management Analyst (MEA)
Step A Step B Step C Step D Step E
Hourly 61.0744 64.1281 67.3345 70.7012 74.2363
Bi-Weekly 4,885.95 5,130.25 5,386.76 5,656.10 5,938.90
Monthly 10,586.22 11,115.53 11,671.31 12,254.87 12,867.62 Annual 127,034.65 133,386.38 140,055.70 147,058.49 154,411.41 Senior Planner (MEA)
Step A Step B Step C Step D Step E
Hourly 55.6386 58.4206 61.3416 64.4087 67.6291
Bi-Weekly 4,451.09 4,673.65 4,907.33 5,152.69 5,410.33
Monthly 9,644.03 10,126.23 10,632.54 11,164.17 11,722.38 Annual 115,728.38 121,514.80 127,590.54 133,970.07 140,668.57 28 Support Services Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 60.6754 63.7092 66.8947 70.2394 73.7514
Bi-Weekly 4,854.04 5,096.74 5,351.57 5,619.15 5,900.11
Monthly 10,517.08 11,042.93 11,595.08 12,174.83 12,783.57 Annual 126,204.93 132,515.17 139,140.93 146,097.98 153,402.88 Utility Manager (MEA)
Step A Step B Step C Step D Step E
Hourly 75.1639 78.922 82.8682 87.0116 91.3621
Bi-Weekly 6,013.11 6,313.76 6,629.45 6,960.92 7,308.97
Monthly 13,028.40 13,679.82 14,363.81 15,082.00 15,836.10 Annual 156,340.82 164,157.86 172,365.76 180,984.04 190,033.25 Van Driver (0.5 FTE, 1040 Hrs) (SEIU)
Step A Step B Step C Step D Step E
Hourly 25.0399 26.2919 27.6065 28.9868 30.4362
Bi-Weekly 1,001.60 1,051.68 1,104.26 1,159.47 1,217.45
Monthly 2,170.13 2,278.63 2,392.56 2,512.19 2,637.80
Annual 26,041.51 27,343.59 28,710.77 30,146.31 31,653.62 Human Resources Technician I (18 Month LTD) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 41.4192 43.4902 45.6647 47.9479 50.3453
Bi-Weekly 3,313.54 3,479.22 3,653.18 3,835.84 4,027.63
Monthly 7,179.33 7,538.30 7,915.22 8,310.98 8,726.53
Annual 86,152.01 90,459.61 94,982.59 99,731.72 104,718.30 Human Resources Technician II (18 Month LTD) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 45.5612 47.8393 50.2312 52.7428 55.3799
Temporary and Limited Duration Classifications
29 Bi-Weekly 3,644.90 3,827.14 4,018.50 4,219.42 4,430.39 Monthly 7,897.27 8,292.14 8,706.75 9,142.08 9,599.19
Annual 94,767.29 99,505.66 104,480.94 109,704.99 115,190.24 Management Analyst I (1 Year LTD) (Non Bargaining)
Step A Step B Step C Step D Step E
Hourly 46.2317 48.5433 50.9704 53.519 56.1949
Bi-Weekly 3,698.54 3,883.46 4,077.63 4,281.52 4,495.59
Monthly 8,013.49 8,414.17 8,834.88 9,276.62 9,740.45
Annual 96,161.91 100,970.01 106,018.51 111,319.43 116,885.40 Management Analyst II (1 Year LTD) (Non Bargaining)
Step A Step B Step C Step D Step E
Hourly 55.5221 58.2982 61.2132 64.2738 67.4875
Bi-Weekly 4,441.77 4,663.86 4,897.05 5,141.91 5,399.00
Monthly 9,623.84 10,105.03 10,610.28 11,140.79 11,697.83 Annual 115,486.05 121,260.35 127,323.37 133,689.54 140,374.01 Police Recruit (Temporary- Non Bargaining)
Hourly 30
Bi-Weekly 1,200.00
Monthly 2,600.00
Annual 31,200.00
Special Projects Manager (960 HRS LTD) (Temporary- Non Bargaining) Hourly 65.1 69.33
Bi-Weekly 2,403.69 2,559.88
Monthly 5,208.00 5,546.40
Annual 62,496.00 66,556.80
Special Projects Manager (2 Year LTD) (Temporary- Non Bargaining) Hourly 65.1 69.33
30 Bi-Weekly 2,403.69 2,559.88
Monthly 5,208.00 5,546.40
Annual 62,496.00 66,556.80
Utility Manager (6-Month LTD) (Non Bargaining- MEA)
Step A Step B Step C Step D Step E
Hourly 75.1639 78.922 82.8682 87.0116 91.3621
Bi-Weekly 6,013.11 6,313.76 6,629.45 6,960.92 7,308.97
Monthly 13,028.40 13,679.82 14,363.81 15,082.00 15,836.10 Annual 156,340.82 164,157.86 172,365.76 180,984.04 190,033.25 Temporary Employee (Reso No. 4576) (Temporary- Non Bargaining) Step A
Hourly 17.45 100
Bi-Weekly
Monthly
Annual
Housing Specialist I (1 Year LTD) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 36.6678 38.5012 40.4263 42.4476 44.5699
Bi-Weekly 2,933.42 3,080.10 3,234.10 3,395.81 3,565.60
Monthly 6,355.75 6,673.54 7,007.22 7,357.58 7,725.46
Annual 76,269.04 80,082.49 84,086.62 88,290.95 92,705.50 Housing Specialist II (1 Year LTD) (Non Bargaining- SEIU) Step A Step B Step C Step D Step E
Hourly 45.8075 48.0979 50.5028 53.0279 55.6793
Bi-Weekly 3,664.60 3,847.83 4,040.22 4,242.23 4,454.35
Monthly 7,939.97 8,336.97 8,753.82 9,191.51 9,651.08
Annual 95,279.63 100,043.61 105,045.79 110,298.08 115,812.98 31 INFORMATIONAL REPORT 6.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: March 3, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Orly Amey, Assistant to the City Manager
Shiri Klima, Assistant City Manager
SUBJECT: City Council Strategic Priorities Fiscal Years (FY) 2025-27 Work Plan - Second Quarter Status Update
Recommendation
Receive a second quarter update on the City Council Strategic Priorities FY 2025-27 Work Plan.

Executive Summary
This report provides an update on the City Council Strategic Priorities FY 2025–27 Work Plan, which outlines the projects and initiatives advancing the City Council’s adopted FY 2025–29 Strategic Priorities. The Work Plan serves as a roadmap for implementing the City Council’s strategic goals through coordinated, measurable actions across departments, ensuring continued alignment between City Council direction, community priorities, and City operations.

This update pertains to the second quarter (Q2) of the Work Plan, which began on October 1, 2025, and ended on December 31, 2025.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:

Priority: Civic Engagement
Priority: Comprehensive Housing
Priority: Governance, Organizational Strength, and Fiscal Sustainability Priority: Land Use, Economic and Workforce Development
Priority: Parks, Recreation, and Community Facilities
Priority: Public Health, Safety, and Quality of Life
Priority: Public Infrastructure and Utilities
32 INFORMATIONAL REPORT 6.1
Background
On June 17, 2025, the City Council adopted its FY 2025–2029 Strategic Priorities and accompanying FY 2025-27 Work Plan, establishing a strategic framework with particular steps to guide the City’s policy direction, resource allocation, and program delivery. These documents represent a coordinated plan for addressing community needs and strengthening organizational capacity over the next several years. They are collectively available at www.cityofepa.org/sites/default/files/fileattachments/city_council/page/13631/epa_strategicpla n_7.1.25_final.pdf.

The Council Priorities serve as overarching focus areas that shape how the City directs its efforts and investments. They reflect the collective input of residents, stakeholders, and community leaders who participated in a robust engagement process in the spring of 2025 to identify East Palo Alto’s most critical challenges and opportunities. By defining clear priorities, the City Council provided policy direction to the City Manager and ensured staff remained focused on initiatives that advance community well-being and measurable results.

The Council Council’s Strategic Priorities for FY 2025 through FY 2029 are:
• Civic Engagement: Provide diverse and inclusive opportunities for all EPA community members to participate in City meetings, have a voice in City affairs, and develop leadership skills for EPA youth.
• Comprehensive Housing: Increase the City’s housing stock at all income levels (from affordable to market rate), facilitate pathways to homeownership, and prevent displacement of existing residents.
• Governance, Organizational Strength, and Fiscal Sustainability: Strengthen the City’s internal capacity, transparency, and long-term financial health by improving core operation, investing in workforce and systems, and implementing data-informed strategies to ensure effective service delivery, accountability, and fiscal resilience. • Land Use, Economic, and Workforce Development: Support balanced development that attracts investment, strengthens local businesses, reduces economic leakage, and expands access to quality jobs and services that meet local needs. • Parks, Recreation, and Community Facilities: Invest in the modernization and expansion of the City’s parks, recreation, and community facilities and services to increase residents’ access to open spaces and recreational opportunities. • Public Health, Safety, and Quality of Life: Implement and enforce strategies to ensure public safety, improve the livability of neighborhoods, and prepare the City for disasters and emergencies.
• Public Infrastructure and Utilities: Maintain, modernize, and expand the City’s physical infrastructure (streets, sidewalks, utilities) to support existing homes and businesses, and new development.

The FY 2025–2029 Strategic Priorities and FY 2025-27 Work Plan were refined in tandem and adopted together to ensure alignment between strategic goals and implementation activities.

While the Council Priorities establish the City’s long-term focus areas, the Work Plan translates 33 INFORMATIONAL REPORT 6.1
those priorities into specific, actionable projects and programs that can be tracked and reported to the City Council and community. This report and Attachment 1 provide an update on the City’s progress implementing the Work Plan from October 1, 2025, through December 31, 2025.

Analysis
The FY 2025–27 Work Plan includes 59 projects. 49 of the 59 projects are active, four projects have been completed, four have been deferred (originally planned to begin by 12/31/2025, but paused until a later date), and two projects are scheduled to begin in the future.

Table 1: Project Status as of December 31, 2025
Project
Completion
Status
Not Yet
Scheduled
to Begin
Deferred
25%
Complete
50%
Complete
75%
Complete
100%
Complete
# of Projects
as of End of
Q2
(12/31/25)
2 4 25 12 12 4
Of the 59 projects:
• 3% are not yet scheduled to begin (2 projects).
• 7% have been deferred (4 projects).
• 42% are a quarter complete (25 projects).
• 20% of the projects are half complete (12 projects).
• 20% are three-quarters complete (12 projects).
• 7% of the projects are completed (4 projects).

The completed projects are:

1. Complete Construction of 965 Weeks/Colibri Commons (CH-1): Staff completed final inspections and issued the final Certificate of Occupancy in December 2025, delivering 136 units of affordable housing.

2. Develop Citywide Sewer Infrastructure Master Plan (PI-11): The EPASD Board adopted a sewer system master plan in July 2025.

3. Expand EPACENTER Services and Programs Through City Funding (PR-6): Staff executed a funding agreement with EPACENTER and programming began in Fall 2025. 34 INFORMATIONAL REPORT 6.1

4. Expand Access to YMCA Programming and Services for the Greater East Palo Alto Community (PR-11): Staff executed a funding agreement with the YMCA and programming began in Fall 2025.

The four deferred projects are:

1. Collaborate with the San Mateo County Libraries (SMCL) to Identify and Implement a Comprehensive Funding Strategy for Library (GOV-1):
a. The fundraising strategy developed with the SMCL and SMCL Foundation is currently paused while the City determines whether the library project will move to the Civic Commons. This project is expected to resume in March 2026 pending City Council direction.

2. Develop a 10-Year Fiscal Strategy and Address the Structural Deficit (GOV-3):
a. This project is temporarily on hold as staff reassess the project approach to refine the process and determine the next steps. The project is expected to resume in FY 2026-27.

3. Finalize Architectural Design for the New East Palo Alto Library (PR-7):
a. The project is currently on hold pending further direction related to the new Civic Center project City Council direction is expected in March 2026.

4. Create a Financing Strategy for Water Infrastructure Upgrades (PI-10):
a. Staff did not make significant progress on this project during the first half of the fiscal year; however, staff expect to relaunch this effort in FY 2026-27.

Aside from progress, it is also critical to understand where in the City the workload of these strategic priority projects falls. Although many projects require cross-departmental collaboration, of the remaining 57 projects, the Public Works Department leads 21, the City Manager’s Office leads 19, the Community and Economic Development Department (CEDD) leads 10, the City Clerk’s Office leads 3, and the Police and Finance Departments each lead 2 projects. Regardless of lead department, most projects require support and collaboration from other departments and divisions, including Finance, Human Resources, IT and the City Attorney’s Office.

This is a list of only the strategic priority projects, which staff estimates to be approximately twenty percent of our work. The other roughly eighty percent of our workload is day to day operations. Still, this demonstrates that, with respect to the work Council has prioritized that is very publicly visible, some departments and divisions have many more projects than others.

Public Works – Engineering is managing multiple public improvement projects in addition to their day-to-day operations. The City Manager’s Office – Administration is designed to lead special projects but relies on contributions from other departments for many.

A comprehensive list of all projects with correlating status updates is included in Attachment 1.

Next Steps
Staff will proceed to work on the pending strategic priority projects and will provide a progress update on the third quarter implementation of the FY 2025-27 Work Plan in April or May 2026. 35 INFORMATIONAL REPORT 6.1
Fiscal Impact
There is no fiscal impact for this item.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Government Code § 84308
Applicability of Levine Act: No, as this item does not entail an entitlement.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Council Strategic Priorities Work Plan Update October 1, 2025, through December 31, 2025 36 Goal ID Project Name Department Division Start Finish Progress Details - Q2 FY 2025-26 Completion Status CIV-1
Develop Recommendations for Establishing a
Youth Commission or Alternative Youth Civic
Engagement Program
City Manager's
Office Community Services 7/1/2025 3/31/2026
Staff coordinated with the City Manager’s Office to finalize next steps for City Council consideration. Due to higher-priority items requiring placement on the December City Council agenda, the item was deferred from the December agenda and scheduled for City Council consideration in January. *City Council approved establishment of a youth commission and youth task force in January 2026.

CIV-2 Implement Sister City and Cultural Exchange
Initiative
City Clerk City Clerk 7/1/2026 6/30/2027
Staff continued early coordination activities, including internal project planning and refinement of objectives and deliverables. Preliminary outreach and stakeholder identification efforts progressed, and internal coordination discussions were held to align roles, expectations, and sequencing. Staff also continued development of a draft framework for the EPA–Tongan Sister Cities Committee and refined a preliminary work plan to guide future implementation, with the understanding that the formal launch of activities will align with the project’s scheduled start timeline. *The City signed a formal Sister City partnerships with Tonga in January 2026.

CH-1 Complete Construction of 965 Weeks/Colibri
Commons
Community and
Economic
Development
Building and Code
Enforcement 7/1/2025 9/30/2025
The Chief Building Official issued the final Certificate of Occupancy on December 24, 2025, formally closing out the Colibri Commons project. With this milestone, the project reached full completion, delivering 136 new affordable housing units for the community.

CH-2 Develop and Launch Home Repair Program
Community and
Economic
Development
Housing 4/1/2026 6/30/2027
Staff continued coordination with the County to assess the feasibility of aligning City and County home repair programs and to advance program development efforts. Staff worked collaboratively with the County to support development of program guidelines and issuance of a joint Notice of Funding Availability (NOFA) in December, and review of proposal submittals in January and February. Staff also continued coordination related to program structure and administrative roles.

These activities further advanced readiness for program launch consistent with the project’s planned start timeline. *In January 2026, the City Council approved an agreement with San Mateo County to coordinate a one-year Senior Home Repair Program.

CH-3
Establish Rent Registry for Both RentStabilized and Market-Rate Rental Units Community and
Economic
Development
Rent Stabilization
Program
7/1/2025 3/31/2027
Staff advanced implementation of the Rent Stabilization Program (RSP) portion of the rent registry system. Additional system testing, initial legal review, and staff training were conducted to support launch readiness. The software vendor finalized fee configurations and issued required notices to landlords, and the City Council held a public hearing related to the program. The RSP database was launched in November, and staff established office hours to assist landlords with annual registration. In December, staff focused on education and outreach, continued training, and development of internal standard operating procedures to support ongoing administration of the program.

Attachment 1: City Council Strategic Priorities Work Plan Update October 1, 2025, through December 31, 2025 37 CH-4
Research Feasibility of a Financial
Empowerment and Foreclosure Prevention
Program
Community and
Economic
Development
Housing 1/1/2026 9/30/2026
Staff continued refining a potential program approach and conducted additional internal analysis to assess feasibility, resource requirements, and organizational capacity. This work focused on identifying viable program options and outlining considerations that would inform a future presentation to the City Council regarding feasibility, required resources, and potential implementation timing. A one-year Pilot Foreclosure Prevention Program, launched after City Council approval in October 2025 will help inform viable program options.

CH-5 Research Feasibility of a First-Time
Homebuyer Assistance Program
Community and
Economic
Development
Housing 10/1/2025 9/30/2026
During this period, staff met with the Housing Endowment and Regional Trust of San Mateo County (HEART) to develop a work plan and discuss alignment opportunities related to first-time homebuyer (FTHB) assistance. These discussions supported continued assessment of potential partnership approaches and informed early understanding of program models under consideration. In February, staff also began informational interviews with banks to learn more about their FTHB opportunities and potential partnerships.

CH-6 Research Feasibility of a Residential Rental
Inspection Program
Community and
Economic
Development
Building and Code
Enforcement 7/1/2025 6/30/2026
Staff continued researching residential rental inspection programs in other jurisdictions, including review of program models and associated funding mechanisms. This work supported further feasibility analysis and informed development of initial considerations related to program structure, costs, and resource requirements.

CH-7 Update the Inclusionary Housing Ordinance
Community and
Economic
Development
Housing 7/1/2025 6/30/2027
Staff advanced implementation efforts by initiating procurement for consultant support to assist with updates to the Inclusionary Housing Ordinance. An RFP for an Inclusionary Housing Project Manager was released, and proposals were reviewed and evaluated. Staff also brought the item forward for City Council consideration in December to support next steps in advancing ordinance amendments, and coordinated with related regional efforts, including participation in the San Mateo County Grand Nexus and Feasibility Study kickoff. Staff also began conducting research and preparing with the project manager for the March 2026 study session.

CH-8 Update the Zoning Code
Community and
Economic
Development
Planning 7/1/2025 6/30/2026
Staff completed and further refined draft Zoning Code amendments, including objective design standards, to address State housing requirements and streamline development review processes. Draft materials were finalized for internal review in preparation for subsequent public hearings.

GOV-1
Collaborate with the SMC Libraries to Identify
and Implement a Comprehensive Funding
Strategy for Library
City Manager's
Office CMO - Administration 7/1/2025 6/30/2027
During this period, work on a comprehensive library funding strategy with San Mateo County Libraries remained paused. Advancement of this effort is dependent on a City decision regarding whether the library project will be incorporated into the broader Civic Commons planning framework.

Deferred
GOV-2 Conduct Council Term Limit Policy Research City Clerk City Clerk 10/1/2025 9/30/2026 During this period, staff initiated the project and began coordinating with the City Attorney’s Office to define the scope of the policy research. Preliminary work included developing an initial list of comparable California cities for analysis. Staff also coordinated internally to discuss key timing considerations, including alignment with a future election cycle, to inform the overall research approach and project timeline.
38 GOV-3 Develop a 10-Year Fiscal Strategy and Address
the Structural Deficit Finance Finance 7/1/2025 3/31/2026 This project is temporarily on hold as staff reassess the project approach to refine the process and determine the next steps. The project is expected to resume in FY 2026-27
Deferred
GOV-4 Develop a Citywide Information Systems
Master Plan
City Manager's
Office
Information
Technology 7/1/2025 6/30/2026
The City Council awarded a contract for IT strategic planning services, and consultant work commenced. Initial project kickoff activities were completed, including early coordination and departmental interviews to inform development of the Citywide Information Systems Master Plan.

GOV-5 Implement a Centralized Grants Management
System
Finance Finance 7/1/2026 12/31/2026 This project is scheduled to begin in July 2026. Not Yet Scheduled to Begin GOV-6
Prepare 2026 Ballot Measure to Raise
Revenue for Infrastructure Improvements and
Public Facilities
City Manager's
Office CMO - Administration 7/1/2025 12/31/2026 Staff advanced early feasibility and planning efforts for a potential 2026 ballot measure to fund infrastructure and public facility improvements.

GOV-7 Update the City’s Personnel Policies and
Procedures
City Manager's
Office Human Resources 1/1/2026 6/30/2027
Staff continued preliminary planning activities in advance of the project’s scheduled start, including internal coordination and preparation to support a smooth launch at the beginning of the next calendar year.

GOV-8 Upgrade and Launch New City Website City Clerk City Clerk 7/1/2025 6/30/2027 Staff continued advancing early project development activities, including further assessment of the City’s website functionality and user experience, and refinement of key goals and success criteria. Work progressed on drafting the Request for Proposals (RFP) scope, and staff began research into municipal website best practices and emerging design trends to inform future development. In addition, staff convened a cross-departmental communications committee, with designated liaisons from each department, to support content review and updates to their respective webpages.

LU-1
Conclude Measure HH Pilot Evaluation and
Initiate Ongoing Workforce Development
Program
Community and
Economic
Development
Housing 7/1/2025 6/30/2027
The consultant completed the Measure HH Pilot Workforce Development Program evaluation, and staff concluded the associated contract. Building on the evaluation findings and City Council input, staff developed a preliminary framework for an ongoing workforce development program, including identification of priority populations and service outcomes to guide future implementation. 39 LU-2 Create an Economic Development Strategic
Plan Focusing on Small and Micro Businesses
City Manager's
Office CMO - Administration 7/1/2025 12/31/2025
The consultant team completed synthesis of community and stakeholder input and finalized the draft Economic Development Strategic Plan and community engagement summary. Staff reviewed the draft plan and prepared materials to support City Council consideration, marking completion of the planning phase and positioning the project for transition to implementation planning.

LU-3
Design and Implement a “Pop-Up”/Sidewalk
Vending Policy and Program
City Manager's
Office CMO - Administration 7/1/2025 12/31/2025
Staff continued outreach and engagement efforts in partnership with County and City departments to educate sidewalk vendors and gather additional input.

Feedback and policy considerations from this outreach were incorporated into a staff report presented to the City Council in December. At that meeting, the City Council provided direction to conduct additional outreach and engagement prior to advancing the ordinance. This direction informed refinement of the policy approach and identification of areas requiring further clarification related to vendor types, locations, and operating conditions.

LU-4
Implement Program to Distribute Community
Resource Funds Grants for Small Business
Assistance
City Manager's
Office CMO - Administration 7/1/2025 12/31/2026
Staff continued coordination with the City’s economic development consultants to refine the approach for distributing Community Resource Funds in alignment with the Economic Development Strategic Plan. Preliminary recommendations regarding program structure, eligibility, and administration were received in November and informed internal assessment of options to maximize impact for small, locally owned businesses. Advancement of the program remained focused on aligning design decisions with broader economic development strategies during the reporting period.

LU-5
Renovate the Cummings Loft Property into a
Small Business Incubator Public Works Engineering 7/1/2025 9/30/2026 During this period, the project was advertised for construction bids; however, no responsive bids were received. Staff subsequently initiated a rebidding process to address limited vendor interest and continue advancing the project toward construction.

PR-1
Complete Construction of Tenant
Improvements at City Facilities Public Works Engineering 7/1/2025 9/30/2026 During this period, construction activities continued across multiple City facilities.

Tenant improvement and roofing work at the Police Department facility were completed in December. At the Tate Street office building, major improvements—including roofing, flooring, and interior painting—were completed, with remaining work focused on final door replacements. 40 PR-2 Conduct a Comprehensive Evaluation of
Senior Service Agreements in East Palo Alto
City Manager's
Office Community Services 10/1/2025 12/31/2026
During this period, staff released the Request for Proposals (RFP) for the senior services evaluation and completed review and evaluation of submitted proposals.

Consultant interviews and selection activities were conducted in December, positioning the project to proceed to the next phase upon completion of the contract approval process.

PR-3 Construct Access Improvements at Rutgers
Street Entrance to the Bay Trail Public Works Engineering 7/1/2025 12/31/2025 During this period, pre-construction activities were completed and construction commenced at the Rutgers Street entrance to the Bay Trail. Site preparation and initial construction work advanced under the leadership of the Midpeninsula Regional Open Space District, with the City continuing to support coordination and implementation efforts. Early planning for a future community opening event was also initiated in coordination with project partners.

PR-4 Create a Pilot Dog Park City Manager's
Office Community Services 7/1/2025 9/30/2026
During this period, staff and the consultant advanced design development for the pilot dog park project. Key permitting requirements were identified, and design coordination continued to support preparation of construction documents. These activities moved the project further toward readiness for procurement while maintaining alignment with the overall project schedule.

PR-5
Establish a Joint Use Agreement with RCSD for
Shared Recreation Sites
City Manager's
Office Community Services 7/1/2025 6/30/2026
Staff and the Ravenswood City School District continued negotiations to refine the terms of a joint use agreement, with focus on operational details and liability considerations. Discussions progressed through December as both parties worked toward finalizing a mutually beneficial arrangement to support shared community access to recreation facilities.

PR-6 Expand EPACENTER Services and Programs
Through City Funding
City Manager's
Office Community Services 7/1/2025 6/30/2027
Staff completed final execution of the funding agreement with EPACENTER and supported initiation of funded program activities. Early implementation efforts moved forward as planned, and staff began internal coordination to assess future funding considerations to support continuity and potential expansion of arts programming.

PR-7
Finalize Architectural Design for the New East
Palo Alto Library Public Works Engineering 7/1/2025 12/31/2026 The project is still on hold pending further direction related to the new Civic Commons project, which will incorporate the future East Palo Alto Library as part of a larger civic campus development. Council direction on next steps is expected in March 2026.

Deferred
41 PR-8 Implement Priority Projects from the Parks,
Recreation and Open Space Master Plan Public Works Engineering 7/1/2025 6/30/2027 Staff advanced implementation of priority projects identified in the Parks, Recreation and Open Space Master Plan. Initial efforts focused on advancing the pilot dog park as an early, visible improvement, with design development progressing and preparatory work underway to support procurement. This work establishes a foundation for subsequent small-scale park enhancements to be implemented as additional projects move forward.

PR-9 Negotiate with County to Finalize Acquisition
of Beech Street
City Manager's
Office CMO - Administration 7/1/2025 12/31/2025 A three party memorandum of understanding that will advance this effort will be presented to the City Council on 2/24/2026.

PR-10 Plan for Development of New Civic Center
Facility
City Manager's
Office CMO - Administration 7/1/2025 12/31/2026
Staff continued advancing planning efforts for the proposed Civic Center facility with a focus on evaluating potential funding strategies to support future phases.

Work remained centered on assessing feasibility of a potential ballot measure as a primary funding mechanism, while staff also conducted preliminary outreach to external partners and philanthropic organizations to explore supplemental funding opportunities. Coordination continued with internal departments and project partners to align planning assumptions as funding options are evaluated.

PR-11
Expand Access to YMCA Programming and
Services for the Greater East Palo Alto
Community
City Manager's
Office Community Services 7/1/2025 6/30/2027
Expanded YMCA programming moved from soft launch into active implementation.

Initial programs launched in late October and early participation met first-quarter targets, demonstrating early community uptake. Staff continued coordination with the YMCA to monitor participation levels, refine outreach strategies, and support enrollment growth across program offerings, with an emphasis on youth programming. The City maintained a supporting role to ensure alignment with program goals and accessibility commitments as implementation progressed.

PH-1 Expand Parking Enforcement Capacity Police Police 7/1/2025 12/31/2026 During this period, staff advanced implementation of the parking enforcement expansion by completing the procurement phase. The Request for Proposals was released, proposals were received and evaluated, and a recommended vendor was identified for City Council consideration.

PH-2 Implement a Crime Data Analytics Platform
for the Police Department Police Police 7/1/2025 6/30/2027 The Police Department continued evaluating options to expand crime data analytics capacity, with a focus on potential alignment with County-led platforms.

Staff monitored the County’s development and assessment of emerging crime analytics tools and participated in discussions to better understand their functionality, scalability, and applicability to East Palo Alto’s public safety needs.

This coordination is informing the City’s approach to selecting an appropriate platform and determining the most effective path forward for implementation.

PH-3 Implement a Shopping Cart Abatement
Program
City Manager's
Office CMO - Administration 1/1/2026 6/30/2027
During this period, no substantive project activity occurred, as the Shopping Cart Abatement Program remains scheduled to begin in early 2026. Staff did not initiate implementation activities during the reporting period.

Not Yet Scheduled to Begin
42 PH-4 Launch a Residential Parking Permit Program Public Works Engineering 7/1/2025 12/31/2026 During this period, work on the Residential Parking Permit Program remained paused in accordance with prior City Council direction. Staff maintained coordination with the City Attorney’s Office to ensure readiness to advance the draft ordinance once further direction was provided.

PH-5 Launch Emergency Preparedness Program City Manager's Office CMO - Administration 7/1/2025 6/30/2027
Staff continued advancing the City’s Emergency Preparedness Program through training, planning, and internal coordination. The City participated in the Great ShakeOut earthquake drill and conducted follow-up evaluation to inform future preparedness efforts. Staff convened regular flood preparedness coordination meetings and continued work associated with the Local Hazard Mitigation Plan.

Internal training and capacity-building efforts expanded, including two Emergency Operations Center (EOC) workshops and tabletop exercises held in November and December to familiarize staff with the Emergency Operations Plan and emergency roles. Feedback from these sessions informed refinement of training approaches and future exercises. Staff also developed an administrative emergency guide to support operational readiness and established a framework for distribution of emergency preparedness supplies to the community. Preparedness activities during the reporting period emphasized education, readiness, and organizational capacity-building.

PH-6 Maintain Senior/Disabled Individuals’
Emergency Contact Database
City Manager's
Office Community Services 1/1/2026 12/31/2026
Preparatory coordination continued in advance of initiating outreach to partners and community organizations that support emergency contact systems for seniors and individuals with disabilities. Staff focused on aligning this effort with related senior services work to ensure future updates to the emergency contact database are informed by coordinated engagement and assessment activities.

PH-7 Strengthen the Clean City Program to Reduce
Illegal Dumping Public Works Environmental and Sustainability 7/1/2025 9/30/2026
Staff continued implementation of Clean City education and outreach efforts, including distribution of the City’s sustainability newsletter and identification of priority locations for installation of “No Dumping” signage. These activities supported expanded public awareness and prevention strategies aimed at reducing illegal dumping.

PH-8 Update the Environmental Justice Element of
the General Plan
Community and
Economic
Development
Planning 7/1/2025 6/30/2026
Staff advanced development of the Environmental Justice Element update by completing public outreach activities and continuing work on the supporting technical analyses. Draft technical appendices were developed and refined in December to inform subsequent policy development and preparation of the Environmental Justice Element.
43 PH-9 Update the Safety Element of the General
Plan
Community and
Economic
Development
Planning 7/1/2025 6/30/2026
Staff advanced development of the Safety Element update by drafting policies informed by community input and preparing a draft document for public review.

These efforts represented a transition from reassessing the project approach to advancing substantive policy content in support of the updated Safety Element.

PI-1 Assess Utility Operations and Prepare
Transition Plan for Post-Lease Operations
City Manager's
Office CMO - Administration 7/1/2025 6/30/2027
Staff continued coordination related to planning for post-lease utility operations, with work remaining focused on water operations. Discussions regarding a shortterm contract extension with the current service provider continued (especially around the true-up costs), supporting additional time for future transition planning.

PI-2 Build Sidewalk and Pedestrian Safety
Improvements on East Bayshore Road Public Works Engineering 7/1/2025 9/30/2026 The project kickoff was completed and the construction agreement was fully executed. Pre-construction coordination continued with the contractor to prepare for the start of construction activities.

PI-3 Collaborate with City of Palo Alto to Replace
the Newell Street Bridge Public Works Engineering 7/1/2025 6/30/2027 Early site preparation activities were completed, including limited tree removal in advance of construction. Project coordination continued under the leadership of the City of Palo Alto, with construction sequencing influenced by required environmental restrictions related to nesting bird protections.

PI-4
Collaborate with SFCJPA to Construct San
Francisquito Creek Flood Protection Upgrades Public Works Engineering 7/1/2025 6/30/2027 During this period, the San Francisquito Creek Flood Protection project continued through study and evaluation, with proposed improvements undergoing formal review by partner agencies within the Joint Powers Authority. City staff remained engaged in coordination and provided input as part of the multi-agency review process supporting advancement of flood protection planning.

PI-5
Collaborate with SFCJPA to Implement the
SAFER Bay Project
Public Works Engineering 7/1/2025 6/30/2027
Design development for the SAFER Bay Project continued in coordination with the San Francisco Bay Joint Powers Authority and regional partners. In parallel, staff advanced planning for a City-managed project segment along Bay Road, refining the scope and approach to ensure consistency with the broader SAFER Bay Project.

Coordination with State partners supported determination of an appropriate procurement strategy for this segment, and staff continued alignment efforts to maintain a coordinated project timeline across related phases. 44 PI-6 Conduct a Siting Study to Identify Locations
for Additional Water Storage Tanks Public Works Engineering 7/1/2025 3/31/2026 The consultant continued development of the water storage tank siting study, incorporating staff review and feedback. Additional technical analysis and coordination were undertaken to address comments and refine the study, and work progressed toward completion of a draft suitable for future review.

PI-7 Construct a Bicycle and Pedestrian
Overcrossing on University Avenue at US 101
Public Works Engineering 7/1/2025 3/31/2026
Construction of the bicycle and pedestrian overcrossing reached substantial completion, and project closeout activities advanced. A community ribbon-cutting event was held in December to mark the opening of the overcrossing. Additional follow-up items were identified during the closeout process, and coordination with project partners continues to address remaining requirements.

PI-8 Construct Full Trash Capture Devices to Meet
Stormwater Compliance Requirements Public Works Engineering 7/1/2025 3/31/2026 The construction contract was fully executed and a purchase order was issued, enabling construction activities to proceed. Installation work for the full trash capture device advanced during the reporting period, with construction underway and progressing as planned.

PI-9 Construct Mini Roundabouts to Replace
Temporary Traffic Circles on Pulgas Avenue Public Works Engineering 7/1/2025 6/30/2026 During this period, construction activities advanced on the Pulgas Avenue mini roundabout project. Initial construction work was completed, with remaining elements—such as roadway striping—temporarily deferred due to seasonal weather conditions requiring dry installation. The project remains positioned to resume once conditions allow.

PI-10 Create a Financing Strategy for Water
Infrastructure Upgrades Public Works Engineering 10/1/2025 12/31/2026 During this period, project activities did not advance. The project is on hold pending further direction and alignment of resources to support development of a financing strategy for water infrastructure upgrades. The project is expected to resume in FY 2026-27.

Deferred
PI-11
Design Roadway Improvements on Woodland
Avenue
Public Works Engineering
During this period, the City was awarded grant funding to support the Woodland Avenue roadway design effort. Following award notification in December, staff began internal coordination in preparation for execution of the grant agreement, which will enable initiation of the design phase once finalized. 45 PI-12 Develop an Asset Management Database Public Works Maintenance 7/1/2025 9/30/2026 During this period, no additional development work was completed on the asset management database. Project activities remained paused as staff prioritized other critical infrastructure and capital planning efforts.

PI-13 Develop Citywide Sewer Infrastructure Master
Plan Public Works Engineering 7/1/2025 6/30/2026 The project is complete.

PI-14 Install Citywide Lighting Improvements –
Phase II Public Works Engineering 7/1/2025 6/30/2027
Staff reassessed the procurement approach for Phase II of the citywide lighting improvements and initiated a rebidding process to ensure alignment with project goals and implementation needs. Preparatory work continued to position the project for contract award and subsequent initiation of the lighting study.

PI-15
Install New Traffic Signal and Complete Safety
Upgrades on University Avenue at
Runnymede
Public Works Engineering 10/1/2025 9/30/2026
During this period, the construction agreement was fully executed and the project was formally initiated. Pre-construction coordination advanced as staff worked with the contractor to prepare for construction activities.

PI-16 Modernize Equipment and Complete
Rehabilitation of the O’Connor Pump Station Public Works Engineering 10/1/2025 6/30/2027 Phase I improvements addressing critical piping upgrades were completed at the O’Connor Pump Station. The project subsequently advanced into Phase II, with design development underway for replacement of diesel pumps and associated electrical system upgrades to support improved long-term reliability and stormwater capacity.
46 INFORMATIONAL REPORTS 6.2

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: March 3, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
SUBJECT: Informational report regarding February 23, 2026, Almanac News Article Concerning Former On-Call Employee Rafael Prado Caballero
Recommendation
Receive an informational report from staff regarding February 23, 2026, Almanac News Article Concerning Former On-Call Temporary Employee Rafael Prado Caballero Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:

Priority: Governance, Organizational Strength, and Fiscal Sustainability Priority: Public Health, Safety, and Quality of Life
Background
On February 23, 2026, The Almanac News published an article written by Arden Margulis titled, “Charged with child sex abuse, East Palo Alto employee gets character reference from council member.” The article concerns an ongoing criminal prosecution brought by the San Mateo County District Attorney’s Office against former on-call temporary City employee Rafael Prado Caballero, who has been charged with five felony counts involving an alleged minor victim.

Given the seriousness of the allegations and the public attention generated by the article, this report provides the City Council and the public with additional context given that the City had employed Mr. Prado on an on-call temporary basis. Specifically, this report addresses the gravity of the alleged harm and the role of the judicial process; the City’s hiring practices and background procedures; clarification of Mr. Prado’s employment status and duties; the permissibility of Councilmember Carlos Romero’s July 2, 2025, character reference letter; and clarification of ambiguous or inaccurate statements contained in the article. This report is provided for informational purposes only.
47 INFORMATIONAL REPORTS 6.2
Analysis
Gravity of the Allegations and Judicial Accountability
The allegations described in the article are extremely serious. Crimes involving the sexual exploitation or abuse of a minor are among the most severe offenses under California law. If proven true, such conduct would be reprehensible and subject to significant criminal penalties.

The City does not minimize the gravity of these charges. The criminal justice system is responsible for determining the facts, ensuring due process, and imposing consequences where appropriate. Mr. Prado is entitled to due process under the law, and the alleged victim is entitled to justice if the charges are sustained. Nothing in this report should be interpreted as commentary on the merits of the prosecution. The purpose of this report is limited to providing additional context concerning the City’s administrative role and responsibilities.

Employment Status and Scope of Duties
Mr. Prado was not a full-time or benefited City employee. He served as a part-time, temporary, on-call support aide from July 11, 2022 through April 2, 2025. On-call classifications are used to provide supplemental assistance on an as-needed basis. Employees in this classification do not have guaranteed hours or regular schedules and are limited to approximately 960 hours per fiscal year. In practice, their work is limited, intermittent and dependent entirely on operational need, and there may be extended periods during which no assignments are performed.

Mr. Prado’s last day worked was April 2, 2025. The City received a Subsequent Arrest Notification from the California Department of Justice in June 2025, approximately two months after his last assignment. His separation date reflects the intermittent nature of on-call employment and was not the result of a disciplinary termination.

With respect to his job responsibilities, Mr. Prado provided administrative and logistical support.

His assignments included assisting with COVID-19 vaccination clinics, performing general office support such as filing and answering phones, and participating in limited community outreach activities such as canvassing. Based on all information available to the City, he was not assigned to work at the East Palo Alto Library. The City cannot assign employees to the library, which is operated by San Mateo County Libraries and not by the City of East Palo Alto. He did not hold a direct youth-serving position, and the City is not aware of any job duties that required him to be in isolated contact with minors.

The article states that prosecutors allege Mr. Prado met the victim at the library sometime between late 2022 and 2023 and then notes that he was working for the City during that period.

This sequencing may suggest a connection between his City employment and the alleged meeting. However, the article does not explain how the alleged meeting was connected to any assigned municipal duties. To date, the City has not been provided documentation establishing a nexus between Mr. Prado’s job responsibilities and the alleged conduct giving rise to the criminal charges outlined in the article.
48 INFORMATIONAL REPORTS 6.2
Hiring Practices and Background Procedures
All City hires undergo fingerprinting and criminal background checks through the Department of Justice. The City also receives Subsequent Arrest Notifications, which provide notice if a previously backgrounded employee is later arrested.

In its hiring practices, the City endeavors to comply with all applicable labor and employment laws, including those consistent with public policy goals of rehabilitation and reducing barriers to employment. Accordingly, the City evaluates criminal history based on several factors, including the nature and gravity of the offense, the time elapsed, the relationship between the offense and the job duties at issue, and evidence of rehabilitation. For example, the California Fair Chance Act (AB 1008; the “Act”), effective since January 1, 2018, prohibits employers with five or more employees from asking about or considering an applicant's criminal history before making a conditional job offer. This “Ban the Box” law requires an individualized assessment if a record is found, allowing applicants to dispute the findings.

Although Mr. Prado was hired prior to the tenure of the current City Manager, City Attorney, and Human Resources Manager, the City’s standard hiring procedures were in place at the time of his employment. There is no indication that he had disqualifying convictions at the time he was hired.

Although the City cannot and will not produce confidential and sensitive personnel record or information, staff can share that after learning of Mr. Prado’s arrest in July 2025, the City Manager directed that he not be assigned any further work pending resolution of the criminal matter. At that time, he had not performed any work for the City for approximately two months.

Character Reference Letter
On July 2, 2025, Councilmember Carlos Romero authored a character reference letter on behalf of Mr. Prado. The letter was written on letterhead bearing the City seal; however, it also included language specifying the letter as from the “Office of Councilmember Carlos Romero.” The City has not conducted a full analysis of the propriety of issuance of the character reference letter. However, staff will note that the City’s Code of Ethics and Conduct for Elected and Appointed Officials (Attachment 1) permits Councilmembers to express personal opinions and provide references in their individual capacities, provided they do not represent that they are speaking on behalf of the City Council as a body unless authorized to do so. Councilmembers retain independent constitutional rights, including their First Amendment right to free expression, and may provide character references as private individuals.

Significantly, there is no evidence that the letter constituted an official action of the City Council or that it reflected a position adopted by the City as an institution.

Clarification of Ambiguous Statements in the Article
The City Manager raised concerns to the Almanac regarding the framing of the article and its 49 INFORMATIONAL REPORTS 6.2
headline because the phrase “East Palo Alto employee” may reasonably be interpreted by readers as referring to a current or regular employee. But city staff reiterate here that Mr. Prado was neither a current employee nor a full-time staff member at the time of publication.

In addition, the article juxtaposes the allegation that Mr. Prado met the victim at the library with the statement that he was employed by the City at that time, without clearly establishing a factual nexus between the two. The article does not clarify that the City does not operate the library, which is a relevant distinction when assessing whether any alleged meeting occurred in an official capacity.

Following communication with the newspaper’s editor, The Almanac added language stating that the City is “not aware” of any job duties requiring isolated contact with minors. However, the article also falsely states that the City Manager “denied that Prado met the teen as part of his work for the city.” That characterization is inaccurate. At no time did the City Manager deny that such a meeting occurred. The City Manager stated only that the City has no evidence establishing that any alleged meeting occurred in connection with assigned municipal duties. As with all matters of this nature, the full facts and circumstances tend to be revealed over time. At this early stage, the City Manager would have no basis for making such and assertion, and indeed, made no such assertion. The distinction between a denial and a statement that no evidence establishes a connection is significant. Specifically, it demonstrates that the City has not prejudged the situation, which is particularly important in matters involving serious criminal allegations and potential reputational implications for all involved, the victim, alleged perpetrator, etc. Nevertheless, the City maintains without more evidence it is not able to make a definitive statement on whether the alleged conduct and Mr. Prado’s employment had simply occurred around the same time or was linked in some more substantial way.

The City Manager’s communications to The Almanac News are attached for reference (Attachment 2).

Conclusion
The City of East Palo Alto remains committed to transparency, lawful process, and the protection of public trust. This report affirms the seriousness of the allegations and the importance of accountability through the judicial system, clarifies the limited and intermittent nature of Mr.

Prado’s employment, explains the City’s background check and arrest notification procedures, addresses questions regarding the character reference letter, and corrects inaccurate or ambiguous public statements.

Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto.

Environmental
50 INFORMATIONAL REPORTS 6.2
The action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (CEQA), pursuant to CEQA Guideline section 15378 (b)(5), in that it is a government administrative activity that will not result in direct or indirect changes in the environment.

Government Code § 84308
Applicability of Levine Act: No, as it does not involve an entitlement.

Analysis of Levine Act Compliance: Not applicable.

Attachments

1. Code of Ethics and Conduct for Elected and Appointed Officials

2. City Manager’s Communications with the Almanac
51 Administrative Policy
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EXHIBIT A

ADMINISTRATIVE POLICY
SUBJECT: CODE OF ETHICS AND CONDUCT FOR ELECTED AND APPOINTED

OFFICIALS
SECTION 1: POLICY
This policy shall be referred to as the Code of Ethics and Conduct for Elected and Appointed Officials (“Code of Ethics and Conduct”).

SECTION 2: PURPOSE
The City of East Palo Alto (“City”) has established this Code of Ethics and Conduct for members of the City Council and the City’s boards, commissions, and committees to assure public confidence in the integrity of local government and its effective and fair operation. The Code of Ethics and Conduct is designed to describe the manner in which Councilmembers and members of City boards, commissions, and committees should treat one another, City staff, constituents, and others they come into contact with while representing the City of East Palo Alto.

SECTION 3: APPLICABILITY
This Code of Ethics and Conduct applies to the East Palo Alto City Council (“City Council”), and City boards, commissions, and committees (“Advisory Bodies”). For ease of reference in the Code of Ethics and Conduct, the term “Member” refers to any member of the City Council or City Advisory Bodies established by City ordinance, resolution, or Council policy.

SECTION 4: ETHICS
A. Introduction: The residents and businesses of the City are entitled to have fair, ethical and accountable local government. To this end, the public should have full confidence that their elected and appointed officials:

1. Comply with both the letter and spirit of the laws and policies affecting the operations of government;

2. Are independent, impartial and fair in their judgment and actions;

3. Use their public office for the public good, not for personal gain; and

4. Conduct public deliberations and processes openly, unless required by law to be confidential, in an atmosphere of respect and civility. 52 Administrative Policy
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B. Rule: Members shall comply with all applicable ethics laws, rules, and guidelines, including those set forth in this section.

C. Act in the Public Interest: Recognize that stewardship of the public interest must be their primary concern, and that Members will work for the common good of the people of East Palo Alto and not for any private or personal interest, and will assure fair and equal treatment of all persons, claims and transactions coming before them.

D. Comply with both the spirit and the letter of the Law and City Policy: Members shall comply with the laws of the nation, the State of California, and the City of East Palo Alto in the performance of their public duties.

E. Conduct of Members: The professional and personal conduct of Members while exercising their office must be above reproach and avoid even the appearance of impropriety. Members shall refrain from abusive conduct, personal charges or verbal attacks upon the character or motives of other members of City Council, Advisory Bodies, City staff or the public.

F. Respect for Process: Members shall perform their duties in accordance with the processes and rules of order established by the City Council.

G. Conduct at Public Meetings: Members shall prepare themselves for public issues, listen courteously and attentively to all public discussions before the body, and focus on the business at hand.

H. Decisions Based on Merit: Members shall base their decisions on the merits and substance of the matter at hand, rather than on unrelated considerations. When making adjudicative decisions (those decisions where the Member is called upon to determine and apply facts particular to an individual case), Members shall maintain an open mind until the conclusion of the hearing on the matter and shall base their decisions on the facts presented at the hearing and the law.

I. Communication: For adjudicative matters pending before the body, Members shall refrain from receiving information outside of an open public meeting or agenda materials, except on advice of the City Attorney. Members shall publicly disclose substantive information that is relevant to a matter under consideration by the body which they may have received from sources outside of the public decision-making process.

J. Conflict of Interest: In order to assure their independence and impartiality on behalf of the common good and compliance with conflict of interest laws, Members shall use their best efforts to refrain from creating an appearance of impropriety in their actions and decisions.

Members shall not use their official positions to influence government decisions in which they have (1) a material financial interest, (2) an organizational responsibility or personal relationship which may give the appearance of a conflict of interest, or (3) a strong personal bias.
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A Member who has a potential conflict of interest regarding a particular decision shall disclose the matter to the City Attorney and reasonably cooperate with the City Attorney to analyze the potential conflict. If advised by the City Attorney to seek advice from the Fair Political Practices Commission (“FPPC”) or other appropriate state agency, a Member shall not participate in a decision unless and until he or she has requested and received advice allowing the Member to participate. A Member shall diligently pursue obtaining such advice.

The Member shall provide the Mayor and the City Attorney a copy of any written request or advice, and conform his or her participation to the advice given. In providing assistance to Members, the City Attorney represents the City and not individual members.

In accordance with the law, Members shall disclose investments, interests in real property, sources of income, and gifts; and if they have a conflict of interest regarding a particular decision, shall not, once the conflict is ascertained, participate in the decision and shall not discuss or comment on the matter in any way to any person including other members unless otherwise permitted by law.

K. Gifts and Favors: Members shall not take any special advantage of services or opportunities for personal gain, by virtue of their public office that is not available to the public in general.

Members shall refrain from accepting any gifts, favors or promises of future benefits which might compromise their independence of judgment or action or give the appearance of being compromised.

L. Confidential Information: Members must maintain the confidentiality of all written materials and verbal information provided to Members which is confidential or privileged. Members shall neither disclose confidential information without proper legal authorization, nor use such information to advance their personal, financial or other private interests.

M. Use of Public Resources: Members shall not use public resources which are not available to the public in general (e.g., City staff time, equipment, supplies or facilities) for private gain or for personal purposes not otherwise authorized by law.

N. Representation of Private Interests: In keeping with their role as stewards of the public interest, members of City Council shall not appear on behalf of the private interests of third parties before the City Council or any Advisory Body or proceeding of the City, nor shall members of any Advisory Body appear before their own bodies or before the City Council on behalf of the private interests of third parties on matters related to the areas of service of their bodies.

O. Advocacy: Members shall represent the official policies or positions of the City Council, or Advisory Body, to the best of their ability when designated as delegates for this purpose.

When presenting their individual opinions and positions, Members shall explicitly state they do not represent their Advisory Body or the City of East Palo Alto, nor will they allow the inference that they do. Councilmembers and Advisory members have the right to endorse candidates for all Council seats or other elected offices. However, it is inappropriate to mention or display endorsements during City Council meetings, or Advisory Body meetings, or other official City meetings.
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P. Policy Role of Members: Members shall respect and adhere to the council-manager structure of City government as outlined in the East Palo Alto Municipal Code. In this structure, the City Council determines the policies of the City with the advice, information and analysis provided by City staff, Advisory Bodies, and the public. Except as provided by the East Palo Alto Municipal Code, Members shall not interfere with the administrative functions of the City or the professional duties of City staff, nor shall they impair the ability of City staff to implement Council policy decisions.

Q. Independence of Advisory Bodies: Members of City Council shall refrain from using their position to unduly influence the deliberations or outcomes of Advisory Body proceedings.

This is necessary due to the value of the independent advice of Advisory Bodies to the public decision-making process.

R. Positive Workplace Environment: Members shall support the maintenance of a positive and constructive workplace environment for City employees and for residents and businesses interacting with the City. Members shall recognize their special role in dealings with City employees and shall not create the perception of inappropriate direction to City staff.

SECTION 5: CONDUCT RULES
The Conduct Rules set forth in Sections 6-14 are designed to describe the manner in which Members should treat one another, City staff, constituents, and others they come into contact with while representing the City of East Palo Alto.

SECTION 6: ELECTED AND APPOINTED OFFICIALS’ CONDUCT WITH EACH

OTHER IN PUBLIC MEETINGS
A. Introduction: Members are individuals with a wide variety of backgrounds, personalities, values, opinions, and goals. Despite this diversity, all have chosen to serve in public office in order to preserve and protect the present and the future of the community. In all cases, this common goal should be acknowledged even though individuals may not agree on every issue.

B. Respect the Chair: It is the responsibility of the chair to keep the comments of Members on track during public meetings. Members should respect efforts by the chair to focus discussion on current agenda items. If there is disagreement about the agenda or the chair’s actions, those objections should be voiced politely and with reason, following procedures outlined in parliamentary procedure.

C. Practice Civility and Decorum: Difficult questions, tough challenges to a particular point of view, and criticism of ideas and information are legitimate elements of debate by a free democracy in action. However, free debate does not require nor justify public officials to make belligerent, personal, impertinent, slanderous, threatening, abusive, or disparaging comments.
55 Administrative Policy
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D. Avoid Offensive Comments: If a Member is personally offended by the remarks of another member, the offended member should make notes of the actual words used and call for a "point of personal privilege" that challenges the other member to justify or apologize for the language used. The chair will maintain control of this discussion.

E. Demonstrate Effective Problem-solving Approaches: Members have a public stage and have the responsibility to show how individuals with disparate points of view can find common ground and seek a compromise that benefits the community as a whole.

SECTION 7: CITY COUNCIL AGENDA SETTING
A. Agenda Setting Process:

1. The Agenda Committee. The Agenda Committee is comprised of the Mayor and Vice Mayor. The charge of the Agenda Committee is to work with Staff to plan City Council Meetings. There are three primary purposes to Agenda Committee meetings: 1) to plan how City Council Meetings will be conducted, including review of approximate time allocations for agenda item presentations and to ensure adequate time for large complex items; 2) to identify any issues or questions that may need greater staff preparation for the meeting; and 3) to discuss future meetings, including items to be included on future meeting agendas.

Consideration in building the agenda should be given to the potential length of the meeting and at what point items of significant public concern may be heard. The purpose of the meeting is not to work on policy issues. Normally, the Mayor and Vice Mayor attend the Agenda Committee meetings with the City Manager, City Attorney, and other staff, as appropriate. The Mayor and Vice Mayor’s roles are to represent the interests of the entire Council.

2. Councilmember Requests to the Agenda Committee. A City Council member may submit a request to the Agenda Committee to add a matter to a future meeting agenda. The request may be written directly to the Agenda Committee or made verbally under Council Reports at any public meeting of the Council. The request will be considered at the Agenda Committee meeting.
i. The Decision. The Agenda Committee may grant any such request as a matter of courtesy without further discussion and will agendize the requested item for a future agenda as soon as practicable, considering staff input on operational and budgetary capacity. If the Agenda Committee is unable to arrive at a consensus on the request, the Mayor or Vice Mayor may grant the request outright.

If the Agenda Committee denies the request, then the requesting councilmember may make the request through the City Manager. In that instance, the City Manager would ensure an item would be added to the next City Council meeting agenda under “Council Reports” to discuss the request for the item to be added to another future agenda. When discussing the request during “Council Reports,” as an ordinary agenda item where parliamentary rules of procedure apply, the entire Council would consider the request to add the item to a future agenda. If a 56 Administrative Policy
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majority of the Council votes to grant the request, the councilmember who made the request will work with the City Manager and a member of the Agenda Committee to agendize the requested item for a future agenda, as soon as practicable considering staff input on operational and budgetary capacity, on a date agreed upon by the councilmember, Agenda Committee representative, and the City Manager.

B. Proclamations: To the extent possible, Councilmembers must submit Proclamations requests to the Mayor or Vice Mayor and the City Clerk at least two weeks in advance of the event for recognition of the person who is the subject of the Proclamation. The Proclamation must have a contact name, email/phone number, and a sample of the wording.

C. Special Presentations: Councilmembers must submit requests for special presentations to the Mayor/Vice Mayor for consideration of agenda placement at the Mayor/Vice Mayor meeting.

D. Letter of Support: If a letter of support is written in an individual Councilmember’s capacity, the letter shall reflect that it reflects only the viewpoint of the author and not the full City Council. The author shall provide the City Clerk a copy of the letter for official retention.

SECTION 8: ELECTED AND APPOINTED OFFICIALS’ CONDUCT WITH THE

PUBLIC IN PUBLIC MEETINGS
A. Introduction: Making the public feel welcome is an important part of the democratic process.

No signs of partiality, prejudice or disrespect should be evident on the part of individual members toward an individual participating in a public forum. Every effort should be made to be fair and impartial in listening to public testimony.

B. Equitable Time Limits: The chair will determine and announce limits on speakers at the start of the public hearing process.

C. Practice Active Listening: While questions or clarification may be asked, a Member’s primary role during public testimony is to listen.

D. Maintain an Open Mind: The public deserves an opportunity to influence the thinking of elected and appointed officials and Members shall maintain an open mind.

E. Avoid Debate or Argument: Only the chair – not individual members – can interrupt a speaker during a presentation. However, a Member can ask the chair for a point of order if the speaker is off the topic or exhibiting behavior or language the Member finds disturbing.

SECTION 9: ELECTED AND APPOINTED OFFICIALS’ CONDUCT WITH THE

CITY STAFF
A. Introduction: Governance of a City relies on the cooperative efforts of elected officials, who set policy, appointed officials who advise the elected officials, and City staff who implement and administer the City Council’s policies. Therefore, every effort should be made to be cooperative and show mutual respect for the contributions made by each individual for the good of the community.
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B. Respect City Staff: Clear, honest communication that respects the abilities, experience, and dignity of each individual is expected. Poor behavior towards City staff is not acceptable.

C. Council Requests to City Manager: City Council requests that deal with policy or fiscal issues or requests that may be construed as direction shall be directed to the City Manager.

City Council members may contact department directors for general inquiries or questions.

City Council members may also correspond directly with the City Attorney.

D. Council Agenda Questions: City Council requests for answers to questions on council agenda items should be submitted to the City Manager, City Attorney or relevant department director or manager prior to the meeting whenever possible.

E. Avoid Disruption: Members should not disrupt City staff while they are in meetings, on the phone, or engrossed in performing their job functions in order to have their individual needs met. Members should not attend City staff meetings unless requested by City staff, as the Member’s presence may imply support, show partiality, intimidate City staff, or hamper City staff’s ability to do their job objectively.

F. Refrain from Public Criticism: Members should never express concerns about the performance of a City employee in public, to the employee directly, or to the employee’s manager. Councilmember comments about City staff performance should only be made to the City Manager or City Attorney through private correspondence or conversation.

Appointed officials should make their comments regarding City staff to the City Manager, City Attorney, or the Mayor.

G. Avoid Administrative Functions: Members acting in their individual capacity must not attempt to influence City staff on the making of appointments, awarding of contracts, selecting of consultants, processing of development applications, or granting of City licenses and permits.

H. Refrain from Political Influence: Members should not solicit any type of political support (financial contributions, display of posters or lawn signs, name on support list, etc.) from City staff. City staff may, as private citizens with constitutional rights, support political candidates but all such activities must be done away from the workplace.

I. No Attorney-Client Relationship: Members shall not seek to establish an attorney-client relationship with the City Attorney, including his or her staff, and attorneys contracted to work on behalf of the City. The City Attorney represents the City and not individual members. Members who consult with the City Attorney cannot enjoy or establish an attorney-client relationship with the City Attorney.

SECTION 10: CITY COUNCIL CONDUCT WITH ADVISORY BODIES
A. Introduction: The City has established several Advisory Bodies as a means of gathering more community input. Residents who serve on Advisory Bodies become more involved in government and serve as advisors to the City Council. They are a valuable resource to the City’s leadership and should be treated with appreciation and respect. 58 Administrative Policy
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B. Conduct at Advisory Body Meetings: Councilmembers may attend any Advisory Body meeting, which are always open to any member of the public. However, Councilmembers should be sensitive to the way their participation – especially if it is on behalf of an individual, business or developer – that could be viewed as unfairly affecting the process.

Any public comments by a Councilmember at an Advisory Body meeting should be clearly made as individual opinion and not a representation of the viewpoint of the entire City Council. Individual Councilmembers are also responsible to ensure compliance with the Brown Act at all times.

C. Limit Contact with Advisory Body Members: It is inappropriate for a Councilmember to contact an Advisory Body member to lobby on behalf of an individual, business, or developer, and vice versa. It is acceptable for Councilmembers to contact Advisory Body members in order to clarify a position taken by the Board, Committee or Commission.

D. Respect the Role of Advisory Body Members: The City Council appoints individuals to serve on Advisory Bodies, and it is the responsibility of Advisory Bodies to follow policy established by the City Council. However, Advisory Body members do not report to individual Councilmembers, nor should Councilmembers feel they have the power or right to threaten Advisory Body members with removal if they disagree about an issue. Appointment and re-appointment to an Advisory Body should be based on such criteria as expertise, ability to work with City staff and the public, and commitment to fulfilling official duties. A Board, Committee, or Commission appointment should not be used as a political "reward." E. Be Respectful of Diverse Opinions: A primary role of Advisory Bodies is to represent many points of view in the community and to provide the City Council with advice based on a full spectrum of concerns and perspectives. Councilmembers may have a closer working relationship with some individuals serving on Advisory Bodies, but must be fair and respectful of all residents serving on Advisory Bodies.

F. Refrain from Political Influence: Advisory Body members may offer political support to a Councilmember, but not in a public forum while conducting official duties. Conversely, Councilmembers may support Advisory Body members who are running for office, but not in an official forum in their capacity as a Councilmember.

SECTION 11: CONDUCT OF CITY STAFF RELATED TO PUBLIC MEETINGS A. Staff Report Writing: The City Manager shall supervise and approve all City staff reports that are published as part of the City Council agenda. City staff shall prepare well-written staff reports and provide accompanying documents on all agenda items in accordance with the agenda format and preparation schedule. Furthermore, the City Manager shall advise management staff of potentially political or controversial issues coming before the City Council and direct City staff to be present and appropriately prepared at City Council meetings.

B. Council Inquiries: City staff shall be available for questions from City Council members in accordance with the Brown Act prior to and during meetings and shall respond to questions during meetings only when requested to do so by Council members, the City Manager, or the City Attorney.
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C. Decorum: City staff shall refrain from arguing with the City Council members, Advisory Body members, and the public. Electronic equipment that is not otherwise being used for public meeting purposes shall be set to silent or off mode during public meetings.

D. Keeping Council Informed: To the extent permitted by the Brown Act, the City Manager and City staff shall keep the Mayor and City Council members informed of significant issues in the City of East Palo Alto.

SECTION 12: CONDUCT WITH THE MEDIA
A. Introduction: Councilmembers are frequently contacted by the media for background and quotes. The best advice for dealing with the media is to never go "off the record." Most members of the media represent the highest levels of journalistic integrity and ethics, and can be trusted to keep their word. However, one bad experience can be catastrophic. Words that are not said cannot be quoted.

B. Mayor as Spokesperson: The Mayor is the designated representative of the City Council to present and speak on an official City position. If an individual Councilmember is contacted by the media, the Councilmember should be clear about whether their comments represent the official City position or a personal viewpoint.

C. Choose Words Carefully: Comments taken out of context can cause problems. Be especially cautious about humor, sardonic asides, sarcasm, or word play. It is never appropriate to use personal slurs or swear words when talking with the media.

D. Limits on Advisory Body Members: Advisory Body members are not authorized to represent the City outside of official advisory body meetings unless specifically authorized to do so.

SECTION 13: SANCTIONS
A. Acknowledgement of Code of Ethics and Conduct: Councilmembers who do not sign an acknowledgement that they have read and understand the Code of Ethics and Conduct shall be ineligible for intergovernmental assignments or Council subcommittees. Advisory Body members who do not sign an acknowledgement that they have read and understand the Code of Ethics and Conduct are not eligible to hold office.

B. Standards and Expectations: The Code of Ethics and Conduct expresses standards of ethical conduct expected for members of the City Council, and Advisory Bodies. Members have the primary responsibility to assure that ethical standards are understood and met, and that the public can continue to have full confidence in the integrity of government. The Mayor and City Council, and chairs of City Advisory Bodies have the additional responsibility to intervene when actions of Members that appear to be in violation of the Code of Ethics and Conduct are brought to their attention.

C. Councilmember Sanctions: Councilmembers who intentionally and repeatedly do not follow proper conduct may be reprimanded or censured by the City Council, lose seniority or 60 Administrative Policy
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committee assignments (both within the City of East Palo Alto and with intergovernmental agencies) or other privileges afforded by the Council (i.e., restrictions on official City travel).

Individual Councilmembers should point out to the offending Councilmember the perceived infractions of the Code of Ethics and Conduct. If the offenses continue, then the matter should be referred to the Mayor in private. If the Mayor is the individual whose actions are being questioned, then the matter should be referred to the Vice Mayor. It is the responsibility of the Mayor (or Vice Mayor) to initiate action if a Councilmember’s behavior may warrant sanction. If no action is taken by the Mayor (or Vice Mayor), then the alleged violation(s) can be brought up with the full City Council.

D. Advisory Body Member Sanctions:

1. Counseling: Counseling and verbal warnings may be administered by the Mayor to an Advisory Body member failing to comply with City policy. This lower level of sanctions shall be kept private to the degree allowed by law. The Mayor shall advise the chair of the respective Advisory Body of the counseling or verbal warning, and also notify the City Manager, City Attorney, and City Clerk.

2. Investigation: When deemed warranted, the Mayor or majority of City Council may call for an investigation of an Advisory Body member’s conduct. In addition, should the City Manager or City Attorney believe an investigation is warranted, they shall confer with the Mayor, or City Council in compliance with the Brown Act. The Mayor or City Council shall ask the City Manager or the City Attorney to investigate the allegation and report the findings.

3. Discipline: Written reprimands, censure and removal are all options available to the City Council for disciplining an Advisory Body member failing to comply with City policy. Any form of discipline imposed by City Council shall be determined by a majority vote of at least a quorum of the City Council at a noticed public meeting and such action shall be preceded by a report to City Council with supporting documentation.

4. Alternative Remedy: These sanctions are alternatives to any other remedy that might otherwise be available to remedy conduct that violates this code or state or federal law. In order to protect and preserve good government, any individual including the City Manager and the City Attorney after complying with Rule 1.13 of the State Bar Rules of Professional Conduct, who knows or reasonably believes a Member acts or intends or refuses to act in a manner that is or may be a violation of law reasonably imputable to the organization, or in a manner which is likely to result in substantial injury to the organization, may report the violation to the appropriate governmental authorities.
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E. Inappropriate City Staff Behavior: Councilmembers should refer to the City Manager, or City Attorney as appropriate, any City staff who do not follow proper conduct in their dealings with Councilmembers, other City staff, or the public. These employees may be disciplined in accordance with standard City procedures for such actions.

SECTION 14: IMPLEMENTATION
The Code of Ethics and Conduct is an expression of the standards of conduct expected by the City for its elected and appointed officials. It therefore becomes most effective when Members are thoroughly familiar with it and embrace its provisions. For this reason, this document shall be included in the regular orientations for candidates for City Council, Advisory Bodies, and newly elected and appointed officials. Members entering office shall sign a statement (example below) acknowledging they have read and understand the Code of Ethics and Conduct. In addition, the Code of Ethics and Conduct shall be periodically reviewed by the City Council, Boards, Committees and Commissions, and update it as necessary.

Example:

I affirm that I have read and understand the City of East Palo Alto Code of Ethics and Conduct for Elected and Appointed Officials.

Signature Date
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64 65
66 67
68 69
70 71
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PUBLIC HEARING ITEM 8.1

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: March 3, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Chris Dacumos, Contract Senior Planner
Elena Lee, Planning Manager
Shiri Klima, Assistant City Manager
SUBJECT: Appeal of Planning Commission Denial of Design Review Permit (DR25-004) for the Townhome Project at 1675 Bay Road and Design Review Permit (DR25-007) for the Mixed-Use Project at 1675 Bay Road
Recommendation
The City Council may take one of the following actions:

1. By motion, approve the appeal, and adopt two resolutions:
a. Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners Townhomes Residential Project (Design Review Permit: DR25-004) and Finding that the University and Bay at 4 Corners Townhomes Residential Project is exempt from the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section 21080.66.
b. Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit:

DR25-007) and Finding that the University and Bay at 4 Corners – Mixed-Use Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66.

2. Or alternatively, by motion, deny the appeal, and direct staff to return with a resolution for adoption supporting the denial.

Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
 Comprehensive Housing
74 PUBLIC HEARING ITEM 8.1
 Land Use, Economic, and Workforce Development
Background
February 9, 2026, Planning Commission Meeting
On February 9, 2026, the Planning Commission held a public hearing to consider two projects submitted by Sand Hill Property Company to develop 1675 Bay Road. The staff report presented to the Planning Commission for the Mixed-Use project is included for reference as Attachment

1. Because both projects are integrated, one staff report was written for both projects. The entire packet, including separate staff reports for both projects and related attachments, are available here for the February 9th Planning Commission meeting1. The two separate projects considered by the Planning Commission include:

1. A Townhome Residential Project consisting of 106 Units, including 11 affordable units

2. A Mixed-Use Project consisting of 168 Units, including 25 affordable units, and 5,555 square feet of retail.

The Planning Commission adopted resolutions to not approve both projects, following an extensive discussion. A detailed description of the discussion is provided in the Analysis section below.

Project Background
Sand Hill Property Company (“Applicant”) submitted applications for two separate projects on one existing parcel located at 1675 Bay Road (Accessor Parcel Number (“APN”): 063-111-250) (Figure 1). The property is within the Ravenswood Business District/4 Corners Specific Plan (RBD) overlay district. The two projects are the Townhomes Residential Project (“Townhomes Project”) consisting of 106 for sale units and the Mixed-Use Project consisting of 168 for rent units (“Mixed-Use Project”).

The Applicant submitted a timely appeal of the Planning Commission’s decision on February 24, 2026. The appeal form is provided as Attachment 1.

Project History
The Applicant originally submitted a project application in November 2020 consisting of the following:
 Approximately 400,000 square feet (sf) of life science/office

1 The link is to the entire Agenda Packet including attachments and exhibits. The attachment just includes the Staff Report with no attachments or exhibits. https://d3n9y02raazwpg.cloudfront.net/cityofepa/f8b329cf-f278-11f0- bb28-005056a89546-b66d8e1b-5f57-400b-9799-cf3a802a8761-1770428531.pdf 75 PUBLIC HEARING ITEM 8.1
 180 units
 22,000 to 30,000 sf of retail and/or community serving space.

During the spring of 2024, the Applicant indicated to the City that they would place their project on hold. Then prior to the City’s adoption of the 2024 Ravenswood Business District/ 4 Corners Specific Plan (2024 RBD Specific Plan)2, the Applicant submitted preliminary applications for projects on the same lot as the previous proposal. These applications included a townhome residential project and a mixed-use project.

The Townhomes Residential Project (PRE) 24-003 was submitted on November 22, 2024, and the Mixed-Use Project PRE24-004 was submitted on December 2, 2024 (collectively “Projects”).

The Applicant sought to vest rights under Government Code Section 65589.5(o)(1), also known as Senate Bill (SB) 330 or the Housing Crisis Act3. The rights vested under SB 330 include subjecting the proposed developments only to the ordinances, policies and standards adopted and in effect at the time a complete SB 330 preliminary application was submitted. That means that the two projects are subject to the 2013 Ravenswood /4Corners Transit Oriented Development Specific Plan4(2013 Specific Plan) and not 2024 RBD Specific Plan.

Project Description
Table 1. Project Data
Project Element Detail/Description
Applicant / Owner Sand Hill Property Company / Four Corners EPA Property Owner, LLC
Location 1675 Bay Road
APN 063-111-250
Size of Existing Site 6.06 acres
Existing Use Undeveloped, vacant lot
Surrounding Uses
North: Existing single-family residential
South: Medium family residential,
Government
West: Commercial, Government, Single
family residential
East: Existing single-family residential
General Plan Designation Mixed Use High

2 https://www.cityofepa.org/planning/page/ravenswood4-corners-specific-plan-adopted-12172024 3 https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330 4 https://www.cityofepa.org/planning/page/archived-2013-ravenswood4-corners-specific-plan-superseded-2024- rbd-update
76 PUBLIC HEARING ITEM 8.1
Table 1. Project Data
Existing Zoning 2013 Ravenswood Specific Plan Overlay District - 4 Corners Gateway
Surrounding Zoning University Village to the north and east, 4 Corners Gateway to the south and west
Townhome Project Mixed-Use Project
Proposed Acreage 4.61 1.45
Total Number of Units 106 168
Number of Affordable Units 11 (10 % of total units) 25 (20% of base units) Number of Stories / Height (6 stories
max) 3 (39’) 6 (75’)
Maximum Floor Area Ratio (1.5) Not Applicable 0.09
Required / Provided Required / Provided
Number of Parking Spaces 211 / 229 168 / 256
Number of Short-Term Bicycle Spaces 8 / 8 12 /13
Number of Long-Term Bicycle Spaces 36 / 106 56 / 64
Call for Review and Applicant Appeal
Councilmember Mark Dinan requested a vote for a call to review the project. This was discussed by the City Council on February 24, 2026. Additionally, staff had presented to the Council that the Applicant had submitted a timely appeal. Staff then noted that a Call for Review would de novo. A de novo review would mean that the City Council’s review of the project would be as if there had not been a Planning Commission decision. Additionally, the City Council would be able to consider additional topics in evaluating the project.

With an appeal, staff noted the City Council is required to review the Planning Commission’s decision with a public hearing. During the hearing, the City Council’s evaluation is limited only to the topics discussed during the Planning Commission meeting. The City Council discussed the differences between the de novo review and the appeal and received public comment on the item.

After deliberating the City Council voted on whether to review the Planning Commission’s decisions regarding the two proposed projects. The motion failed to pass with two ayes, two nays, and one abstention. This staff report is prepared to address this appeal. However, on the 77 PUBLIC HEARING ITEM 8.1
same day, the applicant timely filed and paid the fee to appeal the matter before the Council.

This staff report is prepared to address this appeal.

Procedures for Appeal Hearing
This hearing shall be conducted in compliance with standard appeal processing procedures.

Fundamental due process requires that all parties in a quasi-judicial hearing, such as this appeal, have a reasonable opportunity to present their case. In accordance with past practice, the following procedures are what the City Council may follow to ensure an orderly and fair hearing (Mayor shall allot time to each item, including the amount of time for the applicant, taking into consideration past practice, i.e., 15 minutes):
a. Call to Order and Opening: Mayor or City Manager presents agenda item or opens hearing.
b. Staff Presentation: City staff present background, decision rationale, and applicable legal standards.
c. Appellant Presentation: Appellant presents reasons for appeal. d. Rebuttal: Time is given to respond to new information or claims. e. Public Comments: Open floor to other stakeholders.
f. Appellant Rebuttal: Appellant may provide brief rebuttal or final word. g. City Council Questions/Discussion: Council members ask questions to staff or appellant.
h. Deliberation and Decision: Hearing body discussions in open session, votes on the appeal, state findings on the record, decision conforms with Gov. Code 65852.2, and decision must be based on substantial evidence in the record. i. Close the Hearing or Continue to Next Hearing to Date Certain (where applicable).

Analysis
Planning Staff Review
In the February 9, 2026, Planning Commission staff report, staff recommended approval of the Projects, noting that the Projects:
 Qualify under State Density Bonus Law (“SDBL”) to utilize waivers and concessions from certain East Palo Alto development standards or land use requirements.  Comply with applicable objective development standards of the General Plan and 2013 Ravenswood Business District / 4 Corners TOD (“2013 RBD”) Specific Plan in most areas and use waivers and concessions for other standards or requirements.  Are statutorily exempt from the California Environmental Quality Act under Assembly Bill 130 and codified in Public Resources Code 21080.66.

The General Plan and Specific Plan consistency evaluations are included as Table 2 and Table 78 PUBLIC HEARING ITEM 8.1
3, respectively, in the February 9, 2026 staff report provided in the Planning Commission packet5 (Exhibit B to Attachment 3 and Attachment 4).

Additionally, staff discussed that Housing Accountability Act (“HAA”) regulations concerning the approval or disapproval of the project applies. Specifically local agencies may only disapprove a residential development or substantially residential development (at least two thirds of total square footage must be housing) or a density reduction on objective written health and safety findings (Government Code Section 65589.5(j)). The findings must be supported by a preponderance of evidence in the record. Additionally, the adverse impact to public health or safety must be specific, adverse, and unavoidable without the denial or condition. There also can be no feasible method to mitigate or avoid the adverse impact.

The HAA also addresses instances where projects are disapproved based on non- conformity with applicable development standards, policies, ordinances, and other requirements. Projects that qualify under the SDBL shall not be found to be inconsistent or not in compliance with applicable development standards, policies, ordinances, and other requirements. Staff also provided background on additional state legislation governing the approval of the projects. This information is included in the February 9, 2026, staff report (Attachment 7 and 8).

Planning Commission Review
On February 9, 2026, the Planning Commission held a duly noticed public hearing to consider the proposed the Projects.

At the hearing, staff recommended approval of the project based on staff’s analysis of the projects, CEQA statutory exemptions, and State regulations requiring approval of qualified housing projects. The Planning Commission received a presentation from the Applicant and public comments from community members as noted above under “Background” above.

During the public comment period, speakers generally voiced support for the project citing that the project would:
 Fill a need for housing, with different sized units and different income levels  Construct developments in a long vacant site
 Support local economic activity by adding retail space and by increasing foot traffic with additional residents
 Contribute to City revenue to support infrastructure and services After concluding the public comment period, the Planning Commission discussed comments received, City policies and development standards, the approved alternative compliance plans for inclusionary housing, and each project’s merits. Additionally, the Planning Commission discussed State laws related to the approval or processing of residential projects, including:

5 https://d3n9y02raazwpg.cloudfront.net/cityofepa/f8b329cf-f278-11f0-bb28-005056a89546-b66d8e1b-5f57-400b9799-cf3a802a8761-1770428531.pdf 79 PUBLIC HEARING ITEM 8.1
 Housing Crisis Act (Senate Bill (SB) 330) which allows the vesting of development standards, policies, and ordinances for qualified projects  State Density Bonus Law, including the required application by the City of waivers and concessions for qualified projects and if requested by the Applicant  Housing Accountability Act which mandates the approval of housing development projects that comply with objective general plan, zoning and subdivision standards and criteria
 Assembly Bill (AB) 130 which relates to finding the project statutorily exempt from the California Environmental Quality Act (CEQA) based on meeting criteria of the bill, requirements for tribal consultation, and requirements to approve or disapprove a project within 30 days from the conclusion of tribal consultation After carefully considering the above, the Planning Commission deliberated on the community’s vision for the 4 Corners intersection, the merits of the Projects, and state requirements. The Planning Commission generally supported the effort to increase housing, including affordable housing. However, Commissioners disagreed on how the Projects could be consistent with the City’s vision for development at the University Avenue and Bay Road intersection.

Commissioners discussed and asked staff about the applicability of waivers and concessions.

Other Commissioners noted that SDBL affords the Applicant alleviation from development standards to incentivize housing development would require approval of the project.

Weighing the Projects objectives, state mandates, and the community’s vision, the Planning Commission made a total of seven motions to either approve or to not approve the either project or specific AB 130 CEQA exemption findings. The Planning Commission’s votes on the motions are provided in Attachment 2. One motion did not receive a second and was not voted on. Four other motions resulted in no decision being made due to lack of a majority vote. The Planning Commission and staff discussed the outcomes of no decisions being made on either project.

After receiving additional information that the projects would be deemed approved if no decision were made, the Planning Commission made the following motions:

1. To not approve the Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners Townhomes Residential Project (Design Review Permit: DR25-004) and Finding that the University and Bay at 4 Corners Townhomes Residential Project is exempt from the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section 21080.66

2. To not approve the Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007) and Finding that the University and Bay at 4 Corners – MixedUse Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66 Both motions passed with four ayes, two abstentions, and two absent.

After the votes to not approve, staff noted that under the HAA, the Planning Commission is 80 PUBLIC HEARING ITEM 8.1
required to make from the record of an adverse impact to public health or safety must be specific, adverse, and unavoidable without the denial or condition. Those in favor of the motion noted that the project creates an economic impact citing the lack of sales tax revenue from retail projects, which in turn leads to an adverse impact to public health or safety.

Staff Analysis of the Planning Commission’s Finding
As noted under the Housing Accountability Act section above, if a project is found to have an adverse impact to public health or safety, the finding must be:

1. Supported by a preponderance of evidence in the record.

2. Specific, adverse, and unavoidable without the denial or condition.

3. No feasible method to mitigate or avoid the adverse impact.

In staff’s evaluation, the finding for an adverse impact to public health or safety based on an economic impact from the lack of sales tax revenue does not satisfy the criteria to make the finding as required by the Housing Accountability Act.

Applicant’s appeal
The Applicant requests that the City Council uphold the appeal, overturn the Commission’s decision and approve the project. Below is a summary of the appellant’s key arguments. The Applicant’s grounds for appeal are the same for both projects.

Compliance with the HAA
The Applicant alleges the Four Corners Project is protected under HAA. The appeal notes that the HAA limits a local agency’s ability to deny or reduce the density of a housing development that complies with applicable, objective general plan, zoning, subdivision, and design review standards. The Applicant asserts the statute must be interpreted to give the fullest possible weight to the approval and provision of housing. The appeal notes case law recognizes that the HAA creates a constitutionally protected property interest for due process purposes in qualifying housing developments such as the Projects (North Pacifica, LLC v. City of Pacifica).

As noted above in the discussion of the HAA, the Applicant also notes that disapproving a project must be based on written findings and supported by a preponderance of evidence. The Applicant states that a “specific adverse impact” is defined as a significant, quantifiable, direct, and unavoidable impact based on objective, written public health or safety standards in effect when the application was deemed complete.

The appeal seeks to establish that the projects comply with applicable objective standards. The Applicant points to staff’s reports and environmental analysis on both projects describing the Project’s consistency with applicable objective standards. The appeal also points to staff report materials indicating the Projects would protect public health and safety through compliance with applicable building, fire, and accessibility standards. 81 PUBLIC HEARING ITEM 8.1
The Applicant alleges no written findings were adopted, which falls short of the HAA’s requirements. As also noted above under Planning Commission Review, the Applicant references the Planning Commission finding of an adverse impact to public health and safety being caused by the lack of sales tax. The Applicant asserts that there is no record of evidence regarding any health or safety effects of sales tax.

State Density Bonus Law, Concessions, and Waivers
The Applicant asserts that under SDBL, a city must provide incentives, concessions, and waivers to an applicant who agrees to include specified percentages of affordable units. The Applicant identifies where SDBL allows denying an applicant a waiver or concession which are instances where grant a waiver or concession:

1. Would have a specific, adverse impact upon public health and safety,

2. Would have an adverse impact on any historic resource, or

3. Would be contrary to state or federal law
The applicant asserts the City has not articulated circumstances that would deny a waiver nor identified where circumstances exist and is therefore required to grant the concessions and waivers. The applicant also asserts that the Planning Commission has no basis to deny a concession or waiver based on disliking a requested waiver, such as a waiver from a requirement to provide at least 35% of the ground floor square footage as retail.

Staff Analysis of the Applicant’s Appeal
The Applicant’s grounds for appeal is generally consistent with staff’s understanding of applicable state law including the Housing Accountability Act and State Density Bonus Law, although the appeal materials are prepared by an advocate. The Applicant’s appeal letter is also consistent with the information staff provided in the February 9, 2026, staff reports, presentation to the Planning Commission, and response to questions from the Planning Commission during the meeting.

Fiscal Impact
Pursuant to SB 330 the development and impact fees applicable to the two projects are those that are subject to the Mitigation Fee Act and were in effect when complete SB 330 preliminary applications were submitted to the City. The development and impact fees effective July 1, 2024, but prior to the Impact Fee updates effective on May 5, 2025, are applicable to the project.

The estimated development and impact fees generated by the projects are shown under Table 2:
82 PUBLIC HEARING ITEM 8.1
Table 2. Development and Impact Fees
Estimated Development and Impact Fee Amounts
Development Fee Townhome Project Mixed-Use Project
Parks and Trails Impact Fee $438,098.00 $478,296.00
Public Facilities Impact Fee $768,288.00 $838,824.00
Storm Drain Impact Fee $395,583.33 $161,483.06
Transportation Impact Fee $249,948.00 $298,200.00
Water Capacity $863,582.00 $842,352.00
Total $2,715,499.33 $2,619,155.06
Grand Total $5,334,654.39
Public Notice
The public was provided notice by making the agenda and report available on the City’s website and on a bulletin board located at City Hall: 2415 University Avenue, East Palo Alto. Additionally, notice was published in the Daily News newspaper on February 20, 2026.

Environmental
The projects were determined to be exempt from the California Environmental Quality Act (CEQA) pursuant to the new statutory exemptions enacted by the passage of Assembly Bill 130 and codified under Public Resources Code 21080.66. The analysis of the exemptions are available on the City’s webpages for each of the prospective projects and are attached to this staff report (Exhibit A to Attachment 3 and Attachment 5). The analyses identify how the projects qualify for CEQA exemption under AB 130. The analyses also include a listing of appendices after the conclusion of the analysis which includes:
 Relevant sections of Government Code and Public Resources Code governing the evaluation of the project
 Phase I Environmental Site Assessment
 Burrowing owl Habitat Assessment
 Tribal Monitoring and Tribal Cultural Resources Requested Conditions of Approval. 83 PUBLIC HEARING ITEM 8.1
Government Code § 84308
Applicability of Levine Act: Yes.

Analysis of Levine Act Compliance: The project Applicant is Sand Hill Property Company and is represented by Michael Kramer. Staff is unaware of any other parties or participants relevant to the Planning Commission’s consideration of this item.

Attachments

1. Application to Appeal the Planning Commission’s February 9, 2026, decisions on two separate University and Bay at 4 Corners projects

2. Record of Planning Commission’s motions and votes

3. Resolution approving a Design Review, Tentative Map, and Tree Removal Permit (DR25- 004) for the Construction of the University and Bay at 4 Corners – Mixed-Use Project, a 106- Unit Development and Associated Improvements Located at 1675 Bay Road a. Exhibit A – 4 Corners Mixed-Use Project – AB 130 Statutory Exemption Analysis b. Exhibit B – Findings in Support of Approval of the Site Plan and Design Review Permit and the Tentative Map
c. Exhibit C – Conditions of Approval

4. Townhome Project Plans

5. Resolution approving a Design Review, Tentative Map, and Tree Removal Permit (DR25- 007) for the Construction of the University and Bay at 4 Corners – Mixed-Use Project, a 168- Unit Development and Associated Improvements Located at 1675 Bay Road a. Exhibit A – 4 Corners Mixed-Use Project – AB 130 Statutory Exemption Analysis b. Exhibit B – Findings in Support of Approval of the Site Plan and Design Review Permit and the Tentative Map
c. Exhibit C – Conditions of Approval

6. Mixed-Use Project Plans

7. February 9, 2026, Planning Commission Staff report on the Townhome Project

8. February 9, 2026, Planning Commission Staff report on the Mixed-Use Project 84 85
86 87
88 89
90 91
92 93
94 95
96 97
98 99
Attachment 2 – Record of Planning Commission Votes
On February 9, 2026
First Motion:

Motion to not adopt the Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007)
Motion – Curtis Monette, Second – Michael Mashack
Ayes: Uriel Hernandez, Michael Mashack, Curtis Monette
Noes: Robert Allen Fisk, Christopher Kao
Abstain: Robert Sherrard, Javanni Brown Austin

Absent: Juan Mendez
Second Motion
Motion to adopt the Resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007)
Motion – Christopher Kao, Second – Robert Allen Fisk
Ayes: Robert Allen Fisk, Christopher Kao
Noes: Curtis Monette
Abstain: Robert Sherrard, Uriel Hernandez, Michael Mashack, Javanni Brown Austin

Absent: Juan Mendez
Third Motion
Commissioner Brown Austin left the meeting, and her absence is noted for the following votes.

Motion to adopt the resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007); and finding that the University and Bay at 4 Corners – Mixed-Use Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66
Motion – Robert Allen Fisk, Second – none
100
Fourth Motion
Motion to find that the University and Bay at 4 Corners – Mixed-Use Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66 Motion – Christopher Kao, Second – Uriel Hernandez
Ayes: Robert Allen Fisk, Christopher Kao
Noes: Michael Mashack, Curtis Monette
Abstain: Robert Sherrard, Uriel Hernandez,

Absent: Javanni Brown Austin, Juan Mendez
Fifth Motion
Motion to adopt the resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007); and finding that the University and Bay at 4 Corners – Mixed-Use Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66
Motion – Christopher Kao, Second – Robert Allen Fisk
Ayes: Robert Allen Fisk, Christopher Kao
Noes: Uriel Hernandez, Michael Mashack, Curtis Monette
Abstain: Robert Sherrard

Absent: Javanni Brown Austin, Juan Mendez
Sixth Motion
Motion to not adopt the Resolution Approving the Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners Townhomes Residential Project (Design Review Permit: DR25-004); and finding that the University and Bay at 4 Corners Townhomes Residential Project is exempt from the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section 21080.66 Motion – Curtis Monette, Second – Michael Mashack
Ayes: Michael Mashack, Curtis Monette, Uriel Hernandez, Robert Sherrard
Noes:

Abstain: Robert Allen Fisk, Christopher Kao

Absent: Javanni Brown Austin, Juan Mendez
101
Seventh Motion
Motion to not adopt the resolution Approving Design Review, Tentative Map, and Tree Removal Permit for the University and Bay at 4 Corners – Mixed-Use Project (Design Review Permit: DR25-007); and finding that the University and Bay at 4 Corners – Mixed-Use Project is exempt from CEQA pursuant to Public Resources Code Section 21080.66
Motion – Curtis Monette, Second – Michael Mashack
Ayes: Uriel Hernandez, Robert Sherrard, Michael Mashack, Curtis Monette
Noes:

Abstain: Robert Allen Fisk, Christopher Kao

Absent: Javanni Brown Austin, Juan Mendez
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1 RESOLUTION NO. CC 2026-xx

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO FINDING THAT THE UNIVERSITY AND BAY AT 4 CORNERS TOWNHOMES

RESIDENTIAL PROJECT IS EXEMPT FROM THE CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO PUBLIC RESOURCES CODE 21080.66 AND

APPROVING A DESIGN REVIEW, TENTATIVE MAP AND TREE REMOVAL PERMIT (DR25-004) FOR THE CONSTRUCTION OF THE 106-UNIT RESIDENTIAL DEVELOPMENT, AND ASSOCIATED IMPROVEMENTS LOCATED AT 1675 BAY ROAD
WHEREAS, in May 2025, the East Palo Alto Planning Division received an application from Sand Hill Property Company for Site Plan and Design Review (“Design Review”), Tentative Map and Tree Removal Permit (DR25-004) for the construction of the University and Bay at 4 Corners – Townhome Residential Project (“Project”), a 106 townhome residential unit development, located at 1675 Bay Road in East Palo Alto; and WHEREAS, the current owner of the property located at 1675 Bay Road is Four Corners EPA Property Owner, LLC and is represented by Sand Hill Property Company as the applicant; and
WHEREAS, Sand Hill Property Company submitted on November 22, 2024 a preliminary application consistent with Senate Bill 330 (Government Code 65589.5) application requirements; and
WHEREAS, in accordance with Government Code 65589.5, the project is subject to the ordinances, policies and standards adopted and in effect at the time of preliminary application submittal; and
WHEREAS, for the purposes of Government Code 65589.5, “ordinances, policies, and standards” includes development impact fees, capacity or connection fees or charges, permit or processing fees, and other exactions; and WHEREAS, the State of California passed Assembly Bill 130 on June 30, 2025, which went into effect immediately to exempt certain housing projects from further environmental review under California Environmental Quality Act (“CEQA”) if the housing development project meets certain conditions relating to, for example, size density, location and use; and
WHEREAS, the City of East Palo Alto (“City”) has conducted an evaluation of Project pursuant to AB 130 (Public Resources Code 21080.66) and determined the Project meets the criteria for exemption from further environmental review under CEQA; and
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2 WHEREAS, on February 9, 2026, the East Palo Alto Planning Commission held a duly noticed public hearing to consider the applicant’s request for Design Review, Tentative Map and Tree Removal Permit approval and the analysis for CEQA exemption; and
WHEREAS, on February 9, 2026, the East Palo Alto Planning Commission voted to not approve the project; and
WHEREAS, on February 24, 2026, the applicant submitted an application to the City to appeal the Planning Commission’s decision; and
WHEREAS, on March 3, 2026, the East Palo Alto City Council held a duly noticed public hearing to review the applicant’s request for appeal and to approve the Design Review, Tentative Map and Tree Removal Permit approval.

NOW, THEREFORE, BE IT RESOLVED THAT THE CITY COUNCIL OF THE CITY OF EAST PALO ALTO HEREBY:

1. Finds that the proposed residential project is exempt from the California Environmental Quality Act pursuant to Public Resources Code Section 21080.66, as demonstrated in Exhibit A.

2. Approves the Design Review, Tentative Map and Tree Removal Permit for this proposed residential project based on the findings contained in Exhibit B and Subject to the Conditions of Approval in Exhibit C.

PASSED and ADOPTED on this 3rd day of March 2026, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:

SIGNED:

Webster Lincoln, Mayor
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3 ATTEST:
________________________
APPROVED AS TO FORM:
_______________________________
James Colin, City Clerk John Lê, City Attorney
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 1

TECHNICAL MEMORANDUM
To: Christopher Dacumos
Community & Economic Development
City of East Palo Alto
From: Kimley-Horn and Associates
Date: February 2, 2026
Subject: 4 Corners Residential Project – AB 130 Statutory Exemption

1.0 INTRODUCTION & PURPOSE
On June 30, 2025, Governor Newsom signed Assembly Bill (AB) 130 into law, which, among other changes, enacted a new statutory exemption for certain classes of residential developments.

Where a housing development project qualifies for the new exemption, no further environmental review document is required under CEQA. AB 130 took effect immediately on June 30, 2025.

The City of East Palo Alto has conducted an evaluation of the 4 Corners Residential Project (Project) pursuant to the California Environmental Quality Act (CEQA) and AB 130. As described below, this Technical Memorandum establishes that the Project meets the criteria for the new statutory housing project exemption, meaning that no further environmental review of the Project is required under CEQA.

2.0 STATUTORY AUTHORITY & REQUIREMENTS
AB 130’s new statutory housing exemption is codified in new Public Resources Code (PRC) Section 21080.66; see Appendix A: PRC Section 21080.66.
1 To qualify for the new exemption, a housing
development project must meet all the following conditions:
(1) The project site is not more than 20 acres, unless it is a builder’s remedy project, 2 and then the
builder’s remedy project size or parcel is not more than four acres. (2) The project site is either located within the boundaries of an incorporated municipality or is located within an urban area as defined by the United States Census Bureau. 1 California Legislative Information, Public Resources Code Section 21080.66, https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC&sectionNum=21080.66.. Accessed October 2025. 2 “Builder’s remedy” can be used to avoid certain local zoning requirements when a locality’s housing element does not substantially comply with State law and is codified in the Housing Accountability Act (HAA) (CGC Section 65589.5).

Exhibit A - DR25-004
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 2 (3) The project site meets any of the following criteria:

A. Has been previously developed with an urban use.

B. At least 75 percent of the perimeter of the site adjoins parcels that are developed with urban uses.

C. At least 75 percent of the area within a one-quarter mile radius of the site is developed with urban uses.

D. For sites with four sides, at least three out of four sides are developed with urban uses and at least two-thirds of the perimeter of the site adjoins parcels that are developed with urban uses.
(4) The project is consistent with the applicable general plan and zoning ordinance, as well as any applicable local coastal program as defined in California Government Code (CGC) Section 30108.6. If the zoning and general plan are not consistent with one another, a project shall be deemed consistent with both if the project is consistent with one. The approval of a density bonus, incentives or concessions, waivers or reductions of development standards, and reduced parking ratios pursuant to Section 65915 of the CGC shall not be grounds for determining that the Project is inconsistent with the applicable general plan, zoning ordinance, or local coastal program.
(5) Within the County of San Mateo, the project density must be at least 15 dwelling units per acre (DU/acre).
(6) The project satisfies the requirements specified in paragraph (6) of subdivision (a) of CGC Section 65913.4 (see Appendix B: CGC Section 65913.4), meaning that it:

A. Is not located within certain coastal zone areas;
B. Is not located on prime farmland or farmland of statewide importance; C. Does not include wetlands;
D. Is not located within a very high fire hazard severity zone (HFHSZ); E. Is not located on a site included on the Cortese List pursuant to CGC Section 65962.5; F. Is not located on a delineated earthquake fault zone; G. Is not located within a special flood hazard area;
H. Is not located within a regulatory floodway;
I. Is not located on lands identified for conservation within an adopted Natural Community Conservation Plan (NCCP) or Habitat Conservation Plan (HCP); J. Does not include habitat for protected species;
K. Does not include lands under conservation easement.

Exhibit A - DR25-004
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 3 (7) The project does not require the demolition of a historic structure that was placed on a national, State, or local historic register before the date a preliminary application was submitted for the project pursuant to CGC Section 65941.1. (8) No portion of the project is designated for use as a hotel, motel, bed and breakfast inn, or other transient lodging.

To qualify for the new statutory exemption, a project must also:
• Meet specific tribal consultation requirements and include mitigation for tribal cultural resources, pursuant to PRC Section 21080.66(b);
• Include a condition of approval requiring the development proponent to complete a phase I environmental assessment, as defined in Section 78090 of the California Health and Safety Code, pursuant to PRC Section 21080.66(c)(1);
• Comply with specific environmental hazard and air filtration standards if within 500 feet of a freeway, pursuant to PRC Section 21080.66(c)(2); and • Comply with labor requirements, including payment of prevailing wage for 100 percent affordable projects and use of a skilled and trained workforce for buildings exceeding 85 feet in height, pursuant to PRC Section 21080.66(d).

3.0 PROJECT DESCRIPTION
Project Location and Components
The Project would develop a residential development on a 4.61-acre portion of an approximately 6-acre parcel (Project Site) (Assessor Parcel Number [APN] 063-111-250) located at 1675 Bay Road in the City of East Palo Alto (City), California; see Figure 1: Regional Location Map. The Project Site is bounded by Michigan Avenue to the north, Fordham Avenue to the east, Bay Road to the south, and University Avenue to the west; see Figure 2: Local Vicinity Map. Presently, the Project Site consists of dirt and gravel with no vegetation, surrounded by single and multi-family residential uses to the north and east; community services (United States Postal Service Post Office) and residential uses to the south; and community services and commercial uses west of the Project Site.

The Project would construct 106 new dwelling units (DU) across 10 three-story townhome buildings. Of the 106 DU, 10 percent (11 DU) would be affordable units at a “moderate income” level, which qualifies the Project for a density bonus as allowed under GCS 65915, the State Density Bonus Law (SDBL). The Project would include a unit mix of 24 two-bedroom units, 60 threebedroom units, and 22 four-bedroom units. Each unit would have two dedicated off-street parking spaces provided via a private garage. The Project would also include 17 guest parking spaces, Exhibit A - DR25-004
108
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 4 including American Disability Act (ADA) compliant spaces, for a total of 229 parking spaces as well as 106 class I and eight class II bicycle parking spaces, for a total of 114 bicycle parking spaces. The Project amenities include approximately 4,816 square feet of private open spaces and approximately 31,574 square feet of common open space. Primary access would be provided via Project driveways off Bay Road and University Avenue. Secondary access would be provided via Project driveways on Fordham Street and Michigan Avenue.

Land Use Designation and Zoning
The City’s General Plan designates the Project site as Mixed Use High (MUH). It’s Housing Element identifies the Project Site for a total of 180 DU (36 DU at a “very low” income level and 144 DU at a “above-moderate” income level) and designates the Project as “Projects Not Approved, but High Probability of Development.” The MUH designation allows for the development of up to 86 DU per acre, up to 2.5 floor area ratio, and with a maximum height of eight stories (or 100 feet, whichever is greater), allowing up to 260 persons per acre.

The Project Site is located within the Ravenswood/4 Corners Transit-Oriented Development (TOD) Specific Plan (2013 Specific Plan), which was originally adopted by the City in 2013, and has since been updated and adopted in December 2024. However, because a complete preliminary application for the Project was submitted in November of 2024, this Technical Memorandum evaluates the Project under the ordinances, policies, and standards that were in effect at the time of that submission, including the 2013 Specific Plan, pursuant to the requirements of SB 330. Under the 2013 Specific Plan, the Project Site is zoned as 4 Corners Gateway (4C).

The City’s zoning ordinance identifies the Project Site as being within the Ravenswood Specific Plan Overlay District. The project is within the 4C Zoning District, a district, a district characterized as an area for multi-level, mixed-use buildings that integrate retail shops or community spaces at street level, with residential units, such as apartments or condominiums, situated on the upper floors.

However, under SDBL, the Project is eligible to use an unlimited number of waivers and one concession/incentive for deviation from development standards. As such, the Project would utilize the SDBL to be able to provide ground floor residential units rather than the required retail or community spaces on the ground floor under the Zoning District’s development standard.

The 4CZoning District is consistent with the MUH General Plan land use designation because both the zoning district and land use designation are designed to facilitate the development of multistory, mixed-use buildings that integrate residential units. The maximum density for the 4C Zoning District is 60 DU per acre; the minimum density is not specified. With the requested SDBL concession discussed above, the Project’s proposed development for a new townhouse would be consistent with existing designated land use and zoning codes.

Exhibit A - DR25-004
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 5 Inclusionary Housing Ordinance
The City’s Development Code requires that residential developments include contributions to affordable housing. Residential developments proposing five or more dwelling units must provide 20 percent of the dwelling units as inclusionary units pursuant to Municipal Code Section

18.37.050(A). Alternatively, the City allows developers to provide an alternative compliance method for the inclusion of affordable housing. The Project applicant has determined that the provision of 20 percent affordable housing is economically infeasible. Instead, the Project applicant proposes to include 10 percent affordable housing, resulting in 11 DU at the “moderate income” level and requested the City’s consideration of the alternative compliance. On September 2, 2025, the City Council approved the Project applicant’s request for approval of an in Inclusionary Housing Alternative Compliance Option for the Project. The Project is not considered a builder’s remedy project.

As discussed above, the Project would require a concession under the SDBL to provide residential units on the ground floor without the provision of retail uses. The Project would also require waivers to development standards under the SDBL to reduce the minimum ground floor height and increase the maximum setback along Bay Road. Table 1: Waivers and Concessions/Incentives to Accommodate Density Bonus outlines the types of modifications to development standards that facilitate the construction of the proposed Project.

Table 1: Waivers and Concessions/Incentives to Accommodate Density Bonus Standard Proposed
SDBL Waiver or
Concession/Incentive
Ground floor uses. At least 35% of the
ground floor space of building shall be
retail space (General Plan p. 4-8)
The Project provides no ground-floor
retail; a waiver is required to allow the
Project to proceed without meeting
this standard.

Waiver
Ground floor uses. Multi-family housing
not permitted on ground floor (2013
Specific Plan Table 6-1, p. 92)
The Project includes ground-floor
housing; a concession is required to
allow this use.

Concession
Maximum setback along Bay and
University. At least 65% of a building
shall be built to within 16 feet of
property line (2013 Specific Plan p. 97)
The Project provides an approximately
19-foot setback; a waiver is required to
allow this deviation.

Waiver
Minimum ground floor height. 16 feet
floor to floor (2013 Specific Plan p. 98)
The Project provides an approximately
9-foot floor-to-floor height; a waiver is
required to allow this deviation.

Waiver
Exhibit A - DR25-004
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 6 Discretionary Approvals
The Project applicant has requested the following discretionary approvals from the City:
• Design Review. Approval of the site plan and the design review application. • Subdivision for a Tentative Parcel Map. Approval of the tentative parcel map for a one lot subdivision for condominium purposes consisting of up to 108 residential DU.

However, the Project applicant is only proposing 106 residential units. • Tree Removal Permit. Approval to remove four non-protected, on-site existing trees and nine protected, on-site trees and plant 207 new trees and preserve 15 off-site trees.

Exhibit A - DR25-004
111
N.T.S.

SOURCE: Google Earth, 2025
FIGURE 1: Regional Location

FOUR CORNERS RESIDENTIAL PROJECT
Project Site
Exhibit A - DR25-004
112
N.T.S.

SOURCE: Nearmap, 2025
FIGURE 2: Local Vicinity Map

FOUR CORNERS RESIDENTIAL PROJECT
Bay Road
University Avenue
Michigan Avenue
Fordham Avenue
Project Site
Exhibit A - DR25-004
113
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 9

4.0 FINDINGS CONCERNING CEQA COMPLIANCE
The Project meets the criteria for the new statutory housing project exemption, meaning that no further environmental review of the Project is required under CEQA. Each criterion for applicability of the new statutory housing exemption is addressed below.

Exemption Justification Under AB 130 – Infill Housing Criterion (a) The Project is located on a site of up to 20 acres (or up to four acres for builder’s remedy projects).

The Project Site is approximately 4.61 acres and is not considered a builder’s remedy project.

Therefore, the Project Site is fewer than 20 acres and would be consistent with this criterion. (b) The Project Site is located within the boundaries of an incorporated municipality or within an urban area as defined by the United States Census Bureau.

The Project Site is located entirely within the boundaries of the City of East Palo Alto. Therefore, the Project would be consistent with this criterion.
(c) The Project Site has been previously developed with an urban use, at least 75 percent of the perimeter of the site adjoins parcels that are developed with urban uses, at least 75 percent of the area within one quarter mile radius of the site is developed with urban uses, or with sites with four sites, at least three out of the four are developed with urban uses, or at least two-thirds of the perimeter of the site adjoins parcels that are developed with urban uses.

While the Project Site is currently vacant and undeveloped, it meets the criterion for urban development based on its context and history. The Project Site was previously developed with the Nairobi Village Shopping Center, an established urban use before it burned down in the 1980s and was demolished. The Project Site is surrounded by residential development on the north, east, and south sides, and by commercial and community-serving uses to the west. Therefore, the Project would be consistent with this criterion.
(d) The Project is consistent with the applicable general plan and zoning ordinance, as well as any applicable local coastal program.
(i) General Plan Consistency
As identified above, the Project Site is designated as MUH by the City’s General Plan. The MUH land use designation allows for the following uses: multi-family residential, attached single-family residential, retail, services, office, and research and development. It allows a density of up to 86 units per acre and up to 2.5 floor area ratio (FAR). MUH allows for up to eight stories (or 100 feet, whichever is greater) and allows for up to 260 people per acre. The MUH land use designation Exhibit A - DR25-004
114
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 10 requires that at least 35 percent of the ground floor space of the building be used for retail space.

In areas where retail is removed for the construction of new buildings, the new retail space shall be greater than 85 percent of the previously existing retail space. The Project would include a multi-family residential development consisting of 106 DU across 10 three-story townhome buildings, with a maximum building height of approximately 38 feet, 11 inches. The Project’s density is 23 DU per acre with a FAR of 1.15, both of which are below the maximum density and intensity requirements. Additionally, the Project would require waivers to provide residential units on the ground floor without the provision of retail uses, reduce the minimum ground floor height, and increase the maximum setback along Bay Road. Please refer to Table 1: Waivers and Concessions/Incentives, above, which outlines the types of modifications to develop standards that facilitate the construction of the Project.

As shown in Table 2, Project Consistency with Applicable Policies of the General Plan, the Project would also be consistent with the applicable General Plan policies.

Exhibit A - DR25-004
115
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 11 Table 2: Project Consistency with Applicable Policies of General Plan Objective/Policy Analysis of Project Consistency
LU-4.1 Diversity of building types: Encourage a diversity of building types and styles in areas designated for multi-family housing. These building types should range from duplex/triplex/fourplex to courtyard housing to multi-family housing developments. The diversity of building types will respond to the diversity of the City of East Palo Alto’s population and the desire to create interesting and varied neighborhoods.

Consistent: The Project would provide townhome-style multi-family housing, contributing to the diversity of residential building types within the City of East Palo Alto. Townhome-style multi-family homes along with other smaller homes, such as duplexes, triplexes, cottage cluster, and garden apartments are categorized as the “missing middle” by the City as this housing type is currently limited. Because the majority of housing produced in the City in the last 10-30 years have been singlefamily homes and larger multi-family buildings, the Project provides more options across income, age, and household size.

LU-4.6 Building orientation: Wherever feasible, orient multi-family buildings to face streets, public spaces, or shared private spaces.

Consistent: Multi-family buildings included in the Project are oriented toward Bay Road with active frontages, building entries, and pedestrian walkways facing public sidewalks. Additional shared pedestrian connections are located throughout the internal private drive aisles, ensuring units also face and engage in shared private spaces.

LU-5.8 Streetscape beautification: Proactively beautify existing streetscapes with pedestrian-scale lighting, drought-tolerant street trees, and landscaping.

Consistent: The Project includes pedestrian-scale lighting, street trees, and droughttolerant landscaping along both University Avenue and Bay Road frontages.

LU-6.1 New construction: New construction should provide adequate onsite parking for new residents.Consistent: Parking requirements for the Project require the inclusion of one vehicle parking space per one-bedroom unit, totaling 106 parking spaces, and 0.5 spaces for each additional bedroom, totaling 105 spaces (for the 210 additional bedrooms). As such, 211 spaces are required. However, the Project would provide 212 spaces in private garages and 17 surface parking spaces, totaling 229 parking spaces.

LU 9.2 Parking frontage: Continue to implement parking strategies and standards that ensure parking areas do not dominate street frontage and are screened from public views whenever possible.

Consistent: Each DU included in the Project would include two dedicated off-street parking spaces in private garages, with an additional 17 ADA and guest spaces for a total of 229 parking spaces. All parking areas are internal to the site and screened from public views. Landscaping fronts the sidewalks along University Avenue and Bay Road.

Exhibit A - DR25-004
116
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 12 LU 12.2 Vacant parcel: Prioritize the development of the vacant parcel at the intersection of Bay Road and University Avenue as a catalyst project for the City.

Consistent: The Project would develop a currently vacant and highly visible parcel at the intersection of University Avenue and Bay Road. As a new high-quality residential development, the Project would activate this key gateway location and serve as a catalyst for future reinvestment
ED-3.1 New development: Require new development to pay its fair share of required improvements to public facilities and services through impact fees or other financial and regulatory mechanism.

Consistent: The Project would be required to pay development impact fees and other applicable fees to ensure its fair share contribution toward public services, infrastructure, and community facilities.

T-4.6 Bicycle parking standards: Require large public and private development projects to provide sufficient bicycle parking, shower, and locker facilities.

Consistent: Bicycle parking requirements for the Project include the inclusions of one Class I bicycle parking space per three DU and one Class II bicycle parking spaces per 15 DU as specified by the 2013 Specific Plan. For the Project, this requirement would be 36 Class I bicycle parking spaces and 7 Class II bicycle parking spaces. As such, the Project is required to provide 36 Class I bicycle parking spaces and eight Class II bicycle parking spaces. The Project provides one Class I bicycle parking space in each private garage and eight Class II bicycle parking spaces in the Project’s common open spaces, resulting in 106 class I and 8 class II bicycle parking spaces exceeding City requirements.

POC-3 Park incentives: Encourage developers to include open space and recreational amenities such as outdoor play areas, rooftop gardens, and family gathering spaces, in new multifamily developments Consistent: The Project incorporates approximately 31,574 sf of common open space areas, including landscaped courtyards, seating, and pedestrian walkways.

ISF-1.1 NPDES compliance: Ensure compliance with all NPDES requirements for litter control, dumping, pollutants of control, business operations, and new/re- development
Consistent: The Project would include the implementation of both flow-through planters and bioretention basins as well as self-retaining landscaped areas on the Project Site. The planters and bioretention basins are sized to meet the stormwater drainage requirements on the Project Site. After the stormwater is collected and treated, the water will flow into a detention chamber at the northern end of the Project Site prior to entering the City’s public storm drain system. The Project would be required to implement Low Impact Development measures and comply with Provision C.3 of the Regional Municipal National Pollutant Discharge Elimination System (NPDES) Permit to ensure that post-development runoff does not exceed predevelopment conditions Exhibit A - DR25-004
117
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 13 ISF-1.12: Ravenswood stormwater management. All new projects in the Ravenswood TOD Specific Plan Area must follow the stormwater policies established in Goal LU-9: Hydrological Context in the plan. Guidance in the Specific Plan supersedes policies from this General Plan.

Consistent: Please refer to the analysis of Project consistency with ISF-1.1 Exhibit A - DR25-004
118
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 14 (ii) 2013 Specific Plan Consistency
As identified above, the Project Site is in the 4C Zoning District of the 2013 Specific Plan area. The 4C Zoning District permits multifamily dwellings, which is defined as residential structure that contains three or more dwelling units within the 4C zoning district, residential uses are only allowed on upper floors, and only non-residential uses are allowed on ground floors. The Project would request a concession to override this land use restriction under the State Density Bonus Law, allowing the Project to include residential development on the ground floor. The remaining requirements for the 4 Corners Gateway designation and the Project’s compliance with those requirements are included in Table 3, Project Compliance with 2013 Specific Plan Requirements, below.

Table 3: Project Compliance with 2013 Specific Plan Requirements 2013 Specific Plan Requirement Project Compliance
Multiple-Family Dwellings: permitted use in the 4
Corners Gateway on upper levels and not permitted
on the ground floor.

Complies with SDBL concession. With a concession
under SDBL, the Project would be able to provide
residential development on the ground floor.

Maximum non-residential FAR: is 1.5. Not applicable. The Project does not include nonresidential uses.

Maximum residential density: 60 du/acre. Complies. The Project contains 23 DU per acre.

Maximum height: six stories above grade, plus an
additional 15 feet for equipment and elevator
penthouses
Complies. The Project would be three stories, which
is approximately 39 feet above grade level.

Minimum ground floor height: 16 feet floor-to-floor Complies. The Project would have an approximately nine feet to floor-to-floor height. However, the
Project would employ a waiver for this standard, per
SDBL.

Minimum front setback: six feet dedicated to
landscaping or publicly accessible sidewalk
Complies. The Project would have an approximately
16-foot front setback, including a six-foot dedication
for sidewalk.

Minimum side setback: None required Complies. The Project would have an approximately

10.5-foot side setback.

Minimum exterior side setback: 10 feet setback
along University Avenue.

Complies. The Project would have an approximately
10-foot exterior side setback on University Avenue.

Minimum rear: 30 feet Complies. The Project would have an approximately 32-foot rear setback.

Maximum setback along Bay Road and University
Avenue: at least 65% of building built to within 16
feet of property line.

Complies. The Project would have a building setback
outside of the 16-foot requirement. However, the
Project would employ a waiver for this standard, per
SDBL.

Exhibit A - DR25-004
119
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 15 Minimum parking - residential: one space per
dwelling unit for one-bedroom and studios; 0.5
additional spaces for each additional bedroom.

Complies. The Project would require 211 spaces,
but would include 229, well above the required
amount.

Minimum parking - non-residential: one space per
400 square feet
Not applicable. The Project does not include nonresidential uses.

Bicycle parking: for the residential uses, one Class I
bicycle parking space per three units and one Class
II parking space per 15 units are required. For the
non-residential uses, one Class 1 bicycle parking
space per 30 employees and one Class II per 6,000
square feet of retail are required.

Complies. The Project is required to have 36 Class I
and eight Class II spaces, but the Project includes
106 Class I and 8 Class II spaces, well above the
required amount.

Parking location: parking structures or surface
parking lots cannot be within front or exterior side
setbacks
Not applicable. Parking for the Project would not
include parking structures or surface parking lots.

Loading areas: loading areas located in the rear or
interior side yard areas
Not applicable. The Project does not include loading
areas.

Access: one pedestrian access point per 300 linear
feet off street frontage from the street to parking
lots in the rear of buildings. A maximum of two curb
cuts per street frontage may be provided
Complies. The University Avenue frontage is
approximately 89 feet and includes one pedestrian
access point. The Bay Road frontage is
approximately 304 feet and includes two
pedestrian access points. Both exceed this
requirement.

As shown above, the Project is in compliance with the requirements of the 4 Corners Zoning District. Additionally, as shown in Table 4, Project Consistency with Applicable Policies of the 2013 Specific Plan, the Project would also be consistent with the applicable 2013 Specific Plan policies.

Exhibit A - DR25-004
120
kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 16 Table 4: Project Consistency with Applicable Policies of the 2013 Specific Plan Objective/Policy Analysis of Project Consistency
Policy LU-1.1: Provide a variety of housing types, including mixed-use buildings with apartments or condominiums; standalone multifamily housing; townhomes; small-lot single-family homes; and affordable housing.

Consistent. The Project would construct 106 for-sale multi-family DUs across 10 townhome-style buildings. In addition, the Project proposes 11 affordable units at the “moderate income” level and the remaining DU included in the Project would be market rate.

Policy LU-2.1- On all parcels with frontage on the intersection of University Avenue and Bay Road, encourage new development that exhibits a high quality and character, and that supports this intersection’s identity as the heart of East Palo Alto.

Consistent. The Project Site is bound by University Avenue to the east and Bay Road to the south. While the Project requests waivers under the State Density Bonus Law it otherwise complies with the Specific Plan’s key development standards, including density, height, setbacks, parking, bicycle parking, access, and loading requirements, and maintains a high-quality, pedestrian-oriented frontage consistent with the corridor’s intended character. The architectural features utilize high-quality materials and design. The Project would also include common open space and pedestrian walkways.

Policy LU-2.3: Ensure that all development in the Plan Area along University Avenue and Bay Road adheres to the Specific Plan’s design standards and guidelines.

Consistent. Please refer to the analysis of Project consistency with Policy LU-2.1 and Table 3, Project Compliance with 2013 Specific Plan Requirements, above. As shown above, the Project would be consistent with the applicable 2013 Specific Plan requirements. While the 2013 Specific Plan does not include design standards specific to residential development, and therefore does not require compliance with such standards, the proposed building and site design is consistent with design standards and guidelines applicable to mixed-use development. These include, but are not limited to, building orientation, pedestrian connectivity, internal open space, façade articulation, massing, and material quality.

Policy LU-4.5: Require landscaping and ground cover as a component of all projects to prevent soil erosion.

Consistent. The Project includes a comprehensive landscape plan that provides ground cover and planted areas throughout the site, which will prevent soil erosion.

Landscaping on the Project Site includes 16 tree varieties, 12 shrub varieties, 12 perennial and grass varieties, and three vine varieties.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 17 Policy LU-4.7: Ensure that all new development adheres to this Specific Plan’s development standards, as well as its design standards and guidelines.

Consistent. Please refer to the analysis of Project consistency with Policy LU-2.1 Policy LU-4.10 Development should provide the minimum number of parking spaces necessary to avoid excessive parking lots, which impair community character. Ensure that building forms face onto streets and sidewalks to enhance the pedestrian environment and that parking areas are concentrated toward the inner core of parcels.

Consistent. Each DU included in the Project would include two dedicated off-street parking spaces in private garages, with an additional 17 ADA and guest surface parking spaces for a total of 229 parking spaces, as well as 114 bicycle parking spaces provided on-site. All parking areas are internal to the site and located behind building frontages, which face onto University Avenue and Bay Road with active residential entries and landscaping that promote walkability. Pedestrian access points are provided at intervals not exceeding 300 linear feet along the street frontage, connecting sidewalks to rear parking areas, and each frontage includes no more than two curb cuts to maintain sidewalk continuity. A minimum six-footwide setback zone is dedicated to landscaping or sidewalk improvements, and the Project complies with the required 19-foot front setback, ensuring a consistent and pedestrian-friendly streetscape.

Policy LU-7.1: For all new development or substantial renovation or redevelopment (greater than 20 percent of assessed valuation) of sites in Subareas II and III (as defined by Figure 4.8-3 in the Specific Plan EIR), in the 4 Corners area, or on the south side of Bay Road, require a Phase I Environmental Site Assessment (ESA), and, if recommended by the Phase I ESA, a Phase II ESA to include soil and groundwater sampling and analysis.

Share the results of the Phase I/II ESA with appropriate regulatory agencies to enable an appropriate remediation plan is to be developed. The remediation plan may include soil and groundwater cleanup, engineering controls such as vapor barriers or venting systems, and institutional controls such as deed restrictions or activity use restrictions.

Consistent. A Phase I Environmental Site Assessment (ESA) was prepared by WSP USA Inc. on December 4, 2025, for the Project; see Appendix C: Phase I ESA. The Phase I ESA did not reveal evidence of potential environmental concerns, and no further investigation was warranted at the time. Therefore, the Project would be consistent with Policy LU-7.1.

Policy LU-9.1: Ensure that new development in the Specific Plan area maximizes the amount of area available for groundwater recharge by requiring features such as roof catchment systems, irrigated landscaping, Consistent. The Project would include the implementation both flow-through planters and bioretention basins as well as self-retaining landscaped areas on the Project Site. The planters and bioretention basins are sized to meet the stormwater Exhibit A - DR25-004
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 18 and permeable pavements (where feasible), or other means to enhance on-site infiltration of stormwater runoff or landscape irrigation water.

Ensure all applicable projects under the Specific Plan comply with Provision C.3 of the Regional Municipal NPDES Permit and incorporate Low Impact Development measures to ensure that runoff is not increased. drainage requirements on the Project Site. After the stormwater is collected and treated, the water will flow into a detention chamber at the northern end of the Project Site prior to entering the City’s public storm drain system. The Project would be required to implement Low Impact Development measures and comply with Provision C.3 of the Regional Municipal NPDES Permit to ensure that postdevelopment runoff does not exceed pre-development conditions.

Policy UTIL-5.1: Ensure that new development does not adversely affect the Ravenswood Open Space Preserve and Palo Alto Baylands Natural Preserve.

Consistent. Project is located outside the boundaries of the Ravenswood Open Space Preserve and the Palo Alto Baylands Natural Preserve, and it does not encroach on any environmentally sensitive areas. Additionally, the Project adheres to all applicable design standards and development guidelines, ensuring that it would not adversely affect the ecological functions, visual character, or public access of these preserves.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 19 As supported by the tables above, the Project would be consistent with the General Plan and 2013 Specific Plan land use, density, and design requirements as well as the applicable land use policies, designed to support the City’s overall vision for land use development. (iii) Permitted Uses
The Project Site is currently zoned as “4 Corners Gateway (4C)”. The 4 Corners zoning district is addressed in the City’s Development Code, Section 18.18, which identifies Specific Plan zones including zoning districts of the Ravenswood Specific Plan. The 4C Zoning District is intended to create a vibrant downtown at University Avenue and Bay Road with multi-story mixed-use buildings featuring ground-floor retail or community spaces and upper-floor residential units. The 4 Corners Zoning District is also consistent with the MUH land use designation of the General Plan.

With approval of the SDBL applicable waivers and concession/incentive, the Project would be consistent with existing land uses and zoning. Therefore, the Project would be consistent with this criterion.
(iv) Local Coastal Program
Local Coastal Programs (LCPs) are required under the California Coastal Act for cities and counties that have jurisdiction within a coastal zone, as defined in Division 20 (commencing with Section 30000) of the PRC. The nearest Coastal Zone is the San Mateo Costal Zone, located approximately 12 miles west of the Project Site. As such, the Project Site is not located within a coastal zone and is not subject to an LCP. Therefore, the Project would be consistent with this criterion. (e) The Project will be at least one-half of the applicable density specified in subparagraph (B) of paragraph (3) of subdivision (c) of 65583.2 of the CGC. Section 65583.2(c)(3)(B) establishes the following densities:

The Project would be located within San Mateo County, which is part of the San Francisco-OaklandBerkeley, California Metropolitan Statistical Area and the San Franciso-Redwood City-South San Francisco Metropolitan Division as classified by the United State Office of Management and Budget.
3 As such, San Mateo County is considered a metropolitan county under Section 65583 of the CGC, which is associated with sites of 30 DU per acre. Therefore, because the Project would have a density of 23 DU per acre, it would be greater than one-half of the suburban jurisdiction density (15 DU per acre). Therefore, the Project would be consistent with this criterion. 3 United States Bureau of Labor Statistics, https://www.bls.gov/sae/additional-resources/metropolitan-and-necta-divisions-publishedby-ces.htm. Accessed October 2025.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 20 (f) The Project satisfies the requirements specified in paragraph (6) of subdivision (a) of Section 65913.4 of the CGC. Pursuant to CGC Section 65913.4(a)(6), the development is not located on a site that is in any of the following:

Table 5, Project Consistency with CGC 659413.4(a)(6), below, provides a consistency analysis between the project and the applicable provisions of this requirement.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 21 (a) Table 5: Project Consistency with CGC 659413.4(a)(6) Site Location Analysis of Project Consistency
The development is not located on a site that is in any of the following:
(a) Coastal Zones. A coastal zone, as defined in Division 20 (commencing with Section 30000) of the PRC.

The nearest Coastal Zone is the San Mateo Costal Zone located approximately 12 miles west of the Project Site. As such, the Project would not be in a coastal zone.4
(b) Protected Farmland. Either prime farmland or farmland of statewide importance, as defined pursuant to United States Department of Agriculture land inventory and monitoring criteria, as modified for California, and designated on the maps prepared by the Farmland Mapping and Monitoring Program (FMMP) of the Department of Conservation, or land zoned or designated for agricultural protection or preservation by a local ballot measure that was approved by the voters of that
jurisdiction.

Based on the California Department of Conservation’s FMMP, the Project site is designated as Urban and Built-up Land.5 As such, the Project is not located on Prime Farmland or Farmland of Statewide Importance. (c) Wetlands. Wetlands, as defined in the United States Fish and Wildlife Service (USFWS) Manual, Part 660 FW 2 (June 21, 1993).

Based on the USFWS National Wetlands Inventory Mapping Tool, there are no wetlands on the Project Site.6 Therefore, the Project would not be developed on a wetland.
(d) Very High Fire Hazard Severity Zone. Within a very high fire hazard severity zone, as determined by the California
Department of Forestry and Fire Protection (CAL FIRE) pursuant Based on the CAL FIRE Fire Hazard Severity Zones Viewer, the Project Site is not located in a CAL FIRE-designated State Responsibility Area (SRA) or 4 California Coastal Commission, Coastal Zone Boundary: San Mateo County. Available at: https://www.coastal.ca.gov/maps/czb/. Accessed November 2025. 5 California Department of Conservation (DOC), California Important Farmland Finder. Available at: https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed November 2025. 6 United States Fish and Wildlife Service, National Wetlands Inventory, Wetlands Mapper. Available at https://www.fws.gov/program/national-wetlands-inventory/wetlands-mapper. Accessed November 2025.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 22 to Section 51178, or within a high or very high fire hazard severity zone (FHSZ) as indicated on maps adopted by CAL FIRE pursuant to Section 4202 of the PRC. This subparagraph does not apply to sites excluded from the specified hazard zones by a local agency, pursuant to subdivision (b) of Section 51179, or sites that have adopted fire hazard mitigation measures pursuant to existing building standards or state fire mitigation measures applicable to the development.

Local Responsibility Area (LRA).7 The nearest FHSZ is an LRA designated as a Moderate FHSZ located approximately four miles southeast of the Project Site. Therefore, the Project would not be developed within a very high FHSZ.
(e) Hazardous Waste Site. A hazardous waste site that is listed pursuant to Section 65962.5 or a hazardous waste site
designated by the Department of Toxic Substances Control (DTSC) pursuant to Section 25356 of the Health and Safety Code, unless the DTSC has cleared the site for residential use or mixed uses.

The Project Site is not located on any of the lists which have been compiled pursuant to CGC Section 65962.5.8,9 Additionally, review of the California State Water Resources Control Board (SWRCB) GeoTracker database and the DTSC Cortese database did not identify any sites on or adjacent to the Project Site. Therefore, the Project would not be developed on a hazardous waste site that is listed pursuant to Section 65962.5 and would be consistent with this criterion.
(f) Earthquake Fault Zone. Within a delineated earthquake fault zone as determined by the State Geologist in any official maps published by the State Geologist, unless the development complies with applicable seismic protection building code standards adopted by the California Building Standards
Based on the California Geologic Survey (CGS) Alquist-Priolo Site Investigation Application, the nearest potentially active fault is the Woodside Quadrangle, which is an Alquist-Priolo Earthquake Fault Zone, located approximately 9.3 miles east of the Project Site.10 Therefore, the 7 California Department of Forestry and Fire Protection, FHSZ Viewer. Available at:
https://calfire-forestry.maps.arcgis.com/apps/webappviewer/index.html?id=988d431a42b242b29d89597ab693d008. Accessed November 2025. 8 California State Water Resources Board, Geotracker. Available at: https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=5730+uplander+way. Accessed November 2025.
9 United Stated Department of Toxic Substances Control (DTSC), EnviroStor. Available at: https://www.envirostor.dtsc.ca.gov/public/map/. Accessed November 2025. 10 California Geologic Survey, Alquist-Priolo Site Investigation Reports, https://maps.conservation.ca.gov/cgs/informationwarehouse/apreports/. Accessed November 2025.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 23 Commission under the California Building Standards Law (Part

2.5 (commencing with Section 18901) of Division 13 of the Health and Safety Code), and by any local building department under Chapter 12.2 (commencing with Section 8875) of Division 1 of Title 2.

Project would not be developed within a delineated earthquake fault zone.
(g) Special Flood Hazard. Within a special flood hazard area subject to inundation by the 1 percent annual chance flood (100-year flood) as determined by the Federal Emergency Management Agency (FEMA) in any official maps published by FEMA.

The Project Site and immediate surrounding areas are designated as Flood Zone Z, which is designated for areas of minimal flood hazard by FEMA.11 Therefore, the Project would not be developed within a special flood hazard area subject to inundation by a one percent annual change flood. (h) Regulatory Floodway. Within a regulatory floodway as determined by FEMA in any official maps published by the FEMA, unless the development has received a no-rise certification in accordance with Section 60.3(d)(3) of Title 44 of the Code of Federal Regulations.

The Project Site and immediate surrounding areas are not located within a known floodway. The nearest known regulatory floodway is located approximately 15 miles southeast of the Project site. 13 (i) Adopted Natural Community Conservation Plan. Lands
identified for conservation in an adopted natural community conservation plan pursuant to the Natural Community
Conservation Planning Act (Chapter 10 (commencing with
Section 2800) of Division 3 of the Fish and Game Code), habitat conservation plan pursuant to the federal Endangered Species No portions of the City are located within the boundaries of a Natural Community Conservation Plan (NCCP), Habitat Conservation Plan Programs (HCP) or other approved local, regional, or State habitat conservation plans.12 Therefore, the Project would not be located on land identified for conservation.
11 Federal Emergency Management Agency, National Flood Hazard Layer, Flood Insurance Rate Maps https://msc.fema.gov/portal/search?AddressQuery=2400%20university%20ave%20east%20palo%20alto%20 Accessed November 2025. 12 CDFW, NCCP Plan Map, 2023, https://wildlife.ca.gov/conservation/planning/nccp/plans, Accessed November 2025.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 24 Act of 1973 (16 U.S.C. Sec. 1531 et seq.), or other adopted natural resource protection plan.
(j) Critical Habitat. Habitat for protected species identified as candidate, sensitive, or species of special status by state or federal agencies, fully protected species, or species protected by the federal Endangered Species Act of 1973 (16 U.S.C. Sec. 1531 et seq.), the California Endangered Species Act (Chapter 1.5 (commencing with Section 2050) of Division 3 of the Fish and Game Code), or the Native Plant Protection Act (Chapter 10 (commencing with Section 1900) of Division 2 of the Fish and Game Code).

The potential for the presence of critical habitat for listed and endangered species was assessed using the USFWS Informational for Planning and Consultation (IPaC) map tool and reports and the California Department of Fish and Wildlife (CDFW) California Natural Diversity Database (CNDDB).13 The Project Site does not overlap with any of the critical habitats for the species listed in the databases. As the Project Site does not overlap with critical habitat for the species protected in the regulatory framework identified for this criterion, there is a low probability that the Project would interfere with these species’ habitats and activities.

The IPaC mapping tool indicated that migratory birds have the potential to occur on-site near or on the Project Site. However, construction of the Project would be subject to compliance with the Migratory Bird Treaty Act to reduce potential impacts to migratory birds. Therefore, the Project would not be developed within habitat for protected species identified as candidate, sensitive, or species of special status by State or federal agencies, fully protected species, or species protected by the regulations listed above. Additionally, as concluded in the Burrowing Owl Habitat Assessment (see Appendix D: Burrowing Owl Habitat Assessment), the Project site does not provide suitable habitat for burrowing owls. (k) Land under conservation easement. The Project is not located on land under a conservation easement. 13 U.S. Fish and Wildlife Service, IPaC database, https://ipac.ecosphere.fws.gov/location/MQBD2Z5P2VEAPINFKQDHY454T4/resources. Accessed November 2025.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 25 Therefore, the Project would satisfy the requirement specified in paragraph (6) of subdivision (a) of Section 65913.4 of the CGC.
(l) The Project does not require demolition of a historic structure.

There are no structures present on the Project Site, which would require demolition. Based on the National Register of Historic Places, there are no known historical/cultural resources listed (or eligible for listing) located on or adjacent to the Project Site.14 Additionally, there are no known historical structures identified by the California Register of Historic Resources (CRHR) in or adjacent to the Project Site.15 The Project Site is not located within the City’s designated historic districts. 16 Therefore, the Project would not require demolition of a historic structure. The Project would meet this criterion.
(m) The Project does not include any transient lodging.

The Project would develop 106 DUs as part of a for-sale townhouse development and would not provide transient lodging. Therefore, the Project would meet this criterion. (n) Consultation with Native American Tribes Pursuant to PRC Section 21080.66(b) Under this statutory exemption, the City, as the Lead Agency, is required to provide formal notification via certified mail or email to each California Native American Tribe that is traditionally and culturally affiliated with the Project site. The tribal consultation requirements applicable to the statutory exemption differ from those required under Assembly Bill 52 with respect to timing and procedural requirements. Accordingly, the City is required to coordinate with the applicable Native American Tribes to ensure that the consultation requirements of Public Resources Code Section 21080.66 are implemented appropriately.

The Lead Agency received a request from the Applicant for an AB 130 CEQA Exemption on October 14, 2025. Notices of Invitation for Consultation were provided to tribes traditionally and culturally affiliated with the Project site on October 24, 2025, including the Muwekma Ohlone Tribe of the San Francisco Bay Area, the Tamien Nation, and the Indian Canyon Band of Costanoan Ohlone People.
14 U.S. Department of the Interior, National Register of Historic Places, https://www.nps.gov/maps/full.html?mapId=7ad17cc9-b808- 4ff8-a2f9-a99909164466. Accessed October 2025.
15 California Register of Historic Places, https://ohp.parks.ca.gov/ListedResources/?view=county&criteria=41. Accessed October 2025. 16 City of East Palo Alto, 2013 Ravenswood / 4 Corners TOD Specific Plan EIR. Accessed October 2025.

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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 26 Muwekma Ohlone Tribe of the San Francisco Bay Area
A request for consultation was received from the Tribe on October 25, 2025, and consultation was initiated on October 28, 2025. Consultation concluded on December 27, 2025. A meeting could not be scheduled within the permitted consultation timelines, and the Applicant declined an additional extension request.

Tamien Nation
A request for consultation was received on November 4, 2025, and consultation was initiated on November 18, 2025. Consultation occurred on December 12, 2025, and concluded on January 2, 2026.

Indian Canyon Band of Costanoan Ohlone People
A request for consultation was received on November 18, 2025, and consultation was initiated on December 4, 2025. Consultation concluded on January 18, 2026, following non-responsiveness to follow-up emails and phone calls after requesting consultation.

The outcomes of Tribal consultation require the implementation of Tribal Monitoring and Tribal Cultural Resources measures, as outlined in Appendix E: Tribal Monitoring and Tribal Cultural Resources, which shall be fully implemented and enforced as conditions of project approval. (o) Hazards and Hazardous Materials Pursuant to PRC Section 21080.66(c)(1) A Phase I Environmental Site Assessment (ESA) was prepared by WSP USA Inc. on December 4, 2025, for the Project; see Appendix C: Phase I ESA. The Phase I ESA did not identify any Recognized Environmental Conditions or Controlled Recognized Environmental Conditions requiring further investigation. One Historical Recognized Environmental Condition (HREC) associated with a former dry-cleaning operation was identified and determined to have naturally attenuated to levels suitable for unrestricted use, with no evidence of soil vapor impacts. Accordingly, no Phase II investigation was recommended. Based on these findings, the Project would not expose people or structures to a significant risk involving hazardous materials and would meet the requirements of PRC Section 21080.66(c)(1).
(p) Environmental Hazard and Air Filtration Standards Pursuant to PRC Section 21080.66(c)(2) PRC Section 21080.66(c)(2) mandates building specifications for projects within 500 feet of a freeway. The Project Site is bound by University Avenue to the west and Bay Road to the south.

The City’s General Plan identifies University Avenue and Bay Road as major arterials, which are generally designed to facilitate two or more lanes of moving vehicles in each direction and rarely contain on-street parking. and are not considered freeways. The nearest freeway is located Exhibit A - DR25-004
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kimley-horn.com 2121 South El Camino Real Suite 550, San Mateo, CA 94403 27 approximately 3,767 feet (0.7-mile) from the Project Site and is identified as State Route 101.

Therefore, this criterion does not apply.
(q) Labor Requirements Pursuant to PRC Section 21080.66(d) PRC Section 21080.66(d) imposes labor requirements only on housing development projects that are 100 percent affordable and exceed 85 feet in height above grade. The Project would have a maximum building height of approximately 38 feet, 11 inches, which does not exceed 85 feet above grade, and the Project is not a 100 percent affordable housing development. Because the Project does not meet the eligibility criteria that would trigger the labor requirements under PRC Section 21080.66(d), these labor requirements do not apply.

5.0 CONCLUSION
As is evidenced by the discussions presented above, the Project would meet all the criteria listed by PRC Section 21080.66. Because the Project satisfies all eligibility criteria for the statutory exemption for housing development projects, no further environmental review is required under CEQA.

Figures:

Figure 1: Regional Location Map
Figure 2: Local Vicinity Map
Appendices:

Appendix A: PRC Section 21080.66
Appendix B: CGC Section 65913.4
Appendix C: Phase I ESA
Appendix D: Burrowing Owl Habitat Assessment
Appendix E: Tribal Monitoring and Tribal Cultural Resources Exhibit A - DR25-004
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The appendices described above can be accessed through the City’s webpage on the University & Bay at 4 Corners – Townhome Project
(https://www.cityofepa.org/planning/project/four-corners-townhome-project-dr25-004- pre24-003-1675-bay-road)
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EXHIBIT B

CITY OF EAST PALO ALTO

PLANNING COMMISSION

DESIGN REVIEW, TENTATIVE MAP, AND TREE REMOVAL
DR25-004 – TOWNHOME RESIDENTIAL PROJECT

REQUIRED FINDINGS FOR APPROVAL
The Review Authority may approve, conditionally approve, or deny the Design Review and Tentative Map only after first making all of the following findings.

SITE PLAN AND DESIGN REVIEW FINDINGS
The proposed development is consistent with the General Plan and any applicable specific plan and is in compliance with all applicable provisions of the Development Code and all other City ordinances and regulations;
The proposed development is consistent with the following General Plan and 2013 Ravenswood / 4 Corners TOD Specific Plan goals and policies:

General Plan Goals and Policies
Housing
Goal LU-3. Expand the number, types and diversity of housing within East Palo Alto.

3.1 Infill housing. Encourage new infill housing in residential and mixed use areas of the City in order to expand the amount and diversity of housing.

3.2 Balanced housing. Over time, establish a balance of market rate and affordable housing in East Palo Alto. To achieve this policy, encourage both market rate and affordable housing.

Goal LU-4. Expand multi-family housing.
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4.1 Diversity of building types. Encourage a diversity of building types and styles in areas designated for multi-family housing. These building types should range from duplex/triplex/fourplex to courtyard housing to multi-family housing developments. The diversity of building types will respond to the diversity of the City of East Palo Alto’s population and the desire to create interesting and varied neighborhoods.

4.2 Intensification. Require that development projects maximize the number of residential units in the redevelopment of parcels in areas designated for Medium Density, High Density and Urban Residential.

4.3 Building orientation. Wherever feasible, orient multi-family buildings to face streets, public spaces or shared private spaces.

Analysis
The project is consistent with General Plan Goal LU-3 by expanding the supply and diversity of housing within East Palo Alto through development of 106 new multifamily townhome units on an infill site located within a planned growth area. Policy

3.1 is achieved through the project’s introduction of new housing in a mixed-use and residential transition area, supporting efficient use of existing infrastructure and expanding the City’s housing inventory. The project also supports Policy 3.2 by contributing new housing units at market-rate and moderate income levels which supports the City’s objective of maintaining a balanced mix of market-rate and affordable housing.

The project is consistent with General Plan Goal LU-4 by providing new multi-family housing in a location planned for higher-density residential development.

Consistency with Policy 4.1 is achieved by the project by contributing to a diversity of building types within the City’s multi-family housing inventory through the construction of townhomes in an area that includes single family homes and higher density multifamily units. The project advances Policy 4.2 by redeveloping an underutilized parcel with a residential density (23 units per acre) consistent with the site’s planned designation (up to 86 units per acre), supporting housing production goals. The project is also consistent with Policy 4.3, as buildings are oriented toward Bay Road, internal driveways and pedestrian pathways, and shared open spaces.

Preserving University Village
Goal LU-5. Preserve the character of existing single-family neighborhoods. 135
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5.4 Redevelopment of large lots. Allow for the subdivision of large lots (primarily in the Weeks neighborhood) for single family housing and in conformance with the zoning code. The design of the new infill development should integrate to the greatest extent feasible with adjacent areas.

Analysis
The project is consistent with General Plan Goal LU-5 by incorporating building design, site planning, and landscape treatments that are compatible with the surrounding residential neighborhood and help preserve the character of nearby single-family areas. The townhouse building forms incorporate residential-scaled architecture, articulated façades, and varied rooflines that reflect architecture of the University Village’s single family neighborhood. Consistent with Policy 5.4, the project redevelops 1675 Bay Road, a large underutilized parcel, in conformance with applicable zoning and Specific Plan standards while integrating with adjacent areas through building orientation, pedestrian connections, and streetscape improvements.

The project’s scale (lower density multi-family housing), internalized parking, and enhanced landscaping further support compatibility with the surrounding single family University Village.

Infrastructure and Public Safety
Goal ISF-1. Manage stormwater safely, efficiently, and sustainably.

1.2 On-site stormwater management. Encourage development projects to manage stormwater on site to reduce burdens on the City’s stormwater system. Whenever possible, stormwater should be infiltrated, evapotranspirated, reused or treated on-site in other ways that improve stormwater quality and reduce flows into the storm drain system.

1.3 Stormwater infrastructure for new development. Require development projects to pay for their share of new stormwater infrastructure or improvements necessitated by that development.

Analysis
The project is consistent with General Plan Goal ISF-1 and Policies 1.2 and 1.3 by incorporating on-site stormwater management measures, including bioretention areas, pervious pavement, and drainage features designed to treat and manage stormwater runoff prior to discharge to the municipal system. These measures reduce runoff volumes, improve stormwater quality, and minimize impacts on the City’s storm drain infrastructure. The project will also be required to pay applicable 136
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development impact fees and implement frontage and infrastructure improvements necessary to support stormwater system capacity consistent with City standards.

Goal ISF-2. Ensure a sustainable, clean, long-term water supply.

2.6 Water infrastructure for new development. Require development projects to pay for their share of new water infrastructure or improvements necessitated by that development, including but not limited to water supply, storage, and conservation: and recycled water.

2.7 Water supply for new development. Require new or intensified development to demonstrate that adequate water is available before project approval.
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Analysis
The project is consistent with Goal ISF-2 and Policies 2.6 and 2.7 by contributing its fair share toward water infrastructure improvements and demonstrating that adequate water service is available prior to project approval through coordination with the applicable water service provider. The project will comply with applicable water efficiency standards, conservation requirements, and infrastructure improvement obligations required as part of the development review and building permit process. These measures support long-term water supply sustainability and system reliability.

Goal SN-1. Reduce the risk to people and property from earthquakes and other geologic hazards.

1.3 Licensed geologist. Require that a state licensed engineering geologist prepare and/or review development proposals involving grading, unstable soils, and other hazardous conditions. Incorporate recommendations of the geologist into design plans, potentially including building modifications and open space easements.

Analysis
The project is consistent with Goal SN-1 and Policy 1.3 by incorporating recommendations from project-specific geotechnical and soils reports prepared and reviewed by Atlas-Geosphere Consultants on July 29, 2019 and confirmed by Atlas Technical Consultants on December 4, 2025. The project design incorporates grading, foundation, and site design measures to address site-specific soil conditions and seismic considerations, thereby reducing risk to people and property from geologic hazards.

Goal T-3. Create a complete, safe, and comfortable pedestrian network for people of all ages and abilities.

3.3 Pedestrian network. Create a safe, comfortable, and convenient pedestrian network that focuses on a) safe travel; b) improving connections between neighborhoods and commercial areas, and across existing barriers; c) providing places to sit or gather, pedestrian-scaled street lighting, and buffers from moving vehicle traffic; and d) includes amenities that attract people of all ages and abilities.

Analysis
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The project is consistent with Goal T-3 and Policy 3.3 by providing a pedestrianoriented site design that includes internal walkways, connections to public sidewalks along Bay Road and University Avenue, pedestrian-scaled lighting, landscaping, and separation between pedestrian and vehicular circulation. The project enhances connectivity between surrounding neighborhoods and nearby commercial and transit areas, while incorporating design elements that support safe and comfortable pedestrian travel for users of all ages and abilities.

Ravenswood / 4 Corners TOD Specific Plan Goals and Policies Housing
Goal LU-1 A balanced land use pattern that meets community needs for residential, commercial, industrial and public uses.

Policy LU-1.1Provide a variety of housing types, including mixed-use buildings with apartments or condominiums; standalone multifamily housing; townhomes; small-lot single-family homes; and affordable housing.

Policy LU-1.5Maintain adequate separation between potentially incompatible land uses.

Analysis
The project is consistent with Goal LU-1 and Policy LU-1.1 by providing a townhomestyle multi-family residential development, which is identified within the Ravenswood / 4 Corners Plan Area as an acceptable type of housing. The project contributes to a balanced land use pattern by introducing new residential development in a location planned for housing near transit and services. Consistency with Policy LU-1.5 is achieved through site planning, building orientation, and internal circulation that maintain appropriate separation between residential uses and adjacent rights-of-way and surrounding land uses.

Design
Goal LU-3 Strengthened residential neighborhoods.

Policy LU-3.2Ensure that new development throughout the Plan Area maintains or improves the character of any adjacent residential neighborhoods.

Goal LU-4 Development projects that improve the quality of life in the Plan Area and draw residents and visitors to Ravenswood/4 Corners.
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Policy LU-4.4Ensure that new development respects existing public view corridors within the Plan Area and also allows for the pro-posed east-west view corridor through Ravenswood north of Bay Road.

Policy LU-4.7Ensure that all new development adheres to this Specific Plan’s development standards, as well as its design standards and guidelines.

Policy LU-4.10 Development should provide the minimum number of parking spaces necessary to avoid excessive parking lots, which impair community character. Ensure that building forms face onto streets and sidewalks to enhance the pedestrian environment and that parking areas are concentrated toward the inner core of parcels.

Analysis
The project is consistent with Goal LU-3 and Policy LU-3.2 by employing articulated building massing, townhouse-scale forms, and internalized parking that maintain and improve compatibility with nearby residential neighborhoods.

The project advances Goal LU-4 by introducing new residential development that improves the quality and activation of the Four Corners area. Consistency with Policy LU-4.4 is demonstrated through building placement and height that respect existing and planned view corridors, including the east-west corridor north of Bay Road.

The project complies with Policy LU-4.7 by adhering to the Specific Plan’s development standards and design guidelines, as documented in the project’s Design Review analysis. Consistency with Policy LU-4.10 is achieved through provision of parking that meets project needs without creating excessive surface parking, locating parking primarily within garages and internal areas, and orienting buildings toward streets and pedestrian paths to enhance the public realm.

Streetscape and Mobility
Goal TRA-6 Attractive streetscapes that contribute to a positive image for East Palo Alto.

Policy TRA-6.1 As development occurs, ensure that developers implement the Streetscape Standards contained in this Specific Plan.

Analysis
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The project is consistent with Goal TRA-6 and Policy TRA-6.1 by incorporating pedestrian connections, landscaped frontages, and streetscape improvements consistent with the Specific Plan’s Streetscape Standards, contributing to an attractive and walkable public environment along Bay Road and within the project site.

Summary
The proposed development is consistent with the City of East Palo Alto General Plan and the Ravenswood / 4 Corners TOD Specific Plan (Specific Plan), which designate the project site for mixed-use development including multi-family residential housing. The project advances General Plan and Specific Plan goals related to housing production, infill development, and neighborhood-compatible design through the proposed townhomes, site planning, and pedestrian-oriented layout.

The project complies with applicable Specific Plan development standards, design standards, and guidelines governing building height, massing, circulation, parking, and streetscape design. The proposed site layout and architectural design are compatible with surrounding single-family residential, multi-family, commercial, and government-oriented developments. The proposed project maintains appropriate transitions to adjacent residential areas. The project is consistent with applicable provisions of the City’s Development Code, including zoning regulations, site development standards, and required permit procedures. With approval of the proposed entitlements and implementation of applicable conditions of approval, the project complies with all other applicable City ordinances, regulations, and adopted policies.

The proposed development is to be constructed on a suitable site, adequate in shape, size, topography, and other circumstances to accommodate the proposed development;
Analysis
The project site is of sufficient size (4.61 acres) and adequate in shape to accommodate the proposed 106-unit multi-family townhome development, including building footprints, internal circulation, parking, landscaping, and required open space. The size of the site allows for the proposed 23 townhome units per acre. Adequate access to public streets, utilities, and infrastructure is available to serve the development. The shape of the site is a polygon that allows multiple points of access along University Avenue, Bay Road, Fordham Stret, and Michigan Avenue. The site is generally flat and does not contain topographic constraints that would preclude development consistent with applicable zoning and Specific Plan standards. The proposed site layout organizes buildings, drive aisles, and pedestrian pathways in a manner that responds to existing site conditions and surrounding streets. The project site is an infill development and would be supported by existing roadways and 141
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utilities. Accordingly, the physical characteristics of the site are suitable to support the proposed project.

The proposed development complies with the applicable standards of review; Analysis
The proposed development complies with the applicable standards of review established by the City’s General Plan, Specific Plan, and Zoning Ordinance. The project meets required development standards related to land use, building height, massing, site planning, circulation, and parking, and is consistent with the applicable design standards and guidelines of the Specific Plan. The proposed architectural design, site layout, and landscape treatment have been evaluated for consistency with adopted policies and standards governing neighborhood compatibility and pedestrian orientation. With implementation of the recommended conditions of approval, the project satisfies all applicable standards of review.

General Plan Evaluation
Category Allowed Townhome Project
Density 86 units per acre (max) 23 units per acre
Intensity (FAR) 2.5 max Not Applicable
Height 100’ or 8 stories, whichever
is higher (max)
3 stories above
grade; 39'
Ground Floor Retail 35% (required) None Proposed
Specific Plan Consistency Evaluation
Category Allowed Townhome Project
Density 60 dwelling units per acre (max); 120 total units for the project 23 units per acre
Intensity
(FAR)

1.5 (max) for non-residential units and
commercial components in mixed use projects Not Applicable Height 6 stories above grade, plus an additional 15’ for equipment
3 stories above
grade; 39'
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Specific Plan Consistency Evaluation
Category Allowed Townhome Project
Ground
Floor
Height1
16’ (min) 8’1”
The proposed development is designed and arranged to provide adequate consideration to ensure the public health, safety, and general welfare, and to prevent adverse effects on neighboring property
Analysis
The proposed development is designed and arranged to protect the public health, safety, and general welfare through compliance with applicable building, fire, and accessibility standards, City policies governing site design and circulation, and Conditions of Approval.

The site layout provides clear separation between pedestrian and vehicular areas, adequate emergency access, and internalized parking to reduce potential conflicts and safety hazards. Building massing, setbacks, and architectural articulation are arranged to maintain compatibility with surrounding development and to minimize potential visual, noise, and privacy impacts on neighboring properties. With implementation of standard conditions of approval and applicable mitigation measures, the project avoids adverse effects on adjacent properties and surrounding neighborhoods.

Tentative Map Findings
The proposed map, subdivision design, and improvements are consistent with the General Plan, any applicable specific plan, and this Article.

Analysis
The Tentative Map and site design are consistent with the land use designations, policies, and objectives of the City of East Palo Alto (City) General Plan and the Ravenswood / 4 Corners TOD Specific Plan as it was in effect on the date the project preliminary application was submitted. The subdivision layout supports the planned residential use of the site and facilitates orderly development through appropriately sized parcels, internal

1 State density bonus regulations permit the use of waivers from development standards to encourage the construction off additional housing. The applicant would be requesting a waiver from the General Plan ground floor retail percentage requirement.
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circulation, and access to public streets and utilities. The proposed improvements, including streets, utilities, and infrastructure, are designed to comply with applicable Development Code and subdivision standards. The map and improvements implement the Specific Plan’s goals related to pedestrian connectivity, neighborhood compatibility, and efficient use of land. Accordingly, the proposed map and subdivision design are consistent with the General Plan, applicable specific plans, and this Article.

The site is physically suitable for the type and proposed density of development.

Analysis
The project site is physically suitable to accommodate the townhome development at the proposed density, given its size, configuration, and existing conditions, consistent with all applicable City and state regulations. The site is located in a fully developed area of the City. The site provides sufficient area to support the number of residential units, building footprints, required parking, internal circulation, and open space in compliance with applicable standards. The site is generally flat and free of physical constraints that would limit development at the proposed density. Existing and planned public infrastructure and access are adequate to serve the intensity of development proposed. Accordingly, the physical characteristics of the site support the type and density of development contemplated by the project.

The design of the subdivision and the proposed improvements are not likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.
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Analysis
The proposed subdivision design and associated improvements are not likely to cause substantial environmental damage, as the project is located on an urbanized site that does not contain sensitive biological resources. The project incorporates compliance with applicable environmental regulations, including stormwater management and erosion control measures, to minimize construction- and operation-related impacts. Landscaping and site design are intended to avoid unnecessary disturbance and to incorporate best management practices that protect water quality. With implementation of standard conditions of approval and any required environmental mitigation measures, the project would not substantially or avoidably injure fish or wildlife or their habitat.

The design of the subdivision or type of improvements is not likely to cause serious public health or safety problems.

Analysis
The design of the subdivision and the proposed improvements are not likely to cause serious public health or safety problems, as the project complies with applicable building, fire, and public works standards. The subdivision layout provides adequate vehicular access, emergency access, and internal circulation, while separating pedestrian and vehicular movements to reduce potential conflicts consistent with City and State requirements. The project will be served by existing and planned public utilities and infrastructure designed to accommodate the proposed development. With implementation of required conditions of approval and adherence to applicable codes and standards, the project would not create hazards or adverse public health or safety conditions.

The design of the subdivision or the type of improvements will not conflict with easements acquired by the public at large for access through or use of, property within the proposed subdivision.
 This finding may also be made if the Review Authority finds that alternate easements for access or use will be provided, and that they will be substantially equivalent to ones previously acquired by the public.
 This finding shall apply only to easements of record, or to easements established by judgment of a court of competent jurisdiction, and no authority is hereby granted to the Review Authority to determine that the public at large has acquired easements of access through or use of property within the proposed subdivision.

Analysis
The design of the subdivision and the proposed improvements are not in conflict with existing easements acquired by the public for access or use of property within the 145
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subdivision. The subdivision map identifies and respects all existing utility, access, and drainage easements, and proposed improvements are designed to avoid encroachment into those areas. Where easements are present, building placement and infrastructure improvements maintain required clearances to ensure continued function and access.

Accordingly, the subdivision design preserves public easement rights and does not interfere with their intended purpose.

The discharge of sewage from the proposed subdivision into the community sewer system will not result in violation of existing requirements specified by the California Regional Water Quality Control Board.

Analysis
The proposed subdivision will discharge sewage to the community sewer system in a manner that will not result in a violation of requirements established by the California Regional Water Quality Control Board. A sanitary sewer capacity analysis prepared by BKF Engineers estimates the project’s wastewater generation at approximately 25,440 gallons per day based on East Palo Alto Sanitary District (EPASD) standard design factors, and identifies existing public sewer mains in Bay Road and Fordham Street available to serve the project
The project will connect to the existing EPASD system in accordance with District standards and subject to EPASD review and approval. With compliance with EPASD requirements and applicable permits, the project’s sewer discharge will be adequately accommodated without exceeding system capacity or violating Regional Water Quality Control Board regulations.

The design of the subdivision provides, to the extent feasible, passive or natural heating and cooling opportunities. and
Analysis
The design of the subdivision and project site plan provide passive heating and cooling opportunities through building orientation, spacing, and site planning that maximize access to natural light and ventilation. Buildings are arranged to allow solar exposure and cross-ventilation while minimizing excessive heat gain, supported by articulated massing and landscaped open areas. Primary building entrances are oriented toward the south allowing for the afternoon sun to fall towards the rear of the townhomes. Open circulation areas, including internal walkways and courtyards, are designed to facilitate air movement, daylight access, and shaded pedestrian routes, contributing to occupant comfort and reduced reliance on mechanical heating and cooling systems. 146
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The proposed subdivision, its design, density, and type of development and improvements conforms to the regulations of the Development Code and the regulations of any public agency having jurisdiction by law.

Analysis
The proposed subdivision’s design, density, land use, and associated improvements conform to the applicable regulations of the City’s Development Code and the requirements of all public agencies with jurisdiction over the project. The project complies with zoning and site development standards, and has been reviewed for consistency with applicable Specific Plan regulations and adopted design standards. Infrastructure systems, including stormwater management and sanitary sewer service, have been evaluated and designed in accordance with the standards of the San Mateo Countywide Water Pollution Prevention Program, Menlo Park Fire Protection District, and the East Palo Alto Sanitary District. With approval of the required entitlements and implementation of applicable conditions of approval, the project conforms to applicable City ordinances and the regulations of other responsible agencies.

Criteria for Tree Removal, pursuant to East Palo Alto Municipal Code Section

18.28.070
The subject tree is eligible for removal based on the criterion of subsection D: The trees interfere with proposed development, repair, alteration, or improvement of a site and preservation would stop the implementation of a well-integrated and thoughtful design that enhances the property and neighborhood while meaningfully furthering the goals set forth in the General Plan and the project will incorporate replacement trees.

An arborist report was prepared by HortScience | Bartlett Consulting in August 2025. The arborist concluded that the project will completely encompass the site. Plans depict removal of 13 on-site trees, and indicates it is possible to preserve 13 off-site trees. The project should seek to reduce impacts to coast live oak #178, which is an offsite tree, with a 31-foot overhang and branching to the ground. The arborist recommended providing a 10-foot buffer from the trunk where no work would be completed. 147
Exhibit C - Conditions of Approval
University & Bay at 4 Corners
- Townhome Project
DR25-004
Contents
Contents.......................................................................................................................... 1 A. General Conditions of Approval ............................................................................... 2 B. Standard Conditions of Approval.............................................................................. 3 Air Quality .................................................................................................................... 3 Noise and Vibration ..................................................................................................... 5 Public Works and Utilities ............................................................................................ 6 C. Project Specific Conditions of Approval.................................................................. 11 Planning Division ....................................................................................................... 11 Building Division ........................................................................................................ 15 City Attorney .............................................................................................................. 16 Housing Division........................................................................................................ 16 Police Department ..................................................................................................... 17 Public Works Department .......................................................................................... 19 Menlo Park Fire Protection District ............................................................................ 20 D. Tribal Monitoring and Tribal Cultural Resources .................................................... 24 Tribal Monitoring ........................................................................................................ 24 During Construction or Upon the Discovery of Tribal Cultural Resources.................. 25 Tribal Knowledge, Avoidance and memorialization.................................................... 26 148
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A. General Conditions of Approval

1. Prior to the issuance of any building permits, the property owner and/or developer shall acknowledge in writing all the conditions of approval and must accept these conditions with full awareness of the responsibilities associated with each requirement. The conditions of approval shall be reproduced on the first page of the plan set to the Building Division.

2. Prior to the issuance of Building Permits, the project applicant/developer must obtain all required approvals including the will serve letter and be in compliance with all the conditions of the East Palo Alto Sanitary District.

3. The following Conditions of Approval may be superseded by future State regulations or outside regulatory agency requirements and guidelines. The project must comply with any conditions superseded by State regulations or outside regulatory agency requirements.

4. Prior to issuance of building permits, the property owners shall file with the Director of Community Development, on forms provided by the City, an acknowledgment that they have read, understand and agree to these conditions of approval.

5. All applicable mitigation measures specific to development projects included in the East Palo Alto General Plan Mitigation Monitoring and Reporting Program (MMRP) and the 2013 Ravenswood Business District / 4 Corners Specific Plan shall be implemented.

6. Regulatory and Development Fees
a) The applicant/developer agrees to pay all applicable regulatory fees in effect at the time of Building Permit and Plan Check application submittal, including but not limited to General Plan Update Surcharge, Plan Check, Building Permit, etc., as specified by each respective City Ordinance or the City's Master Fee Schedule.
b) Pursuant to Government Code Section 65589.5(o), the project is subject to development fees, as defined by Government Code Section 65941.1(b)(3)(B)(i), in effect when a complete application was submitted to the City, which are the development fees that were effective on July 1, 2024 and attached to these conditions as Attachment A.
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B. Standard Conditions of Approval
Air Quality
Construction & Operations

1. The project shall implement the following best management practices to ensure that the project’s air quality impacts are less than significant:
• All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. • All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
• All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
• All driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
• Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
• All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
• Post a publicly visible sign with the telephone number and person to contact at the City of East Palo Alto regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.

2. The project shall implement the following standard control measure to ensure potential impacts from increased cancer risk and annual PM2.5 concentrations from project construction are minimized. The use of TAC emission controls is a standard measure for urban development throughout the Bay Area that is located 150
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in close proximity to sensitive receptors. With these measures the project would have a less than significant impact on air quality:
• All construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. EPA Tier 4 emission standards for particulate matter (PM10 and PM2.5) if feasible, otherwise:
o If use of Tier 4 equipment is not available, alternatively use equipment that meets U.S. EPA emission standards for Tier 2 or 3 engines and include particulate matter emissions control equivalent to CARB Level 3 verifiable diesel emission control devices that altogether achieve an 85-percent reduction in particulate matter exhaust in comparison to uncontrolled equipment; alternatively (or in combination).
o Use of alternatively fueled equipment with lower NOx emissions that meet the NOx and PM reduction requirements above.
o Special equipment that cannot meet the above requirements must be approved as exempt by the City after considering reasons for requesting an exemption.
o Use portable electrical equipment where commercially available and practicable to complete construction. Construction contractors shall utilize electrical grid power instead of diesel generators when (1) grid power is available at the construction site; (2) when construction of temporary power lines is not necessary in order to provide power to portions of the site distant from existing utility lines; (3) when use of portable extension lines is practicable given construction safety and operational limitations; and (4) when use of electrical grid power does not significantly compromise construction schedules.
 Diesel engines, whether for off road equipment or on road vehicles, shall not be left idling for more than two minutes, except as provided in exceptions to the applicable state regulations (e.g., traffic conditions, safe operating conditions). The construction sites shall have posted legible and visible signs in designated queuing areas and at the construction site to clearly notify operators of idling limit.  Provide line power to the site during the early phases of construction to minimize the use of diesel-powered stationary equipment.
 Utilize low volatile organic compound (VOC) (i.e., ROG emitting) coatings, that are below current BAAQMD requirements (i.e., Regulation 8, Rule 3; Architectural Coatings), for at least 80 percent of all residential and nonresidential interior paints and 80 percent of exterior paints. This includes all architectural coatings applied during both construction and reapplications throughout the project's operational lifetime. At least 80 percent of coatings applied must meet a "super-compliant" VOC standard of less than 10 grams of VOC per liter of paint. For reapplication of coatings during the project's operational lifetime, the Declaration of Covenants, Conditions, 151
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and Restrictions shall contain a stipulation for low VOC coatings to be used.

Examples of "super-compliant" coatings are contained in the South Coast Air Quality Management District's website.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations). Clear signage shall be posted for construction workers at all access points.

Noise and Vibration

3. Construction Noise. The applicant/developer shall implement the following standard noise control measures during project construction to ensure that the construction noise impacts are less than significant:
• Limit construction activity to weekdays between 7:00 AM and 6:00 PM and Saturdays between 9:00 AM and 5:00 PM, with no construction on Sundays or holidays;
• Utilize "quiet" models of air compressors and other stationary noise sources where such technology exists;
• Equip all internal combustion engine-driven equipment with mufflers, which are in good condition and appropriate for the equipment; • Locate all stationary noise-generating equipment, such as air compressors and portable power generators, as far away as possible from adjacent land uses;
• Locate staging areas and construction material areas as far away as possible from adjacent land uses;
• Prohibit all unnecessary idling of internal combustion engines; • Designate a “disturbance coordinator” who would be responsible for responding to any local complaints about construction noise. The disturbance coordinator will determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and will require that reasonable measures warranted to correct the problem are implemented.
• Conspicuously post a telephone number for the disturbance coordinator at the construction site and include it in the notice sent to neighbors regarding the construction.
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4. Operational Noise. The project would implement the following mitigation measures:
• Prior to issuance of building permits, project mechanical equipment shall be selected and designed to reduce impacts on surrounding uses and meet the City’s exterior and interior noise level requirements. A qualified acoustical consultant shall be retained by the project applicant/developer to review mechanical noise as the equipment systems are selected in order to determine specific noise reduction measures necessary to reduce noise to comply with the City’s 55 dBA L50 daytime exterior limit and 50 dBA L50 nighttime exterior limit at the nearest residential property lines.

5. The project would implement the following control measures to ensure the project’s construction vibration impacts are less than significant:
• Operating equipment on the construction site shall be placed as far as possible from vibration-sensitive receptors.
• Smaller equipment shall be used along shared property boundaries to minimize vibration levels below the limits.
• The use of vibratory rollers or tampers shall be avoided within 20 feet of sensitive uses.
• Dropping heavy objects or materials within 20 feet of sensitive uses shall be avoided.

Public Works and Utilities

6. Grading Permit. Prior to building permit approval, a grading permit shall be obtained from the Engineering Division with payment of fees per EPAMC 15.48.

See the following link for an application.
https://www.cityofepa.org/publicworks/page/grading-permit.

7. Encroachment Permit. The developer shall obtain an encroachment permit from the Engineering Division prior to performing any work in the public right-of-way.

See the link below for an application.
https://www.cityofepa.org/publicworks/page/encroachment-permit.

8. Public Improvements. The developer shall provide public street improvements along the project frontage where existing streets (vehicle and/or pedestrian paths) do not meet current City standards. These improvements may include sidewalk, curb and gutter, driveway approach, curb ramp and any right-of-way 153
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identified in the scaled and dimensioned drawing required under Public Works Department project specific condition #10. See EPAMC 15.04.040.

9. Construction Vehicles, Equipment and Materials. All construction related vehicles, equipment, and materials shall be managed on-site. At no time shall such items be parked or stored in the public right-of-way without an encroachment permit or written approval by the City Engineer.

10.Traffic Control. Activities that require temporary closures of sidewalks, vehicle and/or bike lanes, or other public paths shall require review and approval by the Engineering Division through an encroachment permit.

11.Construction Best Management Practices. This project is required to implement stormwater best management practices (BMP) as described by the San Mateo Countywide Water Pollution Prevention Program. The following sheet in the link below shall be included in the plans. https://www.flowstobay.org/wpcontent/uploads/2020/04/Countywide-Program-BMP-Plan-Sheet-June-2014- Update.pdf.

12.Fences/Walls. No new or existing fence and/or wall shall be permitted outside of the property boundary lines. No new or existing concrete (or similar) wall and/or fence is permitted where there is a public easement. The removal of such existing structures shall be required prior to the issuance of any permits.

13.Water Meters. Water meters shall be purchased by the developer, maintained privately, and stored onsite.

14.Sewer Cleanout. If one does not already exist, the developer shall install a sanitary sewer cleanout at the front property line per East Palo Alto Sanitary District standards.

15.Off-site Improvement Plans. Submit off-site improvement plans separate from the Building on-site improvement plans as the off-site improvement plans are approved through a Public Works Encroachment Permit process.

16.Potholing. An encroachment permit shall be obtained for potholing purposes.

The information should be used during design and construction to prevent utility conflicts related to new service laterals, tree installations, and so on.

17.Construction Material and Staging. All construction related materials, equipment, and construction workers parking need to be managed on-site and not located in the public right-of-way or public easements. 154
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18.Upgrade of Existing Public Improvements. As part of the off-site improvement plan review and approval, any existing public improvements to be re-used by the project, which are not in accordance with current City standards and are not specifically identified in the herein project conditions (such as backflow preventers, sign posts, etc.), shall be upgraded to current City standards and as required by the Department of Public Works.

19.Benchmarks. The improvement plans shall be prepared by using City's latest benchmarks (NAVD88) available on City's website.

20.Utility Connection. This project requires connection to all public utilities or private utilities operating under a City or State franchise which provide adequate levels of service, will-serve letters must be obtained before Building Permit Approval.

21.Storm Manhole. Install a storm manhole at the front property line along the new storm lateral.

22.Existing Utility Abandonment Relocation. Developer is responsible for research on all existing utility lines to ensure that there are no conflicts with the project.

All existing utility lines (public or private) and/or their appurtenances not serving the project and/or have conflicts with the project, shall be capped, abandoned, removed, relocated and/or disposed of to the satisfaction of the City. Existing public facilities within the street right-of-way shall be abandoned per City’s Abandonment Notes and procedures, including abandonment by other utility owners.

23.Modifications to Existing Public Utilities. Developer is required to pay for all changes or modifications, required by the project, to existing City utilities, streets and other public utilities within or adjacent to the project site, including but not limited to utility facilities/conduits/vaults relocation due to grade change in the sidewalk area, caused by the development.

24.Wet Utilities. All sanitary sewer and storm drain facilities on private property shall be privately owned and maintained by the HOA. Refer to Project Specific Conditions of Approval for the water system requirements.

25.Re-use of Existing City Utility Service Lines. The re-use of deficient City water service lines on the project site is not allowed. Developer’s contractor shall replace any deficient facilities as deemed necessary by the Department of Public Works.

26.Sanitary Sewer and Storm Drain Tributary Pattern. This project is required to follow the existing sanitary sewer and storm drain tributary pattern. Any 155
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deviations would require additional analysis and subject to approval by the Public Works Department as part of the off-site improvement plan review process. This project shall not cause any negative impact on the drainage pattern for adjacent properties.

27.Stormwater Drainage. The project shall not create any negative impacts to adjacent properties such as cross-lot drainage. The project shall also mitigate any impacts to the public stormwater system through the installation of rain gardens, bubblers or other infiltration devices, swales, increasing of pervious areas, or other methods. Any excess stormwater beyond a 10-year storm event or the site’s retention capacity may be drained to the public right-of-way via sheetflow. This shall be confirmed thru submittal of a hydrologic/hydraulic study and a final Stormwater Control Plan and stormwater sizing calculations. Postconstruction flows shall not exceed pre-construction flows, up to the 100-year storm.

28.Utility Meter/Vault. No existing or new utility meters or vaults shall be located within the new driveway approach. All existing or new utility vaults serving the project site shall be located on-site and not within the public utility easement, if any.

29.Driveway Approaches. Install a new driveway approach along the project frontage to comply with Americans with Disabilities Act (ADA) requirements and City standard details and specifications.

30.Decorative Pavement. Any and all proposed decorative pavement and vertical curb pertaining to on-site development shall not be located within the City rightof-way.

31.Traffic Control Plan. Submit a traffic control plan with the off-site improvement plans for review and approval. The traffic control plan shall include a summary of the traffic control types, dates, times and blocks affected. All construction related materials, equipment, and construction workers parking need to be stored on-site and the public streets need to be kept free and clear of construction debris.

32.Damage to Existing Public Improvements. Developer shall be responsible to rectify any damage to the existing public improvements fronting and adjacent to the project site as a result of project construction, to City’s satisfaction by the Public Works Department. All existing traffic detector loops and conduits shall be protected in place during construction. Any damaged detector loops shall be replaced within 7 days at the expense of the developer. 156
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33.Reservation/Abandonment of Easements. Reservation of new and/or abandonment of existing public/private utility easement(s), ingress/egress easement(s) necessary for the project shall be delineated on the map or recorded concurrently with the map with a separate instrument. Subdivision Map Act §66475 and §66499.20-1/2 for public easements) Quitclaim deed is required for abandonment of private easements prior to map recordation. All easements shall be kept open and free from buildings and structures of any kind except those appurtenances associated with the defined easements.

34.Utility Company Approval. Obtain map approval letters from the utility companies in regard to any existing or new easements associated with their facilities.

35.Completion of Public Improvements. Developer shall complete all required public improvements as required and in accordance with City approved plans, prior to any building occupancy.

36.Final Map Dedications. Parcel Map must be approved by the City and recorded with the County. The map must include a 5’ Public Utility Easement along the project frontage and a 5’ Sidewalk Easement along Bay Road. A recent (within six months) title report shall be provided with the map. The parcel map shall be recorded prior to building permit issuance.

37.A Homeowner’s Association shall be formed at the time the Final Map is filed.

The HOA shall be responsible for maintaining all onsite improvements unless those improvements that are specifically maintained by the City or a private utility company.

38.Streetscape. The developer shall install new sidewalk and curb & gutter along the entire project. Existing pavement shall be repaired as needed, and the pavement shall have a grind and overlay along the project frontage to the street centerline or as determined by the City Engineer based on utility trenching.

39.The new driveway shall be ADA compliant.

40.New streetlights shall be installed on the project frontages.

41.Red Curbs. Red curbs shall not be used to designate parking/stopping restricted zones, except as required for public fire hydrants.

42.Joint Trench. Joint trench plans shall be included in the improvement plan submittal.

43.Water System. Provide an analysis confirming adequate domestic and fire flow 157
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and pressure.

44.Sewer Capacity. The developer shall obtain approval from the East Palo Alto Sanitary District (EPASD). Any improvements or cash contributions required to accommodate sewer impacts shall be the sole responsibility of the developer.

45.Root Barrier. Install a continuous root barrier along the new sidewalk per City standard details and specifications.

Stormwater Environmental Division Conditions
Prior to Grading Permit Issuance

46.Applicant/developer shall provide a post-construction stormwater site management plan (Site Plan) that includes, at a minimum, exhibit(s) showing drainage areas and location of Low Impact Development (LID) treatment measures; project watershed; total project site area and total area of land disturbed; total new and/or replaced impervious area; treatment measures and hydraulic sizing calculations; a listing of source control and site design measures to be implemented at the site; NRCS soil type; saturated hydraulic conductivity rate(s) at relevant locations or hydrologic soil type (A, B, C or D) and source of information; elevation of high seasonal groundwater table; a brief summary of how the project is complying with Provision C.3 of the MRP; and detailed Maintenance Plans for each site design, source control and treatment measure requiring maintenance.

47.Applicant/developer shall pay most current NPDES fees prior to Grading Permit being issued.

48.LID treatment measures to be shown on final improvement or grading plans shall not differ materially from the LID treatment measures presented on the project’s Planning Application, without written approval from the Planning Department.

49..

C. Project Specific Conditions of Approval
Planning Division

1. The project shall be developed in substantial compliance with the drawings submitted as part of the East Palo Alto planning application DR25-004 dated November 11, 2025, to be revised pursuant to the conditions of this staff report 158
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as may be amended by the Planning Commission. The permit shall be effective 15 days following the date of the decision unless an appeal is filed prior to the effective date.

2. This approval is valid for a period of two (2) years from the effective date, if the applicant/developer has not yet secured building permits and started construction. If the applicant/developer is unable to secure building permits two years from the effective date, the applicant/developer must submit an application for an extension at least thirty (30) days before expiration in order to extend the term of the permit.

3. Any modifications to the approved plans and related information must be submitted to the Planning Division for review and approval and may be subject to review during a public hearing.

4. The Tentative Map approval shall expire within two (2) years of the effective date of its approval unless the approval is extended pursuant to the provisions in the Subdivision Regulations or unless a Final Map has been approved for recordation by the City Council.

5. The cover page of the one lot Condominium Tentative Map shall indicate that the Planning Manager has certified that all the conditions of approval of this Tentative Map have been complied with.

6. Prior to the approval of the Final Map, the developer shall enter into a Subdivision Improvement Agreement (SIA) in accordance with the Subdivision Regulation. The developer shall cover all costs associated with the preparation of the subdivision agreement as determined by the Planning Manager and the Public Works Director.

7. A Final Map shall be submitted for review and approval by the City Council. The One-Lot Condominium Tentative Map shall comply with the regulations of the East Palo Alto Subdivision Ordinance, the Subdivision Map Act, and these conditions of approval. The Final Map shall be drawn in substantial compliance with the approved Tentative Map.

8. Prior to the submittal of a building permit, the plans must meet all minimum requirements for the driveway and parking per Menlo Park Fire Protection District and City requirements.

9. All appeals of discretionary decisions required as part of these conditions of approval are required to be appealed to the City Council unless otherwise stated 159
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herein or in the Development Code Regulations.

10.Exterior colors, materials, design elements, lighting and landscaping shall be consistent with the plans dated November 25, 2025. Plans submitted for Building Permit issuance are subject to final review and must be approved by the Planning Manager prior to the issuance of a building permit.

11.The lighting plan for the common areas, parking areas, and pedestrian easement walkways shall operate independently from the individual residences.

All fixtures shall be located within the common areas and designated easements. Lighting shall be in full compliance with EPAMC Chapter 18.34.110.

12.C.C.&R.’s shall be reviewed by the Planning Division and the City Attorney prior to the submittal of the Final Map. The C.C.&R’s and Conditions of Approval shall be recorded in the office of the County Recorder concurrently with the Final Map or prior to Temporary Certificate of Occupancy per the requirements of the State Department of Real Estate.

13.The applicant/developer is responsible for applying for an address assignment with the Building Division for the subdivision and works directly with the Menlo Park Fire Protection District to review potential addresses.

Trees and Landscaping

14.Off-site trees, as identified in the plans dated November 11, 2025, shall be preserved in accordance with the recommendations and preservation guidelines identified in the Arborist Report dated August 2025 and prepared by Hort Science Bartlett Consulting.

15. If the applicant does not provide documentation demonstrating removal of the approved tree and planting of the replacement tree prior to issuance of Certificate of Occupancy, the applicant shall be required to deposit a surety in the amount of the Hort Science Bartlett Consulting estimated value of removed trees in accordance with Section 18.28.080 of the East Palo Alto Municipal Code to guarantee completion of the approved tree removal and replacement and provided herein:

Tree No. Species Estimated Value
176 Brazilian Pepper $200
179 Coast Live Oak $25,650
182 Italian Buckthorn $500
183 Siberian Elm $4,300
184 Siberian Elm $1,800
185 Siberian Elm $1,250
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186 Siberian Elm $2,350
187 Siberian Elm $1,350
188 Siberian Elm $7,900
189 Siberian Elm $750
191 Siberian Elm $450
192 Siberian Elm $5,450
193 Siberian Elm $3,100
Total $55,050

16.Replacement trees shall comply with the standards and recommendations set forth in the City of East Palo Alto Urban Forest Master Plan related to species diversity. A maximum of twenty percent (20%) of any one general and ten percent (10%) of any one species may be used to meet planting requirements within the city.

17.The applicant shall inform the Planning Division when the replacement trees have been planted. Planting is subject to review and approval by the Planning Division.

18.Off-site tree canopies shall be protected to the extent possible. If pruning is necessary, it shall be done in accordance with standards identified in the in the Arborist Report dated August 2025 and prepared by Hort Science Bartlett Consulting. Pruning shall not extend beyond the subject property lines without the notification of and written consent from the property owner of the offsite tree.

19.All contractors hired to remove trees or to perform on the project shall possess an active business license with the City of East Palo Alto.

20.The applicant/developer or his or her contractor shall contact the City by phone or email at least 48 hours prior to the removal of the existing trees.

21.Tree and debris removal shall only occur between the hours of 8:00 a.m. and 5:00 p.m. on weekdays, or between 9:30 a.m. and 5:00 p.m. on Saturdays.

22.Approval from the Engineering Division (650-853-3119) is required for any encroachment into the public right-of-way or for partial road closures required for the removal of the trees.

23.All tree stumps shall be removed by digging the stump out and grinding a minimum of 16” below grade.

24.The applicant shall hold harmless the City, its officers, agents, and employees 161
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from any liability or claims for damages due to the injury of any person, loss of life, or damage to property caused by, or arising out of activities authorized by these approvals. The applicant shall employ legal counsel approved by the City and/or indemnify the City for the cost of legal counsel and legal services.

25.Project landscaping shall comply with the City of East Palo Alto and State regulations for water-efficient landscaping.

26.The private and dedicated open space and trees shall be preserved and maintained by the owner/occupant and Homeowner’s Association, as appropriate, per the approved plans of this report. If there are any modifications to the current trees and landscaping or if the tree needs to be replaced by something comparable, the applicant/developer will need to get approvals from the Planning Division in order to be permitted to do so. The approval may require, but is not limited to, separate permit fees, arborist reports, and other necessary documents. For common hardscapes areas, the use of previous pavers such as grasscrete or similar types of pavers shall be implemented to expand the open space on site.

Building Division

27.A digital copy of the plans must be submitted for building review; including the digital submittal of all relevant supporting documents; structural calculations, energy compliance forms, soil reports etc.

28.The Plans submitted for building review must be designed to the 2025 California Building Codes. Projects submitted after January 1, 2029, will have to be designed to the 2028 California Building Codes.

29.Please imprint the Conditions of Approval on the plans submitted for building permits.

30.Please imprint on the submitted plans, the Construction Best Management Practices. To access the standard plan, please visit:
http://www.flowstobay.org/construction.

31.The applicant/developer shall properly complete and incorporate the 2019 CAL Green Residential Mandatory Measures on the plans submitted for building permits. The link to access the form: http://www.ci.east-paloalto.ca.us/ArchiveCenter/ViewFile/Item/443.

32.Properly complete and submit the EPA Special Inspection form for any 162
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proposed work requiring special inspections as per CBC 1705. Link to access form: http://www.ci.east-palo-alto.ca.us/ArchiveCenter/ViewFile/Item/458.

33.Provide a note on the plans submitted for building permits: “At a minimum, 65% of the project waste stream shall be recycled; prior to final project approval, a receipt shall be provided to the building inspector to verify 65% recycling has occurred. Self-hauling is prohibited in the City of East Palo Alto; an authorized hauler shall be utilized.

34.“All construction and demolition debris shall be contained on-site (not in the public right-of-way) in constantly covered bins, which include adequate service.”

35.Please note on plan: The City of East Palo Alto Municipal Code Section

15.04.125 limits construction activity to the following hours:
a. Monday through Friday: 7:00 AM to 6:00 PM
b. Saturday: 9:00 AM to 5:00 PM
c. Sundays and national holidays: No activity allowed.

City Attorney

36.To the maximum extent permitted by law, the applicant/developer (or its successor in interest) shall defend (with counsel acceptable to the City), indemnify, and hold harmless the City of East Palo Alto, its City Council, Planning Commission, officials, employees, agents and volunteers (collectively, “Indemnitees”) from and against any and all claims, actions, or proceedings against Indemnitees to attack, set aside, void or annul an approval by Indemnitees relating to this project. This indemnification shall include, but is not limited to, all damages, losses, and expenses (including, without limitation, legal costs and attorney’s fees) that may be awarded to the prevailing party arising out of or in connection with an approval by the Indemnitees relating to this project. The City shall promptly notify the applicant/developer of any claim, action or proceeding and the City shall cooperate in the defense. The City may elect, in its sole discretion, to participate in the defense of said claim, action, or proceeding and the applicant/developer (or its successor in interest) shall reimburse the City for its reasonable legal costs and attorneys’ fees.

Housing Division
Actions Prior to Issuance of a Building Permit. Prior to approval of Building Permits, the applicant/developer is responsible for the following:

37.An executed Inclusionary Housing Agreement with the City of East Palo Alto 163
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codifying the project’s inclusionary obligation, pursuant to Section 18.37.090(B) of the Development Code of the City of East Palo Alto, which shall be recorded against the residential development prior to the approval of any final or parcel map or issuance of a building permit, whichever comes first.

Actions Required for Housing Division’s Clearance of Final Inspection and Issuance of Certificate of Occupancy

38.No Final Inspection Approval, Temporary Certificate of Occupancy, Certificate of Occupancy, or Notice of Completion for any units will be issued until all requirements of the Inclusionary Housing obligations pursuant to Chapter 18.37 of the Development Code of the City of East Palo Alto are met.

Police Department
Addressing

39.When there are multiple structures, an address monument and/or complex map should be erected which incorporates an elevated view of the complex buildings and addresses. It would be illuminated during the hours of darkness and positioned to be readily readable from main vehicular or pedestrian access points.

40.Each individual building and unit should be clearly marked with the appropriate building number and address and should be positioned to be easily viewed from vehicular and pedestrian pathways throughout the complex. Main building numbers should be a minimum height of 12-inches.

Lighting

41.Adequate lighting of parking lots and associated carports, driveways, circulation areas, aisles, passageways, recesses and grounds contiguous to buildings should have enough lighting with sufficient wattage to provide adequate illumination to make clearly visible the presence of any person on or about the premises during the hours of darkness and to provide a safe and secure environment for all persons, property and vehicles on site.

Landscaping

42.Landscaping should be situated in locations to maximize observation while providing the desired degree of aesthetics. Security planting materials are encouraged along the fence and property lines and under vulnerable windows. 164
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Garage and Parking Lot

43.“No Trespassing/Loitering” signs are recommended to be posted at the entrances of parking lots and located in other appropriate places. Signs should be at least 2’by1’ in overall size, with white background and black 2” lettering. a. §9.08.010 of the East Palo Alto Municipal Code should be included as a reference on the no loitering signs.
b. All entrances to parking areas should be posted with the appropriate signs per 22658(a) of the California Vehicle Code to assist in the removal of vehicles at the owner/manager’s request.

Fencing/Access Control

44.Adequate pedestrian and vehicular access control to the development can mitigate many potentially problematic safety issues about surveillance and unwanted entry. It can also help alleviate the need for full-time security in larger developments, notwithstanding factors such as site location, projected growth contiguous to the development, prior crimes in the area, etc. It can be recessed enough so the development will not take on the appearance of a “fortress” but not so far away from the opening that a possible entrapment/ambush area is created. To further enhance safety a digital keypad entry system is recommended for apartment residence access, (over keycards, scanners, etc).

This type of entry provides quick and unhampered emergency personnel access to the interior of the development in the event of a critical incident or medical emergency. This is because emergency personnel en route to an event can confidentially access the entry code via a mobile computer. a. When applicable, perimeter fencing of open design, such as wrought iron, tubular steel, or densely meshed and heavy-posted chain link, should be installed to establish territoriality and defensible space, while maintaining natural surveillance.

Line of Sight/Natural Surveillance

45.If they exist, common use facility rooms such as conference, laundry, TV rooms, etc. should have doors that contain transparent material for surveillance.

Designing a window contiguous to the door would serve the same purpose.

Designing doors to these types of rooms so that they can be locked open during hours of use is another recommendation.
a. Wide angled peepholes should be incorporated into all dwelling front doors and to all solid doors where visual scrutiny to the door from public 165
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or private space is compromised.
b. Stairwells and elevator lobbies should be of open design whenever structurally possible.
c. It is highly recommended to have an elevator shaft that can be transparent, making occupants of the cab visible from the outside. d. Convex mirrors should be installed in elevator cabs and at stairwell landings.
e. Trash enclosures should not hinder needed surveillance. f. Other line of sight obstructions including recessed doorways, alcoves, etc. should be avoided on building exterior walls and interior hallways.

Public Works Department

46.Provide a scaled and dimensioned drawing to confirm that the proposed street improvements fit within the existing right of way. Improvements include a second southbound left turn lane on University Avenue at Bay Road and a second westbound left turn lane on Bay Road at University. Improvements shall also include a new eastbound left turn lane on Bay Road at the project entrance.

The left turn lane median island break and the Bay Road driveway shall be designed to physically prevent left turns out of the driveway. The eastbound left turn lane shall be designed to conform to the aforementioned scaled and dimensioned drawing and shall be constructed in a manner that accommodates the additional westbound left turn lane. If parking needs to be removed on the south side of Bay Road to accommodate the Developer’s proposed improvements, a separate request to remove parking shall be submitted to the City Council for their consideration. If the City Council declines to approve the parking removal, the Developer must submit updated plans that do not remove parking subject to review and approval by the City Engineer.

47.Improvements shall include installation of a traffic signal at the University Avenue entrance opposite the County property driveway. The improvements shall include modification of the County driveway to accommodate the signal phasing/ timing.

48.Provide a solid waste management/ collection plan and forward to Recology for review. Show location of trash dumpster enclosures or interior trash collection areas, and location of container staging for pickup.
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East Palo Alto City CouncilMarch 3, 2026

East Palo Alto City Council
March 3, 2026