Item 14 Public Comment — Palo Alto City Council, May 5, 2025

From: Neilson Buchanan
To: Shikada, Ed; Council, City; Clerk, City
Cc: Baird, Nathan; Lait, Jonathan; Dave Price; Gennady Sheyner Subject: Palo Alto Commons
Date: Monday, May 5, 2025 12:24:06 PM
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There is no doubt in my mind that Palo Alto Commons provides vital, very high quality services. And there is profound need for additiional facilities as our friends and neighbors steadily age duing the next 10-20 years.

Therefore, I urge you to approve the proposed expansion with strong, ENFORCEABLE conditions to monitor the intrusion of all non-resident parked vehicles in nearby residential neighborhoods. The intrusion of parking for non-resident is not limited to Palo Alto Commons. It is a multifactor issue requiring professional planning.

Who has the responsbility to fund and manage the intrusion into residential neighborhoods?
This is a open question becuase neither the Office of Transportation, Planning Department or Police Department has a record of basic stewardship and attention to the Comprehensive Plan which establishes intent to promote commerce but not at the expense of residential neighborhoods.

Only the City Council can set accountability for the Comprehensive Plan and budget resources appropriately.

Neilson Buchanan
155 Bryant Street
Palo Alto, CA 94301
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From: Amie Ashton
To: Council, City
Subject: The Commons
Date: Monday, May 5, 2025 12:11:18 PM
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Honorable Mayor Lauing & City Council,
I am writing in support of The Commons expansion, adding 16 beds for the most infirm of seniors in our community. Putting the beds in a central location allows family members to easily visit and caretakers to easily access. We need more facilities like this in Palo Alto given our rapidly aging population and the tremendous need for the kind of intensive care The Commons provides. Council gave it an initial OK several years ago and it has been slowly moving through the Palo Alto Process ever since.

Staff supports project approval. A daylight plane is included to maintain separation from the property line. The building is overparked for what is required by city code. As much as many of us wish it weren't true, a person or business does not own the street or the street parking spaces as their private property. That space is shared public right of way. How many of us have garages that are unusable for vehicle parking necessitating that we park our cars on the street? I would guess a fair share. Further, until state, federal or local resources are dedicated to the important task of caring for an aging population, we only have private companies to do the work. This is the reality of our political and social situation.

This project is another reason why we need better/updated zoning to facilitate projects we want. PD and PHZ zonings are complicated beasts that do not make for good faith in the public process, something we need to be building to create the city we want.

Our city will have to deal with a lot of changes in the upcoming years. Moving forward with clarity, compromise, compassion, and understanding is how we get the best outcome.

Thank you,
Amie Ashton
From: Nia Porter
To: Council, City; Kallas, Emily
Subject: Palo Alto Commons public comment for May 5 City Council meeting Date: Monday, May 5, 2025 10:00:13 AM
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Dear Mayor Lauing and other City Council Members,
Thank you for visiting my backyard at 4080 Wilkie Way. I have appreciated that you have come to see for yourself what it has been like for me to grow up with the huge Palo Alto Commons building behind me. As a young girl, I have felt that having so many strangers staring at me felt frankly, well, creepy. If they add 16 more units and 2 offices, including one that will be less than 11 feet from my back fence, then our loss of privacy would be that much worse. When I invite friends over to study or celebrate my birthday in the backyard, I have hesitated, because I was worried they would feel the same way.

In school our teachers give us rules that we need to follow for the greater good of the entire classroom or school. I have spoken at multiple City meetings during the development of this project. I have discovered that Palo Alto Commons has not followed the rules for daylight plane, setbacks, reports for prioritizing local residents, parking its construction vehicles and vans, etc. It has also not honestly explained that its staff tell workers and visitors to park in the neighborhood. In addition, I agree with all comments submitted already from Kevin Ji.

Since you are the City Council, you have the authority and responsibility to make Palo Alto Commons follow all the rules, as everyone should, for the benefit of the neighbors in the broader community.

My long-time neighbor and middle school teacher, Mrs. McDaniel, remembers when the company originally promised they would not expand further, and she supported the project to help seniors because of that promise. Now she has moved out because of the expansion plans.

We have talked with the company Wellquest about ways to reduce the impact. I recommended to put more units on the front or to increase the distance of new units from our back fence. Wellquest said that would cost more. I also recommended taller and more dense screening trees. I’m glad that Wellquest finally agreed to plant evergreen instead of deciduous trees behind the fences of neighbors who prefer evergreen. I would still prefer to see taller older trees be planted right away and a greater number of trees. Finally, I recommended that painting the back green, similar to the color of leaves, could allow the building to blend in better. Charlene from Wellquest said to us at a PTC meeting that would be fine. It should not cost Wellquest any extra. But the new plan still shows the back is blue. That seems like such a simple change, so I hope they will consider it.

Of course, I understand that seniors, such as my grandparents, need to have health care and other services when they are going through difficult times. Therefore, please vote for the Planning and Transportation Commission’s recommendation for Palo Alto Commons to add 9 interior living units, to remove the 7 units on the back of the building, and to move the offices farther from our back fence.

Thank you for reading my comments.

Sincerely,
Nia Porter
Resident of 4080 Wilkie Way since 2007
From: Mona He
To: Council, City
Cc: Kallas, Emily; Lait, Jonathan
Subject: Opposition to Palo Alto Commons Expansion and Objection to the Expansion be Exempt From CEQA Date: Monday, May 5, 2025 1:51:31 AM
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Dear Honorable City Council Members,
My name is Mona He, and I reside at 4040 Wilkie Way. I am writing to express my strong opposition to the proposed expansion of Palo Alto Commons. I respectfully urge the Council to vote against this project in its current form. The expansion, as proposed, is deeply flawed both in process and in substance, and it fails to respect the interests and well-being of the Wilkie Way community.

1. Disregard for Council Guidance and Community Impact
During the August 8, 2023 City Council meeting, Palo Alto Commons was explicitly asked to focus its expansion along El Camino Way to minimize the impact on Wilkie Way residents.

Despite this, the revised plan places most new units along Wilkie Way, citing cost savings.

Prioritizing financial convenience over community livability is unacceptable. Wilkie Way residents should not be forced to absorb the consequences of a corporation’s profit-driven decision-making.

2. Improper Claim of CEQA Exemption
The project’s claim of exemption from the California Environmental Quality Act (CEQA) is inappropriate. Our legal counsel outlined this in a detailed letter submitted to the Planning and Transportation Commission (PTC) on December 9, 2024, which remains applicable as no meaningful changes have been made to the plan. The environmental impacts of this expansion must be thoroughly and transparently reviewed. The letter is attached in this email

3. Dismissal of PTC Recommendations
At its final meeting on December 12, 2024, the PTC recommended that the 9 units along Wilkie Way be removed from the plan. This recommendation was ignored entirely. Such disregard demonstrates not only a lack of respect for the city’s planning process, but also a belief that community and commission input can be bypassed or overridden.

4. Long Standing Pattern of Neglect and Poor Neighborhood Relations Palo Alto Commons has been an inconsiderate neighbor for years. Parking overflow continues to spill onto Wilkie Way, with visitors and employees regularly parking at Wilkie Way. Noise disturbances persist, and the building’s bright blue exterior—despite neighborhood objections —remains visually intrusive. These issues have been raised consistently without meaningful response, eroding community trust.

5. Unmet Commitments Under Ordinance 3775
The proposed Transportation Demand Management (TDM) measures—such as carpooling and commuter incentives—are not new. They were required under Ordinance 3775, issued on October 26, 1987, and have never been implemented. If existing commitments have been ignored for nearly four decades, how can we trust that new promises will be fulfilled?

6. Ongoing Ordinance Violations and Lack of Transparency The City has received a formal code enforcement complaint (Case ID: 6747006). One of them is regarding violations of Section 3(d), which requires annual reporting on occupancy, staffing, and parking usage. These reports have not been provided since the ordinance was issued for almost forty years. Without reliable data, how can the City determine whether an expansion is warranted or justified? Data-driven decisions require transparency and accountability, both of which are lacking here.

7. Violation of Daylight Plane and Height Regulations
The current proposal violates Palo Alto Municipal Code Section 18.38.150(e) "Sites sharing any lot line with one or more sites in any RE, R-1, R-2, RM or any residential PC district shall be subject to a maximum height established by a daylight plane beginning at a height of ten feet at the applicable side or rear site lines and increasing at a slope of three feet for each six feet of distance from the side or rear site lines until intersecting the height limit otherwise established for the PC district", which governs height restrictions for developments adjacent to residential properties. The planned second and third story units along Wilkie Way exceed the allowable height under the daylight plane requirement, directly impacting our privacy and neighborhood character.

8. Support for Senior Housing—But Not at a few Residents’ Expense I support the City’s commitment to senior housing. However, it is neither fair nor sustainable for Wilkie Way residents to carry the entire burden for this expansion. Palo Alto Commons, as a for-profit corporation with substantial resources, has the means to redesign the project along El Camino Way—even if that comes at a higher cost. Responsible development must consider both community needs and long-term neighborhood integrity.

9. Broken Commitments to Step-Up Design
Palo Alto Commons originally committed to a “step-up” design along Wilkie Way to reduce the impact on adjacent residents. This approach was intended to preserve privacy and minimize the sense of mass and scale facing single-family homes. However, the current expansion plan completely abandons that commitment, instead proposing a solid wall of construction that fills in the entire step-up area. This is a clear violation of past assurances. We respectfully ask that Palo Alto Commons honor its original promise and keep the step-up design to reduce the negative impact on Wilkie Way residents.

In conclusion, this proposal reflects a pattern of disregard for city direction, community feedback, and legal compliance. I respectfully urge the Council to deny this expansion unless the plan is fundamentally restructured to:

Honor prior city and PTC recommendations,
Comply with existing ordinances and environmental review, and Demonstrate genuine accountability and transparency.

Thank you for your attention and for considering the voices of residents most directly impacted by this development.

Sincerely,
Mona He
4040 Wilkie Way
Palo Alto, CA
J. Randall Toch
408.947.2492
[email protected]
Silicon Valley Office | 55 South Market Street, Suite 900, San Jose, California 95113-2324 phone 408.287.9501 fax 408.287.2583 www.hogefenton.com
December 9, 2024
Via E-Mail only ([email protected]) Honorable Members of the City of Palo Alto
Planning and Transportation Commission
250 Hamilton Ave.

Palo Alto, CA 94301
Re: Meeting Date: December 11, 2024
Agenda Item: 2
Project Description: Proposed Zoning Amendment and
Architectural Approval for Palo Alto Commons
Subject Property: 4075 El Camino Way, Palo Alto, California Report #: 2410-3649
Our Clients: Mona He and Grace (Yan Feng) Wang
Objection to Proposed Categorical Exemption of Project under CEQA Dear Honorable Members of the City of Palo Alto Planning and Transportation Commission:

This law firm represents Mona He and Grace (Yan Feng) Wang who own single story residences on Wilke Way. The residences are adjacent to the real property situated at 4075 El Camino Way, Palo Alto (the “Subject Property”). For the reasons stated in this letter, Ms. He and Ms. Wang object to the proposed categorical exemption of the project under CEQA, and oppose the project itself in its current form.

The project under consideration by the Commission as Agenda Item No. 2 is defined in the staff report for the December 11, 2024 Planning & Transportation Commission Meeting (the “Staff Report”) under the heading “PROJECT DESCRIPTION” as follows: “an amendment to the existing PC Zone District (PC-5116) . . .” (the “Project”).1 I. The Project is a proposed Zoning Amendment which would alter multiple aspects of the City of Palo Alto Municipal Code. (It is not a mere application for a permit to allow minor physical alterations to an existing facility.) The California Environmental Quality Act Requires Environmental Review of Proposed Zoning Amendments. 1 See City of Palo Alto Planning & Transportation Commission Staff Report, Item No. 2, Page 2 of 10 (Packet Pg. 11)
Honorable Members of the City of Palo Alto Planning
and Transportation Commission
December 9, 2024

Page 2 ends

The categorical exemption from environmental review under CEQA that is suggested by staff for the Project is inapplicable to the proposed Project. We carefully reviewed the relevant documentation posted by staff regarding the Project, including, without limitation, the document dated October 9, 2024, entitled “Memorandum”, which David J. Powers & Associates, Inc. prepared (the “Powers Memo”). In brief, the Powers Memo improperly concludes that the requested zoning change application, which is a legislative activity, is categorically exempt from environmental review under the California Environmental Quality Act (“CEQA”) pursuant to 14 C.C.R. Section 15301. However, 14 C.C.R. Section 15301(e)(2), which is relied upon by the authors of the Powers Memo, applies, by its express terms, only to proposed construction projects, and not to legislative activity.2 This inconsistent line of reasoning applied by the Powers Memo and by City staff is false, incorrect, misleading, and, if adopted by the City of Palo Alto would likely be entirely unlawful.

Accordingly, the City of Palo Alto (the “City”) must conduct an environmental review prior to adopting a zoning ordinance, which according to the Staff Report, will modify each of the following aspects of the City of Palo Alto Zoning Ordinance.3 • The provided units would increase by 16 units;
• The allowed lot coverage and floor area would increase to accommodate the approximately 6,890 square foot addition; • The minimum setback would decrease from 8 feet to 6 feet for the southwestern property line adjacent to Goodwill; and
• The parking ratio provided would reduce from 0.46 spaces per unit (1.16 spaces per 2.5 beds) to 0.41 spaces per unit (1.01 spaces per 2.5 beds), as no additional spaces are being provided. However, this is consistent with the standard code requirement for this use, which is one space per 2.5 beds.” (Emphasis Added.)
Proposed Zoning Amendments (and General Plan Amendments) are “Projects” as defined in CEQA. In connection with the foregoing, 14 C.C.R. Section 15378 states, in pertinent part, as follows:
(a) “Project” means . . . any of the following: [¶] (1) An activity directly undertaken by any public agency including but not limited to . . . enactment and amendment of zoning ordinances, and the adoption and amendment of local General Plans or elements thereof . . . (Emphasis added.)
2 The Powers Memo also asserts, without explanation, attribution, or legal authority of any kind whatsoever, that a 13% increase in intensity of use is somehow “negligible” for purposes of CEQA. (Powers Memo, Pg. 12)
3 See City of Palo Alto Planning & Transportation Commission Staff Report, Item No. 2,

Page 6 of 10 ends

Honorable Members of the City of Palo Alto Planning
and Transportation Commission
December 9, 2024

Page 3 ends

And, Public Resources Code Section 21080 states, in pertinent part, as follows:
(a) Except as otherwise provided in this division, this division shall apply to discretionary projects proposed to be carried out or approved by public agencies, including, but not limited to, the enactment and amendment of zoning ordinances, the issuance of zoning variances, the issuance of conditional use permits, and the approval of tentative subdivision maps unless the project is exempt from this division. (Emphasis Added.)
The Powers Memo asserts that the Project (which is an application for a zoning change) is exempt from environmental review under CEQA pursuant to 14 C.C.R. Section 15301, which provides, in pertinent part, as follows:

Class 1 consists of the operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use. The types of “existing facilities” itemized below are not intended to be all-inclusive of the types of projects which might fall within Class 1. The key consideration is whether the project involves negligible or no expansion of use. [¶] Examples include but are not limited to:
. . . (e) Additions to existing structures provided that the addition will not result in an increase of more than: [¶] (1) 50 percent of the floor area of the structures before the addition, or 2,500 square feet, whichever is less; or [¶] (2) 10,000 square feet if: [¶] (A) The project is in an area where all public services and facilities are available to allow for maximum development permissible in the General Plan and [¶] (B) The area in which the project is located is not environmentally sensitive. (Emphasis Added)
Clearly and unequivocally, a proposed zoning amendment that is intended to alter municipal laws relating to zoning restrictions, including, without limitation, reducing property line setback requirements and altering sightlines, ambient light, noise patterns, roadways, traffic, floor area ratios, intensity of use, and reduction of parking requirements, could, and very likely would, have profound environmental impacts, as well as civil and criminal ramifications. The foregoing cannot simultaneously be considered just a “minor alteration of an existing structure” that happens to be located in a zoning district that already permits the intended use. In the current application, the proposed use is expressly prohibited under the existing zoning, hence the need for the requested zoning amendment.

If the state legislature had intended for zoning amendments and general plan amendments to be exempt from environmental review, it could and would have included such legislative activities in the list of statutorily exempt types of projects. Similarly, if the Secretary for Resources had intended for zoning amendments to be categorically exempt from environmental review, the Secretary for Resources would have included such projects in the list of categorical exemptions authorized by Public Resources Code Section 21084, which are published in 14 C.R.C. Section 15300, et seq.

Honorable Members of the City of Palo Alto Planning
and Transportation Commission
December 9, 2024

Page 4 ends

The conclusion is clear and unmistakable. Proposed zoning amendments are specifically INCLUDED in CEQA by statute, because they have great potential to cause significant environmental impacts. Accordingly, the narrow criteria of the categorical exemption set forth in 14 C.C.R. Section 15301, which relate solely to proposed minor alterations to an existing building, without a change of use, do not apply to this proposed Project, which is a proposed zoning amendment that would change multiple aspects of the permitted uses of the Subject Property and would allow activities on the Subject Property that are currently prohibited. Accordingly, environmental review is mandated by CEQA and must be conducted in accordance with applicable laws prior to enactment of any proposed modification of the existing PC Zone District (PC-5116).

II. Potential Significant Environmental Impacts Result from the Project.

Phase 1 of the development of the Subject Property was approved in the late 1980’s through adoption of a Planned Community zoning ordinance (City of Palo Alto Ordinance No. 3775). At that time, potential environmental impacts were discussed and mitigated through the use of a terraced building design in which each higher floor was recessed further from property lines, and this design mitigation was incorporated into the applicable zoning ordinance. Multiple members of the community participated in that negotiation and remember the developer’s promises that the design would not be altered. And, Phase 2 of the development of the Subject Property was approved in the early 2010’s through adoption of a second Planning Community zoning ordinance (City of Palo Alto Ordinance No. 5116).

And, the terraced design was carefully maintained at that time.

However, the developer has now come to the City with a proposed Phase 3, which would disregard the very same environmental mitigations that were incorporated into the prior design in order to be able to alter the use of the Subject Property in a manner that was expressly prohibited at each prior phase. Nevertheless, the Powers Memo claims that these requested zoning changes, which would greatly expand the permitted uses of the Subject Property, are merely a “minor alteration” to the Subject Property that cannot possibly result in an environmental impact, and are therefore exempt from environmental review under CEQA. However, given the fact that the previously approved environmental mitigations would be eliminated upon approval of the current Project, it is apparent that the proposed Project would result in significant environmental impacts, per se.

A review of the public comment for the Project revealed that there was a proposed alternative design in which the existing facility would be built upwards over the existing third floor rather than outward over the first and second floors. This proposal potentially mitigates some of the resulting environmental impacts to a less than significant level, while achieving the benefits of the same proportional increase in intensity of use. However, the developer apparently rejected that mitigation proposal as not economically acceptable. The upshot is that the developer desires to be permitted to cause an environmental impact in order for the developer to be able to benefit financially. This is precisely the type of environmental cost vs. economic benefit analysis that CEQA is intended to cause to be disclosed to the decision makers prior to deciding upon approval of a proposed project.

Additionally, public comment reveals that the facility is already short of available parking, which results in inconvenience to the residents and neighbors, and causes additional Honorable Members of the City of Palo Alto Planning
and Transportation Commission
December 9, 2024

Page 5 ends

neighborhood traffic. A further reduction in parking capacity proposed by the application combined with elimination of entire parking areas to be used for staging during construction will only exacerbate the traffic problems that have not been reviewed and mitigated.

Allowing improvements on the second and third floors to encroach closer to property lines will increase noise and ambient light emitted towards neighborhood properties. The additions will also have an adverse impact on the existing daylight plane in violation of Palo Alto Municipal Code Section 18.38.150(e).

And, finally, it is our understanding that the facility, as presently configured, may currently be operating in violation of the applicable conditions of approval of Ordinance 3775 and/or Ordinance 5116, and that numerous complaints have been made to code enforcement with respect to such violations. If the Subject Property is, in fact, currently out of compliance with applicable zoning and/or use permits, then it should not be eligible to receive additional concessions until all such violations have been remedied.

The foregoing are just some examples of the many potential significant environmental impacts that might occur as the result of approval of the Project and the proposed development.

III. Conclusion.

We urge this commission to follow applicable law and refer the matter to staff to prepare a full environmental review as required in accordance with the California Environmental Quality Act. After an appropriate environmental review has been completed, this commission will be better able to make a recommendation to the City Council that is in compliance with the commission’s legal responsibilities. Such a recommendation should properly take into consideration possible alternative designs, further mitigations, and/or, if appropriate, adoption of a Statement of Overriding Considerations regarding any significant environmental impacts arising from the Project. Alternatively, the proposed Project must be denied.

If you have question about any of the above, or if we can provide you with any other documents or information, please contact the undersigned.

Very truly yours,
HOGE, FENTON, JONES & APPEL, INC.

J. Randall Toch
Of Counsel
JRT/ns
cc: Clients
Emily Kallas – Project Planner (via email only: [email protected]) Sean A. Cottle
From: Leif Erickson
To: Council, City
Cc: Leif Erickson
Subject: Please approve 16-unit expansion for Palo Alto Commons Date: Sunday, May 4, 2025 10:02:05 PM
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Dear Councilmembers,
I usually speak to the Council on behalf of our teens in Palo Alto, but in this case I speak as an advocate for our senior population, and I don't mean high school seniors.

With our population now tipped with more residents over 60 than those under 18, and 20 percent of the city's population now 65 or older, I believe safe and well-serviced senior housing should be one of our community's priorities.

Any decision you make is a balance of trade-offs. What should help you make a choice like approval for the 16-unit expansion at Palo Alto Commons, is this understanding of the growing needs of seniors in our community.

With this goal in mind, to add on to existing housing and services makes more sense than that starting from scratch at another location.

As president of the Palo Alto/University Rotary Club, I have seen the value of the Palo Alto Commons solution for the housing needs of our seniors. Our Rotary Club has had a long relationship with the Commons - one of our members volunteered as a long time board member and one Rotary member is a current resident, with perhaps more headed there in coming years. Recent speakers have shared a broader perspective on the need for a variety of solutions for affordable housing needs in our community.

Some of the Wilkie Way residents raise concerns about parking on their street, but the additional Commons elderly and memory care residents would not be drivers, and staffing increase is only anticipated to be 1-1/2 staff members. With the new El Camino bike lanes removing El Camino street parking city-wide, creative solutions for side street parking will be engaging the attention of City Council and Planning staff in a broader context, rather than project by project.

I appreciate that Commons expansion planners have met four times with neighborhood residents to listen and respond and adapt the plans to respect their requests - again seeking the balance that will best address our broader community.

Please choose to balance your decision with the housing needs of our seniors in mind.

Thank you,
Leif
--
Leif Erickson
cell: 408-406-0005
From: Andie Reed
To: Council, City
Subject: Palo Alto Commons, 5/5/25
Date: Sunday, May 4, 2025 6:41:47 PM
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Dear Mayor Lauing, Vice Mayor Veenker, and Council Members:

I am Andie Reed and I live in Old Palo Alto, not a direct neighbor of the project, but share the plight. I agree with the Planning and Transportation Commission to limit this expansion to units that don’t infringe on neighbors.

To reiterate, 9 of the 16 proposed units face backyards and windows of Wilkie Way neighbors, who are rightfully incensed that the decreased daylight plane negates their previously hard-won agreements, by in-filling the very light and air and privacy rights that they had previously been assured would be protected.

Please note that these units do not reduce Palo Alto’s housing needs as per our RHNA obligations. This is an assisted living and memory care operation offering a very high-level of care; 3 meals, personal care, general supervision and safety, and social services, recreation and medical access. It’s a business, a highly valuable business, an important niche, but Well-Quest, the owner-operator of both Palo Alto Commons and Avant, also has a goal to make a profit.

I supported a close relative in a similar place for 10 years before she passed away recently, and I can attest to how many employees, contractors, outside services and deliveries come and go daily, not to mention guests and medical support personnel who visit residents. It’s a very busy operation, not a condo complex.

Which leads me to parking. Page 7 states that the “property contains a sufficient number of spaces for the expanded use”, but close neighbors' lived experience and documentation proves, even without expanding, that cars affiliated with the applicant take up available Wilkie Way parking. Palo Alto Commons has a history of non-compliance with their original TDM and Conditions of Approval. The new TDM in this application provides assurance that parking on adjacent streets will be discouraged going forward. I ask you, on what basis do we take this as a likely outcome? Perhaps a more valid analysis would include the whole property; Avant, independent senior housing, shares the same ownership and 2-1/2 acre site with Palo Alto commons. Anyone can use either property's parking spaces. The catch is that only 15 of the total 89 parking spaces are ungated. You have to call the front desk to get into the other 74 spaces behind locked gates. Seriously, most in-and-out services aren’t going to do that; they’ll park anywhere, including adjacent streets.

Additionally, PCs are required to provide a public benefit in return for advantages not otherwise permitted. This expansion is a new addition to the PC, but the applicant is not offering any new public benefit in their request for an expansion, sucking up air and light from their neighbors and exacerbating an already bad parking situation. The report states that merely adding more units is a Public Benefit, but if that were true, why did they provide public benefits originally in 1989 and again in 2011, when the Avant was built? For these reasons, I hope you will strongly consider the PTC alternative that allows growth that doesn’t step on long-time neighbors.

Thank you all for your hard work on behalf of the City of Palo Alto. --
Andie Reed
Palo Alto, CA 94301
530-401-3809
From: Jennifer
To: Council, City
Subject: Palo Alto Commons
Date: Sunday, May 4, 2025 6:20:19 PM
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Dear Palo Alto Council members,
I would like to express my support for the decision the PTC made on December 2024, and that is NOT approving the units to be built against the backyards of Wilkie Way residents. The current tiered structure was a result of a compromise made 38 years ago between the Common's and the residents. The tiered structure has already caused some loss of sun light and loss of privacy for those residents. Back then the residents agreed to this sacrifice because the Common's had committed to build this way. The same residents could not have imagined 38 years later the Common's would renege on this promise/commitment. The new proposed units would cause the residents to lose most of their sunglights and privacy. This is totally unethical and unacceptable and maybe even illegal, given that this commitment was documented.

In addition, the Common's has been in code violation for the past 38 years. Also they have not provided adequate parking, causing many cars over flowing to the neighborhood. On paper, it may appear that they have sufficient number of parking spaces but in reality those parking spaces are either blocked or difficult to reach, therefore the number of parking spaces is very misleading and grossly overstated. They claimed to have implemented programs to solve the parking issue but when talking to some staff there, they have not heard of such programs. In addition, the Common's claimed to have implemented valet parking, but many times we didn't see a valet person on site.

The Common's is exhibiting signs of offering solutions, but only temporarily, as a method to gain approval for their project and only to renege later once they have achieved their goals.

They can not be trusted. They need to be held responsible for their proposed solutions on a permanent basis and there should be some kind of monitoring and material punishment if they are caught in violation.

Thanks,
Jennifer
From: Annette Glanckopf
To: Council, City
Subject: Palo Alto Commons Expansion
Date: Sunday, May 4, 2025 5:01:45 PM
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i
Dear Council Members:

This note is in support of the comments sent by Andie Reed. I ask you to accept the PTC recommendations.

Please scale back the proposed expansion of Palo Alto Commons to 7 units for the following reasons:
* The expansion will violate the set-backs for privacy and air space originally agreed on in the initial plan with onerous consequences for Wilkie Way residents. *The Palo Alto Commons operation has a history of non-compliance with their Conditions of Approval with respect to parking. Cars and transit vans currently spill out to Wilkie Way. Currently the project is under parked, and the proposed project with make it even worse.
* The 13 older homes whose backyards border the operation, have organized and held many meetings with City decision-makers, and have attended ARB and PTC meetings over the past couple of years, and so far, neither the applicant nor City staff is amenable to mitigating these issues.
* The parent company, Well Quest has profit as a goal. This new units proposed by this profit-making organization do not constitute “housing” per Palo Alto Regional Housing Needs Assessment (RHNA) and are not housing for the general public; they are very expensive units providing extensive personal services to their users and PROFIT to the owners..
* This isn't "housing" for the general public but provides a very high level of services at a very dear price.
thanks for considering my comments.

Annette Glanckopf
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From: Lily Lee
To: Council, City
Cc: Kallas, Emily
Subject: Palo Alto Commons public comment - Agenda item 14, May 5, 2025, City Council Mtg Date: Sunday, May 4, 2025 3:44:21 PM
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i
Dear Mayor Lauing and City Council Members,
I have lived at 4080 Wilkie Way since 2003. I support more services for seniors. I have enjoyed sidewalk chats with Palo Alto Commons patients over the years.

In addition, however, Palo Alto Commons has harmed our quality of life already, and expansion would make that worse. Thank you to all the City Council members who have visited my backyard to understand better the current conditions and the proposed expansion. As you saw, the current building dominates our backyard. We have no privacy. Patients and staff walk back and forth in common space facing our backyard with floor-to-ceiling windows. Its lights at night are bright.

Our children and I feel uncomfortable spending time in our backyard. The building’s shade has killed almost all plants except invasive weeds. When we refinanced many years ago, the appraiser subtracted $50,000 from the value of our home due to then-current impacts of Palo Alto Commons.

Now, many years later, the reduction would likely be much higher. Parking is limited, and traffic is unsafe for children going to school.

We accepted the impacts of Palo Alto Commons when we moved in. For many years, we wanted to live with a positive neighborly relationship with Palo Alto Commons. Our neighbors on Wilkie Way told us that the company promised that they would not expand. Now, however, these the company has gone back on its word. If this building expands, then all the above impacts would be even worse. Some of our longtime neighbors, beloved local PAUSD teachers, have moved out due to this anticipated expansion. We want to bequeath our home to our children, so they might raise our grandchildren in this neighborhood that we have loved. However, now I worry even more about about the greater loss of value of what we might be able to give them.

Furthermore, Palo Alto Commons has not acted in good faith to work with the City Council, Planning and Transportation Commission (PTC) and residents for many years. It has violated many City requirements. It has violated its Planned Community Ordnance for almost 40 years. It has failed to prioritize Palo Alto residents and report annually on compliance. It has violated parking requirements by repeatedly parking construction vehicles and transport vans where they should not This message needs your attention
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be located. It has misrepresented the true extent of parking impact on its neighbors. I wonder if this company will in the future continue to violate requirements and to renege on past promises.

During this development process, Palo Alto Commons has failed to respond meaningfully to change its plans in spite of clear direction for the City Council to seriously consider constructing on the front of the building. This company has also ignored the PTC direction to cut plans for 7 rearfacing units. Palo Alto Commons claimed to respond to neighbors by reducing the number of residential units from 18 to 16, but only by looking at the fine print did we discover that its architects simultaneously quietly added 2 new offices that actually are even closer (less than 11 feet) to the back fences of 2 neighbors. I recommend exploring moving these offices to the front of the building or to an interior location. In spite of repeated opposition from neighbors and the PTC, the current plan continue to violate the1987 daylight plane. The daylight plane encroachment has in fact increased since the original plan presented to the City Council previously.

Palo Alto Commons is a private company that profits from harming neighbors. It is not providing any below-market-rate units, so only patients with significant resources can afford it. The community benefits it claims to provide are minimal. Palo Alto Commons has not even followed through on its verbal commitment to a no-cost recommendation from multiple neighbors to paint the back of the building a green color that would blend in with foliage.

We supported senior housing, so we did not oppose the Avant expansion, in spite of its multiple violations of usual requirements. However, now we saw that the Avant has created more significant problems than anticipated. Learning from that lesson, we cannot support impacts from 16 new units and 2 new offices.

Please vote to follow the PTC recommendation for 9 interior units only so that seniors can have more services, while complying with City requirements and reducing exacerbation of existing neighborhood impacts. Please eliminate the 7 rear-facing residential units, and move the offices or at least increase the setbacks of the 2 offices so they are no longer less than 11 feet from our back fence. Please also insist on enforcement of new and existing and future parking plans. To be fair to all developers, the City Council should compel developers to follow City requirements and to respond meaningfully to City Council members, who are elected to represent residents, and to PTC members, who are appointed by the City Council.

Thank you very much for considering my comments.

Sincerely,
Lily Lee
4080 Wilkie Way
From: [email protected]
To: Council, City; Lait, Jonathan
Subject: 4075 El Camino Way
Date: Sunday, May 4, 2025 1:36:31 PM
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!
Dear Mayor Lauing,
Please accept the staff recommendations and approve the additional units.

This is one of many projects, past and future, where council will deal with opposition from neighbors.

One of the complaints raised about 4075 El Camino Way is hypocritical and embarrassing to me.

You will hear from residents, all of whom I believe live in homes built by for profit developers, complain that the proponent here is a for profit entity.

This is a non valid complaint
The more difficult issue is that there may be some inconvenience to some neighbors.

On the one hand residents do have the right to voice their perspective to council.

On the other hand if council either rejected or downsized to make infeasible housing when neighbors complained, we will not get much housing built.

Our history on this is not good as council members know with regard to mixed use, primarily market rate projects, which comprise by far the largest share of housing identified as in
our pipeline.

I will be interested to see how council handles this and upcoming housing projects.

Stephen Levy
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From: Kevin Ji
To: Kallas, Emily
Cc: Council, City
Subject: 4075 El Camino Way Zoning Comparison Table (Attachment D) Date: Saturday, May 3, 2025 12:22:15 PM
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Hi Emily,
I noticed that this time, the staff zoning comparison table does not include the CN comparison as it did in almost every other version of the staff report. Can you help me understand why this is?
Thanks,
Kevin
From: Sheri Furman
To: Council, City
Subject: Palo Alto Commons Item 14 on Monday 5: PAN Agrees with PTC Majority Date: Friday, May 2, 2025 5:01:47 PM
May 2, 2025
Subject Line: Palo Alto Commons Item on Monday 5: PAN Agrees with PTC Majority Dear Mayor Lauing, Vice Mayor Veenker and Council Members:

Thank you for your consideration of the impacts to the neighborhood from the proposed Palo Alto Commons expansion. This letter contains our views and those of all the members of PAN who voted to forward this to you at our May 1st meeting.

The question before you is whether Palo Alto Commons, an assisted living and memory care operation, should expand in a manner that takes away the air, light, and privacy of the residents on Wilkie Way. Nine of the 16 additional units proposed for the Commons would overwhelm the backyards and rear window views of these residents. When the project was originally built many years ago, the residents agreed to substantial but limited intrusions – but now that compromise is threatened.

These issues were brought up during the prescreening and at the ARB meetings and the PTC meetings, but the applicant made very minimal changes. The last PTC meeting resulted in a 3-2-2 vote to approve 7 of the 16 additional units and not allow the rear units that would greatly impact the Wilkie neighbors. The PTC pointed out that Palo Alto Commons can still build the additional units by placing them in other locations that would not create new impacts on Wilkie residents.

The 13 older homes whose backyards Palo Alto Commons borders have organized, held many neighborhood meetings and attended ARB and PTC commissions meetings over the past couple of years. Please pay attention to these residents’ concerns.

Also, do not be distracted by claims that reducing the number of units will affect Palo Alto’s housing needs. These units do not constitute “housing” per Palo Alto Regional Housing Needs Assessment (RHNA) and are not housing for the general public.

Rather, they are very expensive units operated by a for-profit entity called Well Quest (the parent company of Palo Alto Commons) and not a local business.

Another critical issue is parking, which frequently overflows from Palo Alto Commons into the adjacent neighborhood. Wilkie residents have provided photos and videos, as well as documented conversations with people who park on their crowded street (employees, service workers, and visitors), that proves Palo Alto Commons’ need for parking vastly overwhelms its onsite spaces. Even the transit vans for Palo Alto Commons often park on Wilkie Way! This incursion will only worsen under the proposed expansion. The very generic TDM associated with this application promises to “discourage” cars from Palo Alto Commons from parking on Wilkie and surrounding streets, but that has not been the case for the past decades. The operation has a history of non-compliance with their Conditions of Approval, per the staff report and the neighbors. You are no doubt aware that it’s unclear which, if any, TDMs in Palo Alto are successful. Please keep that in mind as you deliberate over this project’s proposed TDM and the likelihood it will be observed.

Thank you very much for your attention to these matters Respectfully,
Sheri Furman, PAN Co-Chair
Becky Sanders, PAN Co-Chair
Palo Alto Neighborhoods
From: Penny Brennan
To: Council, City
Subject: NO on Palo Alto Commons Expansion
Date: Friday, May 2, 2025 2:58:23 PM
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Dear City Council Members,
I urge you to vote NO on Palo Alto Commons Expansion. The proposed project represents a dramatic, further incursion into the backyards and homes of Wilkie Way residents by a for-profit business enterprise located outside of our community. Palo Alto Commons already towers over the backyards of individuals who live on Wilkie Way. It blocks natural sunlight from the trees, gardens, and homes of Wilkie Way residents, intrudes on their privacy, and, as a 24/7 business enterprise, is an ongoing source of noise and nighttime light pollution for them. The proposed Palo Alto Commons Expansion will only exacerbate these conditions.

The proposed expansion will worsen the current parking crisis on Wilkie Way. The crisis has been caused by operation of the Palo Alto Commons business. The cars of Palo Alto Commons residents, visitors, and employees routinely fill available parking spaces on Wilkie Way leaving Wilkie Way residents no way to park in front of their own homes. Associated vehicle and foot traffic render the Wilkie Way homes an island amid the busy Palo Alto Commons business enterprise. Although Palo Alto Commons may claim to have done so, it has not made good faith efforts to effectively address the parking crisis on Wilkie Way. Predictably, the proposed Palo Alto Commons Expansion will make the Willkie Way parking crisis worse, and Palo Alto Commons will do little or nothing to resolve it.

Some claim that the Palo Alto Commons Expansion is beneficial because it adds more housing for healthchallenged elders in our community. I note that by virtue of its price-point (which is in line with its web-page branding as "Luxury Senior Living in Palo Alto, California"), and its apparent lack of financial accommodations for low-income elders (such as the HUD-assisted housing program at Lytton Gardens, Palo Alto), Palo Alto Commons is a housing alternative only for wealthy health-challenged elders in our community. Palo Alto Commons' profits from housing these wealthy elders are flowing to WellQuest, a forprofit company headquartered in Salt Lake City, Utah. WellQuest is investing nothing to promote better health and quality of life of Palo Alto residents.

In closing, please, I urge you to vote NO on the Palo Alto Commons Expansion. The expansion will inflict further harms on Wilkie Way residents, provide housing for only a select few (wealthy) elders, and send profits from care of these elders out of Palo Alto and into the coffers of an out-of-state, for-profit corporation.

An expanded Palo Alto Commons will do nothing to give back to the Palo Alto community.

Sincerely,
Penny Brennan, PhD
Ventura Neighborhood
From: Deborah Goldeen
To: Council, City
Subject: Palo Alto Commons
Date: Friday, May 2, 2025 12:36:37 PM
I sympathize with the residents of Wilkie Way who will be negatively impacted by an expansion of Palo Alto Commons. Every time a modest tract home gets torn down in my neighborhood and replaced with a multi-story, 3,500 plus square foot, single family residence, I feel it. It’s awful. But I feel confident in the general understanding that basing decisions on the pretext that property owners have the right to insist that nothing ever changes is not only bad management, but also morally irresponsible.

All the unhappy residents of Wilkie Way plus a cohort of likeminded people will be showing up on Monday to kvetch to the council. I’m sorry I do not have their ear and cannot work to dissuade them taxing the time and patience of the council. But I don’t have to add to the burden. Even though I feel strongly that the Palo Alto Commons should be allowed to proceed without further ado, I won’t address the council in person.

If I had a magic wand, Wilkie Way would be narrowed and the residents could be pacified by the addition of another 250 square feet of property. I know. Not gonna happen and they will suffer, but not as much as the suffering that will result from not allowing Palo Alto Commons a very modest and carefully planned expansion.

Deborah Goldeen, Birch St., 94306
From: Daniel Pei
To: Council, City
Subject: Please Protect Wilkie Way Residents – Palo Alto Commons Expansion Date: Friday, May 2, 2025 8:01:31 AM
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Dear Mayor Lauing and City Council Members,
I’m writing to ask that you deny Palo Alto Commons’ current application and ensure that the daylight plane, privacy, and livability of the Wilkie Way residents are protected.

Approving this kind of expansion—especially one that disregards original setbacks and adds to long-standing parking issues—sets a troubling precedent. It tells other businesses that community impact can be overlooked.

Palo Alto Commons serves an important role, but the proposal needs to meet current building standards and meaningfully address neighborhood concerns around privacy, congestion, and compliance. Please require them to come back with a more balanced plan.

Sincerely,
Daniel Pei
From: yanfeng wang
To: Council, City; Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki
Subject: meeting on 5/5/2025
Date: Thursday, May 1, 2025 9:36:04 PM
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Dear Ed Lauing,
Dear Patrick Burt,
Dear George Lu,
Dear Julie Lythcott-Haims,
Dear Keith Reckdahl,
Dear Greer Stone,
Dear Vicki Veenker,
For about 50 years, it (Commons) has existed here as a commercial estate. The building covers about 90% of the land, three floors high, 10 ft to the fence. Now he ignores the PTC's Code, ignores the law, looks up at the sky, gloriously declared to the government officials and the citizens that it is a residential estate, and then submitted an intrusion addition plan.

Please deny Palo Alto Commons its current application and ensure that the daylight plane and privacy are protected for the residents who live on Wilkie Way. When one business gets away with this kind of expansion it only encourages other businesses to do the same. Please ask Palo Alto Commons to come back with a proposal that meets our current building standards and addresses daylight plane, parking congestion and privacy.

Thank you,
Yanfeng Wang
Ventura Neighborhood
From: [email protected]
To: Council, City
Subject: Palo Alto Commons
Date: Thursday, May 1, 2025 7:21:34 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Lauing and City Council Members:

Please deny Palo Alto Commons its current application and insure that the daylight plane and privacy are protected for the residents who live on Wilkie Way. When one business gets away with this kind of expansion it only encourages other businesses to do the same. Please ask Palo Alto Commons to come back with a proposal that meets our current building standards and addresses daylight plane, parking congestion and privacy.

Thank you.

E. Huang
Ventura Neighborhood
From: Adam Schwartz
To: Council, City
Subject: Palo Alto Commons - please support on May 5!
Date: Thursday, May 1, 2025 3:24:48 PM
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i
To the Palo Alto City Council:

I write in strong support of building 16 new homes at the Palo Alto Commons, and I urge you to approve the necessary code changes. This is item #14 on the agenda for the upcoming May 5 meeting of the City Council.

This is personal for me. My wife and I have lived in Palo Alto for ten years and raised our kids here. My mother lives 3,000 miles away. At age 83, she increasingly needs my assistance, and she wants to move to the Bay Area. But our community is suffering from a housing shortage and extraordinarily expensive homes. We need to increase the supply here of homes for all kinds of people, including for assisted care and memory units in elder housing. Sixteen new homes at Palo Alto Commons would be a great start.

I live in the shadow of Channing House. They are great neighbors. If they wanted to add 16 units, or 160 units, I would quickly sign a petition in support building new homes around the corner from me.

Sincerely,
Adam Schwartz
523 Channing Ave.

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From: Susan Kemp
To: Council, City
Subject: No on Palo Alto Commons Expansion adversely affecting Wilkie Way neighbors Date: Thursday, May 1, 2025 12:09:41 PM
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Dear Mayor Lauing and City Council Members:

Thank you.

Susan Kemp
Ventura neighborhood resident
From: Kevin Ji
To: Council, City; Clerk, City
Cc: Kallas, Emily
Subject: 4075 El Camino Way Comments With Attachments
Date: Tuesday, April 29, 2025 7:25:09 AM
Attachments: City Council Attachments 14.pdf
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Hi Mahea,
Emily has let me know that there was an issue with my public comment for 4075 El Camino Way, an agendized item for 5/5. I've gone ahead and split them into smaller chunks. Hopefully they can get aggregated back into one larger comment. Below is my text comment, and the attachments might be in separate emails, replied to this one.

In addition, I was wondering if you could let me know how much time I get for speaking on behalf of a group? I want to submit a presentation and want to make sure that there is enough time for each slide.

Sincerely,
Kevin
Dear Mayor Lauing and Members of the City Council,
I am writing to express my strong opposition to the proposed expansion of the Palo Alto Commons. This letter outlines serious concerns regarding ongoing code violations and patterns of irresponsible behavior that should be fully considered before any further action is taken. The issues outlined here speak not only to noncompliance with existing agreements, but to a troubling disregard for neighborhood integrity and public trust.

Illegal Behavior
The Palo Alto Commons has a long history of failing to comply with city regulations and the terms of its original Planned Community (PC) ordinance approved in 1987 (PC-3775). These are not minor oversights—they are foundational requirements meant to safeguard the quality of life for nearby residents and ensure a fair, transparent relationship between developers and the City. Specific violations include:
38 + Years of PC Ordinance Violation: Since its original PC ordinance approved in 1987, the Palo Alto Commons has failed to comply with the requirements set out in the original PC (PC3775, Attachment A) in two fundamental ways.

Failure to Prioritize Palo Alto Residents: Section 3(a)(9) of the ordinance clearly states that preference must be given to residents of Palo Alto and their families. This measure was meant to ensure that our community benefits from the services and housing offered.

Yet, there is no evidence that this stipulation has been honored in practice.

Lack of Required Annual Reporting: Section 3(d) mandates that the operator submit annual reports detailing occupancy levels, staffing patterns, and parking usage. This data is essential for monitoring compliance and assessing community impacts. These reports have not been submitted.

Insufficient Parking: Section 3(b)(2) requires a minimum of 55 onsite parking spaces. However, the most recent parking study indicates only 52 spaces are currently available. This ongoing shortfall directly affects neighborhood congestion and quality of life.

Even more troubling is that these violations have been documented in the staff report and in a filed complaint (#16747006), yet no enforcement action has been taken. This lack of accountability erodes public confidence in the City’s oversight mechanisms.

Parking Violations: The Palo Alto Commons have committed numerous parking related violations:

Blocking Visitor Parking with Equipment (Attachment B):

Construction and maintenance equipment often blocks designated visitor spaces, including those in the underground garage, further reducing accessibility. This occurred for several months.

Misuse of Handicap Spaces (Attachment C): The Commons’
shuttle routinely occupies handicap spots and reserves them with cones when not in use—an inappropriate and potentially unlawful practice. This has occurred for several months and continues to occur.

Parking in No Parking Zones (Attachment D): The shuttle van is frequently seen parked in zones marked for no parking. This behavior, noted even in the parking study, indicates a disregard for basic parking laws.

Overflow onto Public Streets (Attachment E): The facility’s lack of adequate parking has forced employees and visitors to park illegally across the street on El Camino Way. Only the Palo Alto Commons has illegal parking in front of it. This is also incredibly dangerous for bikers, as parked cars illegaly blocks the bike lane.

Municipal Code Violations: The proposed Palo Alto Commons expansion violates the Municipal Code in several ways:

Daylight Plane Encroachment: The proposed expansion violates Palo Alto Municipal Code (PAMC) Section 18.38.150, which requires buildings adjacent to R-1 zones to follow a daylight plane to preserve neighbor access to light and air. Ignoring this regulation directly harms adjacent homeowners.

Design Incompatibility: The proposal eliminates prior architectural step-backs, which were designed to reduce visual bulk and preserve neighborhood character. This conflicts with PAMC Sections

18.16.090(b)(4) and 18.13.060(b)(2)(B), which govern appropriate density transitions and context-sensitive design.

Bad Neighbor Behavior
Beyond legal violations, the Commons has consistently demonstrated disregard for its residential neighbors and the spirit of community-based planning. Rather than being a cooperative presence, it has become a source of tension due to the following behaviors:

Abandonment of Original Agreements (Attachment F): The original PC approval was contingent on a lower density design with a step-back architectural transition to respect the surrounding R-1 neighborhood. The proposed expansion disregards these commitments and would impose a larger, more intrusive building on the community. As early as 1978, the El Camino Way area was actually “downzoned to protect the neighbors from over intrusion”. The original developer in 1986 promised that the building would have “comparable density and mass” and proposed a “1-2-3 step-up closest to the property line” as a compromise.

Persistent Parking Burdens: Since 1986, neighbors have expressed concern over parking shortages caused by the Commons. These issues remain unresolved nearly four decades later:

Palo Alto Commons Bus on Wilkie (Attachment G): While the Palo Alto Commons claims to have enough parking on site, their bus will often park on Wilkie.

Palo Alto Commons Vehicles in Visitor Parking (Attachment H):

When not on Wilkie, the Palo Alto Commons Bus and Van will take up visitor parking, causing visitors to park on nearby streets.

Commons Staff Parking in Neighborhood (Attachment I):

While neighbors are sympathetic to the staff, who are clearly left without sufficient alternatives, the resulting strain on street parking has led to significant disruption and frustration. Residents have also been informed that a dedicated off-site staff parking lot was previously available but has since been eliminated by the operator, further exacerbating the issue.

Additional Therapists Parking: Per the Palo Alto Commons’ own parking policy, these people are asked to park on the neighborhood streets. This directly contradicts assurances that parking is sufficient on-site.

Visitors Parking: Numerous people we know have told us that they park in our neighborhood to visit the Palo Alto Commons. In fact, when the phone number was dialed, it used to recommend visitors park on Wilkie. Vice Chair Chang of the PTC had this experience, as described in the 6/12/24 PTC meeting.

Misleading Information on Parking: Past presentations to the PTC and ARB claimed underutilization of parking. However, the current parking study reveals that all spaces are already in use. No additional parking is proposed for the new development, compounding the problem.

There is also no one depicted on page 4 of the parking study. In addition, most of the time, there is no valet. For example, when Mayor Lauing came to visit, there was no valet.

Misleading Landscape Information: The ARB asked the Palo Alto Commons to work with the neighbors on the landscaping. Most of the neighbors wanted evergreen trees, specifically, Italian cyprus, and have stated this on the record. However, the Palo Alto Commons continues to plan on planting deciduous trees. In addition, their landscape architect told us that Italian cyprus do not grow in this region, despite one neighbor having them in her backyard.

Diminished Public Benefit: When the project was originally built, the developers made an “in-lieu contribution of $205,200” (Attachment A) in 1987 dollars ($588,688 in 2024 dollars) When building the Avant, there was a $100,000 contribution to Avenidas (Attachment K, PC5116). Yet the public benefit this time is “2 small trees”, “space for both recycling and compost bins”, and “bike parking” (Attachment L). They claim that the primary public benefit is more housing, but this project does not qualify for RHNA housing.

Conclusion
The Palo Alto Commons has repeatedly violated the terms of its original development agreement, ignored City ordinances, and shown disregard for the neighborhood that surrounds it. To approve an expansion under these circumstances would not only reward noncompliance, but would also set a dangerous precedent for future developments throughout the city.

Our community depends on the integrity of its planning process. If a project fails to honor prior commitments, meet regulatory standards, or respect its neighbors, it should not be allowed to grow further at our expense.

I respectfully urge the City Council to deny the proposed expansion until all existing violations are rectified and meaningful accountability is established.

Sincerely,
Kevin Ji
4072 Wilkie Way

ATTACHMENT A
PC3775 (Original 1987 PC)

ATTACHMENT B
Construction Equipment in Parking
Spaces over Several Months

From: Kevin Ji
To: Council, City; Clerk, City
Cc: Kallas, Emily
Subject: Re: 4075 El Camino Way Comments With Attachments Date: Tuesday, April 29, 2025 7:25:09 AM
Attachments: City Council Attachments 24.pdf
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi,
Here is the second of 4 attachments.

Sincerely,
Kevin
On Mon, Apr 28, 2025 at 6:40 PM Kevin Ji <[email protected]> wrote:

Hi Mahea,
Emily has let me know that there was an issue with my public comment for 4075 El Camino Way, an agendized item for 5/5. I've gone ahead and split them into smaller chunks.

Hopefully they can get aggregated back into one larger comment. Below is my text comment, and the attachments might be in separate emails, replied to this one.

Insufficient Parking: Section 3(b)(2) requires a minimum of 55 on-site parking spaces. However, the most recent parking study indicates only 52 spaces are currently available. This ongoing shortfall directly affects neighborhood congestion and quality of life.

Even more troubling is that these violations have been
documented in the staff report and in a filed complaint (#16747006), yet no enforcement action has been taken. This lack of accountability erodes public confidence in the City’s oversight mechanisms.

Parking Violations: The Palo Alto Commons have committed numerous parking related violations:

Blocking Visitor Parking with Equipment (Attachment B):

Construction and maintenance equipment often blocks designated visitor spaces, including those in the underground garage, further reducing accessibility. This occurred for several months.

Municipal Code Violations: The proposed Palo Alto Commons expansion violates the Municipal Code in several ways:

Design Incompatibility: The proposal eliminates prior
architectural step-backs, which were designed to reduce visual bulk and preserve neighborhood character. This conflicts with PAMC Sections 18.16.090(b)(4) and 18.13.060(b)(2)(B), which govern appropriate density transitions and context-sensitive design.

Abandonment of Original Agreements (Attachment F): The original PC approval was contingent on a lower density design with a step-back architectural transition to respect the surrounding R-1 neighborhood. The proposed expansion disregards these commitments and would impose a larger, more intrusive building on the community. As early as 1978, the El Camino Way area was actually “downzoned to protect the neighbors from over intrusion”. The original developer in 1986 promised that the building would have “comparable density and mass” and proposed a “1-2-3 stepup closest to the property line” as a compromise.

Persistent Parking Burdens: Since 1986, neighbors have expressed concern over parking shortages caused by the Commons. These issues remain unresolved nearly four decades later:

Palo Alto Commons Bus on Wilkie (Attachment G): While the Palo Alto Commons claims to have enough parking on site, their bus will often park on Wilkie.

Palo Alto Commons Vehicles in Visitor Parking (Attachment H): When not on Wilkie, the Palo Alto Commons Bus and Van will take up visitor parking, causing visitors to park on nearby streets.

Commons Staff Parking in Neighborhood (Attachment I):

Numerous residents have observed staff members from the Palo Alto Commons parking along Wilkie Way and adjacent residential streets. Staff are easily identifiable by their uniforms—scrubs and badges bearing the facility’s logo. When approached, some staff have candidly shared that they were instructed by management to park in the neighborhood due to the lack of available spaces onsite. While neighbors are sympathetic to the staff, who are clearly left without sufficient alternatives, the resulting strain on street parking has led to significant disruption and frustration. Residents have also been informed that a dedicated off-site staff parking lot was previously available but has since been eliminated by the operator, further exacerbating the issue.

Additional Therapists Parking: Per the Palo Alto Commons’ own parking policy, these people are asked to park on the
neighborhood streets. This directly contradicts assurances that parking is sufficient on-site.

Misleading Information on Parking: Past presentations to the PTC and ARB claimed underutilization of parking. However, the current parking study reveals that all spaces are already in use.

No additional parking is proposed for the new development, compounding the problem.

Inconsistent Valet (Attachment J): In the new parking study attached in the staff report, the Palo Alto Commons stated that they have a valet helping reduce parking issues. While valet parking is purportedly offered, in practice the stand is frequently unstaffed. There is also no one depicted on page 4 of the parking study. In addition, most of the time, there is no valet. For example, when Mayor Lauing came to visit, there was no valet.

I respectfully urge the City Council to deny the proposed expansion until all existing violations are rectified and meaningful accountability is established.

Sincerely,
Kevin Ji
4072 Wilkie Way

ATTACHMENT C
Cone Reserving Handicap Spot for Palo
Alto Commons Bus

ATTACHMENT D
Palo Alto Commons Vehicles Illegally
Parking

From: Kevin Ji
To: Council, City; Clerk, City
Cc: Kallas, Emily
Subject: Re: 4075 El Camino Way Comments With Attachments Date: Tuesday, April 29, 2025 7:23:50 AM
Attachments: City Council Attachments 34.pdf
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi,
Here is the third of 4 attachments.

Sincerely,
Kevin
On Mon, Apr 28, 2025 at 6:41 PM Kevin Ji <[email protected]> wrote:

Hi,
Here is the second of 4 attachments.

Sincerely,
Kevin
On Mon, Apr 28, 2025 at 6:40 PM Kevin Ji <[email protected]> wrote:

Even more troubling is that these violations have been
documented in the staff report and in a filed complaint (#16747006), yet no enforcement action has been taken. This lack of accountability erodes public confidence in the City’s oversight mechanisms.

Parking Violations: The Palo Alto Commons have committed numerous parking related violations:

Blocking Visitor Parking with Equipment (Attachment B):

Construction and maintenance equipment often blocks
designated visitor spaces, including those in the underground garage, further reducing accessibility. This occurred for several months.

Municipal Code Violations: The proposed Palo Alto Commons expansion violates the Municipal Code in several ways:

Daylight Plane Encroachment: The proposed expansion
violates Palo Alto Municipal Code (PAMC) Section 18.38.150, which requires buildings adjacent to R-1 zones to follow a daylight plane to preserve neighbor access to light and air.

Ignoring this regulation directly harms adjacent homeowners.

The proposed expansion disregards these commitments and would impose a larger, more intrusive building on the community. As early as 1978, the El Camino Way area was actually “downzoned to protect the neighbors from over intrusion”. The original developer in 1986 promised that the building would have “comparable density and mass” and proposed a “1-2-3 step-up closest to the property line” as a compromise.

Persistent Parking Burdens: Since 1986, neighbors have expressed concern over parking shortages caused by the Commons. These issues remain unresolved nearly four decades later:

Palo Alto Commons Bus on Wilkie (Attachment G): While the Palo Alto Commons claims to have enough parking on site, their bus will often park on Wilkie.

Palo Alto Commons Vehicles in Visitor Parking (Attachment H): When not on Wilkie, the Palo Alto Commons Bus and Van will take up visitor parking, causing visitors to park on nearby streets.

Commons Staff Parking in Neighborhood (Attachment I):

Numerous residents have observed staff members from the Palo Alto Commons parking along Wilkie Way and adjacent
residential streets. Staff are easily identifiable by their uniforms —scrubs and badges bearing the facility’s logo. When
approached, some staff have candidly shared that they were instructed by management to park in the neighborhood due to the lack of available spaces on-site. While neighbors are sympathetic to the staff, who are clearly left without sufficient alternatives, the resulting strain on street parking has led to significant disruption and frustration. Residents have also been informed that a dedicated off-site staff parking lot was previously available but has since been eliminated by the operator, further exacerbating the issue.

Misleading Information on Parking: Past presentations to the PTC and ARB claimed underutilization of parking. However, the current parking study reveals that all spaces are already in use.

No additional parking is proposed for the new development, compounding the problem.

They claim that the primary public benefit is more housing, but this project does not qualify for RHNA housing.

I respectfully urge the City Council to deny the proposed expansion until all existing violations are rectified and meaningful accountability is established.

Sincerely,
Kevin Ji
4072 Wilkie Way

ATTACHMENT E
Illegal Street Parking from Overflow
Visitor Parking
P
arkingonEl CaminoWayontherightside is illegal andonlyoccurs infrontofthePalo AltoCommons.

ATTACHMENT F
1986/1987 Public Meeting Notes

ATTACHMENT G
Palo Alto Commons Bus on Wilkie

Attachment H
Palo Alto Commons Vehicles in
Visitor Parking

From: Kevin Ji
To: Council, City; Clerk, City
Cc: Kallas, Emily
Subject: Re: 4075 El Camino Way Comments With Attachments Date: Tuesday, April 29, 2025 7:23:39 AM
Attachments: City Council Attachments 44.pdf
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi,
Here is the fourth of 4 attachments.

Sincerely,
Kevin
On Mon, Apr 28, 2025 at 6:42 PM Kevin Ji <[email protected]> wrote:

Hi,
Here is the third of 4 attachments.

Sincerely,
Kevin
On Mon, Apr 28, 2025 at 6:41 PM Kevin Ji <[email protected]> wrote:

Hi,
Here is the second of 4 attachments.

Sincerely,
Kevin
On Mon, Apr 28, 2025 at 6:40 PM Kevin Ji <[email protected]> wrote:

Even more troubling is that these violations have been
documented in the staff report and in a filed complaint (#16747006), yet no enforcement action has been taken. This lack of accountability erodes public confidence in the City’s oversight mechanisms.

Parking Violations: The Palo Alto Commons have committed numerous parking related violations:

Blocking Visitor Parking with Equipment (Attachment B):

Construction and maintenance equipment often blocks
designated visitor spaces, including those in the underground garage, further reducing accessibility. This occurred for several months.

Misuse of Handicap Spaces (Attachment C): The
Commons’ shuttle routinely occupies handicap spots and
reserves them with cones when not in use—an inappropriate and potentially unlawful practice. This has occurred for several months and continues to occur.

Parking in No Parking Zones (Attachment D): The shuttle van is frequently seen parked in zones marked for no parking.

This behavior, noted even in the parking study, indicates a disregard for basic parking laws.

Municipal Code Violations: The proposed Palo Alto Commons expansion violates the Municipal Code in several ways:

Daylight Plane Encroachment: The proposed expansion
violates Palo Alto Municipal Code (PAMC) Section 18.38.150, which requires buildings adjacent to R-1 zones to follow a daylight plane to preserve neighbor access to light and air.

Ignoring this regulation directly harms adjacent homeowners.

Abandonment of Original Agreements (Attachment F): The original PC approval was contingent on a lower density design with a stepback architectural transition to respect the surrounding R-1 neighborhood. The proposed expansion disregards these
commitments and would impose a larger, more intrusive building on the community. As early as 1978, the El Camino Way area was actually “downzoned to protect the neighbors from over intrusion”. The original developer in 1986 promised that the building would have “comparable density and mass” and proposed a “1-2-3 step-up closest to the property line” as a compromise.

Persistent Parking Burdens: Since 1986, neighbors have expressed concern over parking shortages caused by the Commons. These issues remain unresolved nearly four decades later:

Palo Alto Commons Bus on Wilkie (Attachment G): While
the Palo Alto Commons claims to have enough parking on site, their bus will often park on Wilkie.

Palo Alto Commons Vehicles in Visitor Parking
(Attachment H): When not on Wilkie, the Palo Alto Commons Bus and Van will take up visitor parking, causing visitors to park on nearby streets.

Commons Staff Parking in Neighborhood (Attachment I):

Numerous residents have observed staff members from the Palo Alto Commons parking along Wilkie Way and adjacent residential streets. Staff are easily identifiable by their uniforms —scrubs and badges bearing the facility’s logo. When
approached, some staff have candidly shared that they were instructed by management to park in the neighborhood due to the lack of available spaces on-site. While neighbors are sympathetic to the staff, who are clearly left without sufficient alternatives, the resulting strain on street parking has led to significant disruption and frustration. Residents have also been informed that a dedicated off-site staff parking lot was previously available but has since been eliminated by the operator, further exacerbating the issue.

Visitors Parking: Numerous people we know have told us
that they park in our neighborhood to visit the Palo Alto Commons. In fact, when the phone number was dialed, it used to recommend visitors park on Wilkie. Vice Chair Chang of the PTC had this experience, as described in the 6/12/24 PTC meeting.

Misleading Information on Parking: Past presentations to the PTC and ARB claimed underutilization of parking.

However, the current parking study reveals that all spaces are already in use. No additional parking is proposed for the new development, compounding the problem.

They claim that the primary public benefit is more housing, but this project does not qualify for RHNA housing.

I respectfully urge the City Council to deny the proposed expansion until all existing violations are rectified and meaningful accountability is established.

Sincerely,
Kevin Ji
4072 Wilkie Way

ATTACHMENT I
Palo Alto Commons Staff in
Neighborhood

ATTACHMENT J
Inconsistent Valet
There is often no one at the valet stand.

There is often no valet at all.

ATTACHMENT K
Avant Public Benefit (PC5116)

ATTACHMENT L
Current Public Benefit
(6/12/24 PTC Packet Page 182)

Palo Alto City CouncilMay 5, 2025

Palo Alto City Council
May 5, 2025