From: James Lloyd
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki
Cc: Clerk, City; City Attorney; City Mgr; PlannerOnDuty; Kallas, Emily Subject: Public comment re item 9 for 3/17/25 Council meeting Date: Friday, March 14, 2025 2:17:28 PM
Attachments: Palo Alto - 4335-4345 El Camino Real - HAA Letter - CC.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Dear Palo Alto City Council,
The California Housing Defense Fund (“CalHDF”) submits the attached public comment regarding item 9 for the 3/17/25 Council meeting, the proposed 29-unit housing development project at 4335- 4345 El Camino Real, which includes four units affordable to moderate-income households.
Sincerely,
James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
[email protected]
CalHDF is grant & donation funded
Donate today - https://calhdf.org/donate/
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Mar 14, 2025 City of Palo Alto
250
Hamilton
Avenue
Palo Alto, CA 94301 Re: Proposed Housing Development Project at 4335-4345 El Camino Real By email: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Dear Palo Alto City Council, The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation
to
abide
by
the
Housing
Accountability
Act
(“HAA”)
and
California
Environmental
Quality
Act
(“CEQA”)
Guidelines
when
evaluating
the
proposed
29-unit
housing
development
project
at
4335-4345
El
Camino
Real,
which
includes
four
units
affordable
to
moderate-income
households.
The HAA provides the project legal protections. It requires approval of zoning and general plan
compliant
housing
development
projects
unless
findings
can
be
made
regarding
specific,
objective,
written
health
and
safety
hazards.
(Gov.
Code,
§
65589.5,
subd.
(j).)
The
HAA
also
bars
cities
from
imposing
conditions
on
the
approval
of
such
projects
that
would
reduce
the
project’s
density
unless,
again,
such
written
findings
are
made.
(
Ibid.
)
As
a
development
with
at
least
two-thirds
of
its
area
devoted
to
residential
uses,
the
project
falls
within
the
HAA’s
ambit,
and
it
complies
with
local
zoning
code
and
the
City’s
general
plan.
The
HAA’s
protections
therefore
apply,
and
the
City
must
not
reject
the
project,
except
based
on
health
and
safety
standards,
as
outlined
above.
Furthermore, the project is exempt from state environmental review under the Class 32 CEQA
categorical
exemption
(In-Fill
Development
Projects)
pursuant
to
section
15332
of
the
CEQA
Guidelines,
as
the
project
is
consistent
with
the
applicable
general
plan
designation
360 Grand Ave #323, Oakland 94610 www.calhdf.org
and all applicable general plan policies as well as the applicable zoning designation and regulations;
the
proposed
development
occurs
within
city
limits
on
a
project
site
of
no
more
than
five
acres
substantially
surrounded
by
urban
uses;
the
project
site
has
no
value
as
habitat
for
endangered,
rare,
or
threatened
species;
approval
of
the
project
would
not
result
in
any
significant
effects
relating
to
traffic,
noise,
air
quality,
or
water
quality;
and
the
site
can
be
adequately
served
by
all
required
utilities
and
public
services.
And
recent
caselaw
from
the
California
Court
of
Appeal
affirms
that
local
governments
err,
and
may
be
sued,
when
they
improperly
refuse
to
grant
a
project
a
CEQA
exemption
or
streamlined
CEQA
review
to
which
it
is
entitled.
(
Hilltop
Group,
Inc.
v.
County
of
San
Dieg
o
(2024)
99 Cal.App.5th
890,
911.)
As you are well aware, California remains in the throes of a statewide crisis-level housing shortage.
New
housing
such
as
this
is
a
public
benefit:
it
will
mitigate
our
housing
crisis
by
providing
affordable
housing;
it
will
bring
new
customers
to
local
businesses;
and
it
will
reduce
displacement
of
existing
residents
by
reducing
competition
for
existing
housing.
While
no
one
project
will
solve
the
statewide
housing
crisis,
the
proposed
development
is
a
step
in
the
right
direction.
CalHDF
urges
the
City
to
approve
it,
consistent
with
its
obligations
under
state
law.
CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased
access
to
housing
for
Californians
at
all
income
levels,
including
low-income
households. You may learn more about CalHDF at www.calhdf.org. Sincerely, Dylan Casey CalHDF Executive Director James M. Lloyd CalHDF Director of Planning and Investigations 2 of 2