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Item 15 Staff Report

Palo Alto City Council
February 10, 2025

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Item 15 Staff Report
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February 10, 2025
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Palo Alto City Council
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: February 10, 2025
Report #:2412-3928
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 3265 El Camino Real [24PLN-00012]: Approval of an Ordinance Rezoning the Subject Parcel From Commercial Services (CS) to Planned Community Zoning (PC) and Adoption of a Record of Land Use Action to Construct a 100% Affordable, Five- Story, 55 Unit Residential Rental Project. Environmental Assessment: Initial Study/15183 Streamlined CEQA Review.

RECOMMENDATION
Staff Recommends the City Council take the following actions:

1. Consider the Initial Study Checklist/Streamlined Environmental Review prepared in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183;

2. Adopt the Ordinance in Attachment B amending the zone district from CS to PC; and

3. Approve the Record of Land Use Action in Attachment C.

EXECUTIVE SUMMARY
The applicant proposes to rezone the vacant parcel located at 3265 El Camino Real (Attachment A) from Commercial Services (CS) to Planned Community (PC), which is sometimes referred to as Planned Home Zoning (PHZ).1 The parcel would be developed with a 100% affordable, 55- unit residential rental project. Fourteen of the units are proposed to be dedicated at a rate affordable to low income, not to exceed 70% of area median income (AMI) levels. Forty-one of the units would be dedicated at a rate affordable to moderate income, not to exceed 110% of AMI. The applicant has also established a private agreement with the Palo Alto Educator Association (PAEA) to prioritize housing Palo Alto teachers when seeking tenants ; however, there is no guarantee that teachers will be the only occupants of the building.

Staff’s review of the revised project concludes that it is consistent with the findings for approval of a Planned Community rezoning. The ARB and PTC recommended approval of the project on November 21, 2024, and January 15, 2025, respectively. Accordingly, staff recommends that the Council adopt the PC/PHZ ordinance in Attachment B and approve the record of land use 1 Referred to in this report as "Planned Home Zoning" (PHZ) to emphasize the focus on housing as the benefit to the community. PAMC Section 18.38, which outlines the requirement and process for Planned Community (PC) Zoning, remains the underlying code supporting application of this policy.

action in Attachment C. The Program Statement and Development Schedule are included as Attachment H and the Development Plan is included as Attachment I.

The City prepared an analysis of the project in accordance with CEQA Guidelines Section 15183, which evaluated the project’s consistency with the Comprehensive Plan and the Comprehensive Plan Environmental Impact Report (EIR). The analysis concludes that the project is consistent with the previously adopted Comprehensive Plan and that the adopted EIR adequately addresses the impacts of the proposed project.

BACKGROUND
On February 3, 2020, Council unanimously endorsed using Planned Community (PC) Zoning for housing and mixed-use housing projects to help spur housing production and rebranded it Planned Home Zoning (PHZ). In exchange for deviation from certain standards as allowed under the rezoning, if approved by Council, the project must include at least 20% of the housing units as deed restricted for lower-income households. Moreover, the number of housing units must offset the number of net new commercial jobs that are generated by the project. The project’s consistency with this Council direction is discussed further in this analysis.

The applicant filed a prescreening application in 2023 to consider a zone change in accordance with Council’s direction regarding PHZ projects. Council held a prescreening hearing on September 11, 2023, to consider the proposed project.

Project Description
On January 10, 2024, Trachtenberg Architects filed an application on behalf of Half Dome Capitol to rezone the subject parcel from CS to PC/PHZ and to redevelop the site with 44 residential rental units. Twenty percent of the units were proposed to be restricted at a rate affordable to low income (not to exceed 80% AMI) and 80% of the units would be restricted at a rate affordable to moderate income (not to exceed 110% AMI).

After the April 10, PTC meeting, the applicant revised the submittal in response to commissioner requests for a deeper level of affordability and more units. The revised proposal is a six-story building with 55 units that is 70 feet tall to the top of the roof deck line, 79 feet tall to the elevator overrun. Twenty-five percent of the units are proposed to be restricted at a rate affordable to low income (rents based on 70% AMI) and 75% of the units are proposed to be restricted at a rate affordable to moderate income (rents based on 110% AMI). The project includes 33,089 square feet of gross floor area on a 7,493 square foot lot (floor area ratio of

4.42: 1.0). The project also includes a 1,700 square foot roof top deck and 32 total parking spaces provided in an at-grade parking garage utilizing a parking lift system. The building’s exterior materials will be stucco siding, metal infill panels to frame the windows, and a painted cementitious paneling at the elevator and stairs on the side of the building which faces the Kasa Hotel and at the rear. The applicant’s project description is included in Attachment H. The project plans are included in Attachment I.

Requested Entitlements, Findings and Purview:

The following discretionary application is being requested:
• Planned Community (PC/PHZ) Rezoning: The process for evaluating this type of application is set forth in PAMC 18.38.065. PC rezoning applications require review by the PTC and the Architectural Review Board, a final review of a development plan for review and recommendation by the PTC, and a decision by the Council. The findings under 18.38.060 must be made in the affirmative for project approval. The Architectural Review Board makes a recommendation on the development plan in accordance with the findings for architectural review in Section 18.76.020 pursuant to 18.38.065(b).

These findings are included in Attachment B. For housing projects rezoning to PC (labeled “Planned Home Zoning”) Council expressed an expectation that projects provide at least 20% of the units at below market rate.

Council Prescreening
City Council held a prescreening to evaluate the proposed rezoning of the property for a 100% affordable housing project at the subject property on September 11, 2023. At the prescreening, Councilmembers provided the following feedback (applicant responses provided):
•How long do the parking stackers take to cycle through? Will tenants be leaving all at once and create a circulation issue?
o10-60 seconds depending on vehicle location; Different zones can operate individually.
•How will parking be allocated? Will spaces be un-bundled with units? oUnbundled; anticipated rates are $150/space.
•What is the estimated rent and will it be affordable to teachers? oSee “Public Benefit” discussion below.
•Is the proposed driveway wide enough to allow vehicles to move in and out? oDriveway expanded from 14 feet to 20 feet
Unbundled parking is a tool that encourages alternative modes of transit to and from work by providing parking on-site as a cost, rather than for free. Coupling unbundled parking with providing a free transit pass to tenants are incentives in the proposed TDM plan to reduce vehicle trips to and from work. While the applicant has proposed unbundled parking at a rate of $150/unit for units that receive a parking stall, it is a deviation and request of the PHZ application from the City’s definition of “affordable rent” under PAMC 16.65.020(d) which requires that parking be included in a tenant’s rent. . However, if parking were included in each unit’s rent, this would require rents to be uniformly lowered to maintain the effectiveness of unbundled parking as a tool. The applicant has noted that this would also make the project financially infeasible.

Staff has concerns that applying a flat fee for unbundled parking will disproportionately impact low-income tenants. As a result, staff recommends adopting COA #14 which provides that the unbundled parking cost be capped at 4% and 5% of anticipated rent plus the utility allowance for the low-income and moderate-income units, respectively. This ratio would result in low- income units paying roughly $90.36 or $103.28 a month for parking, and moderate-income units paying roughly $177.40 or $202.80 a month for parking (see anticipated rents in Public Benefit section below). Either option would be a deviation from the City’s current code requirements, but Council could also require the applicant include the cost for parking in rent for these units.

Planning and Transportation Commission (PTC)
The PTC held the first formal hearing for this project on April 10, 2024, and the second hearing on January 15, 2025. Links to the PTC staff reports, meeting minutes, and video recordings are provided in the footnote below.2
At the initial hearing Commissioners provided feedback/requested information on expanding the rooftop open space, expanding the TDM plan provisions, the affordability level of the units, and analyzing site circulation. Following the PTC and ARB’s initial review, the applicant made substantive changes to the project design, which included increasing the unit count from 44 units to 55 units. The proposed floor area ratio (FAR) and height increased commensurate to the increase in units, resulting in a proposed FAR of 4.42 (previously 3.58 FAR) and height of 79 feet, 8 inches (previously 64 feet). The applicant has stated that this change allowed the project to be economically viable while addressing PTC and Council feedback to provide the units at a deeper level of affordability.

On January 15, 2025, the PTC recommend approval of the project on a 3-2 vote [Chang, Summa – against]. Both Chair Chang and Commissioner Summa raised concerns that the project was not an Affordable Housing project based on the anticipated rent levels shown in the staff report for the Moderate-Income deed-restricted units and should not benefit from provisions in Title 16 that waive development impact fees for 100% Affordable Housing projects. At the hearing, the PTC made the following motion:

Recommend approval of the project subject to the following additional conditions of approval:

1. Future residents shall be notified that if a future Residential Parking Permit (RPP) will be enacted, that they may be excluded from it.

2. The property manager shall provide an annual report to the City of the number of Palo Alto Unified School District employees that occupy the building and which unit types they are occupying.

There was a robust discussion between the commissioners about whether units that are deed- restricted at a Moderate-Income level are truly below market rate or are charging rents that are comparable to market rate units based on available data. The PTC recommended that Council 2 April 10, 2024, PTC Agenda Item #2, 3265 El Camino Real:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13632 November 21, 2024 ARB Agenda Item #3, 3265 El Camino Real:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=15699 could study this to inform decisions on future housing projects and the options within the PHZ process. Staff would recommend that this item be added to the PTC or Council Work Plan and prioritized to other work if the Council would like to investigate this further.

The PTC also wanted to understand the length of time that these units will be deed-restricted for and when that will be decided as it is not explicitly captured in draft Condition of Approval #14. During the discussion, staff noted that PAMC 16.65.075 requires that all affordable units be deed restricted to 99-years or a 55-year timeframe, when required by tax credit financing, and that those timeframes are typically negotiated by staff through the regulatory agreement after the project is approved. It is important to note that PAMC 16.65.075 applies to the City’s inclusionary housing requirements for ownership projects and that rental projects do not have an inclusionary housing requirement. Other 100% affordable housing projects have been deed restricted to a 55-year timeframe to maintain tax credit financing and staff recommends these units be similarly restricted given that the project is not receiving public subsidy. Draft Condition of Approval (COA) #14 has been updated to capture this recommendation.

Architectural Review Board
The ARB reviewed the project on April 18, 2024 and suggested improvements to the design related to the front and rear stucco facades, window placement towards Kasa Hotel, privacy screening between patios at level 2, expanding the rooftop deck, recessing the garage door, including an interior door to the garage from the lobby, and introducing a skylight over the bike area at the rear of the building. On November 1, 2024, the ARB reviewed the revised design and recommended approval of the project on a 4-1 vote [Baltay – against]. Board member Baltay was concerned that the design of the units and open space were substandard and inappropriate to expect residents to occupy given the physical limitations of the site and the density proposed. At the hearing, the ARB made the following motion:

Recommend approval of the project with the following additional conditions of approval:

1. Modify the façade at the stairwells to introduce natural light.

2. Modify the rear wall to introduce natural light into the bike storage room.

3. Include auditory/visual warnings at garage door when opening.

4. Consider a schedule for garage door operation (e.g. open certain hours)

5. Return to the ARB Ad-Hoc to evaluate the painted cementitious panel along the stairwells
a. Provide a detail showing how the articulation will be handled; consider using different colors/materials to create shadow and depth on the façade.
b. Provide detail which shows the vertical transition between boards

6. Remove the requirement to recess the garage door from COA #28; Require that the door must open in less than 10 seconds to ensure efficient access to the site from El Camino Real.

Except for COA #5a and 5b above, all other conditions were provided to be addressed at the building permit stage. Following Council approval of the project, staff will return to the ARB Ad- Hoc Committee to resolve COA #5a and 5b.

ANALYSIS
Comprehensive Plan, Area Plans, and Guidelines Compliance The Comprehensive Plan land use designation for the project site is Service Commercial, which allows for higher density multi-family near transit. The proposed project is located along El Camino Real, which is considered a high-quality transit corridor. Therefore, the proposed use is consistent with this land use designation. The project is also consistent with the policies set forth in the Comprehensive Plan, as detailed in Attachment C.

Housing Element
This site is included as a Housing Inventory Site in the adopted Housing Element, with an anticipated capacity of 44 units that may be provided at market rate. The project proposes 55 units, all of which would be below market rate, provided at a rate affordable to low income (70%) or moderate income (110%). Therefore, the project is consistent with the Housing Element and contributes to the City’s Regional Housing Needs Allocation (RHNA) goals, including goals to increase the number of units provided at below market rate levels.

North Ventura Coordinated Area Plan
The proposed development is located within the boundaries of the North Ventura Coordinated Area Plan (NVCAP). Therefore, the land use designation and the zoning of the site has changed since the application was first filed. However, as detailed in the ordinance implementing the NVCAP, projects that have been deemed complete prior to the effective date of the ordinance, would not be subject to the NVCAP goals and policies or the zoning regulations set forth in the ordinance. This project was deemed complete prior to adoption of the NVCAP and therefore continues to be analyzed in accordance with the regulations set forth under the existing zoning and land use designation. Nevertheless, the proposed land use designation under NVCAP is High-Density Mixed-Use. This land use designation is “intended to support five-to-six story mid- rise apartment buildings.” This designation requires active uses for ground floor frontages. As detailed in NVCAP, active uses include building lobbies. Therefore, the project is also consistent with the land use designation under the NVCAP.

El Camino/South El Camino Real Design Guidelines3
The project is subject to both the El Camino Real and the South El Camino Real Design Guidelines. As detailed in Attachment F, the project is consistent with these guidelines. 3 South El Camino Real Design Guidelines: chrome: www.cityofpaloalto.org/files/assets/public/v/1/planning-amp- development-services/file-migration/current-planning/forms-and-guidelines/south-el-camino-real-design- guidelines.pdf
Zoning Compliance
For a PHZ project, the zoning development standards are customized for the building/site.

Therefore, this project would deviate from the zoning development standards in a manner that is consistent with the zoning ordinance through to rezoning process. However, as detailed in the Zoning Comparison Table (Attachment D), there are several aspects of the project that exceed the underlying Service Commercial (CS) zoning district development standards, including:
•Floor Area Ratio: 4.42:1.0 where 0.6:1.0 FAR is permitted; •Lot Coverage Ratio: 0.87:1.0 where 0.5:1.0 is permitted; •Height: 79 feet, 8 inches where 50 feet is permitted;
•Parking: 32 4 parking stalls where 55 are required;
•Rear Yard Setback: 0-5 feet where 10 feet is required; •Minimum Landscape/Open Space per Unit: 31 square feet where 150 square feet is required;
•Rooftop Open Space: Rooftop garden provides 76% of open space for project where only 60% is permitted to be provided by rooftop garden; •Bike Parking: Four short-term bike parking spaces are provided off-site where six are required on-site;
•Vehicle Loading Space: No short-term vehicle loading space is provided on site where one is required for projects with 50 or more units.

Given that the project is 100% affordable, the Affordable Housing Incentive Program (AHIP) standards could also be applied to the site by-right to modify some development standards.

Therefore, Attachment D also includes a comparison of the proposed development standards and the AHIP development standards for informational purposes.

Multi-Modal Access & Parking
The property is located on El Camino Real near the cross street of Lambert Avenue and is accessed via a right-in, right-out-only driveway entrance. The applicant proposes 32 parking spaces, or 0.5 spaces per residential unit. 30 parking spaces would be provided in vehicle stackers that would be independently accessible and two ADA parking spaces would be provided. This is an increase in the provided parking ratio from the original proposal reviewed by Council, which included 22 parking spaces in vehicle stackers for the 44 units proposed at that time. Typically, one parking space per unit is required for studio and one-bedroom units, and a Transportation Demand Management (TDM) plan can be used for an up to 100% reduction in required spaces for a 100% affordable housing project where units are available to households with income levels at or below the 120% AMI thresholds. The applicant has proposed a TDM plan for the proposed project, which is provided in Attachment E. The Office of Transportation has reviewed and approved the proposed TDM plan which includes, among 4 PAMC 18.52.040(b)(8) provides that the accessible loading zone adjacent to an accessible parking stall contributes to the number of vehicle spaces provided on site. While 32 spaces are provided, only 31 can be used to park a vehicle.
other measures, a provision to provide free bus passes to all tenants via the Valley Transportation Authority (VTA) Smart Pass program.

There are north and south-bound VTA bus stops within the immediate vicinity of the site that connect the site to other regional transit options like Caltrain. Conditions of Approval #30 and #31 require monitoring of the parking lift system and TDM program to ensure they are effective. If any deficiencies are found within the annual monitoring reports, penalties or modifications to the programs can be enacted to ensure the lift system works and the TDM plan goals are achieved. Fifty-five long-term bike parking spaces are proposed on the ground floor in a shared storage room, four short-term bike parking stalls are provided along El Camino Real, and five on-site shared electric bikes are provided in the storage room.

Based on the nature of the puzzle lift system, vehicle stalls are shuffled around using the wall kiosk in the garage or a remote key fob until a stall is moved to the ground level for a vehicle to exit from or pull into the space. For the puzzle lift system to function properly, some stalls need to be left unused. In this case, two stalls will be left unused resulting in 30 of the 32 parking lift stalls being usable within the garage. The City’s traffic consultant Fehr & Peers analyzed the vehicle turning radii for the proposed parking lift stalls as detailed in the transportation analysis in Attachment I. Given that all stalls comply with the size requirements set forth in Chapter

18.54, in accordance with the conditions of approval that require proper management of the system, the proposed design is consistent with the City’s requirements.

Caltrans is currently developing El Camino Real along the project frontage to add a bicycle lane.

This eliminates the potential for a vehicle loading area as well as a trash loading area (e.g. for trash pickup) along El Camino Real in front of the property. Therefore, vehicle pick-up and drop- off as well as trash pickup for the project are anticipated to occur on Lambert Avenue. Bins will be brought out to Lambert Avenue and staged there by the property management prior to pick- up, then moved back to the trash enclosure following pick-up.

Public Benefit
As noted in the background section of this report, in February 2020 Council provided direction to staff to consider planned community rezoning applications for housing development projects that provide increased inclusionary below market rate units, rebranding these as Planned Home Zoning projects to emphasis the increased BMR units and/or affordability level of those units as the public benefit of the project.

As a part of Council’s direction, a menu of options was identified as possible ways to meet the increased affordability requirements. Using Option #2, the weighted system, as shown below, the project is proposing an equivalency of 75% affordable units, exceeding the 20% minimum requirement in accordance with Council’s direction, as noted in Table 1 below. Since no commercial component is proposed, this project would inherently create more housing than jobs.

Several Council members and commissioners raised concerns that these units would not be affordable to the target demographic the applicant has committed to serving and requested additional information from staff about affordability levels and teacher salaries. The California Department of Housing and Community Development (HCD) provides yearly data on the AMI limits for each income category, which varies based on the number of individuals in each household. The image below reflects the AMI for Santa Clara County for 2024:5 An image of the 2024-25 Palo Alto Unified School District (PAUSD) salary schedule is below:6 5 HCD Income Table: https://www.hcd.ca.gov/sites/default/files/docs/grants-and-funding/income-limits-2024.pdf 6 PAUSD Salary Schedule:
https://resources.finalsite.net/images/v1717104008/pausdorg/r4v8ge0e5ln1e3szj8zw/salary_schedule_teachers_ 202425.pdf

Based on the income limits, a low-income studio would be affordable to all individual salaries in the schedule and low-income 1-bedrooms would be affordable to over 90% of individual salary levels. Most of the salary steps in the PAUSD schedule, however, are too high for an individual to income-qualify to rent these low-income units.

Moderate-income studios would be affordable for 35% of individual salary levels, and moderate-income 1-bedrooms would be affordable to 4% of individual salary levels. These figures are likely too low, however, because the PAUSD salary schedule only represents one individual’s income, while many units may be occupied by households with more than one income. Even the most expensive unit in the project will be affordable to a household making

1.8 times the lowest individual salary in the PAUSD schedule, and many households may have a combined income too high to qualify for these restricted units.

Given the sizes of each unit within the proposed project, it’s likely that a two-person household would be the largest household size occupying these units. The City’s Below Market Rate (BMR) administrator would be responsible for income certifying individual(s) who apply to live in these units with the additional caveat that any teachers that apply to live in these units would be considered first over other potential tenants. There is no requirement in the draft ordinance that all or any of the future tenants in the building be teachers.

As noted earlier in the report, following the April PTC and ARB meetings, the developer modified their design to increase the number of units from 44 to 55. This was driven by feedback from the PTC which encouraged ways to deepen the levels of affordability for the project. By increasing the number of units in the project, the applicant has been able to commit to limiting rent for the low-income units at 70% AMI as well as limiting rents for moderate- income units at 110% AMI. Previously, the applicant noted that it was not financially feasible to limit the low-income rents at 70% AMI and had proposed limiting them to 80% AMI instead.

Anticipated 2024-25 rents for each unit type are shown below, as well as the household incomes at which these units would be affordable; anticipated rents are subject to change each year. The anticipated rents below reflect the cost of rent, plus an assumed utility allowance that Santa Clara County provides for units ($210/month for studios, $220/month for one- bedrooms). Rents for each unit type and income range would be $2,049/$2,362 for 70% AMI, or $3,338/$3,836 for 110% AMI. Notably, although rents are set using assumed household sizes of 1-person per studio and 2-persons per 1-bedroom, income qualification is based on actual household size. Thus, although rent plus utilities for a low-income studio may not exceed $2,259 per month, a two-person household may qualify for such studio with a household income of up to $118,000 per year (80% AMI for a two-person household).

Rent + Utility Allowance
Rent at
70% AMI
Affordable to
Annual Income
Rent at
110% AMI
Affordable to
Annual Income
Studio $2,259 $90,370 $3,548 $142,010
1-Bed $2,582 $103,250 $4,056 $162,250
Consistency with Application Findings
Staff has prepared a detailed review of the proposed project’s consistency with the Findings for approval. The draft Architectural Review findings for the proposed project and draft findings for the PC ordinance are provided in Attachment C. Staff finds that the proposed project, as conditioned, meets all of the applicable findings for Architectural Review and the required determinations for PC ordinances.

POLICY IMPLICATIONS
Approving the proposed affordable housing project would support the city’s housing goals, providing 55 units with priority for local educators while aligning with the Comprehensive Plan and making progress toward the City’s RHNA targets. Redevelopment activates an underutilized site and would increase property tax revenue. However, the PTC, despite its support for the project, has noted concerns over affordability thresholds and the loss of revenue from development impact fees, as noted above. This project is entitled to an exemption from impact fees because it fits the City’s definition of 100% affordable housing. Staff believe the rent restrictions for the moderate-income units are a meaningful benefit that are likely to be more impactful over time. In addition, this project represents an unusual model for rent-restricted housing production that does not rely on public funding or competitive tax credits.

Ultimately, the subject entitlement process as a legislative application conveys broad latitude to the City Council in terms of its discretion to approve or deny the project. Not approving the project could slow progress on housing production and may discourage future, similar, affordable housing proposals and influence ongoing work related to expanding the Housing Focus Area along a strategic location on El Camino Real. Moreover, with the recent upzoning of this site through the NVCAP, a substantially similar project could likely be achieved through use of the state density bonus law.

FISCAL/RESOURCE IMPACT
In accordance with the adopted fee schedule, applications for zone changes are processed as Cost Recovery applications; therefore, the City recovers the cost of staff time for processing the application. Additionally, because this is a 100% affordable housing development, no impact fees are required. The property is currently undeveloped; accordingly, the current site does not generate any revenue for the City. Therefore, there is no financial impact as a result of processing of this application except that property taxes would increase as a result of the development, once constructed.

STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post on January 31, 2025. Postcard mailing occurred on January 29, 2025.

Public Comments
As of the writing of this report, the City received one comment from the property owner for 3295 El Camino Real, which is provided in Attachment G. At a follow up meeting with staff and the applicant, the neighboring property owners asked for further clarity as to how their site would be protected during construction and afterwards for any regular maintenance needs, as well as understand whether any shoring or maintenance easements would be necessary between the two properties. The applicant noted that they designed the project to ensure that all shoring would be done within their own property boundaries and that no access or maintenance easements would be needed from the adjacent owners. Staff confirmed with the Chief Building Official that should any easements be necessary in the future; the City does not need to be party to those agreements and they can be established and recorded between the property owners at their own expense outside of the City’s review process. Additional public comments in support of the project are included in Attachment G.

ENVIRONMENTAL REVIEW
The City, acting as the lead agency, has analyzed the project in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA). Specifically, the City prepared an analysis of the project in accordance with CEQA Guidelines Section 15183, which evaluated the project’s consistency with the Comprehensive Plan and the Comprehensive Plan Environmental Impact Report (EIR). Section 15183 allows for streamlining of infill projects where the previously adopted EIR for a Comprehensive Plan adequately addresses the impacts of the proposed project. Plan level technical reports were prepared to confirm that the Comprehensive Plan EIR, including any mitigation that would be addressed as required through that EIR, would adequately address the impacts of the proposed project. This analysis and relevant attachments are included in Attachment I.

ATTACHMENTS
Attachment A: Location Map
Attachment B: Ordinance
Attachment C: Draft Record of Land Use
Attachment D: Zoning Comparison Table
Attachment E: TDM Plan
Attachment F: South El Camino Real Design Guidelines Comparison Attachment G: Public Comments
Attachment H: Program Statement and Schedule
Attachment I: Development Plan and Environmental Documents APPROVED BY:

Jonathan Lait, Planning and Development Services Director

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