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CITY COUNCIL
STAFF REPORT
From: City Manager
Report Type: Action
Lead Department: Administrative Services
Meeting Date: December 11, 2023
Report # 2309-2043
TITLE
Direction to Pursue Development of New Parking and Refined Proposals for Housing in the University Avenue Downtown and Development Goals for Housing Investment. CEQA Status – Not a Project.
RECOMMENDATION
Staff recommends that the City Council direct staff to:
1. Resume work on a new parking structure in the downtown core on a City surface parking lot (previously designed for on Hamilton / Waverley Lot D at 375 Hamilton Avenue) and
2. Pursue refined proposals for potential housing development on City surface parking lot on Lytton / Kipling Lot T at 450 Lytton Avenue with direction on key development goals such as,
a. 100% affordable housing or alternative such as workforce housing b. Height allowance and/or density
c. Parking availability on site for housing.
EXECUTIVE SUMMARY
At the direction of the City Council, staff issued a request for information for the development of affordable or workforce housing and new parking in the University Downtown Core and received two submittals from affordable housing developers. Proposals outlined concepts for housing on the City’s downtown surface parking lots. Staff seeks Council direction on next steps to further pursue both new parking and housing development in the University Avenue downtown core based on these responses including 1) direction to resume pursuit of new parking facility (previously designed for Lot D at Hamilton and Waverly) and 2) to seek further information and refinement on a housing development with guidance on development goals with a recommendation to pursue this further work first on Lot T at Lytton and Kipling. The resumption of pursuit of new parking facility is in alignment with the Council objective ”f” under the Council 2023 priority, Economic Recovery and Business Transition, evaluate
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opportunities for new parking facilities in the University Avenue downtown and direct next steps.
BACKGROUND
Downtown Surface Parking Lots
The City of Palo Alto owns the 12 surface parking lots listed below in its downtown. Condition of Title Guarantees prepared by Old Republic Title for each of these lots show that title to their fee interest are vested in the City of Palo Alto and there are no restrictions or outstanding debt recorded on title.
Lots Address Approximate Lot
Area (Sq. Ft.)
Number of
Stalls
Emerson/Lytton Lot (A) 431 Emerson Street 20,265 68
Ramona/Lytton Lot (C) 264 Lytton Avenue 17,000 52
Hamilton/Waverley Lot (D) 375 Hamilton Avenue 27,969 84 Gilman/Bryant Lot (E) 642 Gilman Street 11,251 35
Florence/Lytton Lot (F) 415 Florence Street 17,174 47
Gilman/Waverley Lot (G) 643 Gilman Street 16,873 53
Cowper/Hamilton Lot (H) 530 Cowper Street 30,409 93
Lytton/Waverley Lot (K) N/A 21,180 47
Emerson/Ramona Lot (N) 539 Emerson Street 14,997 48
Emerson/High Lot (O) 460 Emerson Street 22,500 78
High/Hamilton Lot (P) 551 High Street 15,980 51
Lytton/Kipling Lot (T) 450 Lytton Avenue 19,236 51
Lot D Parking Garage Project
In 2019, the City Council certified the Environmental Impact Record and approved planning entitlements for a Downtown Parking Garage project on Lot D.1 However the Council declined to approve a contract for final design and instead directed staff to suspend work on the Downtown Garage Project and return to the Policy and Services Committee with a broader parking management strategy and options to address downtown parking needs. The Downtown Parking Garage Project has been paused since that time and a placeholder remains in the City’s five-year Capital Improvement Program pending further action.
Parking Garage and Affordable Housing Request for Information (RFI) At the December 6, 2021 City Council meeting2, the Council voted 6 – 1 to direct staff to:
1 https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-Services/Engineering- Projects/Downtown-Parking-Garage-Project
2 See Item 10 (ID # 13633) starting on Packet Page 285 of the 12/6/2021 City Council Meeting Packet:
https://www.cityofpaloalto.org/files/assets/public/v/8/agendas-minutes-reports/agendas-minutes/city-council- agendas-minutes/2021/12-december/20211206/20211206pccsm-amended-linked.pdf
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A. Initiate a RFI to examine feasibility of partnering with a private entity (for-profit or non- profit) on development of new parking using Downtown In-Lieu Parking Fees, in conjunction with housing or other uses, including the use of City surface lots or privately held parcels; and
B. Council supports a preference for pursuing affordable housing as the preferred housing component, a preference for lot D as the preferred location, and limits the use of general funds to subsidize parking construction.
On December 28, 2022, the City released an RFI for Downtown New Parking & Housing or Other Uses3 with a due date of March 7, 2023. The City received responses from Alta Housing (Attachment A) and MidPen Housing (Attachment B). In May 2023, each firm presented and discussed their submittals to the City’s project team, consisting of staff from Administrative Services – Real Estate Division, Planning, Public Works, Transportation, and the Office of the City Attorney. Both submittals suggest that it may be feasible to partner with a developer to construct new parking and affordable housing on the City-owned downtown surface parking lots.
Housing Element Program 1.4 City-Owned Land Lots
Program 1.4 of the City’s Housing Element, as revised and adopted in November 2022 and May 2023, identifies City-owned lots in the University Avenue Downtown Area as potential sites for affordable housing development. The Implementing Objective A states that projects on City- owned surface parking lots shall provide 100% affordable housing, capped at 80% AMI, or for workforce housing for City and PAUSD employees.4
Alta Housing Submittal Summary
Alta Housing is a 501c3 nonprofit organization based in Palo Alto and was incorporated in California in 1970. They are focused exclusively on providing affordable housing and resident services in Santa Clara and San Mateo counties. Recent examples of 100% affordable housing projects completed by the firm include:
1. Luna Vista: 71 units (70 studios and 1 two-bedroom unit) with 32 automobile parking spaces situated on a 0.61-acre site in downtown Mountain View completed in November 2021
2. Fair Oaks Commons: 67 units (61 studios, 5 one-bedroom units, and 1 two-bedroom unit) with 50 automobile parking spaces developed on 0.59 acres in the North Fair Oaks neighborhood of Redwood City in November 2020
3. Wilton Court: 59 units (55 studios and 4 one-bedroom units) with 41 automobile parking spaces constructed on 0.46 acres in Palo Alto’s Ventura neighborhood in October 2022. 3 https://pbsystem.planetbids.com/portal/25569/bo/bo-detail/100949 4 See motion passed on Page 3: https://portal.laserfiche.com/Portal/DocView.aspx?id=49777&repo=r- 704298fc&searchid=e83d2953-d1bc-461f-a984-e67019e79ccf
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Alta Housing’s response identified Lots A, C, and T for 206 affordable housing units. The residential units could serve families between 30% and 60% AMI (area median income), seniors, and City or Palo Alto Unified School District employees (workforce housing). Various onsite amenities include community rooms and kitchens, laundry room, bike parking, and outdoor recreation areas. Residential site selection considered integrating Alta Housing’s Barker Hotel and proximity to the Avenidas Senior Center. The proposed projects would rise five stories over a one level podium with the roof line reaching 60 feet and the top of the parapet extending 70 feet. Residential buildings would range from approximately 56,050 to 76,397 square feet.
Alta Housing chose Lots D and O for new above grade parking structures that would increase parking supply by 130 spaces. The lots are near the proposed residential projects and would contain six levels above grade. All of the new parking was intentionally designated to be constructed offsite from the housing projects to maximize the number of residential units and reduce costs, although onsite parking is possible. Details on the approximate financial implications can be found below in the Resource Impact section.
MidPen Housing Submittal Summary
MidPen Housing is a nonprofit organization based in Foster City and was incorporated in California in 1970. The majority of their development communities are located in Santa Clara and San Mateo counties. Examples of 100% affordable housing projects completed by the firm include:
1. Kiku Crossing: 225 units (66 studios, 41 one-bedroom units, 57 two-bedroom units, 59 three-bedroom units, and two manager units) with 164 automobile parking spaces situated on 3.57 acres over two lots in downtown San Mateo that is in progress and projected to be completed in April 2024
2. Brooklyn Basin: four phases totaling 465 units (231 one-bedroom units, 93 two- bedroom units, and 141 three-bedroom units) with 504 automobile parking spaces developed on 4.04 acres in Oakland completed in December 2020 to April 2022 and Phase IV expected to be complete in February 2024
3. Station Center: two phases totaling 157 units (33 one-bedroom units, 74 two-bedroom units, and 50 three-bedroom units) with 157 automobile parking spaces constructed on
2.18 acres in Union City in April 2012.
MidPen’s goal in their original response was to work with the City to identify five to seven of the most developable sites to deliver 41 new affordable rental opportunities on each site and use the remaining lots to replace and expand public parking and provide 21 off-site parking spaces for each of the 41 unit housing developments. Lots A, D, E, G, N, P, and T were thought to have housing development potential, recognizing that the City had a garage plan proposed for Lot D, Lots E and P have some configuration challenges, and Lot G may displace a farmer’s market. A new above-grade parking structure was proposed to be developed first, followed by the housing developments. Additional above ground parking can be added later, if demand exceeds supply.
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The majority of the new homes would serve families with 30% to 80% AMI. An example of a project would be to resume the City’s previous proposal to replace the existing 84 parking spaces in Lot D with a new 324 stall parking structure and then develop Lots G, N, and T for affordable housing, resulting in a parking surplus of 25 stalls. MidPen’s proposed housing projects would stay under the City’s 50-foot height allowance at four stories tall. This is intended to mainly leverage the Low-Income Housing Tax Credit (LIHTC) program. Details on the approximate financial implications can be found below in the Resource Impact Section.
Later on, MidPen presented three additional different development approaches (Attachment C). The first approach starts off by building a new 239-stall garage on Lot D. This is followed by constructing 41 family units on Lot G and 51 senior units on Lot E. The City can then evaluate and reassess for the next phase. The second approach commences with building 41 family units each on Lots F and P. Garages S/L and R would be utilized to accommodate the new housing developments, respectively. A parking study would then be completed to assess demand, and if warranted, a 233-stall garage would be constructed on Lot A. The final approach presented by MidPen envisions 41 family units with 21 onsite parking stalls constructed on Lot T and 51 senior units with 21 onsite parking stalls developed on Lot C. A parking assessment would be completed after the housing is developed, and if needed, a 238-stall parking garage would be built on Lot A.
ANALYSIS
Both submittals reflect the City’s broad request to seek information from developers to understand development potential for the City-owned downtown surface parking lots. Staff seeks the City Council’s input on several variables including the amount of new parking desired, site selection, and desired development goals. This input will allow staff to request refined submittals based on project criteria with significantly more focus on both location of development and goals of the development.
New Parking Desired in University Avenue Downtown Core
Since the Council’s decision regarding the Lot D parking garage in 2019, several important developments have occurred and it remains unclear how much, if any, additional parking the Council desires to add to downtown. In light of these developments, staff is seeking updated direction with a specific recommendation that Council direct staff to resume work on a new downtown parking garage on Lot D [and/or any other lots the Council or staff identifies as appropriate].
First, both submittals include construction of off-site parking structures to replace the loss of public parking spaces on sites that are redeveloped into housing, as well as new spaces that would serve the residential development. Although recent changes in state law (AB 2097) preclude parking requirements for projects located within one half mile of a major transit stop, the developers proposed providing parking at a ratio of 0.5-0.75 spaces for each newly built housing unit for marketability purposes.
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Second, the COVID-19 pandemic has obscured the parking supply and demand scenario downtown. The table below is provided by the City’s Office of Transportation and shows the parking supply and demand as of October 5, 2023 for the City’s downtown surface and garage parking facilities.
In October 2019, the City's Office of Transportation conducted occupancy counts, and we have now compared those findings to our recent data from 2023. At noon in 2019, 92% of permit parking spaces in the Downtown Garages and Lots were occupied, while in 2023, only 45% were occupied. However, by 3 pm, both 2019 and 2023 showed similar occupancy rates for permit spaces. This is because these garages offer three hours of free parking, and after 5 pm, there is no parking enforcement, making these spaces free and accessible to all.
This data along with historic data show that demand for parking in the downtown has increased since the COVID-19 pandemic, although demand is still below pre-pandemic levels. Even though there is arguably adequate parking supply to serve the current demand and there are alternative solutions to relieve parking congestion, building additional parking spaces may be warranted to serve future development (commercial and residential) in downtown, particularly in light of AB 2097. The planned University Streetscape Project could also likely result in a decrease to the downtown street parking supply.
In addition to considering the construction of new parking facilities, it remains important to explore policy measures that can optimize the use of existing parking spaces. Implementing strategic parking policies can direct vehicles to the most appropriate parking locations based on their duration of stay. For instance, encouraging longer-term parking to occur in off-street garages could help in reserving valuable on-street parking for customers and visitors making shorter trips. This approach not only maximizes the efficiency of parking infrastructure but also aligns with broader urban mobility and sustainability goals. As we deliberate on the addition of new parking spaces, a parallel review of parking policies could be instrumental in ensuring a holistic and effective parking management strategy for downtown.
ID Name Supply Total Permit Daily Total Permit Daily Total Permit DailyA Emerson/Lytton Lot 68 68 2 34 68B Ramona/University Garage 128 37 53 35C Ramona/Lytton Lot 51 33 7 39 6 50CCCivic Center Garage 704 363 225 6 275 161 10 58 43 3D Hamilton/Waverley Lot 84 69 53 70E Gilman/Bryant Lot 35 19 19 17 17 13 13F Florence/Lytton Lot 47 21 24 21G Gilman/Waverley Lot 53 28 28 27 27 8 8H Cowper/Hamilton Lot 93 66 52 56K Lytton/Waverley Lot 97 18 12 12 11 9 7N Emerson/Ramona Lot 48 42 1 40 40O Emerson/High Lot 77 65 2 57 77P High/Hamilton Lot 52 46 35 49Q High/Alma North Garage 130 72 72 59 59 28 28R High/Alma South Garage 210 200 116 4 163 99 7 110 37SL Bryant/Lytton Garage 681 350 102 10 304 127 5 246 44 6T Lytton/Kipling Lot 52 16 9 21 9 18 4WCWebster/Cowper Garage 587 168 79 7 165 76 11 84 38 2 Noon 3PM 6PM
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Third, potential future changes to the University Avenue Streetscape provide an additional wrinkle to consider as that project will affect both the number and availability of on-street parking spaces.
Housing Development & New Parking Site Selection
Staff recommends narrowing the potential housing and parking structures to allow the developers to provide more focused project proposals. For the housing sites, both developers were interested in developing Lots A, C, and T. These sites are rectangular shaped corner lots, which allows for simpler, more efficient designs. The other downtown parking lots are more constrained due to size, shape, location (i.e. in the middle of a block), or a combination these factors. In recognition of the considerations that follow, staff recommends an initial housing development focus at Lot T at Lytton Avenue and Kipling Street.
Staff recommends requesting from one or both developers for their best development proposal for a housing development project on Lot T based on the City Council’s development preferences and project parameters. Lot T’s rectangular shape configuration, relatively large size, and corner location makes it an ideal development site for an affordable large family rental housing project. In addition, its relatively low usage, proximity to neighboring commercial and residential zones and distanced from the central “busy” blocks were also consideration in recommending a focus on this lot.
For the parking component, staff recommends resuming or modifying the Downtown Parking Garage Project at Lot D as part of the 2014 Council Infrastructure Plan. Staff would immediately conduct an updated review of the appropriateness of proceeding with Lot D versus alternative locations or designs. Final design needs to be completed to develop construction documents for bidding of the project. Lot A could be an alternative parking site due to its large rectangular configuration in a highly trafficked area and current high parking utilization and proximity to alternative transit opportunities.
Desired Development Goals
Both submittals provided project concepts that generally complied with criteria set forth in RFI.
Summary of RFI Responses
ALTA HOUSING MIDPEN HOUSING
Affordability 30% - 60% 30% - 80% AMI
Density 123 – 165 du/ac (family)
195 du/ac (senior)
93 – 112 du/ac (family)
131 – 197 du/ac (senior)
Average Unit Size 535 – 780 square feet 825 square feet Building Height Up to 70 feet Under 50 feet
Family Housing Unit Mix Studios: 5% - 7% (400 SF)
1 BR: 43% - 37% (550 SF)
2 BR/TH: 27% (825 – 1,100 SF)
3 BR: 25% - 29% (1,100 SF)
1 BR: 24%
2 BR: 25% minimum
3 BR: 25% minimum
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ALTA HOUSING MIDPEN HOUSING
Senior Housing Mix Studio: 12% (400 SF)
1 BR: 87% (550 SF)
2 BR: 1% (950 SF)
Primarily 1 BR
Since the RFI was issued, the City Council has significantly revised the City’s housing policies to encourage housing production through the Housing Element update and corresponding zoning code amendments. These revisions include substantial increases to building height limits (up to 85 feet) and floor area ratio (4.0:1) within the El Camino Real Focus Area.
Staff anticipates additional housing policy updates when the Council considers a Downtown Housing Plan and comprehensive economic development strategies in both Downtown and California Avenue areas. And while formal policy discussions on those items are several months away, staff is seeking the Council’s input on its initial development goals. Based on this input, staff will request more refined proposals for a housing development. Housing Affordability: The initial proposals considered a range of income restricted units, including family, senior housing and supportive housing but all generally at 80% of the area medium income level. Council direction on the desired affordability level has an impact on funding and who the units would serve. For instance, adding workforce housing (greater than 120% AMI but less than 150% AMI) is not expected to qualify for tax credits potentially requiring greater City subsidy. Supportive housing for individuals with special needs may require on-site supportive care facilities or programing. Clarity from Council on housing populations served by this project would enable the prospective developers to provide more focused proposals. Housing Unit Mix and Size: Smaller units yield a greater housing density and may be appropriate in a downtown setting. However, the City also needs family-sized units of three or four bedrooms. Units of this size will result in fewer units but serves a need in Palo Alto. Staff requests Council’s direction on how best to balance these objectives. Building Height and Floor Area: The base height limit downtown is 50 feet and the highest achievable FAR is 3.0 using the City’s Housing Incentive Program, this program however, is not eligible for additional state density bonus incentives. While more study is expected on appropriate housing development standards through the Downtown Housing Plan effort, staff seeks Council’s input on increased height and FAR allowances.
By way of reference, multi-family home builders tend to prefer seven or eight story buildings that extend 75 – 85 feet in height. This type of construction utilizes a two or three-story concrete podium structure with five stories of wood framed construction above. Adding height also adds costs especially for the podium construction so the respondents would need to consider associated cost implications. Staff is also sensitive to the concern that taller buildings in Palo Alto would result in privacy or shading impacts and may disrupt the suburban scale. Actual achievable FAR would depend on other building design features and components and may not be something that requires
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specific guidance at this time if there is general support to increase FAR beyond the current, housing incentive program 3.0 standard.
On-site Parking: The initial project concepts contemplate off-site parking for the new housing developments. However, on-site parking may be provided, albeit with at an increased cost and reduced density. In addition to new parking to be provided at a separate facility, understanding that recent state law allows developments within 0.5 miles of the transit center to be construct with any on-site parking, Council direction on whether to provide parking onsite for the housing development will better inform these refined proposals and assist in planning for the separate new parking discussed previously.
Other Considerations. Staff welcomes additional feedback or expectations on other design components, such as:
oGround Floor Retail. There is no retail currently located at Lot T and the property is not located in the ground floor protection overlay. Staff does not recommend requiring ground floor retail.
oOpen Space. The affordable housing incentive program identifies a minimum of 50 square feet per unit of useable open space that can be achieved through balconies, terraces, at ground level, and rooftop gardens. oTransitional Height. Portions of Lot T are located within 150 of residential uses that may otherwise limit maximum achievable heights unless the Council were willing to consider adjustments to applicable standards. oOther Code Provisions. Development proposals may require other modifications or adjustments to base district zoning, staff will evaluate and identify these when a refined concept plan is presented to Council for consideration.
FISCAL/RESOURCE IMPACT
Request for Information Alta Housing and Mid Pen Housing Proposed Project Financials Based on project proformas provided by Alta Housing and MidPen Housing, their estimated average total cost is approximately $900,000 to $1,100,000 per housing unit. Similar to other affordable housing public-private partnership arrangements, there is expected to be a variety of funding and contribution from state and local agencies, as well as tax credits and loans.
Financing is expected to significantly improve if the housing units are 60% AMI or lower.
Conversely, financing the development of workforce housing would be more difficult and require significantly more financial support. Based on the responses, the City is expected to contribute the sites to the developer at a nominal cost via a long-term ground lease, and approximately $100,000 per housing unit to be developed and pay for the majority of the parking portion of the project.
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New Parking Garage Financials
As noted in Staff Report # 92635, the estimated cost to construct the previously proposed 324- stall Lot D parking structure was approximately $30 million in March 2019. This includes four levels of above grade and one level of below grade parking, along with a 2,026 square foot retail unit. Using Engineering News-Record’s Construction Cost Index, the cost escalated to November 2023 would be roughly $36 million. Therefore, a rough order of magnitude cost estimate to develop a garage of similar size and footprint would be between $35 and $40 million. Construction costs of below grade parking are expected to be more expensive than above grade parking. Cost of constructing the parking component will likely be similar whether the City takes on the project or if it was built by a private firm, as prevailing wage is required and the permitting process will likely be the same, although private firms could potentially complete the project quicker as they usually have dedicated staff for these types of projects.
The City’s Fiscal Year 2024 parking in-lieu fee is $130,823.17 per parking space. This amount is based on the cost per incremental space added for the most recently constructed garage (California Avenue garage), and is calculated by dividing the total project cost by the total number of spaces minus the number of parking stalls that were previously on the surface lot.
The in-lieu fee is not an estimate of construction cost, however can be used as a rough order of magnitude to estimate the cost to construct parking, absent any site-specific design information. For example, considering that the Lot D parking structure was proposed to include 324 stalls and was to be built on a surface lot with 84 existing stalls, the parking in-lieu fee can be used to develop a rough estimate of $31.4 million.
The amount of in-lieu fees available for a new public parking garage is currently uncertain due to pending litigation, but approximately $12.5 million is projected to be available. In-lieu fees from new projects in downtown going forward are expected to be lower, as parking requirements become less stringent. Other funding sources will be required, in amounts that depend on the magnitude of the project selected. Funding from the State may also be available for an affordable housing project.
Recent Nearby Capital Projects
Staff has reviewed construction costs of other capital investments in neighboring jurisdictions for affordable housing projects and/or parking structure projects in the region for reference.
Housing Projects
Project Name Status Year
# of
Units
Total Development
Costs
Cost Per
Unit
Parkmoor Community
Apartments, San Jose
Preconstruction Dec-23 81 $77,880,350 $961,486
Dry Creek Crossing, San Jose Preconstruction Dec-23 64 $61,630,513 $962,977 777 W San Carlos, San Jose Under construction Jul-23 154 $138,030,091 $896,299 5 https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports- cmrs/year-archive/2019/9263.pdf
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Project Name Status Year
# of
Units
Total Development
Costs
Cost Per
Unit
1860 Alum Rock Multifamily,
San Jose
Under construction Jul-23 60 $58,879,963 $981,333
Tamien Station, San Jose Under construction Jul-23 135 $133,192,614 $986,612 The Charles (551 Keyes), San
Jose
Under construction Jul-23 99 $88,453,887 $893,474
797 Almaden, San Jose Preconstruction Jun-24 99 $110,380,539 $1,114,955 353 Main St., Redwood City Complete 2023 125 $87,500,000 $700,000 1304 El Camino Real, Redwood
City
Under construction 2022 38 $28,880,000 $760,000
3500 E. 12th Street, Oakland Complete 2023 181 $144,568,335 $798,720 Parking Projects
Project Name Status Year Type
Building
Area in
Sq. Ft.
# of
Parking
Stalls
Total Cost of
Parking
Cost per
Stall
400 Middlefield Road,
Redwood City CA
Complete Sep-21 Below
grade
345,100 1,022 $52,122,000 $51,000
2300 Airport Blvd, San
Jose, CA 95110
Complete Jun-21 Above
grade
341,600 1,156 $43,028,337 $37,222
Livermore Village
Parking Garage
Construction
Under
construction
2021 -
2023
Unlisted Unlisted 550 $38,781,564 $70,512
175 N I Street,
Livermore, CA 94551
Under
construction
2021 -
2023
Unlisted Unlisted 274 $13,500,000 $49,270
STAKEHOLDER ENGAGEMENT
The RFI that was issued gives the City the latitude to work with the firms directly and dictate the desired development standards. Staff is seeking policy direction from the City Council so that staff can address what the process might be and what process changes might be need in order to arrive at those policy outcomes. Staff will conduct additional stakeholder engagement as the projects progress.
ENVIRONMENTAL REVIEW
Council action on this item is not a project as defined by the California Environmental Quality Act (CEQA) in that staff is seeking general policy direction for a future project. CEQA Guidelines Section 15378(b)(2).
ATTACHMENTS
Attachment A: Alta Housing RFI Response
Attachment B: MidPen Housing RFI Response
Attachment C: MidPen Presentation
APPROVED BY:
Kiely Nose, Administrative Services Director