Agenda packet, second session — East Palo Alto City Council, October 20, 2026 (part 2 of 2)

Rent Stabilization Board Application 2026
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Q7
Why would you like to serve on the Rent Stabilization Board? I would like to support and contribute in any way to a community I was a part in.

Rent Stabilization Board Application 2026
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Q1
Name
Uhila Makoni
Q2
Home Address
Respondent skipped this question
Q3
City
East Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
Respondent skipped this question
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#4

CCOOMMPPLLEETTEE
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Rent Stabilization Board Application 2026
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Q7
Why would you like to serve on the Rent Stabilization Board? I have served diligently on PTWC for the past four years and I have gained valuable knowledge on how the city works from the perspective of Public Works. I would like to expand on this from the Rent Stabilization Board perspective. I do believe in affordable housing and protections for our residents. I would like to understand the nuisance of housing dynamics in City of EPA and support its residents.

Rent Stabilization Board Application 2026
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Q1
Name
Colina Williams
Q2
Home Address
1650 Bay rd
Q3
City
E.Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
6509219517
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#5

CCOOMMPPLLEETTEE
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Rent Stabilization Board Application 2026
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Q7
Why would you like to serve on the Rent Stabilization Board? I want to serve because safe, stable housing is foundational. And I want to help make decisions that are fair, transparent, and grounded in lived experience, as well as respectful of residents.

Rent Stabilization Board Application 2026
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Q1
Name
Jose
Q2
Home Address
Sanchez
Q3
City
East Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
650-391-5979
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#1

CCOOMMPPLLEETTEE
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IP Address: 108.147.93.38

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Rent Stabilization Board Application 2026
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Q7
Why would you like to serve on the Rent Stabilization Board? I would like to serve on the Rent Stabilization Board because I believe stable housing is essential to the well-being of families in East Palo Alto. In my work with youth and families, I see how housing instability directly impacts education, health, and overall quality of life.

I am interested in contributing to fair, balanced decisions that reflect the realities of the community. I value the importance of both protecting tenants and recognizing the responsibilities of property owners, and I would approach this role with a commitment to listening, careful review, and thoughtful decision-making.

I am motivated to serve and support a stable and equitable community for all residents.

Rent Stabilization Board Application 2026
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Q1
Name
Goolrukh A. Vakil
Q2
Home Address
1875 Woodland Avenue
Q3
City
East Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
Respondent skipped this question
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#2

CCOOMMPPLLEETTEE
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IP Address: 23.124.107.33

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Rent Stabilization Board Application 2026
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Q7
Why would you like to serve on the Rent Stabilization Board? I would like to continue serving on the Rent Stabilization Board because I believe in service and I care about this city. I feel that because I have served on this board for 20 years, I can contribute to the issues that arise before the board. I am on the Rules and Regulations subcommittee as I have always been; I also teach Law and Ethics in psychology. Often the tenant is considered the underdog and is focused upon, however, I am aware that both sides of a dispute need to be fairly considered. This is also true in the case of ensuring that terms and conditions going forward are fair to both landlord and tenant. I would be honored to continue serving on the Rent Stabilization Board.

Goolrukh A. Vakil
Rent Stabilization Board Application 2026
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Q1
Name
Stephanie Hinckley
Q2
Home Address
1729 Woodland AVE
Q3
City
East Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
6507875488
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#3

CCOOMMPPLLEETTEE
Collector: Web Link 1 (Web Link)
Started: Sunday, April 19, 2026 10:12:08 PM
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IP Address: 99.24.48.5

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Rent Stabilization Board Application 2026
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Q7
Why would you like to serve on the Rent Stabilization Board? My passion is to help others. My skills in communication and education make me a great asset to this Rent Stabilization board. I would like to mention that I am fluent in Spanish.

Rent Stabilization Board Application 2026
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Q1
Name
Nimish Vora
Q2
Home Address
871 Willow Glen Way
Q3
City
Respondent skipped this question
Q4
E-mail Address
[email protected]
Q5
Phone Number
Respondent skipped this question
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
Q7
Why would you like to serve on the Rent Stabilization Board? I am a landlord (preferably called "homeowner") of a single family house in East Palo Alto. It is important to have a Balanced Board that will maintain interests and stewardship for both Tenants and Landlords. #4

CCOOMMPPLLEETTEE
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IP Address: 76.217.55.105

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Rent Stabilization Board Application 2026
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Q1
Name
Luis Rosas
Q2
Home Address
2310 Glen Way
Q3
City
East Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
6506691146
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#6

CCOOMMPPLLEETTEE
Collector: Web Link 1 (Web Link)
Started: Friday, May 08, 2026 1:27:25 PM
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IP Address: 174.62.81.24

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Rent Stabilization Board Application 2026
10 / 11 272
Q7
Why would you like to serve on the Rent Stabilization Board? I would like to serve on the Rent Stabilization board to provide more perspective on the everyday experience of residents that rent in East Palo Alto. I have many friends, family, and neighbors who rent in East Palo Alto. I would like to collaborate with the rent board and help inform the decisions that directly impact my community around me.

Rent Stabilization Board Application 2026
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Q1
Name
Ariana Aranda
Q2
Home Address
2361 University Avenue
Q3
City
East Palo Alto
Q4
E-mail Address
[email protected]
Q5
Phone Number
6502838797
Q6
Are you available to attend regular Board meetings
scheduled for the second Wednesday of every month at
7:00 pm?
Yes
#6

CCOOMMPPLLEETTEE
Collector: Web Link 1 (Web Link)
Started: Friday, October 02, 2026 12:45:51 PM
Last Modified: Friday, October 02, 2026 1:04:32 PM
Time Spent: 00:18:41
IP Address: 172.56.47.123

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Rent Stabilization Board Application 2026
11 / 12 274
Q7
Why would you like to serve on the Rent Stabilization Board? I am applying to serve on the rent stabilization board because I am passionate about protecting my community by ensuring fairness for our rentors and lessors
As a case manager that supports families experiencing homelessness, I know first hand how important rent stabilization is in order to ensure people can afford to house themselves and their families. I am passionate about serving the city that I and my family have called home for three generations. This city and our growing community is very important to me and I have loved ones that are both renters and property owners, and understand the importance of making sure there is fairness and protection for both leasers and tenants.

Rent Stabilization Board Application 2026
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PUBLIC HEARING ITEM 14.1

EAST PALO ALTO

CITY COUNCIL

Recommendation
Adopt a resolution:
1) Finding and determining that the proposed alternative, as set forth in Attachment 2 of the staff report, for the West Bayshore-Newell Improvements residential development project at 1-9 Newell Court (APNs 063-513-820 and 063-513-880) and other locations described herein (“Project”), to provide 124 rental units, deed-restricted at 80 percent of Area Median Income (“AMI”) meets the Inclusionary Housing Ordinance (“IHO”) requirements under Section 18.37.080 of the East Palo Alto Municipal Code (“EPAMC”) based on reasons offered by the applicant or other substantial evidence provided at the public hearing;
2) Providing direction on the replacement of rent-stabilized units that are or were occupied by households with incomes above lower income, as authorized by California Government Code Section 65915(c)(3)(C), by selecting one of the following options:
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PUBLIC HEARING ITEM 14.1
a. Require that each such unit be replaced with a unit of equivalent size that is made available at affordable rent to, and occupied by, low-income households, subject to a recorded regulatory agreement with a term of at least 55 years under Government Code Section 65915(c)(3)(C)(i), and in perpetuity to the extent required by EPAMC Section 18.48.220(D); or
b. Require that each such unit be replaced as a unit subject to the City’s Rent Stabilization Ordinance (“RSO”), EPAMC Chapter 14.04, under a recorded regulatory agreement with the City as required by EPAMC Section 18.48.220(D), as described in the Analysis section of this report; and 3) Directs staff to include the selected option as a recommended condition of approval in the Project entitlement resolution to be presented to the Planning Commission. Replacement units for currently rent-stabilized units occupied by lower-income households, including units presumed to be occupied by lower-income households under Government Code Section 65915(c)(3)(B), must be deed-restricted under state law and as such are not subject to local agency discretion; and
4) Finding that the action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment.

Executive Summary
Woodland Park Property Owner, LLC, c/o Sand Hill Property Company (the “Applicant”) proposes a 766 residential unit development. The project would renovate 315 existing rental units in 8 buildings, add 8 new rental units to the renovated buildings, demolish and replace 144 rental units, create 239 new mixed-income rental apartments in one building, and create 60 new ownership/for-sale townhomes. In total, the Project would construct 451 units, of which 307 would be net new units.

The Applicant is proposing an alternative compliance plan (referred to herein as “Alternative Compliance”) for the Inclusionary Housing Ordinance (“IHO”) requirements that would create 124 affordable, deed-restricted rental units at 80 percent of Area Median Income (“AMI”) or below instead of the 49 affordable rental units and 12 affordable ownership/for-sale units required onsite by the IHO, at deeper levels of affordability under the IHO’s original requirements (“Original Compliance”), or the 76.75 units (five percent additional units) under Alternative Compliance of the IHO. While these units proposed by the Applicant would be restricted to households making 80 percent of AMI or below, the rental amount would be based on 30% of a 60% of AMI household’s income, in accordance with State Density Bonus Law (“SDBL”). As part of the Alternative Compliance request, the affordable units would not be required to be comparable to 277
PUBLIC HEARING ITEM 14.1
market rate units or distributed throughout the property. Affordable units would also be limited to rental units and no affordable ownership units would be provided as part of this Alternative Compliance Plan
The purpose of this staff report is to present the proposed Alternative Compliance Plan, in accordance with the City’s IHO, for Council’s consideration. The Project would be required to adhere to requirements of the SDBL and IHO, except for the requested waivers to the IHO described herein. All inclusionary housing units would be subject to the City’s local preference policy, which gives preference to East Palo Alto residents, and to those who work within the City or have been displaced from residence in the City.

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

Priority: Comprehensive Housing
Priority: Land Use, Economic and Workforce Development
Priority: Public Health, Safety, and Quality of Life
Background
West Bayshore and Newell is a proposed residential project (“Project”) encompassing approximately 13.2 across multiple parcels with the following addresses and Assessor’s Parcel Numbers (“APNs”):

Table 1: Project Addresses
Address APN
1-9 Newell Court 063-513-820
063-513-880
1720 West Bayshore Road 063-513-660
1750 West Bayshore Road, 77 Newell Road, 95 Newell
Road, adjacent parcel, private road, 1796 West Bayshore Road
063-513-710
063-513-720
063-513-730
063-513-740
063-513-170
45 Newell Road and 55 Newell Road 063-513-380
35 Newell Road (excluding non-adjacent Parcel Two) 063-513-460 25 Newell Road 063-513-450
15 Newell Road 063-513-440
5 Newell Road 063-513-350
30 Newell Road and 40 Newell Road 063-513-360
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The Project area is currently designated and zoned as follows:

Table 2. General Plan / Zoning Designation and Acreage
General Plan / Zoning Designation Description Acres
R-HD-5 High Density Residential 11.65
C-N Neighborhood Commercial 01.56
Total 13.21
The Project area currently contains 459 units across 21 buildings. All 495 units are subject to the City’s Rent Stabilization Ordinance.

Table 3. Project Information
Project Element Detail/Description
Applicant Sand Hill Property Company
Owner Woodland Park Property Owner, LLC
Location West Bayshore Avenue and Newell Road
(see Figure 1)
APN See Figure 1
Size of Existing Site 13.21 acres
Existing Use Multi-Family Housing and Neighborhood
Commercial
Total Number of Units
766 total units, including the renovation of 315
rental units, the replacement of 144 rental
units, and the creation of 307 net new units
(247 rental and 60 homeownership).

Base Density Units 536
Proposed Number of Affordable Units
124 (40.3% of the newly constructed units), all
at 80% of AMI (Rent Calculation Set at 60% of
AMI)
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PUBLIC HEARING ITEM 14.1
Proposed Unit Program
The proposed project would result in a total of 766 residential units, including the renovation and replacement of existing rental housing and the construction of new rental and ownership/for-sale housing.

Table 4: Count and Description of Proposed Unit Breakdown Component Units Description
Existing rental units to be
substantially renovated
315 Existing units in seven buildings that would
be substantially renovated
Net new units added to
renovated buildings
8 Additional rental units within the renovated
buildings
Replacement rental units 144 Existing rental units that would be replaced as part of the redevelopment
Net new mixed-income rental
apartments
239 New rental units in four buildings
Net new for-sale townhomes 60 New ownership units
Total Project Units 766 Total unit count
The rental units included in the Project would comprise of 127 studios, 398 one-bedroom, and 181 two-bedroom units. The ownership/for-sale townhomes would include 16 three-bedroom, 36 four-bedroom 2.5-bath, and 8 four-bedroom 3.5-bath units.

Table 5. Proposed Unit Mix by Bedroom Count
# of Bedrooms
Studio
1 2 3 4
New Rental 31 236 116 - -
Renovated 96 162 65 - -
Townhomes - - - 16 4436
Subtotal 127 398 181 16 44
Total 766
Construction and Net New Units
Of the 766 total units in the completed Project, 459 units would be constructed as part of the proposed development, consisting of the renovation and construction activities described above.

The Project would result in 307 net new residential units compared with existing conditions. The Project therefore combines preservation and substantial renovation of existing rental housing, replacement of existing rental units, new mixed-income rental housing, and new ownership/forsale housing. 280
PUBLIC HEARING ITEM 14.1
Project History
On December 9, 2025, the Applicant submitted a preliminary application for a residential project, and on June 1, 2026, the Applicant submitted an application (DR26-003) seeking to vest rights under Government Code Section 65589.5(o)(1), also known as Senate Bill (SB) 330, o (‘referred to herein as “the HCA”). The rights vested under the HCA include making the proposed developments subject only to the ordinances, policies and development standards in effect when the HCA preliminary application was deemed complete.

To meet its inclusionary housing requirement, the Applicant proposed an Alternative Compliance Plan on September 13, 2026, proposed to provide 124 deed-restricted, affordable units to comply with State Density Bonus Law requirements for the density bonus being applied by the Applicant.

Inclusionary Housing Requirement
The City’s Inclusionary Housing Ordinance (“IHO”) applies to all net new residential units (“Net New Units”). Units attributable to a density bonus granted under California Government Code Section 65915 and additionally to what is permitted by the zoning designation are excluded from the IHO calculation. In practice, this means that the base allowable density is used to calculate the number of IHO units to be provided. However, when the Net New Unit count is lower than the base density, the Net New Unit count can be used to calculate the IHO requirement. In this case, the Net New Units count (307 units) is lower than the base density (536 units), so the Net New Unit count is used to calculate the number of IHO units to be provided. In a project providing entirely new units, the base density will always be lower than the Net New Units, since the density bonus is allowing a project to exceed base density. However, in this case, since the Project is replacing a large number of units, the Net New Units are lower than the base density, so Net New Units is the number used.

For rental housing projects, the IHO requires that 20 percent of the Net New Units within the project's total base units be provided as affordable housing. The required affordability mix is:

Table 6. Required Rental Affordability Levels for IHO
Income Level Percent Required Affordability Level
Extremely Low-Income 5% 35% AMI
Very Low-Income 10% 50% AMI
Low-Income 5% 60% AMI
Total 20%
For ownership/for-sale projects, the IHO requires that 20 percent of the Net New Units within the project’s total base units be provided as affordable. The required affordability mix is:
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Table 7: Required Ownership Affordability Levels for IHO Income Level Percent Required Affordability
Median-Income 10% 80% AMI
Moderate-Income 10% 120% AMI
Total 20%
All units are required to be deed-restricted in perpetuity.

Project IHO Requirements – Net New Unit Calculation
Of the 766 project units, the 144 replacement units and 315 retained/renovated units are not considered net new units. The Net New Units are the 8 added rental units in the renovated building, 239 new rental apartments, and 60 new townhomes, for a total of 307 Net New Units.

With 307 Net New Units, the project generates an IHO obligation of 61.4 affordable units, consisting of:
 49.4 total affordable rental units, including 12.35 at 35 percent of AMI, 24.7 at 50 percent of AMI, and 12.35 at 60 percent of AMI; and
 12 affordable ownership units, including 6 at 80 percent of AMI and 6 at 120 percent of AMI.

Table 8. IHO Requirements for Project by Tenure (Rental vs. Ownership) Component Net New Units IHO Rate Affordable Units Required Rental 247 20% 49.4
Ownership /
For-Sale 60 20% 12
Total 307 20% 61.4
The IHO guidelines state that “if the inclusionary requirement does not evenly divide into the percentages provided in Section 18.37.050, the requirement shall default to the lowest affordability level. If the calculation results in a fraction of an Inclusionary Unit, the developer shall pay an In-Lieu Fee for the fractional unit.”
Applicant’s Alternative Compliance Request
As outlined in EPAMC Section 18.37.080, “Alternative Compliance” is when an Applicant requests to meet their IHO obligations through the provision of off-site units, the payment of a fee in-lieu of creating the units, or some other means. As the Applicant is not proposing off-site units or payment of an in-lieu fee, the request falls under EPAMC Section 18.37.080(D), “Other Alternative Compliance Methods,” which states:

A developer may propose an alternative compliance method to provide inclusionary units 282
PUBLIC HEARING ITEM 14.1
through other means consistent with any adopted inclusionary housing guidelines. The approval body may approve or conditionally approve such an alternative only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site.

The Applicant argues that building in compliance with the City’s IHO is financially infeasible and that their proposed Alternative Compliance Plan, including the alternative affordability request and the waivers to additional requirements of the IHO, would make the project financially feasible. They also argue that status quo, where no project is advanced, many existing units would still require renovation and no new affordable units would be created.

While these units proposed by the Applicant would be restricted to households making 80% of AMI or below, they would be priced to be affordable to households at or below 60% of AMI, in accordance with State Density Bonus Law (“SDBL”). Further, the Applicant is requesting that as part of the Alternative Compliance option, that they be allowed to provide affordable units that are not comparable. Compliance with the IHO would require City Council approval of an alternative means of compliance, as described further herein.

Analysis
The Applicant is requesting the City Council’s approval of the Applicant’s Alternative Compliance Plan under the City of East Palo Alto Inclusionary Housing Ordinance.

State Density Bonus Law
California’s Density Bonus Law (Government Code Section 65915 referred to herein as “SDBL”) allows a developer to increase density on a property above the maximum set under a jurisdiction’s General Plan and zoning. In exchange for the increased density, a certain number of the new affordable dwelling units must be reserved as affordable or at below market rate (“BMR”). Qualifying projects can also receive reductions in required development standards via waivers and/or concessions.

SDBL requires a city or county to provide a developer who agrees to construct specified percentages of units for lower income, very low income, senior citizen housing, or other qualifying housing types, with a density bonus and other incentives, concessions, and waivers upon their request. East Palo Alto Municipal Code (“EPAMC”) Chapter 18.36 implements the State law.

SDBL allows qualified projects to request waivers and concessions for reduced development standards, including setbacks, square footage requirements, parking, and open space.

The Project proposes a total of 766 renovated and new units across the Project’s 13.21 acres.

To determine how many units can be added under the SDBL, one must first determine the 283
PUBLIC HEARING ITEM 14.1
number of “base units” that are allowed at the Project site, based on the underlying zoning. The base units are calculated by multiplying the base density allowed by each zoning designation without a density bonus (e.g., 43 dwelling units per acre) by the number of acres of each site (e.g. 11.65 acres) and rounding down.

The percentage density bonus is then determined by multiplying a certain percentage by the base density. This percentage is based on the maximum income limits of the affordable units, and percent of affordable units.

Table 9. Base Density Calculation
Parcel Size
(approximate)
Max Dwelling
Units Per Acre
(du/acre)
Max Total
Base Units
Bonus Units
(46.25% x Max
Base Units)
R-HD-5 Zone 11.65 43 du/ac 501 232
C-N Zone 1.56 22 du/ac 35 17
Parcel Total 13.21 22 – 43 du/ac 536 249
The Applicant has proposed that 124 units would be deed-restricted to 80 percent of Area Median Income (“AMI”). Given that these units make up 23.1 percent of the newly constructed units, the Project qualifies for a 46.25 percent of density bonus, and therefore 249 additional units than the base density would allow. It should be noted that given the included affordability, the project is entitled to up to 249 density bonus units even though the Applicant elects to utilize only 230 density bonus units.

Under SDBL, households with incomes up to eighty percent of AMI may rent the affordable units, but the rents are set at thirty percent of monthly income of a household making sixty percent of AMI, adjusted for assumed household size. The assumed household size is one person for a studio, two persons for a one-bedroom, three persons for a two-bedroom, and four persons for a three-bedroom. The applicable AMI for the current fiscal year is provided in the San Mateo County 2026 Income Limits in the table titled “California State Income Limits for SMC.” Replacement Unit and Relocation Assistance Requirements In accordance with SDBL and the Housing Crisis Act (Government Code Section 66300, et seq.), units that the Project would demolish must be replaced. The Project would demolish and rebuild 144 units that are rent-stabilized under the East Palo Alto Rent Stabilization Ordinance (“RSO”).

As such, these 144 units must be replaced as described below. The 315 units that would be renovated would remain subject to the RSO.

Under SDBL, Government Code Section 65915(c)(3)(D), the replacement units must be equivalent in size to the protected units being replaced. As such, the replacement units must contain at least the same total number of bedrooms as the units being replaced. This requirement would be spelled out in any relevant project approval documents.

The income category that governs each replacement unit is that of the household in occupancy of the existing unit on the date of application or, for an unoccupied unit in a development with 284
PUBLIC HEARING ITEM 14.1
occupied units, the last household in occupancy within the five-year period preceding the project application (Government Code Section 65915(c)(3)(B)(i)-(ii)). If a household’s income category is not known, state law presumes, subject to rebuttal, that lower income renter households occupied the units in the same proportion as lower income renter households to all renter households in the City, as determined by the most recently available data from the U.S.

Department of Housing and Urban Development’s Comprehensive Housing Affordability Strategy (“CHAS”) database. Replacement units for units occupied, or presumed to be occupied, by lower income households must be made available at affordable rent to, and occupied by, households in the same or lower income category, and must be subject to a recorded affordability restriction for at least 55 years, and in perpetuity to the extent required by EPAMC Section 18.48.220(D).

For rent-stabilized units that are or were occupied by households above lower income, the City may either (Option I) require that the replacement units be made available at affordable rent to, and occupied by, low-income households, subject to a recorded affordability restriction for at least 55 years, or (Option II) require that the units be replaced in compliance with the City’s RSO, in which case the units are not subject to a recorded affordability restriction unless the RSO requires one (Government Code Section 65915(c)(3)(C)).

Separately, EPAMC Section 18.48.220 requires a conditional use permit from the Planning Commission for the demolition of these units and requires that each demolished unit be replaced with either an affordable designated unit for a qualifying household in perpetuity, at an affordability level set by City Council resolution, or a unit subject to the RSO, under a regulatory agreement recorded with the San Mateo County Recorder (EPAMC Section 18.48.220(D)).

Deed-restricted replacement units are considered in determining whether the Project satisfies the requirements of the SDBL (Government Code Section 66300.6(b)(1)(B)).

In addition, the Applicant is required under both the Housing Crisis Act and EPAMC Chapter

14.02 to provide relocation assistance to certain tenants during the relocation period. I Compliance with these tenant protection requirements would be required as part of the approval of the project’s planning entitlements, including through the project’s Conditions of Approval.

The Applicant has not yet provided the incomes of the households occupying the 144 units to be demolished. The number of replacement units that must be deed-restricted, and the number subject to Council’s direction, will be determined from that income information or, where incomes are not known, from the CHAS presumption described above. Because the CHAS presumption 285
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assigns only a proportion of units of unknown income to lower income households, Council’s direction would apply to the remaining units even if actual incomes are not established. Staff will request the income information from the Applicant before the Planning Commission hearing, and the unit-by-unit determination would be documented in the Project’s conditions of approval.

Under Option II, the replacement RSO units would be newly constructed. The RSO exempts units that received a certificate of occupancy on or after January 1, 1988 from its registration, rent increase limit, and rent adjustment provisions (EPAMC Section 14.04.050(B)(2)), and state law allows owners to set the initial and all subsequent rents for units that received a certificate of occupancy after February 1, 1995, unless the owner has agreed by contract with the City in consideration for a density bonus or other specified assistance (Civil Code Section 1954.52(a)(1), (b)). EPAMC Section 18.48.220(D) requires the Applicant to enter a recorded regulatory agreement with the City for the replacement units. Because the Applicant is requesting a density bonus, that regulatory agreement would provide that the replacement units are subject to the RSO, including its rent limits, in consideration for the density bonus.

The options also differ in who may occupy the replacement units. Under Option I, replacement units would be limited to income-qualified households, and existing tenants with incomes above lower income may not qualify to occupy them. Under Option II, replacement units would be available to households of any income, with the protections described above. The City’s tenant protection ordinance requires that tenants displaced by the demolition be offered the right of first refusal to occupy replacement housing constructed on the site, regardless of income, except that occupancy of inclusionary units is governed by the City’s inclusionary housing requirements (EPAMC Section 14.02.140(C)). State law separately provides lower income households a right of first refusal to a comparable unit (Government Code Section 66300.6(b)(4)(B)).

Deed-Restriction of Replacement Units
State law governs whether these units are deed-restricted. Government Code § 65915(c)(3)(B)(i) requires that replacement units be reserved for the same income category as the household they replace, and where that household’s income is unknown, presumes lower income in the same proportion that lower-income renter households bear to all renter households citywide, based on HUD Comprehensive Housing Affordability Strategy (CHAS) data.

Government Code § 65915(c)(3)(C) allows the City to instead apply the local rent or price control ordinance’s own replacement requirement, but only for units shown to have been occupied by persons or families above lower income within five years preceding the application. That showing has not been made for units outside the CHAS-presumed proportion. The applicant has provided no evidence to date to make that showing.

Accordingly, the deed restriction applies to the replacement units by default under § 65915(c)(3)(B)(i) unless and until the Applicant produces evidence that specific units were occupied by above-lower-income households, triggering the City’s election under § 65915(c)(3)(C).
286
PUBLIC HEARING ITEM 14.1
Local Preference Policy
In 2020, the City adopted a Local Preference Policy where the selection of tenants for affordable housing is prioritized for people who live, work, or have been displaced from a residence in East Palo Alto. The Local Preference Policy applies to occupancy of City-subsidized affordable housing units, density bonus units, and development projects subject to the City’s Inclusionary Housing Ordinance. Thus, the Local Preference Policy applies here.

Inclusionary Housing Ordinance
In addition to complying with the SDBL, the IHO outlines requirements relative to the percentage of affordable units, the depth of affordability of those units, as well as other requirements including, but not limited to, the term of affordability, the comparability of the units to the market rate units, the location of the units, and timing of the delivery of the units.

The proposed 766-unit project includes a maximum density of 566 units to which the IHO would apply. However, the Project is only providing 307 Net New Units. As such, the IHO requirements would only apply to these 307 units. Under the IHO, the Project would provide

61.4 affordable units, of which 49 would be rental units, and 12 would be ownership/for-sale units, and 0.4 units would be paid out as an in-lieu fee. EPAMC Section 18.37.050(C)(3) states that "[w]hen a residential development includes both ownership and rental dwelling units, the provisions of this chapter that apply to ownership residential development shall apply to that portion of the development that consists of ownership dwelling units, while the provisions of this chapter that apply to rental residential development shall apply to that portion of the development that consists of rental dwelling units." See Figure 9 for the number of required IHO units, by tenure and affordability level.

Because the Applicant is electing an Alternative Compliance Option under EPAMC Section

18.37.080(D), Section 18.37.080(A) increases the inclusionary housing requirement by five percentage points over the Section 18.37.050 baseline shown as “Required” in Figure 11 below, to approximately 76 units. Applied to the Project’s 247 net new rental units and 60 net new ownership units (see above), the increased requirement is approximately 61.75 rental inclusionary units (7% at 35% AMI, 12% at 50% AMI, and 6% at 60% AMI) and 15 ownership inclusionary units (13% at 80% AMI and 12% at 120% AMI), for a total of approximately 76.75 inclusionary units, rather than the 61 units Figure 11 shows below.

The Applicant is proposing the provision of 124 deed-restricted rental units at 80 percent of AMI, however under SDBL the units would be priced based on sixty percent of AMI. See the table below for the comparison of the requirements under the IHO and the Applicant’s proposal. 287
PUBLIC HEARING ITEM 14.1
Table 10: Project’s Inclusionary Housing Requirement
and Applicant Proposal
Affordability Level
IHO Original
Compliance
Requirement
(Percent of
Base Units)
IHO Original
Compliance
Requirement
(Units)
IHO
Alternative
Compliance
Requirement
Applicant
Proposal
(Units)
Rental Units
35% of AMI 5% 13
25% or
76 units
0 Very Low-Income
(50% of AMI) 10% 24 0
Low-Income
(60% of AMI) 5% 12 0
Median Income
(80% of AMI) 124
Ownership/For-Sale
Units
Median-Income
(80% of AMI) 10% 6 0
Moderate-Income
(120% of AMI) 10% 6 0
Total Inclusionary Units 61 Units 76 Units 124 Units
Average AMI of Units 58.6% 80% (Priced
at 60%)
Partial Unit Payment 0.4 Rental
unit

0.25 unit None
Additional Waivers to the Inclusionary Housing Ordinance Applicants may request waivers, adjustments, or reductions to the IHO. The city must approve the requested incentive or concession unless it makes a written finding, supported by substantial evidence, that: (1) the request would not produce identifiable, actual cost reductions needed to provide the required affordable housing or restricted rents; (2) the request would cause a specific, adverse impact on public health and safety or certain protected historic resources that cannot be feasibly mitigated or avoided without making the project unaffordable to low- or moderate-income households; or (3) the request would violate state or federal law.

As part of the Alternative Compliance Plan, the Applicant is seeking the following waivers to the IHO: the affordable units need not be dispersed, need not have the same proportion of unit types as the market rate units, and need not have comparable square footage or bedroom count as the market rate units. These waivers are further explained in the table below.
288
PUBLIC HEARING ITEM 14.1
Table 11: Inclusionary Housing Ordinance Waivers Applicant Requested Requirement Developer Proposal
EPAMC 18.37.050(C)(3) When a residential
development includes both ownership and
rental dwelling units, the provisions of this
chapter that apply to ownership residential
development shall apply to that portion of the
development that consists of ownership
dwelling units, while the provisions of this
chapter that apply to rental residential
development shall apply to that portion of the
development that consists of rental dwelling
units.

The Applicant is not proposing the deedrestriction of any for-sale townhouses.

The Applicant is requesting that the
affordable units not have the same
proportion of unit types as to the market
rate units to “produce financially feasible
projects that will maximize affordable
housing in EPA.”
EPAMC 18.37.060(C). Bedroom Mix and Unit
Size. The number of bedrooms and the size of
the inclusionary units shall be comparable to or
greater than the average number of bedrooms
and average size of the market-rate units
consistent with any adopted inclusionary housing
guidelines.

The affordable units would not have a
comparable square footage or bedroom
count as market rate units.

EPAMC 18.37.060(D). Location. The
inclusionary units shall be located so as not to
create a geographic concentration of inclusionary
units within the residential development.

Units would not be disbursed throughout
the development. The Applicant has not
indicated where the units would be
located and/or if they would be
concentrated in one building or area.

The following evaluation details why the City may assume that the Applicant is proposing to provide the most economical inclusionary units feasible.

Evaluation of the Alternative Compliance Option: Public Benefit Analysis The Project is proposing 124 units at 80 percent of AMI, which is substantially more units than required by the IHO, though the average AMI of the required IHO units (58.6 percent of AMI) is lower than the average AMI of the proposed units (80 percent of AMI). However, these units would be priced to be affordable to households at 60% of AMI, even though the income restriction is 80% of AMI, bringing the affordability close to levels required by the IHO. Given the additional units provided, the proposed affordability would appear to provide additional public benefit. For a more thorough evaluation, City staff would need the Applicant to submit details on the proposed units in the development by tenure type, bedroom count, unit sizes, and affordability level.

Staff Recommendation

The Applicant is currently proposing to provide 124 units restricted to households making 80 percent of AMI or less but priced at levels affordable to households making 60 percent of AMI 289
PUBLIC HEARING ITEM 14.1
or less. This is in line with requirements from State Density Bonus Law, outlined in Government Code Section 65915. Under the Inclusionary Housing Ordinance, average affordability of rental units provided would be fifty-eight-point six (58.6) percent of AMI. The average affordability of units being provided by the Applicant would be sixty (60) percent of AMI, so it is only slightly higher than what is required under the Inclusionary Housing Ordinance. This Alternative Compliance Option would not provide the units required at 35% and 50% of AMI traditionally required by the IHO. By providing 124 units, the Applicant is providing 40.4 percent of Net New Units as affordable, exceeding the 61 units or 25 percent requirement for an Alternative Compliance Option under the IHO.

However, the Applicant is also proposing to build sixty for sale or ownership townhome units as part of this development. The Applicant is not proposing to provide any for sale units restricted as affordable units. As shown in Table 11, under IHO Original Compliance, the Applicant would be required to provide 12 of those units as affordable units (6 at 80 percent of AMI and 6 at 120 percent of AMI). Under IHO Alternative Compliance, the Applicant would be required to provide 15 total affordable ownership units, with 8 at 80 percent of AMI and 7 at 120 percent of AMI.

The Applicant has provided no evidence to support the conclusion that failure to provide affordable ownership units would provide “greater public benefit.” Based on the Applicant’s proposal to provide 124 rental units deed restricted to individuals at 80 percent of AMI or below but priced to be affordable to individuals at 60 percent of AMI or below. While the proposal does not provide affordable ownership units, it substantially increases the number of affordable rental homes, with affordability only slightly above the IHO's 58.6 percent AMI average.

This additional rental housing is consistent with the San Mateo County 2023–2031 Housing Element, which identifies both ownership and rental housing as unaffordable to most households and specifically identifies a need for “greater production of rental housing” and additional housing dedicated to lower-income households. The Housing Element also includes policies supporting the preservation and rehabilitation of lower-income, deed-restricted multifamily rental housing and protecting existing rental housing from conversion to ownership.

While County policy does not establish a categorical preference for rental housing over affordable ownership housing, it does recognize the production and preservation of affordable rental housing serving lower-income households as a specific housing need.

Based on the overall increase in affordable rental housing, staff finds that the proposal provides sufficient public benefit to support approval of the Alternative Compliance Plan.

Fiscal Impact
Approval of the proposed Inclusionary Housing Plan has no direct fiscal impact on the City’s General Fund.

Estimated Impact Fees
290
PUBLIC HEARING ITEM 14.1
Pursuant to the Housing Crisis Act the development impact fees applicable to the project are those that are subject to the Mitigation Fee Act that were in effect when complete HCA preliminary applications were submitted to the City. The development impact fees were vested on December 9, 2025, when the HCA preliminary application was submitted. The project shall pay all applicable impact fees pursuant to the fee schedule in effect on December 9, 2025, prior to final building inspection or issuance of the Certificate of Occupancy. The project is estimated to generate over $5.3 million in Sewer and Storm Drain Impact Fees, as well as additional Parks and Trails Impact Fees, Public Facilities Impact Fees, and other applicable fees not yet determined. All City impact fees shall be finalized and collected prior to issuance of the Certificate of Occupancy or final building permit approval.

In order to provide an estimate on the potential property tax revenue the Project would generate for the City, the City would need additional information such as the current and new assessed property value and how the proposed affordable units would be qualified for the welfare exemption. In the future, the City Council may wish to consider retaining a consultant to provide property tax revenue analysis for fiscal impact reports.

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. Notice was also published in the San Mateo Daily on Saturday, September 26, 2026.

Environmental
The action being considered does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment. In the alternative, a decision to deny a project is exempt from CEQA pursuant to Public Resources Code § 21080(b)(5).

Government Code § 84308
Applicability of Levine Act: Yes
Analysis of Levine Act Compliance: The project applicant is Sand Hill Property Company.

Staff are unaware of any other parties or participants relevant to the City Council’s consideration of this item.

Attachments

1. Resolution

2. Inclusionary Housing Plan
291
RESOLUTION NO. XX — 2026

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

ACCEPTING AN INCLUSIONARY HOUSING ALTERNATIVE COMPLIANCE OPTION FOR A 766-UNIT RESIDENTIAL DEVELOPMENT PROJECT (“WEST BAYSHORE-NEWELL IMPROVEMENTS”) ON WEST BAYSHORE ROAD AND NEWELL ROAD (APN 063-513-820, 063- 513-880, AND OTHER PARCELS DESCRIBED HEREIN)
WHEREAS, on November 19, 2020, the City Council of the City of East Palo Alto ("City Council") adopted Ordinance No. 425 ("Ordinance"), adding Chapter 18.37 — Inclusionary Housing to the City of East Palo Alto Municipal Code; and
WHEREAS, Woodland Park Property Owner, LLC, c/o Sand Hill Property Company (the “Applicant”) submitted an application for a residential development consisting of seven hundred and sixty-six residential units on the corner of West Bayshore and Newell Street (“West Bayshore-Newell Improvements”), identified by assessor's parcel numbers 063-513-820, 063-513-880, and additional parcels described herein (“Project”), on June 1, 2026; and WHEREAS, the additional parcels include: 1720 West Bayshore Road, 063-513-660; 1750 West Bayshore Road, 77 Newell Road, 95 Newell Road, adjacent parcel, private road, 1796 West Bayshore Road, APNs 063-513-710, 063-513-720, 063-513-730, 063-513-740, and 063-513-170; 45 Newell Road and 55 Newell Road, 063-513-380; 35 Newell Road (excluding non-adjacent Parcel Two), 063- 513-460; 25 Newell Road, 063-513-450; 15 Newell Road, 063-513-440; 5 Newell Road, 063-513-350; 30 Newell Road and 40 Newell Road, 063-513-360; and
WHEREAS, the Applicant submitted an Inclusionary Housing application requesting an alternative compliance option under EPAMC Section 18.37.080 for the Project (“Alternative Compliance Plan”) on September 14, 2026; and
WHEREAS, the Project' s baseline inclusionary obligation ("Original Compliance") under Section

18. 37.050 of the IHO is to provide: 49 affordable rental units, with 25% of those for 35% Area Median Income ("AMI") Households, 50% for Very Low-Income Households, and 25% for Low-Income Households, as defined in Section 18.37.020 of the IHO; and to provide 12 on-site affordable ownership/for-sale units, 50% of those for Median-Income Households and 50% for Moderate-Income Households, as defined in Section 18.37.020 of the IHO; and WHEREAS, Section 18.37.080 of the IHO provides that an applicant of a residential development may choose from a list of alternative compliance options to meet the inclusionary obligation if the inclusionary requirement for the project is increased by 5% over the inclusionary housing requirement for projects with five or more units, and this option must be approved by the City Council; and
WHEREAS, applying this five-percentage-point increase under Section 18.37.080(A) the Project’s 307 net new units yields an inclusionary alternative compliance inclusionary obligation of approximately 76.75 units at varying affordability levels; and 292
WHEREAS, Subsection (D) of section 18. 37. 080 of the East Palo Alto Municipal Code allows the Council to grant a residential development applicant "Other alternative compliance methods" but only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site"; and WHEREAS, in lieu of the inclusionary obligation, the Applicant proposed an Alternative Compliance Plan to provide 124 on-site Inclusionary Units, to be rented at an affordable rent for Median Income-Households (80% of AMI); and
WHEREAS, while the units proposed would be restricted to households making 80% of AMI or below, they would be priced to be affordable to households at or below 60% of AMI, in accordance with State Density Bonus Law (“SDBL”); and
WHEREAS, the Applicant is providing 124 on-site rental units affordable to Median-Income households to utilize SDBL to increase their maximum density by 46.25% for an additional 249 units, in accordance with State law.

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 into this action by this reference;
2) Finds and determines that the proposed alternative, as set forth in Attachment 2 of the staff report, for the West Bayshore-Newell Improvements residential development project at 1-9 Newell Court (APNs 063-513-820 and 063-513-880) and other locations described herein (“Project”), to provide 124 rental units, deed-restricted at 80% of Area Median Income (“AMI”) meets the Inclusionary Housing Ordinance (“IHO”) requirements under Section 18.37.080 of the East Palo Alto Municipal Code (“EPAMC”) based on reasons offered by the applicant or other substantial evidence provided at the public hearing;
3) Require that each such unit be replaced with a unit of equivalent size that is made available at affordable rent to, and occupied by, low-income households, subject to a recorded regulatory agreement with a term of at least 55 years under Government Code Section 65915(c)(3)(C)(i), and in perpetuity to the extent required by EPAMC Section 18.48.220(D); or 4) Directs staff to include the selected option as a recommended condition of approval in the Project entitlement resolution to be presented to the Planning Commission. Replacement units for currently rent-stabilized units occupied by lower-income households, including units presumed to be occupied by lower-income households under Government Code Section 65915(c)(3)(B), must be deed-restricted under state law and as such are not subject to local agency discretion; and
5) Finds that the action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 293
15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment. 294
PASSED AND ADOPTED this 20th day of October 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
295
RESOLUTION NO. XX — 2026

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

18. 37.050 of the IHO is to provide: 49 affordable rental units, with 25% of those for 35% Area Median Income ("AMI") Households, 50% for Very Low-Income Households, and 25% for Low-Income Households, as defined in Section 18.37.020 of the IHO; and to provide 12 on-site affordable ownership/for-sale units, 50% of those for Median-Income Households and 50% for Moderate-Income Households, as defined in Section 18.37.020 of the IHO; and WHEREAS, Section 18.37.080 of the IHO provides that an applicant of a residential development may choose from a list of alternative compliance options to meet the inclusionary obligation if the inclusionary requirement for the project is increased by 5% over the inclusionary housing requirement for projects with five or more units, and this option must be approved by the City Council; and
WHEREAS, applying this five-percentage-point increase under Section 18.37.080(A) the Project’s 307 net new units yields an inclusionary alternative compliance inclusionary obligation of approximately 76.75 units at varying affordability levels; and 296
WHEREAS, Subsection (D) of section 18. 37. 080 of the East Palo Alto Municipal Code allows the Council to grant a residential development applicant "Other alternative compliance methods" but only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site"; and WHEREAS, in lieu of the inclusionary obligation, the Applicant proposed an Alternative Compliance Plan to provide 124 on-site Inclusionary Units, to be rented at an affordable rent for Median Income-Households (80% of AMI); and
WHEREAS, while the units proposed would be restricted to households making 80% of AMI or below, they would be priced to be affordable to households at or below 60% of AMI, in accordance with State Density Bonus Law (“SDBL”); and
WHEREAS, the Applicant is providing 124 on-site rental units affordable to Median-Income households to utilize SDBL to increase their maximum density by 46.25% for an additional 249 units, in accordance with State law.

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 into this action by this reference;
2) Finds and determines that the proposed alternative, as set forth in Attachment 2 of the staff report, for the West Bayshore-Newell Improvements residential development project at 1-9 Newell Court (APNs 063-513-820 and 063-513-880) and other locations described herein (“Project”), to provide 124 rental units, deed-restricted at 80% of Area Median Income (“AMI”) meets the Inclusionary Housing Ordinance (“IHO”) requirements under Section 18.37.080 of the East Palo Alto Municipal Code (“EPAMC”) based on reasons offered by the applicant or other substantial evidence provided at the public hearing;
3) Require that each such unit be replaced as a unit subject to the City’s Rent Stabilization Ordinance (“RSO”), EPAMC Chapter 14.04, under a recorded regulatory agreement with the City as required by EPAMC Section 18.48.220(D), as described in the Analysis section of this report; and
4) Directs staff to include the selected option as a recommended condition of approval in the Project entitlement resolution to be presented to the Planning Commission. Replacement units for currently rent-stabilized units occupied by lower-income households, including units presumed to be occupied by lower-income households under Government Code Section 65915(c)(3)(B), must be deed-restricted under state law and as such are not subject to local agency discretion; and
5) Finds that the action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 297
15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment. 298
PASSED AND ADOPTED this 20th day of October 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
299
West Bayshore-Newell Improvements
Applicant Statement – June 2026
3 West Bayshore-Newell Improvements
West Bayshore and Newell Roads
Applicant Statement

OVERVIEW AND PROJECT INTRODUCTION
The applicant team is pleased to submit this application package to substantially renovate 315 existing units, create 247 net new mixed-income rental apartments, and create 60 new for-sale townhomes within the Woodland Park neighborhood, west of Highway 101 and north of University Avenue. This applicant statement includes:

1. Project Description

2. Project Background

3. Project Compliance with General Plan

4. Project Compliance with Zoning

5. State Density Bonus Law

6. Inclusionary Housing Plan

7. Fair Housing and Marketing Plan

8. California Environmental Quality Act (“CEQA”) Compliance

9. Relevant Statutory Framework

10. Required Findings

11. Community Outreach

12. Project Team
Property Information
Project Area: ±13.2 acres + streetscape
Addresses: See Exhibit A to Universal Planning Application APNs: See Exhibit B to Universal Planning Application
General Plan Designations: High Density Residential and Neighborhood Commercial Zoning Designations: Residential High Density (R-HD-5) and Commercial Neighborhood

1. PROJECT DESCRIPTION

The Proposed Project would substantially renovate 315 existing units in 8 buildings, add 8 new units to those renovated buildings, create 239 net new mixed-income rental apartments in 1 building, and create 60 new for-sale townhomes. The Proposed Project will add 307 net new dwelling units to East Palo Alto’s housing supply.

Table 1: Project Description
Existing Units Proposed Units Net New Units
Rental units in buildings to be renovated 315 323 8
Rental units in buildings to be replaced 144 383 239
For-sale units 0 60 60
Total 459 766 307
300
West Bayshore-Newell Improvements
Applicant Statement – June 2026
4 The project site is ±13.2 acres, portions of which are designated as “High Density Residential” and “Neighborhood Commercial” in the East Palo Alto General Plan.

Each new apartment unit will have at least 1 off-street parking space in a garage and each townhome unit will have 2 dedicated off-street parking spaces in a private garage. There will also be ADA and guest surface parking spaces, for a total of 868 spaces. There will be 255 bicycle parking spaces in the new buildings.

The project site is near Highway 101 and University Avenue, which are both major commercial corridors well served by SamTrans public transit.

The proposed housing development project is submitted pursuant to Senate Bill 330 (Gov. Code § 66300) and subject to the modifications and protections of State Density Bonus Law (Gov. Code § 65915) and the Housing Accountability Act (Gov. Code § 65589.5). The Inclusionary Housing Plan, described in Section 6, proposes an alternative compliance option whereby the Proposed Project will include affordable units at the lower-income level at an amount equal to 23% of net new units.

2. PROJECT BACKGROUND

Existing Conditions
The project site is part of the Woodland Park neighborhood. There are 459 existing rental units in approximately 21 buildings that would be affected by the project. These existing rental units are in singlefamily homes and apartments. There are also shared access lanes, parking areas, a restaurant, and a convenience store.

Proposed Project
This application reflects a re-envisioned Woodland Park neighborhood that includes a mix of housing types and affordability. There will continue to be rental apartments, both in existing renovated rent-stabilized units and in new mixed-income buildings. There will also be for-sale townhomes available at mixed income levels. The Proposed Project includes adjustments to the streetscape design to ensure a unified, coherent neighborhood that fits within the existing context.

3. PROJECT COMPLIANCE WITH GENERAL PLAN
The City of East Palo Alto’s General Plan includes several designations within the Woodland Park neighborhood, including High Density Residential and Neighborhood Commercial on the West BayshoreNewell Improvements site.

The High Density Residential designation is intended to provide for higher density multi-family housing and a variety of housing types. New development in this zoning designation should create attractive frontages.

The Neighborhood Commercial designation provides for a variety of retail, office, business activities, and residential units.

The Proposed Project will meet all of the General Plan requirements, except as modified pursuant to SDBL. 301
West Bayshore-Newell Improvements
Applicant Statement – June 2026
5 Table 2: General Plan Objective Requirements

General Plan requirement Compliance
Allowed Land Uses:

High Density Residential: A range of multi-family
housing types ranging from townhomes to multifamily apartments at moderate to high densities.

Neighborhood Commercial: Retail, services and
related uses. Office and residential uses allowed on
the upper floors.

Complies.

Apartments and townhomes are planned on land
designated as High Density Residential. Both are
allowed uses.

Apartments are also planned on land designated
as Neighborhood Commercial. This is an allowed
use above the ground floor. A SDBL concession
permits residential uses on the ground floor.

Density/Intensity:

High Density Residential: 22.1 - 43 units/acre
(maximum of 1 dwelling unit per 1,000 feet of parcel
area), or 80 to 150 persons/acre.

Neighborhood Commercial: Up to 22 units/acre. Up
to 1.0 FAR.

Complies. The housing development project is
entitled to a 46.25% density bonus. The base
density for the project is calculated in Table 3
below. The base density for the project plus the

46.25% density bonus allows up to 785 housing
units. A total of 766 housing units are being
proposed.

Height:

High Density Residential: Maximum height of 5
stories and 60 feet
Neighborhood Commercial: Maximum of 3 floors or
36 feet.

Complies with density bonus waiver.
x Substantially renovated apartment
buildings are 3 stories tall and therefore
comply with High-Density Residential
designations.
x Townhouse units comply with R-HD-5
height limit.
x The apartment building uses a SDBL
waiver for height.

4. PROJECT COMPLIANCE WITH ZONING

Please see the application plan set for a detailed analysis of each building’s compliance with the applicable zoning requirements.

5. STATE DENSITY BONUS LAW

Providing affordable units within the Proposed Project qualifies the project for a density bonus under SDBL.

Density bonus projects are eligible for a number of benefits, including: increased density (a higher number of dwelling units per acre); a fixed number of incentives or concessions from development standards; an unlimited number of waivers of development standards that would physically preclude the construction of the housing development project and certain other limits on the local agency’s discretion.

The Proposed Project includes affordable housing for rent to lower income (80% AMI) households in an amount equal to 23% of the net-new base units. 23% of 247 net-new units is 57 affordable units. With this 302
West Bayshore-Newell Improvements
Applicant Statement – June 2026
6 level of affordable housing, the Proposed Project qualifies for a 46.25% density bonus. This increases the permissible density as shown in Table 3 below.

Under SDBL, each component of the density calculation, including base density and bonus density, resulting in fractional units is separately rounded up to the next whole number pursuant to SDBL and as shown in the following table. Moreover, the SDBL provides that the bonus may be used in geographic areas of the Proposed Project other than the areas where the units for lower income households are located. Hence the bonus units can be used throughout the Proposed Project.

Table 3: Density Bonus Calculations

Total Area
(acres)
Max Density
(du/acre)
Max # of Base Units
(acres x density)
Bonus Units
(46.25% x Max #
of Units)
R-HD-5 Zone 11.65 43 501 232
C-N Zone 1.56 22 35 17
TOTAL (785) 13.21 NA 536 249

By providing affordable housing, the Proposed Project is entitled to use an unlimited number of waivers of development standards that physically preclude the construction of the Proposed Project. The waivers are set forth in Table 4, below.

Table 4: Waivers to Accommodate Density Bonus
Standard Required Proposed
Minimum site
coverage
70% 45% (Apartments & Townhouses)
Height limit 3 stories or 36’, whichever is higher in C-N 5 Stories or 50’in R-HD-5
85’ (Apartments in C-N)
85’ (Apartments in R-HD-5)
Front Setbacks 15’ in R-HD-5 7’ (Townhouses)
Side Street Setbacks 15’ in R-HD-5 Varies—5’ to 9’ (Apartments) 8’ (Townhouses)
Rear Setbacks 20’ in R-HD-5 18’ (Townhouses)
Common Open
Space
100 sq. ft. per unit 3,600 for 60 units (Townhouses)
Private Open Space
(ground floor)
50-100 sq. ft. per unit Varies—approx. 8’ x 10’
(Apartments)
Varies—3,908 sq. ft. for 60 units
(Townhouses)
Private Open Space
(upper floor units)
50 sq. ft. per unit 9,090 sq. ft. for 347 units
(Apartments)
Parking Lot Design
Standards
24 ft. drive aisle 20 ft. drive aisle (Townhouses)
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7 The Proposed Project’s provision of affordable housing in an amount equal to 23% of base units at 80% AMI also entitles it to two concessions/incentives for development standards that impede the project’s ability to utilize the density bonus or increase feasibility, as shown in Table 5, below.

Table 5: Concession/Incentive to Accommodate Density Bonus

Standard Required Proposed
Ground floor uses No residential ground floor uses in C-N zone
Apartment building in the C-N zone.
[Reserved]

At the request of a developer, the SDBL governs the maximum number of parking spaces a local agency can require of density bonus projects. At most, the local agency can require 1 space per studio and 1-bedroom unit and 1.5 spaces per unit with 2 or more bedrooms. This is “inclusive of parking for persons with a disability and guests.” Developer hereby requests that the SDBL parking requirements apply. All of the buildings comply with the SDBL parking requirements.

The Applicant reserves the right to amend the density bonus proposal, including the use of concessions/incentives and waivers, as may be appropriate during the application process.

6. INCLUSIONARY HOUSING PLAN

The City’s Development Code requires that residential developments include contributions to affordable housing supply. Residential developments proposing five or more dwelling units must provide inclusionary units in the amount of 20% of the net new dwelling units. See Municipal Code section 18.37.050(A). In forrent projects, one quarter of these must have a rent affordable to households at 35% of AMI, half must have a rent affordable to very-low income households, and one quarter must have a rent affordable to lowincome households. The City defines “low-income” as 60% AMI and “very-low income” as 50% AMI. In forsale projects, half of these must have a sales price affordable to median-income households and half must have a sales price affordable to moderate-income households.

Alternatively, a developer may propose an “alternative compliance method” to be considered by the approval body to determine “based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels…” In this application, the Applicant is proposing an alternative compliance method as the “Preferred Inclusionary Housing Plan.”
Preferred Inclusionary Housing Plan—Alternative Compliance.

Applicant proposes that within the Proposed Project, there be affordable units in the amount of 23% of the net new dwelling units. These are to be rented at the “lower income” level. As shown in Table 2 above, there are 247 net new dwelling units. 23% of 247 net new units is 57 affordable rental units.

As part of this alternative compliance plan, the affordable units need not be dispersed, need not have the same proportion of unit types as the market rate units, and need not have comparable square footage or 304
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8 bedroom count as the market rate units. This Preferred Inclusionary Housing Plan makes the provision of affordable housing cost-effective, with actual and identifiable cost-savings that make the project feasible.

The approval body would be able to make the required findings for this Preferred Inclusionary Housing Plan. It will provide as many or more inclusionary units at the same or lower income levels as would strict compliance with the Inclusionary Housing Ordinance. Including 20% of the units as affordable units at the affordability levels set forth in the local Inclusionary Housing Ordinance renders the housing development project infeasible. The expense of a high inclusionary requirement makes it impossible to construct a project that includes so many affordable units, especially at deep affordability levels. If a 20% requirement at deep affordability is imposed, the project will not be built so there will be zero affordable units. Similarly, if a 25% requirement were imposed at deep affordability, the project would be even less feasible and no affordable units would be built. Therefore, providing affordable units in the amount of 23% of base project units at Low Income levels delivers more affordable units than a project that would propose compliance with the City’s requirements because it could not be built. 57 affordable homes is more than zero affordable units, so the Preferred Inclusionary Housing Plan would provide more inclusionary units.

Other inclusionary requirements. The City imposes a number of additional requirements on inclusionary units as follows:

Table 6: Inclusionary Requirements
Inclusionary requirement Compliance
Single-family detached affordable units shall be
dispersed throughout the housing development.

Townhouses, row-houses, and multiple-family
affordable units shall be located so as not to create
a geographic concentration of affordable units
within the housing development.

Complies because requirement modified by
alternative compliance plan.

The quality of exterior design and overall quality of
construction of the affordable units shall be
consistent with the exterior design of all market rate
units in the housing development and meet all site,
design, and construction standards of this Code,
including but not limited to, compliance with all
design guidelines included in applicable specific
plans or otherwise adopted, and the affordable
housing guidelines. Affordable units shall have
functionally equivalent parking.

Complies.

Affordable units may have different interior finishes
and features than market rate units in the same
housing development, so long as the finishes and
features are functionally equivalent to the market
rate units and are durable and of good quality and
comply with the affordable housing guidelines.

Complies
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9 Inclusionary requirement Compliance
The affordable units shall have the same amenities
as the market rate units, including the same access
to and enjoyment of common open space and
facilities in the housing development.

Complies
The affordable units shall have the same proportion
of unit types as the market rate units in the housing
development except that single-family detached
housing projects may include single-family attached
affordable units and single-family detached
affordable units may have smaller lots than singlefamily detached market rate units.

Complies because requirement modified by
alternative compliance plan.

The affordable units shall have a comparable square
footage and the same or greater bedroom count
and bedroom count ratio as the market rate units.

Complies because requirement modified by
alternative compliance plan.

All required affordable units shall be made available
for occupancy concurrently with the market rate
units.

Complies

7. FAIR HOUSING AND MARKETING PLAN

Project Information:

Address: See Exhibit A | APN: See Exhibit B | Census Tract: 612101

Applicant Information: Woodland Park Property Owner, LLC or successor entity

Entity Responsible for Marketing: Woodland Park Property Owner, LLC, successor entity, or third-party administrator

Target Date of Initial Occupancy: TBD

Estimated Advertising Start Date: TBD

Acknowledgment of Local Preference: The Applicant acknowledges the City of East Palo Alto Local Preference Policy and intends to comply with it.

Description of Outreach and Marketing Activities to Community: The applicant will follow local requirements and best practices, including local advertising, outreach to community groups, and providing marketing materials in both English and Spanish.

Acknowledgment of Need to Partner with Housing Department and City Third-Party Administrator:

Applicant acknowledges that it is responsible for the marketing of all units and must follow fair marketing practices between the market rate units and the Inclusionary Units. The Applicant may market, sell, and rent the inclusionary units in partnership with a third-party administrator to implement and oversee this part of the Inclusionary program. Ultimately, the Applicant is responsible for the fair marketing of units and through this acknowledgement understands that this is a requirement of the City’s Inclusionary Housing Program. 306
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10 8. CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) COMPLIANCE

The Proposed Project is eligible for statutory exemption from CEQA under AB 130. Applicant requests that the project be processed under AB 130. The project qualifies for this exemption because it meets all of the following criteria:

Table 7: AB 130 Statutory Exemption
Public Resources Code 21080.66
Requirements
Compliance

1. The Project site is not
more than 20 acres.

Complies. The Proposed Project is located on 13.2 acres.

2. The proposed
development occurs within the
boundaries of an incorporated
municipality.

Complies. The Proposed Project is within the City of East Palo Alto, which is an incorporated municipality.

3. The project site meets
any of the following criteria:

A. Previously developed
with an urban use.

Complies.
x Previous development. The project site has been
developed with urban uses, including existing apartments and retail uses.
x Surroundings. The site is surrounded by urban uses
including commercial offices, Highway 101, and existing residential uses. The area within ¼ mile radius of the site is also developed with urban uses and the entire perimeter is developed with urban uses.

4. The project is consistent
with the applicable general plan
and zoning ordinance. The
approval of a density bonus,
incentives or concessions, waivers
or reductions of development
standards, and reduced parking
ratios shall not be grounds for
determining that the Project is
inconsistent.

Complies. As described above, the Proposed Project is consistent with the General Plan and zoning ordinance, together with a density bonus, concessions, and waivers.

5. In San Mateo County, the
project density must be at least
15 dwelling units per acre.

Complies. The Proposed Project contains 766 units on 13.2 acres, for an average density of 58 dwelling units per acre. This meets the minimum density.
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11 Public Resources Code 21080.66
Requirements
Compliance

6. The project satisfies the
requirements in Government
Code 65913.4:
x Not located in a coastal
zone
x Not on prime farmland
x Does not include
wetlands
x Not in a very high fire
severity zone
x Not on the Cortese List
x Not in an earthquake
fault zone
x Not in a special flood
hazard area
x Not in a regulatory
floodway
x Not on lands identified
for conservation
x Does not include habitat
for protected species
x Does not include lands
under conservation
easement
Complies.
x Coastal zone. The Proposed Project site is not in the coastal zone.
x Farmland. The Proposed Project site is not on prime
farmland.
x Wetlands. The Proposed Project site does not include any wetlands.
x Fire zone. The Proposed Project site is not in a very high fire severity zone.
x Cortese List. The Proposed Project site is not on the Cortese List.
x Earthquake fault zone. The Proposed Project site is not in a delineated earthquake fault zone.
x SFHA. The proposed development is either not located in a special flood hazard area or if it is, the site meets the FEMA requirements necessary to meet minimum flood plain
management criteria of the NFIP.
x Regulatory floodway. The Proposed Project site is not in a regulatory floodway.
x Conservation land. The Proposed Project site is not on lands identified for conservation.
x Habitat. The Proposed Project site does not include
habitat for protected species.
x Conservation easement. The Proposed Project site does not include lands under conservation easement.

7. The project does not
require demolition of a historic
structure on a historic register.

Complies. There are no registered historic structures within the project site.

8. The project is not
designated for transient lodging.

Complies. The Proposed Project does not include a hotel, motel, bed and breakfast inn, or other transient lodging.

9. RELEVANT STATUTORY FRAMEWORK

The California State Legislature has adopted a number of relevant updates to the legislative framework governing the City’s review and approval of the Proposed Project. We respectfully highlight the following legislation governing this application:

SB 330. The Proposed Project is a “housing development project” subject to SB 330 and protected by the HAA because more than two-thirds of the Project’s square footage is devoted to residential uses. Gov’t Code §65905(b)(3); Gov’t Code §65589.5(h)(2). The Applicant submitted a preliminary application 308
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12 pursuant to SB 330 on December 9, 2025. By submitting that preliminary application with all of the information specified in SB 330 and a permit processing fee, the Applicant obtained a vested right to develop a housing development project in accordance with the applicable ordinances, policies, and standards in effect as of that date, when the preliminary application was submitted. Gov’t Code §65589.5(o)(1).

SB 330 prohibits a local agency from disapproving, or conditioning approval in a manner that renders infeasible, a housing development project that provides affordable housing. Because the Proposed Project provides affordable housing, it would not be lawful for the City to disapprove the project or condition it in a manner that makes it infeasible.

Permit Streamlining Act. The Project is required to go through a completeness review under the PSA and the PSA imposes several relevant obligations on the City as it conducts its completeness review of the project’s application. First, the City is required to compile lists that include the information required for a complete submittal. Gov’t Code § 65940. Second, Gov Code § 65943(a) spells out a jurisdiction’s obligations after submittal: Not later than 30 calendar days after any public agency has received an application for a development project, the agency shall determine in writing whether the application is complete and shall immediately transmit the determination to the applicant...

If the City determines that the application is incomplete, the City is required to “specify those parts of the application which are incomplete and shall indicate the manner in which they can be made complete.” Gov’t Code § 65943(a). In any subsequent review of the application determined to be incomplete, the local agency shall not request the applicant to provide any new information that was not stated in the initial list of items that were not complete.

Housing Accountability Act. The project is subject to the Housing Accountability Act (“HAA”). Gov’t Code § 65589.5. The Legislature has directed that the HAA be “interpreted and implemented in a manner to afford the fullest possible weight to the interest of, and the approval and provision of, housing.” Id. (a)(2)(L).

The HAA requires the City to approve the project because it is consistent with all objective standards. The City would only be permitted to reject a project if it can make findings based on a preponderance of evidence that the project would have a significant, unavoidable, and quantifiable impact on “objective, identified written public health or safety standards, policies, or conditions.” Gov’t Code §65589.5(j). The Legislature has an expectation that these types of conditions “arise infrequently.” Gov’t Code § 65589.5(a)(3). Here, there is no evidence that the project would have any impact on public health and safety, so the City could not be permitted to reject the project.

10. REQUIRED FINDINGS
This section outlines the Proposed Project’s compliance with the required findings for approval of 1.) Design Review, 2.) a Vesting Tentative Map, and 3.) Alternative Compliance under the Inclusionary Housing Ordinance.
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13 1.) Design Review under Municipal Code § 18.86.050 to allow new multi-family construction Required Findings. The Review Authority may approve a Site Plan and Design Review application only after first making all of the following findings:

1. 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;

2. The proposed development is to be constructed on a suitable site, adequate in shape, size, topography, and other circumstances to accommodate the proposed development;

3. The proposed development complies with the applicable standards of review; and

Suggested Findings: The Proposed Project is consistent with the General Plan, all applicable provisions of the Development Code, and all other applicable City ordinances and regulations. Multi-family residential is a permitted use throughout the site. The proposed density is in alignment with the General Plan and zoning, in addition to the SDBL. The Proposed Project plan meets the SDBL requirements for parking spaces and also meets the City’s bicycle parking standard. There are adequate pedestrian access points along the frontages throughout the project. The project proposes affordable housing in compliance with the Inclusionary Housing Ordinance and relies on waivers and a single concession under SDBL to ensure full compliance with local standards.

The site is suitable because it is currently used for multi-family housing, which is the same use as is planned by the Proposed Project. It is large and flat enough to accommodate the proposed development, including the proposed circulation for vehicles, bicycles, and pedestrians.

The project will receive all required entitlements before proceeding and substantial record evidence supports all findings, so the Proposed Project complies with the applicable standards of review.

The Proposed Project ensures public health, safety and general welfare. The Proposed Project complies with the applicable General Plan, and other development code requirements, all of which together ensure that there will be no adverse effects on neighboring property. The Proposed Project includes appropriate circulation and landscaping, as well as appropriate screening for loading, parking and mechanical equipment.

2. Tentative Map Findings Municipal Code 18.52.060 to allow approval of vesting tentative map Required Findings for Approval:

1. Mandatory Findings Required. The Review Authority shall approve a tentative parcel or tract map only after first making all of the findings as required by the Act. The findings shall apply to each proposed parcel as well as the entire subdivision, including any parcel specified as a designated remainder.
a. The proposed map, subdivision design, and improvements are consistent with the General Plan, any applicable specific plan, and this Article;
b. The site is physically suitable for the type and proposed density of development; c. 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; 310
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14 d. The design of the subdivision or type of improvements is not likely to cause serious public health or safety problems;
e. 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… f. 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;
g. The design of the subdivision provides, to the extent feasible, passive or natural heating and cooling opportunities; and
h. 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…
Suggested findings: The Proposed Project, including the proposed map and subdivision design and improvements are consistent with the General Plan and the Subdivision Ordinance. The site of the Proposed Project is physically suitable for residential development. It is currently used for residential uses and would continue to be used for that type of development. The site is also suitable for the proposed density of development, which is in compliance with the existing land use designation and zoning, as the same is modified by the SDBL with a density bonus of 46.25%. The design of the subdivision and proposed improvements are not likely to cause substantial environmental damage or affect fish or wildlife or their habitat. The Proposed Project site is currently developed with residential uses in an urban environment and will continue to be developed with residential uses in an urban environment. The design of the subdivision and improvements are not likely to cause serious public health or safety problems because the design is in compliance with all applicable requirements, including the local and state building codes which protect public health and safety. The design of the subdivision and the type of improvements will not conflict with public easements because there are no public access easements through the site. The discharge of sewage from the proposed subdivision will not result in a violation of existing requirements because the development will be served by the sewer system in compliance with all applicable laws. The design of the subdivision provides, to the extent feasible, passive or natural heating and cooling opportunities in alignment with existing building code requirements and the orientation of the buildings.

The proposed subdivision and its design, density, and type of development and improvements conform to the Development Code and the regulations of all public agencies having jurisdiction over the site. The Proposed Project complies with the General Plan and the Development Code.

3. CEQA Findings. The Review Authority must make the required California Environmental Quality Act (CEQA) findings of fact for each project subject to the Subdivision Map Act.

Suggested Findings: The Proposed Project, including the subdivision design and improvements are consistent with the General Plan and the City’s Municipal Code. The site is physically suitable for multifamily residential development at the proposed densities, which comply with the City’s standards. The Proposed Project includes compliance setbacks, circulation, landscaping, and appropriate screening for loading, parking, and mechanical equipment. The design of the subdivision is not likely to cause environmental damage because it qualifies for the AB 130 statutory exemption. The subdivision is not likely to cause serious public health or safety concerns as the Proposed Project has been designed to avoid public health and safety problems and to comply with all applicable codes. The site is adequately served by public and emergency services. The design does not conflict with easements acquired by the public at large for access through or use of property within the proposed subdivision. The Proposed Project has been designed to accommodate existing easements and provide for safe, appropriate vehicular and pedestrian 311
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15 access. There will be no discharge of sewage in violation of existing requirements because the Proposed Project will be connected to the existing sewer system and all discharged sewage will be treated by the East Palo Alto Sanitary District in compliance with law. The Proposed Project is planned to provide, to the extent feasible, passive or natural heating and cooling opportunities. It is being designed to integrate sustainable design features to maximize energy efficiency, reduce waste streams, conserve water, and minimize greenhouse gas emissions. The proposed subdivision and its design, density, and type of development and improvements conform to the requirements in the Development Code an all other applicable regulations.

The project is subject to the AB 130 statutory exemption on a site less than 20 acres.

3. Inclusionary Housing Under Municipal Code 18.37.080 to allow alternative compliance D. Other alternative compliance methods. A developer may propose an alternative compliance method to provide inclusionary units through other means consistent with any adopted inclusionary housing guidelines.

The approval body may approve or conditionally approve such an alternative only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site.

Suggested Findings: The Preferred Inclusionary Housing Plan will provide as many or more inclusionary units at the same or lower income levels as would strict compliance with the Inclusionary Housing Ordinance. This is because it is infeasible to include 20% of the net new units at the deep levels of affordability required by the Inclusionary Housing Ordinance. The expense of a high inclusionary requirement makes it impossible to construct a project that includes so many affordable units, especially at deep affordability levels. If a conventional requirement is imposed, the project will not be built so there will be zero affordable units. 57 affordable units is more than zero affordable units, so the Preferred Inclusionary Housing Plan would provide more inclusionary units.

11. COMMUNITY OUTREACH

The applicant has conducted significant community outreach, starting in February 2016 when the Applicant purchased the properties. From 2018-2024 we had over 40 community meetings, info booths and listening sessions to understand and get input from the neighborhood, the community, and our residents. During this time, we also had 17 City Council Meetings and 5 Planning Commission meetings. These meetings were to understand the wants, needs, and concerns of the community, and helped inform the Euclid Improvements project, which was unanimously approved by City Council in 2024.

In 2025 we went back to our residents, neighbors, and community members in a series of 6 community meetings and information sessions to understand the desire for additional improvements; the sought-after changes were similar to what was approved at Euclid. We received a great deal of positive feedback and heard a strong desire for more improvements across the property, including all types of new housing, and the improvement of the existing housing. We developed the Proposed Project and shared it with community members during two additional meetings in February. We received more input and feedback.

We expect to have a similar study session with City Council next month.

All our planning started with the 2016 East Palo Alto General Plan, and the Westside Area Plan that is part of it. This includes provisions for no displacement, a right for tenants to remain in the neighborhood, and including either rent-controlled or subsidized affordable housing in any new development. 312
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16 From the foundation of the Westside Area Plan, we had many meetings throughout the community. We had some in our pop-up parks, some at the local school, some inside our building courtyards and some at City Hall or at the YMCA.

From all the input we received, we developed a community-informed proposal with five core principles: No Displacement, Preserve Housing Affordability and Stability, Community-Informed Plans, Better Parking and Mobility, and Safer, Healthier Buildings. This reflects what we heard from the community.

In February and March 2026, we held community meetings in the project area, walking distance from affected residents. We mailed notices within a 600-foot radius. We presented the specifics of the proposal and got overall positive feedback. Many of the participants also attended our 2025 community meetings and were happy to see that we listened to their input.

The City held a Planning Commission study session on April 13, 2026. The meeting was open to the public and there were members of the East Palo Alto community that provided public comments. We received feedback from the Planning Commissioners.

12. PROJECT TEAM

Applicant / Developer:

Woodland Park Property Owner, LLC
c/o Sand Hill Property Company
2600 El Camino Real, Suite 410, Palo Alto, CA 94306
Contact: Michael Kramer | [email protected] | 650-772-4319 Architects:

David Baker Architects
461 2nd St., Loft C-127, San Francisco, CA 94107
Contact: Daniel Simons | [email protected] | 415-896-6700 Dahlin Group
5865 Owens Drive, Pleasanton, CA 94588
Contact: Justin Doull | [email protected] | 925-251-7200 Landscape Architect:

GLS Landscape Architecture
2677 Mission St #200, San Francisco CA 94110
Contact: Gary Strang | [email protected] | 415.285.3614
Civil Engineer:

BKF
150 California Street, Suite 600, San Francisco CA 94111 Contact: Jacob Nguyen | [email protected] | 415.930.7900
Planning Consultant:

Rhoades Planning Group
2140 Shattuck Avenue, Suite 705, Berkeley CA 94704
Contact: Mark Rhoades, FAICP | [email protected] | 510-545-4341 313
PUBLIC HEARING ITEM 14.2

EAST PALO ALTO

CITY COUNCIL

STAFF REPORT
DATE: October 20, 2026
TO: Honorable Mayor and Members of the City Council
VIA: Melvin E. Gaines, City Manager
BY: Yajaira Morales, Housing Project Manager
Alex Waggoner, Program Manager, HEART Housing Consulting Services Karen Camacho, Housing & Economic Development Manager
Elena Lee, Community and Economic Development Director
Shiri Klima, Assistant City Manager
SUBJECT: Inclusionary Housing Alternative Compliance Option for the O’Keefe-Manhattan Improvements at Woodland Park (“O’Keefe-Manhattan Improvements”) Residential Project at 300 O’Keefe Street, APN 063-441-240, and additional locations, described herein.
___________________________________________________________________________ Recommendation
Adopt a resolution:
1) Finding and determining that the proposed inclusionary housing alternative, as set forth in Attachment 2 of the staff report, for the O’Keefe-Manhattan Improvements residential development project at 300 O’Keefe Street, APN 063-441-240, and additional locations described herein (“Project”), to provide 172 rental units, deed-restricted at 80% of Area Median Income (“AMI”), meets the Inclusionary Housing Ordinance (“IHO”) requirements under Section 18.37.080 of the East Palo Alto Municipal Code (“EPAMC”) based on reasons offered by the applicant or other substantial evidence provided at the public hearing.
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2) Providing direction on the replacement of rent-stabilized units that are or were occupied by households with incomes above lower income, as authorized by California Government Code Section 65915(c)(3)(C), by selecting one of the following options:
a. Require that each such unit be replaced with a unit of equivalent size that is made available at affordable rent to, and occupied by, low-income households, subject to a recorded regulatory agreement with a term of at least 55 years under Government Code Section 65915(c)(3)(C)(i), and in perpetuity to the extent required by EPAMC Section 18.48.220(D); or
b. Require that each such unit be replaced as a unit subject to the City’s Rent Stabilization Ordinance (“RSO”), EPAMC Chapter 14.04, under a recorded regulatory agreement with the City as required by EPAMC Section 18.48.220(D), as described in the Analysis section of this report; and 3) Directs staff to include the selected option as a recommended condition of approval in the Project entitlement resolution to be presented to the Planning Commission. Replacement units for currently rent-stabilized units occupied by lower-income households, including units presumed to be occupied by lower-income households under Government Code Section 65915(c)(3)(B), must be deed-restricted under state law and as such are not subject to local agency discretion; and
4) Finding that the action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment.

Executive Summary
Woodland Park Property Owner, LLC, c/o Sand Hill Property Company (the “Applicant”) proposes a 1,071 residential unit development (“Project”). The Project would transform 14.73 acres with 565 residential units by renovating 221 units while adding 7 units in existing buildings, and replacing 344 rental units with 729 new rental and 114 new ownership units. In total, the Project would construct 850 units, of which 506 would be net new units.

The Applicant is proposing an alternative compliance plan (referred to herein as “Alternative Compliance”) for the Inclusionary Housing Ordinance ("IHO”) requirements by creating 172 affordable, deed-restricted rental units at 80% of Area Median Income (“AMI”) or below instead of the 78 affordable rental units and 22 affordable ownership/for-sale units required on-site by the IHO, at deeper levels of affordability under the IHO’s original requirements (“Original Compliance”), or 126.5 units (five percent additional units) under Alternative Compliance of the IHO. While these units proposed by the Applicant would be restricted to households making 80% of AMI or below, the rental amount would be based on 30% of a 60% of AMI household’s income, , in accordance with State Density Bonus Law (“SDBL”). As part of the Alternative Compliance, the Applicant is requesting that the affordable units not need be comparable to market rate units 315
PUBLIC HEARING ITEM 14.2
or distributed throughout the property. Affordable units would be limited to rental units; no affordable ownership units would be provided as part of this Alternative Compliance Plan The purpose of this staff report is to present the proposed Alternative Compliance Plan, in accordance with the City’s IHO, for Council’s consideration. The Project would be required to adhere to requirements of the SDBL and IHO, except for the waivers to the IHO described herein.

All inclusionary housing units would be subject to the City’s local preference policy, which gives preference to East Palo Alto residents and to those who work within the City or have been displaced from residence in the City.

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

Priority: Comprehensive Housing
Priority: Land Use, Economic and Workforce Development
Priority: Public Health, Safety, and Quality of Life
Background
O’Keefe and Manhattan is a proposed residential development (“Project”) encompassing approximately 14.73 acres across multiple parcels with the following addresses and Assessor’s Parcel Numbers (“APNs”):

Table 1. Project Addresses
Address APN
300 E. O’Keefe St 063-441-240
320 E. O’Keefe St 063-441-440
355 E. O’Keefe St 063-464-010
395 E. O’Keefe St, 435 E. O’Keefe St, and 404 Donohoe St. 063-464-020 438 Donohoe St. 063-464-030
445 E. O’Keefe St. 063-464-050
1488 W. Bayshore Rd. and 1480 W. Bayshore Rd. 063-464-080 1496 W. Bayshore Rd. 063-284-030
2061 Euclid Ave. 063-284-020
1994 Euclid Ave. 063-473-100
504-508 O’Connor St. 063-473-110
1986 Euclid Ave. 063-473-090
1974 Euclid Ave. 063-473-080
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The Project area is currently designated and zoned as follows:

Table 2. General Plan / Zoning Designation and Acreage
General Plan / Zoning Designation Description Acres
R-UHD Urban Residential 2.02
R-HD-5 High Density Residential 12.36
C-N Neighborhood Commercial 0.35
Total 14.73
The Project area currently contains 565 units across 37 buildings. All 565 units are subject to the City’s Rent Stabilization Ordinance.

Table 3. Project Information
Project Element Detail/Description
Applicant Sand Hill Property Company
Owner Woodland Park Property Owner, LLC
Location O’Keefe St, Donohoe St, W. Bayshore Rd., Euclid Ave., and O’Connor St. (see Table 1)
APN See Table 1
Size of Existing Site 14.73 acres
Existing Use Multi-Family Housing and Neighborhood Commercial Total Number of Units
1,071 total units, including the renovation of 221 rental units, the replacement of 344 rental units, and the
creation of 506 net new units (392 rental and 114
homeownership).

Base Density Units 714
Proposed Number of Affordable
Units
172 (34% of the Net New Units), all at 80% of AMI (Rent Calculation set at 60% of AMI)
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Proposed Unit Program
The proposed Project would result in a total of 1,071 residential units, including the renovation and replacement of existing rental housing and the construction of new rental and ownership/forsale housing.

Table 4. Count and Description of Proposed Unit Breakdown Component Units Description
Existing rental units to be
substantially renovated
221 Existing units in seven buildings that would be
substantially renovated
Net new units added to renovated
buildings
7 Additional rental units within the renovated
buildings
Replacement rental units 345 Existing rental units that would be demolished and replaced as part of the redevelopment
Net new mixed-income rental
apartments
385 Net new rental units in four buildings
Net new for-sale townhomes 114 Net new ownership units
Total Project Units 1,071 Total unit count
The rental units included in the Project would be comprised of 185 studio, 489 one-bedroom, 273 two-bedroom, and 10 three-bedroom units. The ownership/for-sale townhomes would include 36 three-bedroom, 69 four-bedroom 2.5-bath, and 9 four-bedroom 3.5-bath units.

Table 5. Proposed Unit Mix by Bedroom Count
# of Bedrooms
Studio 1 2 3 4
New Rental 71 400 247 10 -
Renovated 114 89 25 - -
Townhomes - - - 36 78
Subtotal 185 489 273 46 78
Total 1071
Construction and Net New Units
Of the 1,071 total units in the completed Project, 850 units would be constructed as part of the proposed development, consisting of the renovation and construction activities described above.

The Project would result in 506 net new residential units compared with existing conditions. The Project therefore combines preservation and substantial renovation of existing rental housing, replacement of existing rental units, new mixed-income rental housing, and new ownership/forsale housing. 318
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Project History
On October 30, 2025, the Applicant submitted a preliminary application for a residential project, and on April 27, 2026, the Applicant submitted an application (DR26-002) seeking to vest rights under Government Code Section 65589.5(o)(1), also known as Senate Bill 330, or the Housing Crisis Act (referred to herein as “the HCA”). The rights vested under the HCA include making the proposed developments subject only to the ordinances, policies and development standards in effect when the HCA preliminary application was deemed complete. To meet its inclusionary housing requirement, the Applicant on September 13, 2026, proposed an Alternative Compliance providing 172 deed-restricted, affordable rental units to comply with State Density Bonus Law requirements for the density bonus being applied by the Applicant.

Inclusionary Housing Requirement
The City's Inclusionary Housing Ordinance (“IHO”) applies to net new residential units (“Net New Units”). Units attributable to a density bonus granted under California Government Code Section 65915 and additionally beyond what is permitted by the zoning designation are excluded from the IHO calculation. In practice, this means that the base allowable density is used to calculate the number of IHO units to be provided. However, when the Net New Unit count is lower than the base density, the Net New Unit count can be used to calculate the IHO requirement. In this case, the Net New Units count (506 units) is lower than the base density (714 units), so the Net New Unit count is used to calculate the number of IHO units to be provided. In a project providing entirely new units, the base density will always be lower than the Net New Units, since the density bonus allows a project to exceed base density. However, in this case, since the Project is replacing a large number of units, the Net New Units are lower than the base density, so the Net New Unit count is the number used.

For rental housing projects, the IHO requires that 20% of the Net New Units within the project's total base units be provided as affordable housing. The required affordability mix is as follows:

Table 7. Required Ownership Affordability Levels for IHO Income Level Percent Required Affordability Level
Median-Income 10% 80% AMI
Moderate-Income 10% 120% AMI
Total 20%
All inclusionary units are required to be deed-restricted in perpetuity.

Project IHO Requirements – Net New Unit Calculation
Of the 1,071 Project units, the 344 replacement units and 221 retained/renovated units are not Net New Units. The Net New Units are the 7 added rental units in the renovated building, 385 new rental apartments, and 114 new town homes, for a total of 506 Net New Units. With 506 Net New Units, the Project generates an IHO obligation of 101.2 affordable units, consisting of:
 78.4 affordable rental units, including 19.6 at 35% AMI, 39.2 at 50% AMI, and 19.6 at 60% AMI; and
 22.8 affordable ownership units, including 11.4 at 80% AMI and 11.4 at 120% AMI.

Table 8. IHO Requirements for Project by Tenure (Rental vs. Ownership) Component Net New Units IHO Rate Affordable Units Required Rental 392 20% 78.4
Ownership/ For-Sale 114 20% 22.8
Total 506 20% 101.2
The IHO guidelines state that “if the inclusionary requirement does not evenly divide into the percentages provided in Section 18.37.050, the requirement shall default to the lowest affordability level. If the calculation results in a fraction of an Inclusionary Unit, the developer shall pay an In-Lieu Fee for the fractional unit.”
Applicant’s Alternative Compliance Request
As outlined in EPAMC Section 18.37.080, “Alternative Compliance” is when an Applicant requests to meet their IHO obligations through the provision of off-site units, the payment of a fee in-lieu of creating the units, or some other means. As the Applicant is not proposing off-site units or payment of an in-lieu fee, the request falls under EPAMC Section 18.37.080(D), “Other Alternative Compliance Methods,” which states:

A developer may propose an alternative compliance method to provide inclusionary units 320
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through other means consistent with any adopted inclusionary housing guidelines. The approval body may approve or conditionally approve such an alternative only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site.

The Applicant argues that building in compliance with the City’s IHO is financially infeasible and that their proposed Alternative Compliance Plan, including the alternative affordability request and the waivers to additional requirements of the IHO, would make the Project financially feasible. They also argue that status quo, where no project is advanced, many existing units would still require renovation, and no new affordable units would be created.

The Applicant is requesting Alternative Compliance rather than satisfying the IHO through the standard on-site affordability requirements (“Original Compliance”). Specifically, the Applicant proposes providing 172 affordable rental units for tenants who are at 80% of Area Median Income (“AMI”). While these units proposed by the Applicant would be restricted to households making 80% of AMI or below, the rent for these units would be calculated based on 60% of AMI, in accordance with State Density Bonus Law (“SDBL”) [Further, the Applicant is requesting that as part of the Alternative Compliance option, that they be allowed to provide affordable units that are not comparable. Compliance with the IHO would require City Council approval of an alternative means of compliance, as described further herein.

Analysis
The Applicant is requesting the City Council’s approval of the Applicant’s Alternative Compliance Plan under the City of East Palo Alto Inclusionary Housing Ordinance.

State Density Bonus Law
California’s Density Bonus Law (Government Code Section 65915, et seq, referred to herein as “SDBL”) allows a developer to increase density on a property above the maximum set under a jurisdiction’s General Plan and zoning. In exchange for the increased density, a certain number of the new affordable dwelling units must be reserved as affordable or at below market rate (“BMR”). Qualifying projects can also receive reductions in required development standards via waivers and/or concessions.

SDBL requires a city or county to provide a developer who agrees to construct specified percentages of units for lower-income, very low-income, senior citizen housing, or other qualifying housing types, with a density bonus and other incentives, concessions, and waivers upon their request. East Palo Alto Municipal Code (“EPAMC”) Chapter 18.36 implements the State law.

SDBL allows qualified projects to request waivers and concessions for reduced development standards, including setbacks, square footage requirements, parking, and open space.

The Project proposes a total of 1,071 renovated and new units across the Project’s 14.73 acres.

To determine how many units can be added under the SDBL, one must first determine the 321
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number of “base units” that are allowed at the Project site, based on the underlying zoning. The base units are calculated by multiplying the base density allowed by each zoning designation without a density bonus (e.g. 43 dwelling units per acre) by the number of acres of each site (e.g. 12.36 acres) and rounding up if the result is a fraction of a unit.

Table 9. Base Density Calculation
Parcel Size
(approximate)
Max Dwelling
Units Per Acre
(du/ac)
Max Total
Base Units
Bonus
Units
(50%
x Max
Base
Units)
R-UHD Zone 2.02 86 du/ac 174 87
R-HD-5 Zone 12.36 43 du/ac 532 266
C-N Zone 0.35 22 du/ac 8 4
Parcel Total 14.73 22 – 86 du/ac 714 357
The Applicant has proposed that 172 units would be deed-restricted to 80% of Area Median Income (“AMI”). Given that these units make up 24.0% of base density units, the Project qualifies for a 50% density bonus, and therefore, 357 additional units than the base density would allow.

Under SDBL, households with incomes up to eighty percent of AMI are eligible to rent the affordable units, but the rents are set at thirty percent of monthly income of a household making sixty percent of AMI, adjusted for assumed household size. The assumed household size is one person for a studio, two persons for a one-bedroom, three persons for a two-bedroom, and four persons for a three-bedroom. The applicable AMI for the current fiscal year is provided in the San Mateo County 2026 Income Limits in the table titled “California State Income Limits for SMC.

In comparison to the IHO, SDBL units with an 80% AMI income limits have functional rents equivalent to the IHO low-income/60% AMI affordability level.

Replacement Unit and Relocation Assistance Requirements In accordance with SDBL and the Housing Crisis Act (Government Code Section 66300, et seq.), units that the Project would demolish must be replaced. The Project would demolish and rebuild 344 units that are rent-stabilized under the East Palo Alto Rent Stabilization Ordinance (“RSO”).

As such, these 344 units must be replaced as described below. The 221 units that would be renovated would remain subject to the RSO.

Under SDBL Government Code Section 65915(c)(3)(D), the replacement units must be equivalent in size to the protected units being replaced. As such, the replacement units must 322
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contain at least the same total number of bedrooms as the units being replaced. This requirement would be spelled out in any relevant project approval documents.

The income category that governs each replacement unit is that of the household in occupancy of the existing unit on the date of application or, for an unoccupied unit in a development with occupied units, the last household in occupancy within the five year period preceding the project application (Government Code Section 65915(c)(3)(B)(i)-(ii)). If a household’s income category is not known, state law presumes, subject to rebuttal, that lower income renter households occupied the units in the same proportion as lower income renter households to all renter households in the City, as determined by the most recently available data from the U.S.

Deed-restricted replacement units are considered in determining whether the Project satisfies the requirements of the SDBL (Government Code Section 66300.6(b)(1)(B)).In addition, the Applicant is required under both the Housing Crisis Act and EPAMC Chapter 14.02 to provide relocation assistance to tenants during the relocation period. Compliance with these tenant protection requirements would be required as part of the approval of the project’s planning entitlements, including through the project’s Conditions of Approval.

Council Direction on Replacement of Rent-Stabilized Units The EPAMC reserves to the City Council the City’s policy on restrictions on demolition of rental units and conditions for replacement housing (EPAMC Section 14.04.220). The Planning Commission will apply the selected option through the conditional use permit required for the demolition of the existing units (EPAMC Section 18.48.220(A), (C), (D)). Staff therefore requests Council direction on which option under Government Code Section 65915(c)(3)(C) should apply to units in the Project that presently have, or in the five years preceding the application if the unit is vacant, tenants with incomes greater than low income, so that the selected option can be included as a recommended condition of approval in the entitlement resolution to be presented to the Planning Commission.
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The Applicant has not yet provided the incomes of the households occupying the 344 units to be demolished. The number of replacement units that must be deed-restricted, and the number subject to Council’s direction, will be determined from that income information or, where incomes are not known, from the CHAS presumption described above. Because the CHAS presumption assigns only a proportion of units of unknown income to lower income households, Council’s direction would apply to the remaining units even if actual incomes are not established. Staff will request the income information from the Applicant before the Planning Commission hearing, and the unit-by-unit determination would be documented in the Project’s conditions of approval.

Under Option II, the replacement RSO units would be newly constructed. The RSO exempts units that received a certificate of occupancy on or after January 1, 1988 from its registration, rent increase limit, and rent adjustment provisions (EPAMC Section 14.04.050(B)(2)), and state law allows owners to set the initial and all subsequent rents for units that received a certificate of occupancy after February 1, 1995, unless the owner has agreed by contract with the City in consideration for a density bonus or other specified assistance (Civil Code Section 1954.52(a)(1), (b)). EPAMC Section 18.48.220(D) requires the Applicant to enter a recorded regulatory agreement with the City for the replacement units. Because the Applicant is requesting a density bonus, the regulatory agreement would establish the applicable affordability or RSO restrictions for the replacement units, consistent with EPAMC Section 18.48.220(D).

Deed-Restriction of Replacement Units
State law governs whether these units are deed-restricted. Government Code § 65915(c)(3)(B)(i) requires that replacement units be reserved for the same income category as the household they replace, and where that household's income is unknown, presumes lower income in the same proportion that lower-income renter households bear to all renter households citywide, based on HUD Comprehensive Housing Affordability Strategy (CHAS) data.

Government Code § 65915(c)(3)(C) allows the City to instead apply the local rent or price control ordinance's own replacement requirement, but only for units shown to have been occupied by persons or families above lower income within five years preceding the application. That showing has not been made for the units outside the CHAS-presumed proportion. The applicant has provided no evidence to date to make that showing.
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Accordingly, the deed restriction applies to the replacement units by default under § 65915(c)(3)(B)(i) unless and until the Applicant produces evidence that specific units were occupied by above-lower-income households, triggering the City's election under § 65915(c)(3)(C).

Local Preference Policy
In 2020, the City adopted a Local Preference Policy where the selection of tenants for affordable housing is prioritized for people who live, work, or have been displaced from a residence in East Palo Alto. The Local Preference Policy applies to occupancy of City-subsidized affordable housing units, density bonus units, and development projects subject to the City’s Inclusionary Housing Ordinance. Thus, the Local Preference Policy applies here.

The proposed 1,071-unit Project includes a maximum density of 714 units to which the IHO would apply. However, the Project is only providing 506 Net New Units. As such, the IHO requirements would only apply to these 506 units. Under the IHO, the Project would be required to provide 101 affordable units and an in-lieu fee based on 0.2 units. Of these units, 78 would be rental units, and 23 would be ownership/for-sale units. EPAMC Section 18.37.050.(C)(3) states that "[w]hen a residential development includes both ownership and rental dwelling units, the provisions of this chapter that apply to ownership residential development shall apply to that portion of the development that consists of ownership dwelling units, while the provisions of this chapter that apply to rental residential development shall apply to that portion of the development that consists of rental dwelling units." See Table 10 for the number of required IHO units, by unit type and affordability level.

Because the Applicant is electing an Alternative Compliance Option under EPAMC Section

18.37.080(D), Section 18.37.080(A) increases the inclusionary requirement by five percentage points over the Section 18.37.050 baseline show as required in the table below, to approximately 126 units. Applied to the Project’s 392 Net New Rental Units and 114 Net New Ownership Units, an alternative compliance option would require 98 new rental units, 24.5 at 35% of AMI, 49 at 50% of AMI, and 24.5 at 60% of AMI. It would also require 28.5 ownership units to be deed restricted as affordable, 14 at 80% of AMI and 14 at 120% of AMI. The Applicant’s proposed 172 units exceeds this figure as well.

The Applicant is proposing the provision of 172 deed-restricted rental units to tenants at 80% of AMI; however, under SDBL the units would be priced based on sixty percent of AMI. See the table below for the comparison of the requirements under the IHO and the Applicant’s proposal.

Table 10: Project’s Inclusionary Housing Requirement
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and Applicant Proposal
Affordability Level
IHO Original
Compliance
Requirement
(Percent)
IHO Original
Compliance
Requirement
(Units)
IHO
Alternative
Compliance
Requirement
Applicant
Proposal
(Units)
Rental Units
35% of AMI 5% 20
25% or
126 Units
0 Very Low-Income
(50% of AMI)
10% 38 0
Low-Income
(60% of AMI)
5% 20 0
Median-Income
(80% of AMI)
- - 172
Ownership/ For-Sale
Units
Median-Income
(80% of AMI)
10% 11 0
Moderate-Income
(120% of AMI)
10% 11 0
Total Inclusionary Units 101 Units 126 Units 172 Units
Average AMI of Units 60.2% 80% (Priced
at 60%)
Partial Unit Payment 0.2 rental unit
+0.8 ownership
unit

0.5 unit None
Additional Waivers to the Inclusionary Housing Ordinance As part of the Alternative Compliance Plan, the Applicant is seeking the following waivers to the IHO: the affordable units need not be dispersed, need not have the same proportion of unit types as the market rate units, and need not have comparable square footage or bedroom count as the market rate units. These waivers are further explained in the table below.

Table 11: Inclusionary Housing Ordinance Waivers Applicant Requested Requirement Developer Proposal
EPAMC 18.37.050(C)(3) When a
residential development includes both
ownership and rental dwelling units, the
provisions of this chapter that apply to
ownership residential development shall
apply to that portion of the development that
consists of ownership dwelling units, while
the provisions of this chapter that apply to
rental residential development shall apply to
The Applicant is not proposing the deedrestriction of any for-sale townhouses. The Applicant is requesting that the affordable units
not have the same proportion of unit types as
to the market rate units to “produce financially
feasible projects that will maximize affordable
housing in EPA.”
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that portion of the development that consists
of rental dwelling units.

EPAMC 18.37.060(C). Bedroom Mix and
Unit Size. The number of bedrooms and the
size of the inclusionary units shall be
comparable to or greater than the average
number of bedrooms and average size of the
market-rate units consistent with any
adopted inclusionary housing guidelines.

The affordable units would not have a
comparable square footage or bedroom count
as market rate units.

EPAMC 18.37.060(D). Location. The
inclusionary units shall be located so as not
to create a geographic concentration of
inclusionary units within the residential
development.

Units would not be disbursed throughout the
development. The Applicant has not indicated
where the units would be located and/or if they
would be concentrated in one building or area.

The following evaluation details why the City may assume that the Applicant is proposing to provide the most economical inclusionary units feasible.

Evaluation of the Alternative Compliance Option: Public Benefit Analysis

The Project is proposing 172 units on-site to tenants at 80% of AMI, which is substantially more units than required by the IHO, though the average AMI of the required IHO units (58.6% of AMI) is lower than the average AMI of the proposed units (80% of AMI). However, these units would be rented to be affordable to households at 60% of AMI, even though the income restriction is 80% of AMI, bringing the affordability close to levels required by the IHO. Given the additional units provided, the proposed affordability would appear to provide additional public benefit. For a more thorough evaluation, City staff would need the Applicant to submit details on the proposed units in the development by tenure type, bedroom count, unit sizes, and affordability level.

Staff Recommendation
The Applicant is currently proposing to provide 172 units restricted to households making eighty percent of AMI or less, but priced at levels affordable to households making sixty (60) percent of AMI or less. This is in line with requirements from State Density Bonus Law, outlined in Government Code Section 65915. Under the Inclusionary Housing Ordinance, average affordability of rental units provided would be fifty-eight-point six (58.6) percent of AMI. The average affordability of units being provided by the Applicant would be sixty (60) percent of AMI, so it is only slightly higher than what is required under the Inclusionary Housing Ordinance. This Alternative Compliance Option would not provide the units required at 35% and 50% of AMI traditionally required by the IHO. By providing 172 units, the Applicant is providing thirty-threepoint nine (33.9) percent of Net New Units as affordable, exceeding the twenty-five (25) percent requirement for an Alternative Compliance Option under the IHO. 327
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However, the Applicant is also proposing to build one hundred and fourteen (114) ownership townhome units as part of this development. The Applicant is not proposing to provide any ownership units restricted as affordable units. As shown in Table 10, under IHO Original Compliance, the Applicant would be required to provide 22 of those units as affordable units, 11 at eighty (80) percent of AMI and 11 at one hundred and twenty (120) percent of AMI and a partial unit in-lieu fee payment for 0.8 units. Under IHO Alternative Compliance, the Applicant would be required to provide 28 affordable ownership units, 14 at eighty (80) percent of AMI and 14 at one hundred and twenty (120) percent of AMI and a partial in lieu fee payment for 0.5 units.

The Applicant has not provided evidence demonstrating that the proposed alternative, including the elimination of affordable ownership units, would independently provide a “greater public benefit” than strict compliance with the IHO requirements. However, the proposed alternative would provide a substantially greater number of affordable rental units at a deeper level of rental affordability. The alternative would provide 172 deed-restricted affordable rental units, compared with approximately 101 affordable units required under the IHO, an increase of approximately 71 percent. The 172 units would also exceed approximately 126 units contemplated under the IHO alternative-compliance framework and would represent approximately one-third of the 506 net-new units.

Under the IHO, approximately 77 affordable rental units and 23 affordable ownership units would be provided. The proposed alternative would instead provide 172 affordable rental units, or approximately 95 additional affordable rental homes, with rents affordable to households earning 60 percent of AMI or less. While the alternative would not provide the approximately 23 affordable ownership units otherwise required, it would substantially increase the overall number of income-restricted homes and would respond to an identified local housing need.

Considering these factors, staff finds that the significant increase in the number of affordable units, together with the deeper rental affordability, provides a substantial public benefit that supports approval of the Alternative Compliance Plan.
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Fiscal Impact
Approval of the proposed Inclusionary Housing Plan has no direct fiscal impact on the City’s General Fund.

Estimated Impact Fees
Pursuant to the Housing Crisis Act the development impact fees applicable to the Project are those that are subject to the Mitigation Fee Act that were in effect when complete the HCA preliminary applications were submitted to the City. The development impact fees were vested on October 30, 2025, when the HCA preliminary application was deemed complete. The Project shall pay all applicable impact fees pursuant to the fee schedule in effect on October 30, 2025, prior to final building inspection or issuance of the Certificate of Occupancy. The project is estimated to generate nearly $2.5 million in Sewer and Storm Drain Impact Fees, as well as additional Parks and Trails Impact Fees, Public Facilities Impact Fees, and other applicable fees not yet determined. All City impact fees shall be finalized and collected prior to issuance of the Certificate of Occupancy or final building permit approval.

In order to provide an estimate on the potential property tax revenue the Project would generate for the City, the City would need additional information such as the current and new assessed property value and how the proposed affordable units would be qualified for the welfare exemption. The City Council may wish in the future to consider retaining a consultant to provide property tax revenue analysis for fiscal impact reports.

Government Code § 84308
Applicability of Levine Act: Yes
Analysis of Levine Act Compliance: The project applicant is Sand Hill Property Company.

Staff are unaware of any other parties or participants relevant to the City Council’s consideration of this item.
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Attachments

1. Resolution

2. Inclusionary Housing Plan
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RESOLUTION NO. XX — 2026

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

ACCEPTING AN INCLUSIONARY HOUSING ALTERNATIVE COMPLIANCE OPTION FOR A 1072-UNIT RESIDENTIAL DEVELOPMENT PROJECT (“O’KEEFE-MANHATTAN IMPROVEMENTS”) ON O’KEEFE STREET AND MANHATTAN STREET (APN 063-441-240 AND

OTHER PARCELS DESCRIBED HEREIN)
WHEREAS, on November 19, 2020, the City Council of the City of East Palo Alto ("City Council") adopted Ordinance No. 425 ("Ordinance"), adding Chapter 18.37 — Inclusionary Housing to the City of East Palo Alto Municipal Code; and
WHEREAS, Woodland Park Property Owner, LLC, c/o Sand Hill Property Company (the “Applicant”) submitted an application for a residential development consisting of one thousand seventytwo residential units on the corner of O’Keefe and Manhattan Street (“O’Keefe-Manhattan Improvements”), identified by assessor's parcel number 063-441-240, and additional parcels described herein, on June 1, 2026; and
WHEREAS, the additional parcels include: 320 E. O’Keefe St, 063-441-440; 355 E. O’Keefe St, 063-464-010; 395 E. O’Keefe St, 435 E. O’Keefe St, and 404 Donohoe St., 063-464-020; 438 Donohoe St., 063-464-030; 445 E. O’Keefe St., 063-464-050; 1488 W. Bayshore Rd. and 1480 W. Bayshore Rd., 063-464-080; 1496 W. Bayshore Rd., 063-284-030; 2061 Euclid Ave., 063-284-020; 1994 Euclid Ave., 063-473-100; 504-508 O’Connor St., 063-473-110; 1986 Euclid Ave., 063-473-090; and 1974 Euclid Ave.,063-473-080; and
WHEREAS, the Applicant submitted an Inclusionary Housing application requesting an alternative compliance option under EPAMC Section 18.37.080 for the Project (“Alternative Compliance Plan”) on September 14, 2026; and
WHEREAS, the Project' s baseline inclusionary obligation ("Original Compliance") under Section

18.37.050 of the IHO is to provide: 78 on-site affordable rental units, with 25% of those for 35% Area Median Income ("AMI") Households, 50% for Very Low-Income Households, and 25% for Low-Income Households, as defined in Section 18.37.020 of the IHO; and to provide 22 on-site affordable ownership/for-sale units, 50% of those for Median-Income Households and 50% for Moderate-Income Households, as defined in Section 18.37.020 of the IHO; and WHEREAS, Section 18.37.080 of the IHO provides that an applicant of a residential development may choose from a list of alternative compliance options to meet the inclusionary obligation if the inclusionary requirement for the project is increased by 5% over the inclusionary housing requirement for projects with five or more units, and this option must be approved by the City Council; and
WHEREAS, applying this five-percentage-point increase under Section 18.37.080(A) to the Project’s 506 net new units yields an alternative compliance inclusionary obligation of approximately 126 units at varying affordability levels; and
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WHEREAS, Subsection (D) of section 18.37.080 of the East Palo Alto Municipal Code allows the Council to grant a residential development applicant "Other alternative compliance methods" but only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site"; and WHEREAS, in lieu of the inclusionary obligation, the Applicant proposed an Alternative Compliance Plan to provide 172 on-site Inclusionary Units, to be rented at an affordable rent for Median Income-Households (80% of AMI); and
WHEREAS, while the units proposed would be restricted to households making 80% of AMI or below, they would be priced to be affordable to households at or below 60% of AMI, in accordance with State Density Bonus Law (“SDBL”); and
WHEREAS, the Applicant is proposing to provide the 172 on-site rental units affordable to Median-Income households to utilize SDBL to increase the maximum density by 50% for an additional 357 units, in accordance with State law.

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 into this action by this reference;
2) Finds and determines that the proposed alternative, as set forth in Attachment 2 of the staff report, for the O’Keefe-Manhattan Improvements residential development project at 300 O’Keefe Street, APN 063-441-240, and additional locations described herein (“Project”), to provide 172 rental units, deed-restricted at 80% of Area Median Income (“AMI”), meets the Inclusionary Housing Ordinance (“IHO”) requirements under Section 18.37.080 of the East Palo Alto Municipal Code (“EPAMC”) based on reasons offered by the applicant or other substantial evidence provided at the public hearing; and
3) Require that each such unit be replaced with a unit of equivalent size that is made available at affordable rent to, and occupied by, low-income households, subject to a recorded regulatory agreement with a term of at least 55 years under Government Code Section 65915(c)(3)(C)(i), and in perpetuity to the extent required by EPAMC Section 18.48.220(D); and 4) Directs staff to include the selected option as a recommended condition of approval in the Project entitlement resolution to be presented to the Planning Commission. Replacement units for currently rent-stabilized units occupied by lower-income households, including units presumed to be occupied by lower-income households under Government Code Section 65915(c)(3)(B), must be deed-restricted under State law and as such are not subject to local agency discretion; and
5) Finds that the action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment. 332
333
PASSED AND ADOPTED this 20th day of October 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
334
RESOLUTION NO. XX — 2026

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EAST PALO ALTO

18.37.050 of the IHO is to provide: 78 on-site affordable rental units, with 25% of those for 35% Area Median Income ("AMI") Households, 50% for Very Low-Income Households, and 25% for Low-Income Households, as defined in Section 18.37.020 of the IHO; and to provide 22 on-site affordable ownership/for-sale units, 50% of those for Median-Income Households and 50% for Moderate-Income Households, as defined in Section 18.37.020 of the IHO; and WHEREAS, Section 18.37.080 of the IHO provides that an applicant of a residential development may choose from a list of alternative compliance options to meet the inclusionary obligation if the inclusionary requirement for the project is increased by 5% over the inclusionary housing requirement for projects with five or more units, and this option must be approved by the City Council; and
WHEREAS, applying this five-percentage-point increase under Section 18.37.080(A) to the Project’s 506 net new units yields an alternative compliance inclusionary obligation of approximately 126 units at varying affordability levels; and
335
WHEREAS, Subsection (D) of section 18.37.080 of the East Palo Alto Municipal Code allows the Council to grant a residential development applicant "Other alternative compliance methods" but only if the approval body determines, based on substantial evidence, that such alternative compliance will provide as many or more inclusionary units at the same or lower income levels or will otherwise provide greater public benefit than would provision of the inclusionary units on-site"; and WHEREAS, in lieu of the inclusionary obligation, the Applicant proposed an Alternative Compliance Plan to provide 172 on-site Inclusionary Units, to be rented at an affordable rent for Median Income-Households (80% of AMI); and
WHEREAS, while the units proposed would be restricted to households making 80% of AMI or below, they would be priced to be affordable to households at or below 60% of AMI, in accordance with State Density Bonus Law (“SDBL”); and
WHEREAS, the Applicant is proposing to provide the 172 on-site rental units affordable to Median-Income households to utilize SDBL to increase the maximum density by 50% for an additional 357 units, in accordance with State law.

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 into this action by this reference;
2) Finds and determines that the proposed alternative, as set forth in Attachment 2 of the staff report, for the O’Keefe-Manhattan Improvements residential development project at 300 O’Keefe Street, APN 063-441-240, and additional locations described herein (“Project”), to provide 172 rental units, deed-restricted at 80% of Area Median Income (“AMI”), meets the Inclusionary Housing Ordinance (“IHO”) requirements under Section 18.37.080 of the East Palo Alto Municipal Code (“EPAMC”) based on reasons offered by the applicant or other substantial evidence provided at the public hearing; and
3) Require that each such unit be replaced as a unit subject to the City’s Rent Stabilization Ordinance (“RSO”), EPAMC Chapter 14.04, under a recorded regulatory agreement with the City as required by EPAMC Section 18.48.220(D), as described in the Analysis section of this report; and
4) Directs staff to include the selected option as a recommended condition of approval in the Project entitlement resolution to be presented to the Planning Commission. Replacement units for currently rent-stabilized units occupied by lower-income households, including units presumed to be occupied by lower-income households under Government Code Section 65915(c)(3)(B), must be deed-restricted under State law and as such are not subject to local agency discretion; and
5) Finds that the action being considered does not constitute a “Project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections 15378(b)(4) and (5) in that it is a governmental fiscal, organizational or administrative activity that will not result in direct or indirect changes in the environment. 336
337
PASSED AND ADOPTED this 20th day of October 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
338
2600 El Camino Real, Suite 410 | Palo Alto, California 94306 2020 Dumbarton Avenue | East Palo Alto, California 94303 1 April 27, 2026
Melvin Gaines, City Manager
City of East Palo Alto
2415 University Avenue
East Palo Alto, CA 94303
Re: Application for O’Keefe-Manhattan Improvements at Woodland Park Dear Mr. Gaines,
Sand Hill Property Company is proud to submit the application package for the O’Keefe-Manhattan Improvements at Woodland Park, a housing development project (the “O’Keefe Manhattan Improvements”) on a portion of the Woodland Park neighborhood, on the west side of Highway 101. This follows a robust pre-application process starting in October 2025, including listening sessions, community meetings, and a Planning Commission study session. A complete SB 330 Preliminary Application for this project was submitted to the City of East Palo Alto on October 30, 2025.

With no displacement, these improvements propose to update or replace aging, outdated structures on the Westside of East Palo Alto by: a) substantially renovating and adding units to several apartment buildings, b) building new for-sale townhomes, and c) building new mixed-income apartment buildings. We will retain and renovate rent-stabilized units, increase the housing supply, and provide better parking and mobility options for existing and future residents.

We are acting on broad community feedback requesting the improvement of more of our buildings across Woodland Park. Adjacent to and connected to the Euclid Improvements, renovated and new housing will be provided along East O’Keefe Street and Manhattan Avenue with additional improvements along Euclid Avenue, including frontage and streetscape improvements to the Euclid Improvements to ensure there is a single, cohesive neighborhood feel and improved connectivity for all.

These improvements celebrate the vision and goals of the city’s Westside Area Plan and are fully compliant with the city’s General Plan. The preliminary application for this project was submitted pursuant to the Housing Crisis Act of 2019, also known as “SB 330.” The project is a “housing development project” subject to SB 330 and the Housing Accountability Act (“HAA”) because more than two-thirds of the project’s square footage is residential.

Under SB 330, we have a vested right to develop a housing development project in accordance with the applicable ordinances, policies, and standards in effect as of October 2025.

We are now submitting a complete planning application for the Project within 180 days of submitting the project’s Preliminary Application, as required by statute, and more broadly consistent with the HAA, SB 330, and the Permit Streamlining Act. The O’Keefe-Manhattan Improvements will affect 565 of our existing units, of which 221 will be substantially renovated. There will be 385 net new mixed-income rental apartments and 114 new for-sale townhomes. Please see below for the city’s Universal Planning Application and required supporting documents.

By providing a portion of the units at affordable levels, the O’Keefe-Manhattan Improvements qualifies for a density bonus, concessions, incentives, and waivers pursuant to Government Code §65915 and EPA Municipal 339
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Applicant Statement – April 2026
2 Code §18.36. With the density bonus concessions and waivers specified in the application, the O’Keefe-Manhattan Improvements comply with the General Plan (including the Westside Area Plan) and zoning standards, and other applicable objective development standards in place at the time of the pre-application submittal.

The site will be pedestrian-friendly, bike-friendly, and easily and safely accessible by all modes of transportation.

The buildings and site layout have been designed deliberately in consideration of the neighborhood. Finally, the project will have a significant positive fiscal impact on the City.

We are deeply appreciative of the community for their engagement and input so far. Their contributions helped us understand community priorities, which we have made extensive efforts to address in our proposal. We have held dozens of community meetings, listening sessions, cafecitos, and one-on-one conversations throughout 2025 and 2026, building upon our expansive and on-going engagement since purchasing Woodland Park in 2016.

We recognize that in East Palo Alto, displacement has historically been a major concern. We believe it’s critical that those living here now be able to stay and enjoy the benefits they helped inspire. To that end and similar to the Euclid Improvements, we will create a “Tenant Protection and Community Housing Preservation Plan,” which will detail our commitments to existing tenants and how we will prevent displacement and preserve housing affordability and stability. Based on community input to date, we have decided to continue our commitment to our five community-based core principles for this project:

1. No Displacement

2. Preserve Housing Affordability and Stability

3. Community Informed Plans

4. Better Parking and Mobility

5. Safer, Healthier Buildings
Thank you for receiving our application and we look forward to continuing our engagement with the City, our tenants, and the broader East Palo Alto community, and contributing to realizing the Westside Area Plan vision.

Sincerely,
Mike Kramer
Sand Hill Property Company
Mike Kramer
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Applicant Statement – April 2026
3 O’Keefe-Manhattan Improvements
E. O’Keefe Street, Euclid Ave., and Manhattan Ave
Applicant Statement

OVERVIEW AND PROJECT INTRODUCTION
The applicant team is pleased to submit this application package to substantially renovate 221 existing units, create 392 net new mixed-income rental apartments, and create 114 new for-sale townhomes within the Woodland Park neighborhood, west of Highway 101 and north of University Avenue. This applicant statement includes:

1. Project Description

2. Project Background

3. Project Compliance with General Plan

4. Project Compliance with Zoning

5. State Density Bonus Law

6. Inclusionary Housing Plan

7. Fair Housing and Marketing Plan

8. California Environmental Quality Act (“CEQA”) Compliance

9. Relevant Statutory Framework

10. Required Findings

11. Community Outreach

12. Project Team
Property Information
Project Area: ±14.7 acres + streetscape
Addresses: See Exhibit A to Universal Planning Application APNs: See Exhibit B to Universal Planning Application
General Plan Designations: Urban Residential, High Density Residential, and Neighborhood Commercial Zoning Designations: R-UDH, R-HD-5, and C-N.

1. PROJECT DESCRIPTION

The proposed project would substantially renovate 221 existing units in 7 buildings, add 7 new units to those renovated buildings, create 385 net new mixed-income rental apartments in four buildings, and create 114 new for-sale townhomes. The proposed project will add 506 net new dwelling units to East Palo Alto’s housing supply.

Table 1: Project Description
Existing Units Proposed Units Net New Units
Rental units in buildings to be renovated 221 228 7
Rental units in buildings to be replaced 344 729 385
For-sale units 0 114 114
Total 565 1,071 506
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4 The project site is ±14.7 acres, portions of which are designated as “Urban Residential,” “High Density Residential,” and “Neighborhood Commercial” in the East Palo Alto General Plan.

Each apartment unit will have at least 1 off-street parking space in a garage and each townhome unit will have 2 dedicated off-street parking spaces in a private garage. There will also be ADA and guest surface parking spaces, for a total of 1,385 spaces. There will be 1,403 bicycle parking spaces. The project provides 188,380 square feet of open space (4.3 acres).

The project site is near Highway 101 and University Avenue, which are both major commercial corridors well served by SamTrans public transit.

2. PROJECT BACKGROUND

Existing Conditions
The project site is part of the Woodland Park neighborhood. There are 565 existing rental units in approximately 37 buildings that would be affected by the project. These existing rental units are in singlefamily homes, duplexes, and apartments. There is also a shared alleyway, a laundromat and a convenience store.

Proposed Project
This application reflects a re-envisioned Woodland Park neighborhood that includes a mix of housing types and affordability. There will continue to be rental apartments, both in existing renovated rent-stabilized units and in new mixed-income buildings. There will also be for-sale townhomes available at mixed income levels. The Proposed Project includes adjustments to the streetscape design of the Euclid Improvements to ensure a unified, coherent neighborhood that fits within the existing context.

3. PROJECT COMPLIANCE WITH GENERAL PLAN
The City of East Palo Alto’s General Plan includes several designations within the Woodland Park neighborhood, including Urban Residential, High Density Residential, and Neighborhood Commercial on the O’Keefe-Manhattan Improvements site.

The Urban Residential designation is intended to support the development of very high-density housing, especially mid-rise and high-rise residential development. Parking structures in the Urban Residential should be designed not to face primary public streets.

The Neighborhood Commercial designation provides for a variety of retail, office, business activities, and residential units.

The proposed project will meet all of the General Plan requirements, except as modified pursuant to SDBL. 342
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5 Table 2: General Plan Objective Requirements

General Plan requirement Compliance
Allowed Land Uses:

Urban Residential: High-density multi-family
dwellings (apartments, condos, and SROs)
High Density Residential: A range of multi-family
housing types ranging from townhomes to multifamily apartments at moderate to high densities.

Neighborhood Commercial: Retail, services and
related uses. Office and residential uses allowed on
the upper floors.

Complies.

Apartments and townhomes are planned on land
designated as Urban Residential and High Density
Residential. Both are allowed uses.

Townhouses are planned on land designated as
Neighborhood Commercial. This is an allowed use
above the ground floor. A SDBL concession
permits residential uses on the ground floor.

Density/Intensity:

Urban Residential: 43.1 - 86 units/acre, or 150 to
300 persons/acre.

High Density Residential: 22.1 - 43 units/acre
(maximum of 1 dwelling unit per 1,000 feet of parcel
area), or 80 to 150 persons/acre.

Neighborhood Commercial: Up to 22 units/acre. Up
to 1.0 FAR.

Complies. The housing development project is
entitled to a 50% density bonus. The base density
for the project is calculated in Table 3 below. The
base density for the project plus the 50% density
bonus allows up to 1,071 housing units. That is
the number of housing units being proposed.

Height:

Urban Residential: Maximum height of 7 stories and
75 feet
High Density Residential: Maximum height of 5
stories and 60 feet
Neighborhood Commercial: Maximum of 3 floors or
36 feet.

Complies with density bonus waiver.
x Substantially renovated apartment
buildings are 2 or 3 stories tall and
therefore comply with Urban Residential
and High-Density Residential
designations.
x Townhouse units comply with R-HD-5
height limit and use a SDBL waiver for CN height.
x Buildings 1, 2, 3, and 4 use a SDBL waiver
for height.

4. PROJECT COMPLIANCE WITH ZONING

Please see the application plan set for a detailed analysis of each building’s compliance with the applicable zoning requirements.

5. STATE DENSITY BONUS LAW

Providing affordable units within the proposed project qualifies the project for a density bonus under SDBL.

Density bonus projects are eligible for a number of benefits, including: increased density (a higher number of dwelling units per acre); a fixed number of incentives or concessions from development standards; an unlimited number of waivers of development standards that would physically preclude the construction of 343
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Applicant Statement – April 2026
6 a development at the densities or with the concessions/incentives; and certain other limits on the local agency’s discretion.

The proposed project includes 24% of the net-new base units for rent to lower income (80% AMI) households. 24% of 506 net-new units is 122 affordable units. With 24% of the net new base units for lower income households, the proposed project qualifies for a 50% density bonus. This increases the permissible density as shown in Table 3 below.

Moreover, the SDBL provides that the bonus may be used in geographic areas of the proposed project other than the areas where the units for lower income households are located. Hence the bonus units can be used throughout the proposed project.

Table 3: Density Bonus Calculations

Total Area
(acres)
Max Density
(du/acre)
Max # of Base Units
(acres x density)
Bonus Units
(50% x Max # of
Units)
R-UHD Zone 2.02 86 174 87
R-HD-5 Zone 12.36 43 532 266
C-N Zone 0.35 22 8 4
TOTAL (1,071) 714 357

By providing affordable housing, the proposed project is entitled to use an unlimited number of waivers of development standards that physically preclude the construction of the proposed project. The waivers are set forth in Table 4, below.

Table 4: Waivers to Accommodate Density Bonus
Standard Required Proposed
Parcel Depth 240’ in R-HD-5 190’ (Building 4)
Minimum site
coverage
70% 46% (Townhouses)
FAR 2.0 in C-N zone 0.88 (Townhouses in C-N)
Height limit 3 stories or 36’, whichever is higher
5 Stories or 50’in R-HD-5
3 stories and 38’ (Townhouses in CN)
7 stories; 81’ to top of parapet
(Building 1)
6 stories; 71’ to top of parapet
(Building 2)
7 stories; 81’ to top of parapet
(Building 3)
6 stories; 69’ to top of parapet
(Building 4)
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7 Standard Required Proposed
Front Setbacks 15’ in R-HD-5 12’ (Townhouses)
7’ (Building 1)
Varies—8” inches to 18’ (Building 2)
Varies—5’ to 17’ (Building 3)
Varies—0’ to 7’ (Building 4)
Side Street Setbacks 15’ in R-HD-5 Varies—8’ to 9’ (Townhouses) Varies—4’ to 11’ (Building 2)
Side Setbacks 10’ abutting residential in C-N
10’ in R-HD-5
Varies 5’ to 15’ (Building 3)
Varies—6’ to 7’ (Building 4)
Rear Setbacks 20’ in R-HD-5 12’ (Townhouses)
5’ (Building 1)
Varies 9’ to 12’ (Building 2)
8’ (Building 3)
5’ ‘(Building 4)
Common Open
Space
100 sq. ft. per unit 9,325 for 111 units (Building 4)
Private Open Space
(ground floor)
50-100 sq. ft. per unit None (Building 1)
Private Open Space
(upper floor units)
50 sq. ft. per unit 1,745 sq. ft. for 113 units (Building 1)
10,530 sq. ft. for 261 units (Building
2)
8,910 sq. ft. for 243 units (Building
3)
4,950 sq. ft. for 111 units (Building
4)
Parking Lot Design
Standards
24 ft. drive aisle 20 ft. drive aisle (Townhouses)
The Proposed Project’s 24% of base units at 80% AMI also entitles it to three concessions/incentives for development standards that impede the project’s ability to utilize the density bonus or increase feasibility, as shown in Table 5, below.

Table 5: Concession/Incentive to Accommodate Density Bonus

Standard Required Proposed
Ground floor uses No residential ground floor uses in C-N zone
3-story townhouses, including in
the C-N zone.

At the request of a developer, the SDBL governs the maximum number of parking spaces a local agency can require of density bonus projects. At most, the local agency can require 1 space per studio and 1-bedroom unit and 1.5 spaces per unit with 2 or more bedrooms. This is “inclusive of parking for persons with a 345
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Applicant Statement – April 2026
8 disability and guests.” Developer hereby requests that the SDBL parking requirements apply. All of the buildings comply with the SDBL parking requirements.

The Applicant reserves the right to amend the density bonus proposal, including the use of concessions/incentives and waivers, as may be appropriate during the application process.

6. INCLUSIONARY HOUSING PLAN

The City’s Development Code requires that residential developments include contributions to affordable housing supply. Residential developments proposing five or more dwelling units must provide 20% of the net new dwelling units as inclusionary units. See Municipal Code section 18.37.050(A). In for-rent projects, one quarter of these must have a rent affordable to households at 35% of AMI, half must have a rent affordable to very-low income households, and one quarter must have a rent affordable to low-income households. The City defines “low-income” as 60% AMI and “very-low income” as 50% AMI. In for-sale projects, half of these must have a sales price affordable to median-income households and half must have a sales price affordable to moderate-income households.

Applicant proposes that 24% of the net new dwelling units of the proposed project be rented at the “lower income” level. As shown in Table 2 above, there are 506 net new dwelling units. 24% of 506 net new units is 122 affordable rental units.

As part of this alternative compliance plan, the affordable units need not be dispersed, need not have the same proportion of unit types as the market rate units, and need not have comparable square footage or bedroom count as the market rate units. This Preferred Inclusionary Housing Plan makes the provision of affordable housing cost-effective, with actual and identifiable cost-savings that make the project feasible.

The approval body would be able to make the required findings for this Preferred Inclusionary Housing Plan. It will provide as many or more inclusionary units at the same or lower income levels as would strict compliance with the Inclusionary Housing Ordinance. This is because it is infeasible to include 20% of the units as affordable units at the affordability levels set forth in the local Inclusionary Housing Ordinance. The expense of a high inclusionary requirement makes it impossible to construct a project that includes so many affordable units, especially at deep affordability levels. If a 20% requirement at deep affordability is imposed, the project will not be built so there will be zero affordable units. Similarly, if a 25% requirement were imposed at deep affordability, the project would be even less feasible and no affordable units would be built.
122 affordable homes is more than zero affordable units, so the Preferred Inclusionary Housing Plan would provide more inclusionary units.
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9 Other inclusionary requirements. The City imposes a number of additional requirements on inclusionary units as follows:

Table 6: Inclusionary Requirements
Inclusionary requirement Compliance
Single-family detached affordable units shall be
dispersed throughout the housing development.

Townhouses, row-houses, and multiple-family
affordable units shall be located so as not to create
a geographic concentration of affordable units
within the housing development.

Complies because requirement modified by
alternative compliance plan.

Complies.

Complies
The affordable units shall have the same amenities
as the market rate units, including the same access
to and enjoyment of common open space and
facilities in the housing development.

Complies because requirement modified by
alternative compliance plan.

The affordable units shall have a comparable square
footage and the same or greater bedroom count
and bedroom count ratio as the market rate units.

Complies because requirement modified by
alternative compliance plan.

All required affordable units shall be made available
for occupancy concurrently with the market rate
units.

Complies

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10 7. FAIR HOUSING AND MARKETING PLAN

Project Information:

Address: See Exhibit A | APN: See Exhibit B | Census Tract: 612101

Applicant Information: Woodland Park Property Owner, LLC or successor entity

Entity Responsible for Marketing: Woodland Park Property Owner, LLC, successor entity, or third-party administrator

Target Date of Initial Occupancy: TBD

Estimated Advertising Start Date: TBD

Acknowledgment of Local Preference: The Applicant acknowledges the City of East Palo Alto Local Preference Policy and intends to comply with it.

Acknowledgment of Need to Partner with Housing Department and City Third-Party Administrator:

8. CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) COMPLIANCE

The proposed project is eligible for statutory exemption from CEQA under AB 130. Applicant requests that the project be processed under AB 130. To qualify for this exemption, the project must meet the following criteria:

Table 7: AB 130 Statutory Exemption
Public Resources Code 21080.66
Requirements
Compliance

1. The Project site is not
more than 20 acres.

The proposed project is located on 14.7 acres, plus a de minimis quantity of additional streetscape where new public realm improvements are planned to improve the neighborhood
cohesion.

2. The proposed
development occurs within the
The proposed project is within the City of East Palo Alto, which is an incorporated municipality.
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11 Public Resources Code 21080.66
Requirements
Compliance
boundaries of an incorporated
municipality.

3. The project site meets
any of the following criteria:

A. Previously developed
with an urban use.

B. At least 75% of perimeter
adjoins parcels that are
developed with urban uses
C. At least 75% of the area
within ¼ mile radius is developed
with urban uses
D. At least 3 of 4 sides are
developed with urban uses and
2/3 of perimeter of site adjoins
parcels that are developed with
urban uses.
x Previous development. The project site has been
developed with urban uses, including existing apartments and retail uses.
x Surroundings. The site is surrounded by urban uses
including commercial offices, Highway 101, and existing residential uses. The area within ¼ mile radius of the site is also developed with urban uses and the entire perimeter is developed with urban uses.

As described above, the proposed project is consistent with the General Plan and zoning ordinance, together with a density bonus, concessions, and waivers.

5. In San Mateo County, the
project density must be at least
15 dwelling units per acre.

The proposed project contains 1,071 units on 14.7 acres, for an average density of 72.8 dwelling units per acre. This meets the minimum density.

6. The project satisfies the
requirements in Government
Code 65913.4:
x Not located in a coastal
zone
x Not on prime farmland
x Does not include
wetlands
x Not in a very high fire
severity zone
x Not on the Cortese List
x Not in an earthquake
fault zone
x Coastal zone. The proposed project site is not in the coastal zone.
x Farmland. The proposed project site is not on prime
farmland.
x Wetlands. The proposed project site does not include any wetlands.
x Fire zone. The proposed project site is not in a very high fire severity zone.
x Cortese List. The proposed project site is not on the Cortese List.
x Earthquake fault zone. The proposed project site is not in a delineated earthquake fault zone.
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12 Public Resources Code 21080.66
Requirements
Compliance
x Not in a special flood
hazard area
x Not in a regulatory
floodway
x Not on lands identified
for conservation
x Does not include habitat
for protected species
x Does not include lands
under conservation
easement
x SFHA. The proposed project site is not in a special flood hazard area.
x Regulatory floodway. The proposed project site is not in a regulatory floodway.
x Conservation land. The proposed project site is not on lands identified for conservation.
x Habitat. The proposed project site does not include
habitat for protected species.
x Conservation easement. The proposed project site does not include lands under conservation easement.

7. The project does not
require demolition of a historic
structure on a historic register.

There are no registered historic structures within the project site.

8. The project is not
designated for transient lodging.

The proposed project does not include a hotel, motel, bed and breakfast inn, or other transient lodging.

9. RELEVANT STATUTORY FRAMEWORK

The California State Legislature has adopted a number of relevant updates to the legislative framework governing the City’s review and approval of the proposed project. We respectfully highlight the following legislation governing this application:

SB 330. The Proposed Project is a “housing development project” subject to SB 330 and protected by the HAA because more than two-thirds of the Project’s square footage is devoted to residential uses. Gov’t Code §65905(b)(3); Gov’t Code §65589.5(h)(2). The Applicant submitted a preliminary application pursuant to SB 330 on October 30, 2025. By submitting that preliminary application with all of the information specified in SB 330 and a permit processing fee, the Applicant obtained a vested right to develop a housing development project in accordance with the applicable ordinances, policies, and standards in effect as of that date, when the preliminary application was submitted. Gov’t Code §65589.5(o)(1).

SB 330 prohibits a local agency from disapproving, or conditioning approval in a manner that renders infeasible, a housing development project that provides affordable housing. Because the proposed project provides affordable housing, it would not be lawful for the City to disapprove the project or condition it in a manner that makes it infeasible.

The Act also requires the City to consider and either approve or disapprove the housing development project within 5 allowable public hearings, and consistent with the applicable timelines under the Permit Streamlining Act (“PSA”). Gov’t Code §65905.5. The City has already held a public hearing on the proposed project: a Planning Commission hearing on April 16, 2026. A second public hearing, at City Council, is scheduled for later this spring.
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O’Keefe-Manhattan Improvements
Applicant Statement – April 2026
13 Permit Streamlining Act. The Project is required to go through a completeness review under the PSA and the PSA imposes several relevant obligations on the City as it conducts its completeness review of the project’s application. First, the City is required to compile lists that include the information required for a complete submittal. Gov’t Code § 65940. Second, Gov Code § 65943(a) spells out a jurisdiction’s obligations after submittal: Not later than 30 calendar days after any public agency has received an application for a development project, the agency shall determine in writing whether the application is complete and shall immediately transmit the determination to the applicant...

10. REQUIRED FINDINGS
This section outlines the proposed project’s compliance with the required findings for approval of 1.) Design Review, 2.) a Vesting Tentative Map, and 3.) Alternative Compliance under the Inclusionary Housing Ordinance.

1.) Design Review under Municipal Code § 18.86.050 to allow new multi-family construction Required Findings. The Review Authority may approve a Site Plan and Design Review application only after first making all of the following findings:

2. The proposed development is to be constructed on a suitable site, adequate in shape, size, topography, and other circumstances to accommodate the proposed development;

3. The proposed development complies with the applicable standards of review; and

4. 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.
351
O’Keefe-Manhattan Improvements
Applicant Statement – April 2026
14 Suggested Findings: The proposed project is consistent with the General Plan, all applicable provisions of the Development Code, and all other applicable City ordinances and regulations. Multi-family residential is a permitted use throughout the site. The proposed density is in alignment with the General Plan and zoning, in addition to the SDBL. The proposed project plan meets the SDBL requirements for parking spaces and also meets the City’s bicycle parking standard. There are adequate pedestrian access points along the frontages throughout the project. The project proposes affordable housing in compliance with the Inclusionary Housing Ordinance and relies on waivers and a single concession under SDBL to ensure full compliance with local standards.

The project will receive all required entitlements before proceeding and substantial record evidence supports all findings, so the proposed project complies with the applicable standards of review.

The proposed project ensures public health, safety and general welfare. The proposed project complies with the applicable General Plan, and other development code requirements, all of which together ensure that there will be no adverse effects on neighboring property. The proposed project includes appropriate circulation and landscaping, as well as appropriate screening for loading, parking and mechanical equipment.

2. Tentative Map Findings Municipal Code 18.52.060 to allow approval of vesting tentative map Required Findings for Approval.

1. Mandatory Findings Required. The Review Authority shall approve a tentative parcel or tract map only after first making all of the findings as required by the Act. The findings shall apply to each proposed parcel as well as the entire subdivision, including any parcel specified as a designated remainder.
a. The proposed map, subdivision design, and improvements are consistent with the General Plan, any applicable specific plan, and this Article;
b. The site is physically suitable for the type and proposed density of development; c. 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; d. The design of the subdivision or type of improvements is not likely to cause serious public health or safety problems;
e. 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… f. 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; g. The design of the subdivision provides, to the extent feasible, passive or natural heating and cooling opportunities; and
h. 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…
352
O’Keefe-Manhattan Improvements
Applicant Statement – April 2026
15 Suggested findings: The Proposed Project, including the proposed map and subdivision design and improvements are consistent with the General Plan and the Subdivision Ordinance. The site of the Proposed Project is physically suitable for residential development. It is currently used for residential uses and would continue to be used for that type of development. The site is also suitable for the proposed density of development, which is in compliance with the existing land use designation and zoning, as the same is modified by the SDBL with a density bonus of 50%. The design of the subdivision and proposed improvements are not likely to cause substantial environmental damage or affect fish or wildlife or their habitat. The Proposed Project site is currently developed with residential uses in an urban environment and will continue to be developed with residential uses in an urban environment. The design of the subdivision and improvements are not likely to cause serious public health or safety problems because the design is in compliance with all applicable requirements, including the local and state building codes which protect public health and safety. The design of the subdivision and the type of improvements will not conflict with public easements because there are no public access easements through the site. The discharge of sewage from the proposed subdivision will not result in a violation of existing requirements because the development will be served by the sewer system in compliance with all applicable laws. The design of the subdivision provides, to the extent feasible, passive or natural heating and cooling opportunities in alignment with existing building code requirements and the orientation of the buildings.

3. CEQA Findings. The Review Authority must make the required California Environmental Quality Act (CEQA) findings of fact for each project subject to the Subdivision Map Act.

Suggested Findings: The proposed project, including the subdivision design and improvements are consistent with the General Plan and the City’s Municipal Code. The site is physically suitable for multifamily residential development at the proposed densities, which comply with the City’s standards. The proposed project includes compliance setbacks, circulation, landscaping, and appropriate screening for loading, parking, and mechanical equipment. The design of the subdivision is not likely to cause environmental damage because it qualifies for the AB 130 statutory exemption. The subdivision is not likely to cause serious public health or safety concerns as the proposed project has been designed to avoid public health and safety problems and to comply with all applicable codes. The site is adequately served by public and emergency services. The design does not conflict with easements acquired by the public at large for access through or use of property within the proposed subdivision. The proposed project has been designed to accommodate existing easements and provide for safe, appropriate vehicular and pedestrian access. There will be no discharge of sewage in violation of existing requirements because the proposed project will be connected to the existing sewer system and all discharged sewage will be treated by the East Palo Alto Sanitary District in compliance with law. The proposed project is planned to provide, to the extent feasible, passive or natural heating and cooling opportunities. It is being designed to integrate sustainable design features to maximize energy efficiency, reduce waste streams, conserve water, and minimize greenhouse gas emissions. The proposed subdivision and its design, density, and type of development and improvements conform to the requirements in the Development Code an all other applicable regulations.

The project is subject to the AB 130 statutory exemption on a site less than 20 acres. 353
O’Keefe-Manhattan Improvements
Applicant Statement – April 2026
16 3. Inclusionary Housing Under Municipal Code 18.37.080 to allow alternative compliance D. Other alternative compliance methods. A developer may propose an alternative compliance method to provide inclusionary units through other means consistent with any adopted inclusionary housing guidelines.

Suggested Findings: The Preferred Inclusionary Housing Plan will provide as many or more inclusionary units at the same or lower income levels as would strict compliance with the Inclusionary Housing Ordinance. This is because it is infeasible to include 20% of the net new units at the deep levels of affordability required by the Inclusionary Housing Ordinance. The expense of a high inclusionary requirement makes it impossible to construct a project that includes so many affordable units, especially at deep affordability levels. If a conventional requirement is imposed, the project will not be built so there will be zero affordable units. 122 affordable units is more than zero affordable units, so the Preferred Inclusionary Housing Plan would provide more inclusionary units.

11. COMMUNITY OUTREACH

We expect to have a similar study session with City Council next month.

From the foundation of the Westside Area Plan, we had many meetings throughout the community. We had some in our pop-up parks, some at the local school, some inside our building courtyards and some at City Hall or at the YMCA.

354
O’Keefe-Manhattan Improvements
Applicant Statement – April 2026
17 In February and March 2026, we held community meetings in the project area, walking distance from affected residents. We mailed notices within a 600-foot radius. We presented the specifics of the proposal and got overall positive feedback. Many of the participants also attended our 2025 community meetings and were happy to see that we listened to their input.

12. PROJECT TEAM

Applicant / Developer:

Woodland Park Property Owner, LLC
c/o Sand Hill Property Company
2600 El Camino Real, Suite 410, Palo Alto, CA 94306
2020 Dumbarton Ave., East Palo Alto, CA 94303
Contact: Michael Kramer | [email protected] | 650-772-4319 Architects:

David Baker Architects
461 2nd St., Loft C-127
San Francisco, CA 94107
Contact: Daniel Simons | [email protected] | 415-896-6700 Dahlin Group
5865 Owens Drive, Pleasanton, CA 94588
Contact: Justin Doull | [email protected] | 925-251-7200 Landscape Architect:

GLS Landscape Architecture
2677 Mission St #200
San Francisco CA 94110
Contact: Gary Strang | [email protected] | 415.285.3614
Civil Engineer:

BKF
150 California Street; Suite 600
San Francisco CA 94111
Contact: Jacob Nguyen | [email protected] | 415.930.7900
Planning Consultant:

Rhoades Planning Group
2140 Shattuck Avenue, Suite 705
Berkeley CA 94704
Contact: Mark Rhoades, AICP | [email protected] | 510-545-4341 355

East Palo Alto City CouncilOctober 20, 2026

East Palo Alto City Council
October 20, 2026