Item 7 Public Comment — Palo Alto City Council, May 27, 2025

From: Tiny Home Lady
To: Council, City
Subject: Urge you to Rezone El Camino
Date: Tuesday, May 27, 2025 11:39:45 AM
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Hello esteemed council members. As someone who has been an advocate for more housing in the Bay Area for 7 years, I strongly urge you to revision and rezone the El Camino Real. After visiting Europe recently and seeing how they live in smaller homes and in more centralized areas Palo Alto and the El Camino with all it's access and urban could follow suit and create a thriving area offering housing, commerce and community.

On a typical day, commuters traveling into Palo Alto account for approximately 6.6 million vehicle miles, representing about 80% of the city's total daily VMT. This substantial figure underscores the city's traffic challenges and the environmental impact of inbound commuting.

To mitigate these VMT challenges, Palo Alto has set ambitious targets within its Sustainability and Climate Action Plan (S/CAP). By 2030, the city aims to reduce total VMT by 12% compared to 2019 levels. This includes a 20% reduction in commute-related VMT, a 10% decrease in visitor VMT, and a 6% cut in resident VMT. Additionally, the city seeks to increase the share of active transportation (walking, biking) and transit use from 19% to 40% of local work trips.

My question is how are you going to achieve this without adding more housing? We can't keep passing the preverbial challenge from one council to another we need to enact change now and the rezoning of El Camino to allow for more housing and more community is where to start.

Sincerely,
--

Lindsay Wood
Founder | The Tiny Home Lady
California | (415) 378-8398
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From: Thomas Agramonte
To: Council, City
Subject: Item 7: May 27 City Council Meeting
Date: Tuesday, May 27, 2025 10:58:35 AM
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Hello Palo Alto City Council,
On behalf of the Agramonte Family, a four-generation Palo Alto family and landowners of 2951 El Camino Real (ECR) and 470 Olive Avenue. We are writing regarding Agenda Item 7 of the May 27th City Council Meeting. We ask the City Council to extend the Housing Focus Area to include 2951 El Camino Real and adjacent parcels in the Housing Focus Area expansion, as recommended by the Department of Planning & Transportation. We encourage you to collaboratively work with landowners, developers, and the community to find a balance for the City of Palo Alto that respects the desperate need for housing by making guidelines that support economically viable multifamily residential development.

I am 32 years old and grew up in this community playing sports and I do not have a single friend or teammate that can afford to live here. We need more housing to allow the people who grew up in this community and who work and provide for this community, a place to live in this community.

We request the City of Palo Alto expand the Housing Focus Area on the East side of El Camino to promote high-density multifamily development, which would include 2905 El Camino, 2951 El Camino, 2999 El Camio, and 470 Olive (the “Project”). Implementing this Housing Focus Area supports the City of Palo Alto’s Housing Element objectives, including high-density multifamily housing located along transit corridors, within ½ mile of Caltrain, and on underutilized sites.

We strongly recommend the City of Palo Alto implement a Housing Focus Area for the East side of El Camino, including this Project, in support of the Housing Element objectives to create over 6000 new housing units by 2031
Thank you!
Best,
Thomas
From: Palo Alto Forward
To: Council, City
Cc: PAHousingElement
Subject: Item #7 - El Camino Focus Area
Date: Tuesday, May 27, 2025 10:50:38 AM
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Honorable Mayor Lauing and City Councilmembers,
Tonight's El Camino Real Focus Area expansion builds on the collaborative efforts between the city and home builders that will bring large numbers of housing units online in the near term. This rezoning of approximately 20 parcels will further shape El Camino Real into the Grand Boulevard envisioned for the last three decades!
Please ensure that the Focus Area becomes a housing success story for our city. We ask you to consider the following in your motion:

The 45-degree daylight plane is adequate for neighboring residential protection. Experts on the ARB and city staff agree that this is the best option.

Eliminate dated-looking, prescriptive stepbacks for upper floors -- there is no "canyon effect" to be wary of. A noticeable canyon effect only occurs when buildings are significantly taller than the right-of-way between them. The El Camino right-of-way (measured to the back of sidewalk) is over 100 feet in every location considered for rezoning. Stepbacks are "water-proofing, fire proofing, unit-eating nightmares" and make for-sale condominium units all but impossible to build. They also significantly shrink upper floor unit sizes.

We already have modulation, massing, window penetration, roofline, vertical and horizontal break requirements; as well as texture, material, color, and pattern-change requirements to articulate building facades as part of our city's objective standards. We urge you to allow architects to be creative with design, instead of mandating a cookie- cutter building envelope with stepbacks.

Study extending the Focus Area zoning to more parcels. We crunched our housing numbers below. These zoning changes are what make housing a reality (as opposed to years-long PHZ rezoning processes). These Focus Area zoning regulations are effective, and if we are serious about housing, we should do even more!
This is a pivotal action in our city’s efforts to ease our massive housing shortage, while simultaneously addressing our climate crisis, supporting businesses on California Avenue and El Camino Real with new customers, upgrading our aging rental housing stock, and fostering a renewed sense of vibrancy in Palo Alto.

Thank you for your consideration,
--
Amie Ashton
Executive Director, and on Behalf of the Board
Palo Alto Forward
650-793-1585
From: Steve Levy
To: Council, City; Lait, Jonathan
Subject: ECR focus area expansion
Date: Tuesday, May 27, 2025 7:11:14 AM
Dear Mayor Lauing, council members and staff,
I encourage you to go big on expanding the focus area. Please include Tiers 1 and 2 and the area around ECR and San Antonio as it perfectly matches the criteria as the ARB noted.

With regard to development standards, please take note of stated concerns of potential applicants as noted in the staff report.

While the city has a large pipeline, most of these projects are not moving forward.

On the other hand, several developers have expressed strong interest in ECR sites that when included can move quickly with the focus area incentives.

I believe this will send a clear signal to residents and HCD that Palo Alto is serious about meeting our Housing Element goals and promises
Thank you
Stephen Levy
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From: [email protected]
To: Council, City
Cc: Ted O"Hanlon; Sarang (Sar) Peruri ([email protected]); Yang, Albert; Arellano, Caio Subject: Stakeholder public comment on Item 7 for May 27th Council agenda - SF Creekside LLC Date: Monday, May 26, 2025 8:51:59 PM
Attachments: Creekside Letter to City Council 5-26-2025 FINAL.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Good evening Councilmembers,

On behalf of our client SF Creekside LLC, attached please find public comment on Item 7 on your agenda for tomorrow evening, regarding proposed amendments to the El Camino Real Focus Area standards.

Thank you for your attention to this matter.

Genna Yarkin | Holland & Knight PRIDE
She/Her/Hers
Partner
Holland & Knight LLP
560 Mission Street, Suite 1900 | San Francisco, California 94105 Phone 415.743.6990 | Fax 415.743.6910
[email protected]
| www.hklaw.com
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Re: SF Creekside, LLC’s Stakeholder Comments on Item 7 Regarding Amendments to the El Camino Real Focus Area
Dear Councilmembers:

We represent SF Creekside, LLC, an Oxford Capital Group-led joint venture (the “Applicant”) in connection with its application to redevelop and revitalize the approximately 3.6-acre property at 3398, 3400, and 3490 El Camino Real (the “Property”), including work to demolish and replace several low-rise buildings with 295 residential units including 20% low income units, hotel use, and updating the existing structures to remain (the “Project”).

The Project is protected by the Housing Accountability Act (the “HAA”) inclusive of the “Builder’s Remedy” and was also applied for under the Housing Crisis Act of 2019 (“SB 330”).

While the Applicant has used these processes to safeguard its rights under the law, the Applicant has a track record of listening to City feedback about development on this Property, much of which has shaped the Project as it exists tod ay. The most significant feedback the Applicant has heard and implemented is to maintain the existing hotel use, proceeding with a mixed-use project. City feedback also influenced circulation design – since 2022 the Applicant has shifted proposed driveway access away from Matadero and instead placed this access on El Camino Real, resulting in a three-fold benefit to the adjacent R1 properties: (1) shifting the primary access, (2) maintaining the integrity of Matadero as a Safe Route to School, and (3) breaking up Project massing. The creation of this break is achieved by shifting the primary access to El Camino Real that splits the residential and continued hotel uses. Finally, to address feedback about this Project potentially creating a “food desert”, the Applicant is maintaining at least two existing food and beverages uses that will serve future residents, hotel guests, and the neighborhood.

The Applicant remains open to City feedback and specifically to transitioning its Builder’s Remedy Project to an alternative City process, so long as it is feasible and beneficial for both the

May 26, 2025

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City and the Applicant. Specifically, the Applicant team is hopeful that it may be able to use the El Camino Real Focus Area development standards while still providing the requisite low income housing, and taking advantage of the City’s “Streamlined Housing Development Project Review Process.” We understand that the City has a preference for applicants to pursue this route, rather than using the “Builder’s Remedy.”
On May 27
th, the Council will be considering amendments to its Zoning Code and Building Regulations to modify the El Camino Real Focus Area . While the Applicant’s team is still evaluating overall feasibility of transitioning to the Focus Area standards for the Project, we have identified four of the specific recommended updates that would certainly jeopardize the Applicant’s ability to transition its Project away from the Builder’s Remedy.

On behalf of the Applicant, we therefore request that Council consider modifying these specific four items during its hearing on the 27th, or delaying its decision until a later date while it further considers our requested changes. Further details on each of the four items follow.

1. Daylight Plane – 60 Degrees Instead of 45 Degrees , or Consider Averaging/Allowing Encroachments
We request that a 60-degree daylight plane be applied – this commonly used standard is critical to achieving enough residential units to maintain the economic feasibility of the Project. A 60-degree daylight plane has been utilized in the Project’s current site plan. Alternatively, we request that if Council does impose the 45 degree requirement, that it consider allowing some mitigation factors, such as: (1) that the daylight plane be averaged over a site; (2) that certain development features be permitted to encroach into the daylight plane; or (3) allowing a greater than 45-degree daylight plane even where a site is adjacent to R1 parcel, so long as the applicant can demonstrate negligible differences in solstice and equinox shadowing over the adjacent parcels.

For sites like this Property (and any others within the Focus Area that are similarly affected by the Creek), there are development limitations already imposed by the Creek, and an additional 45 degree daylight plane would greatly c ompromise efficient utilization of the Property and others, including ability of this Project to meet parking requirements and usable open space requirements.

The Applicant has thus far determined that without a 60 degree daylight plane, this Project’s Building A would lose 16 total units and also result in fewer 3 bedroom units. There is simply no other space on this site to accommodate the density needed to maintain the Project’s feasibility.

2. Maximum FAR (Non Residential) – Modify/Reconsider this Restriction Since receiving City feedback in 2022 to continue a hotel use on this P roperty, the Applicant returned with a formal application in 2024 with a mixed use , residential and hotel project that follows the at least 2/3 residential requirement to qualify for HAA protections. As proposed, the Project’s hotel component is a combination of new FAR and 2 reused buildings, and together encompasses less than 1/3 of the proposed FAR.

May 26, 2025

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However, the staff report’s proposal to limit non-residential use to underlying zoning (for this Property that translates to a 2.0 FAR and 50 foot height limit ), would significantly reduce the proposed hotel FAR for this Project by 40%. As the Project’s feasibility is dependent on both the residential and hotel uses (and City feedback thus far has been to maintain the hotel use) , we hereby request that the City consider one of a few options to modify this restriction.

First, the restriction on non-residential use could be narrowed to specific commercial uses such as office use (which we understand to be the intended target of this restriction). Hotel is an existing use on the Property, and an active revenue generator for the City. Hotel uses are also quasi - residential in nature, offering transient habitation, thus not entirely a non -residential use of the property, when compared to other non- residential uses. Forcing a dramatic reduction in the Project’s hotel use to qualify for use of the Focus Area standards, would not allow the Applicant to do its part to support expanded food and beverage offerings at this site either, as the assumption that such uses could be supported is underpinned by the proposal for a specific density of hotel beds.

Alternatively, Council could reconsider imposing this requirement at all, and instead maintain the overall 4.0 FAR requirement for the Focus Area, perhaps while instead requiring a 2/3 residential to commercial balance, to better align proposals with the HAA while achieving the intent of this restriction.

3. Upper Story Step Back – Consider Alternatives to the 10 Feet The staff report proposes a 10 foot step back at 55 feet in height – this will greatly reduce density, whereas other considerations, which could offer a wider variety of solutions while maintaining “objective” language, can provide similar visual variation but maintain density. For example, we estimate the 10 foot step back would reduce the Project’s unit count by approximately 4- 5%, an impact that would effectively make the Project economically infeasible in this financial environment. Further, when combined with a building taking advantage of the full, allowable 85’ limit beginning the step back at a relatively lower 55’ also results in an awkward building proportion.

Alternatively, to maintain needed density we propose that the City either (1) instead of imposing a one-size stepback, provide a menu in the Focus Area standards of specific design elements and articulation methods that achieve visual breaks in the upper floors, such as balconies and other variations; or (2) imposing a stepback that is more shallow than 10 feet and that only applies if a building is higher than 5 stories, and only applies to the top 2 stories of any given project, because of the more harmonious proportions associated with the resultant upper and lower stories.

Finally, the City could consider relaxing this requirement where a building “reads” as transparent, such as with the use of glazing, glass or otherwise open railings in upper stories. In the Applicant’s case, the Project design s can be enhanced to feel light despite its number of stories, through generous use of glazing and balcony articulation.

May 26, 2025

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4. Open Space
The Focus Area standard for open space of 100 square feet per unit is cumbersome. The Project has already incorporated very large balconies and decks, which add to building articulation across El Camino Real as well as the sides and rear building facades. The P roject goes out of its way to maximize open space for the enjoyment of all residents by concentrating open space at the Creekside and on the ground level , and by pushing parking underground. We believe th ese qualities are worth far more than meeting an open space standard and will therefore be a more marketable and successful project when we dedicate project development ar ea to private living space.

Accordingly, we request that the Focus Area standards allow a “credit ”, or usable open space reduction of 1:1 but no more than 50% of the total requirement , where improvements such as vegetated areas, park space, naturalized creeks, or other community areas are improvements made as part of a project. The intent of this language is to acknowledge that the W ater District’s creek will be naturalized as part of the P roject (and any others on sites affected by the presence of the Creek), and that this creates a public benefit and satisfies the intent of the open space requirement.

Thank you for considering our requests and the future of this Project.

Sincerely,

HOLLAND & KNIGHT LLP

Genna Yarkin

Cc: Sar Peruri [email protected]
Ted O'Hanlon [email protected]

From: Leela Hebbar
To: Council, City
Subject: Amending Palo Alto Municipal Code Titles 18 (Zoning) and 16 (Building Regulations) Date: Monday, May 26, 2025 2:30:38 PM
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Hi,
I am writing in support of changing the zoning of the El Camino Real Focus Area to allow for multi-family housing developments (i.e. apartments).

I especially support the creation of more units that are for sale to families. My family has been renting in Palo Alto for about 15 years because we cannot afford a house. But we probably could afford an apartment. Families owning apartments is very common in European cities and towns, and I wish it was more common here in Palo Alto.

Please support the change in zoning, encourage units for sale and/or a co-op model, and to keep the units affordable do not require additional design requirements. The additional requirements would make building the housing more expensive.

Thank you for your attention to this important topic,
Leela Hebbar
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From: Tom Harris
To: Council, City
Subject: In support of Rezoning Parcels on El Camino Real Date: Monday, May 26, 2025 8:30:01 AM
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Dear Council Members,
I am writing to express support for the rezoning of El Camino Real to support housing development. In particular please
Expand the proposed development standards to all the Tier 1 areas that can be accommodated within the current Environmental Impact Report.

Lessen or remove the 10’ stepback above 55’ along the El Camino Real frontage. Stepbacks inefficiently consume more land; require costly structural support,waterproofing, and fire rating; shrink overall unit count and unit size (i.e. force more, smaller studio units); and give buildings a “dated” look.

Remove the Hansen Way special setback for all projects, not just for hotels. A sidewalk, trees, and a protected bike lane already exist. This area should be made vibrant and useful.

Provide direction to staff to further study the remainder of the corridor (i.e., the rest of Tier 2, 3, and 4 parcels and 470 Olive).

Thank you.
--
Rev. Tom Harris
Pastor
First Presbyterian Church Palo Alto
If you need me urgently please call or text my cell phone. I check and respond to email less frequently from Thursday evening to Monday.

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From: Alexandra Konings
To: Council, City
Subject: Supporting easier housing development along El Camino Date: Sunday, May 25, 2025 3:47:33 PM
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i
Dear City Council,
As a College Terrace homeowner, I'm writing in favor of the proposed rezone of the parcels along El Camino Real, (item #7 on Tueday's agenda) expanding the Focus Area so that these parcels can be used for housing. I support this rezoning in part because our city desperately needs more housing to be built - so that it can be a place where all can afford to live, but also to provide much-needed customers for Palo Alto's local businesses (including those along nearby California Avenue).

As such, I hope the city council can make building housing in the new Focus Area as easy as possible within the current Environmental Impact Report, including removing the special setback along Hansen Way.

Thank you,
Alexandra Konings
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From: Jeffrey Lu
To: Council, City
Subject: comment on 27-May agenda item 7 (El Camino Real) Date: Saturday, May 24, 2025 4:15:47 PM
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City Council members,
We are writing to comment on agenda item 7 regarding rezoning several parcels on El Camino Real for housing. Our household is supportive of rezoning to enable additional infill housing in Palo Alto, particularly in job, amenity, and transit rich areas such as the El Camino Real corridor.

Infill housing is an especially important tool as we continue addressing our housing crisis and the negative impacts of decades of misguided planning decisions that have made living in the Bay Area unaffordable for most. Infill housing is a smart way to provide additional housing supply for those who work in or otherwise support our communities. Infill housing can help support more vibrant neighborhoods for current or future residents, and is also important for mitigating transportation and infrastructure impacts.

We urge the city council to move forward with rezoning parcels along El Camino Real for housing without adding new requirements that make housing more difficult to build.

Thank you.

Lu Family
Midtown
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From: Phyllis Brown
To: Council, City
Subject: zoning changes for new housing
Date: Saturday, May 24, 2025 11:26:27 AM
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Dear members of the Palo Alto CIty Council,
As a Palo Alto resident, I strongly support new City efforts to increase housing supply in ways that will make living in Palo Alto more affordable for workers–teachers, firefighters, police officers, and others in the service sector. I also believe it is important for the new housing to be near public transportation and safe paths for biking and walking. I hope rezoning will make it easier for quality, lower-cost housing to be built throughout the city.

The proposals and requests for amendments for building in the San Antonio Road Area, on El Camino, and on Forest Avenue all are promising.

Modified zoning related to parking will be particularly important, but it must be accompanied by improved public transportation options. Research showing that younger adults more often than in the past prefer not to own cars should factor into decisions.

Attention to Palo Alto fire stations, vehicles, and staff will also be important since fire dangers in new housing proposed will be different from current dangers.

Phyllis Brown
451 Adobe Place
Palo Alto CA 94306
[email protected]
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From: Susan Hartzell
To: Council, City
Subject: Re: Housing item on May 27 agenda
Date: Friday, May 23, 2025 4:04:33 PM
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To Members of the City Council:

I strongly support efforts to increase the housing supply in Palo Alto.

Housing near transportation, jobs, and shopping is particularly important.

So is streamlining the process so that construction can begin and housing become available soon.

Our neighboring communities can do it. We should too!
Sincerely,
Susan Hartzell
Susan and Harry Hartzell
850 Webster Street Apt 430
Palo Alto, CA 94301
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From: Deborah Goldeen
To: Council, City
Subject: Zoning Changes for El Camino Real
Date: Friday, May 23, 2025 2:14:12 PM
If I was a betting woman, I’d wager that council will approve the requested zoning changes unanimously. I assume discussion in mandatory, but the proposed changes are so overwhelmingly positive and so long overdue, you all could probably skip the discussion and nobody would bat an eye.

My personal sentiment is that I am embarrassed for our city. I feel, when it comes to housing and to housing people, we could have done a lot better. Hopefully, for the sake of the people who are going to have to live there, the apartments that will be built will have ample, secure bike parking, are finished on their interiors with compounds that contain a minimal amount of volatile organic compounds so that they aren’t toxic, and have robust sound proofing.

Thank you for considering, Deborah Goldeen, Birch St., 94306 From: A M
To: Council, City; Clerk, City; Architectural Review Board; Switzer, Steven Subject: Subject: Concerns Regarding Proposed Project and Rental Practices Date: Friday, May 23, 2025 1:19:54 PM
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To the Architectural Review Board and City Council,
This letter addresses concerns regarding a proposed project that, while potentially a wonderful idea, presents two essential problems that need to be addressed before moving forward.

First, the reputation of the company responsible for renting apartments within this project is not great. As of today, VRENT holds a Google rating of 2.7 stars from 79 reviews. This indicates a significant number of renters have had negative experiences, which is a serious concern for any new housing development in our city.

Secondly, the city needs to implement effective rent control measures before we can trust in huge new projects that could further impact housing affordability. Without such protections, large developments risk exacerbating existing housing challenges for current and future residents.

Sincerely,
Grant D.

From: Meri Gruber
To: Council, City
Subject: Support for rezoning of El Camino Real
Date: Friday, May 23, 2025 1:14:37 PM
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Dear Palo Alto City Council,
I am writing in advance of your meeting on Tuesday, May 27, 2025, item # 7.

As a longtime resident of Palo Alto, I support the rezoning of El Camino Real for housing because it’s a necessary step toward a more inclusive, sustainable, and vibrant community. El Camino is a major corridor with access to transit, jobs, and services—exactly the kind of place where housing makes sense.

Thank you for your service to our community.

Best regards,
Meri Gruber
4123 Briarwood Way, Palo Alto, CA 94306

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From: Joy Sleizer
To: Council, City
Subject: The Commons
Date: Friday, May 23, 2025 10:30:16 AM
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Dear City Council Members,
I am Joy Sleizer & have lived in Palo Alto since 1962. For the last 13 years, I have lived at Channing House.

I urge you to support the addition of 16 units at The Commons.

I attended the May 5 Council meeting & heard the negative concerns of neighbors & friends of neighbors.

The Commons is locally owned, and has made changes to accommodate the neighbors concerns, including hiring a valet service & opening the garage to visitors. I'm not sure the comments I heard on May 5 took into account the changes that have been made. I am hoping you have notes from previous meetings that will help you make an informed decision.

Being a Sr citizen & living at Channing House, I am acutely aware of the need for housing for those folks who need AL & Memory Care.

Thank you for serving on the City Council!
Respectfully yours,
Joy Sleizer
850 Webster Street Apt 706
Palo Alto, CA 94301
650-324-7425
650-353-4481 cell
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From: Laura Bowser
To: Council, City; Lait, Jonathan; Armer, Jennifer; Yang, Albert Subject: First Reading of an Ordinance to Amend the El Camino Real Focus Area (May 27, 2025 - Agenda Item #7) Date: Thursday, May 22, 2025 5:41:38 PM
Attachments: SHP Letter re ECR Focus Area - May 22 2025.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Councilmembers of the City Council,

Please see attached for our comments regarding the amendments to the El Camino Real Focus Area under consideration at Tuesday’s meeting.

Best,
Laura

Laura Bowser
Sand Hill Property Company
2600 El Camino Real, Suite 410
Palo Alto, CA 94306
Tel. +1 650 344 1500
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018002.0006 4914-2961-9005.6
May 22, 2025
Jonathan Lait
Director, Planning & Development Services
Email: [email protected]
Councilmembers of the City Council,
City of Palo Alto
[email protected]
Jennifer Armer
Asst. Director, Planning & Development
Services
City of Palo Alto
Email: [email protected]

Re: Ordinance to Amend El Camino Real Focus Area (City Council Hearing May 27, 2025 – Agenda Item 7)
Dear Jonathan, Jennifer, and Councilmembers:

On behalf of Sand Hill Property Company (SHP), I am writing regarding the pending amendments to the El Camino Real Focus Area regulations and area boundary. As you know, SHP has a longstanding working relationship with the City and is committed to delivering high quality projects that help achieve the City’s goals of both delivering more housing while also preserving and providing a home for the vibrant R&D and technology communities.

SHP currently ground leases from Stanford several properties within the Stanford Research Park, including the three contiguous sites addressed at 3300 El Camino Real, 607 Hansen Way and 811 Hansen Way. 3300 El Camino Real is within the existing El Camino Real Focus Area boundary, whereas the 607 Hansen Way and 811 Hansen Way sites next door are currently outside of the El Camino Real Focus Area.

For the last several years, SHP has spent considerable efforts and resources on developing a feasible mixed-use housing project proposal for the 3300 El Camino Real site. In connection with the City’s 6th Cycle Housing Element, SHP worked with the City to successfully include 3300 El Camino Real as a housing opportunity site under the Housing Element’s housing inventory list.

We have engaged a design team to develop a project proposal that would maintain the allowable

0.4 FAR of office development in the Stanford Research Park (this being one of the few remaining undeveloped parcels in the City), while also incorporating new housing opportunities that will contribute to the City’s regional housing allocation goals.

We greatly appreciate the City’s current efforts to update the El Camino Real Focus Area standards to improve the feasibility of delivering housing, as well as Staff’s work in engaging with the development community to better understand and respond to the existing El Camino Real Focus Area constraints.

2 We largely support the proposed revisions to the El Camino Real Focus Area development standards as reflected in the draft Ordinance. However, as detailed in this letter, there are several outstanding issues related to both development standards and the on-site BMR requirements that affect the feasibility of delivering a viable mixed-use project. We respectfully request that these issues be addressed in the Ordinance currently being considered by the City Council.

Option to Pay BMR In-Lieu Fee
The El Camino Real Focus Area was created to incentivize the development of housing along the El Camino Real corridor, which is well-served by transit and amenities. However, the current ordinance imposes a 20% on-site BMR requirement at low-income (LI) rents, with no option to pay an in-lieu fee, unlike all other areas of the City. Not affording the option to pay an in-lieu fee disincentivizes housing development within the El Camino Real Focus Area, including at 3300 El Camino Real, because projects cannot achieve financial feasibility while providing 20% of their units at LI rents.

Mandatory 20% BMR on-site requirements without any option to pay an in-lieu fee have been repeatedly deemed infeasible by Bay Area cities. This is especially true in the current economic environment in which residential projects are already struggling with high interest rates, record high construction costs and lack of funding. We are not aware of the City conducting any feasibility analysis that demonstrates the viability of a 20% BMR on-site requirement in today’s economic climate, nor do we believe that such a finding could be made.

Multifamily rental developments in the remainder of the City – everywhere other than the El Camino Real Focus Area – are able to pay a BMR in-lieu fee per PAMC Chapter 16.65 Citywide BMR Affordable Housing Requirements (i.e., 15% of units for projects on sites less than 3 acres, such as the 3300 El Camino Real site), as opposed to providing BMR housing on-site. Unlike developments in the remainder of the City, El Camino Real Focus Area projects also forgo the right to use the State Density Bonus Law (SDBL) to utilize concessions and waivers to reduce residential project costs of expensive development and open space standards. Under the SDBL, a project including 20% LI units would qualify for two concessions and unlimited waivers.

Restricting El Camino Real Focus Area developers from utilizing the SDBL while also imposing a 20% on-site BMR requirement effectively imposes a double penalty that will likely prevent residential projects from moving forward and will inadvertently undermine the City’s present efforts to incentivize development within the El Camino Real Focus Area.

We understand that the ECR Focus Area’s 20% on-site BMR requirement was originally adopted to provide an alternative to many builder’s remedy projects, which at the time required 20% LI units on-site. However, under recently passed State law, builder’s remedy projects now only need to provide 13% of units as LI. The state law allows jurisdictions to adopt more restrictive affordability requirements for builder’s remedy projects if they provide an analysis indicating that the more restrictive standards do not make projects financially infeasible. Rather than conducting such an analysis to see whether the more restrictive affordability standards were feasible, the PTC recommended reducing the required BMR requirement for builder’s remedy projects to 13% LI to match the statewide standards. This leaves only projects attempting to follow the Focus Area standards to bear the burden of providing 20% of their on-site units at BMR rents with no

3 confirmation from the City that this set-aside is financially feasible. We support the City’s goal of providing a greater level of affordable housing, but request that it at least allows projects to pay an in-lieu fee to meet the BMR requirement. If the City decides that BMR units must be provided on- site, we request that the BMR requirement for code-compliant projects be made the same as builder’s remedy projects at 13% LI to hold Focus Area sites to the same standard.

We appreciate the City’s recommendation to exempt BMR units themselves from development fees. This is consistent with other cities’ fee policies and is a policy that the City should apply to all sites that provide any percentage of affordable housing as a means of incentivizing on-site affordable housing. Unfortunately, this change alone has a minimal impact on the feasibility of building housing projects within the El Camino Real Focus Area when there is a 20% on-site BMR requirement.

We respectfully request that El Camino Real Focus Area standards be revised to allow for the option of paying an in-lieu housing impact fee consistent with the City’s PAMC Chapter

16.65 Citywide BMR Affordable Housing Requirements, as allowed in the remainder of the City, rather than mandating 20% BMR units on-site. This change would make housing projects feasible and more likely to move forward, while still contributing to the City’s affordable housing goals. If the City decides that BMR units must be provided-onsite, we request that the BMR requirement for code compliant projects be made equal to builder’s remedy projects at 13% LI. Leaving the 20% on-site BMR policy threatens the viability of projects and the entire policy of promoting housing in the Focus Area.

Further Revisions to El Camino Real Focus Area Development Standards We request that the City Council consider the following revisions to the Ordinance in connection with the other proposed updates to the El Camino Real Focus Area development standards.

These changes are particularly important given that all applicable El Camino Real Focus Area standards – including the City’s Objective Design Standards (PAMC Chapter 18.24) – cannot be otherwise modified by using SDBL waivers and concessions that other housing development projects utilize because the Focus Area program prohibits the use of the SDBL.

1. Clarify Height Limits for Nonresidential Uses
We appreciate staff addressing the Ordinance’s ambiguity on which height limit applies to nonresidential uses within a mixed-use project. To qualify as a “housing development project” that can take advantage of the Focus Area standards, two-thirds of the total area of the mixed-use project must be dedicated to residential use. Staff has also interpreted the base zoning FAR 0.4:1 for 3300 El Camino Real as continuing to apply to office uses. We agree with these restrictions on office area as long as the height limit of nonresidential uses is set at a minimum of 50 feet to allow for additional residential to be produced on site. If 3300 El Camino Real instead had to abide by the 35-foot height limit of the RP zone, nonresidential uses would need to build wider to achieve

4 0.4 FAR, covering more of the lot area and thereby reducing the lot space available for housing development. Less lot area for housing development means less housing units can be built on site.

Additionally, we request that rooftop occupancy be permitted beyond the imposed height limit to allow for more outdoor space. This does not impact the overall building bulk and provides office tenants an increasingly sought after area to gather more safely post-COVID, both formally and informally.

We support the El Camino Real Focus Area allowing nonresidential uses to build up to at least 50 feet and further encourage the City Council to allow rooftop occupancy above the height limit to promote the provision of outdoor amenity space.

2. Remove Hansen Way Special Setback
We strongly support the removal of the 50-foot Hansen Way special setback. We urge City Council to reincorporate the removal of the setback into the El Camino Real Focus Area zoning amendments after the issue was tabled by the PTC. The existing setback is no longer necessary, and should be removed. Removing the Hansen Way special setback will facilitate more housing on 3300 El Camino Real and will result in better street frontage activation at the corner of El Camino Real and Hansen Way, consistent with the El Camino Real Focus Area goals.

Unless the Hansen Way setback is removed, developing the corner of El Camino Real and Hansen Way at 3300 El Camino Real will be infeasible, reducing the amount of lot area available for development on site. As depicted in Figure B-2 of the staff report, there is an existing utility easement running diagonally across 3300 El Camino Real that cannot be relocated. If the 50-foot setback along Hansen Way is maintained, development between the easement and Hansen Way will not be feasible due to the constrained buildable area, leaving the corner of Hansen Way and El Camino Real undeveloped. If the setback is removed, 3300 El Camino Real can develop the area between the easement and Hansen Way rather than having the street corner remain vacant.

Removing the setback would facilitate the addition of 50 housing units or a retail component to the corner of El Camino Real and Hansen Way.

The Hansen Way setback was originally envisioned to provide for bicycle connectivity along Hansen Way through the Stanford Research Park. However, Hansen Way already includes an existing Class IIb buffered bicycle lane that provides a safe bike path for bicyclists. The City’s pending Bicycle and Pedestrian Transportation Plan Update shows that the existing Class IIb buffered bicycle lane would be maintained, indicating there is no further need for the extensive 50-foot setback.

To avoid delaying forward progress on the redevelopment of 3300 El Camino Real, we respectfully request that the Hansen Way special setback be removed in the proposed Ordinance, rather than deferring this decision to a future date.

3. Clarify No Below Grade Setbacks
We also strongly support staff’s recommendations to establish rear and interior side yard setbacks that allow for RP zoned sites within the El Camino Real Focus Area (such as 3300 El Camino

5 Real) to better utilize available site area to deliver housing. However, in a multi-building, mixed- use context as is proposed for 3300 El Camino Real, it is important that these rear and interior side yard setbacks not be applied to below-grade parking structures.

To accommodate adequate parking for both the contemplated office and residential uses on the Property, it is likely that the proposed project will incorporate below-grade parking. Application of the rear and interior side yard requirements to the below-grade structure would considerably reduce the below-grade buildable area, limiting parking and therefore housing, yet it would not serve a purpose since there would be no visible structure in the setback area.

As such, we respectfully request that the Ordinance clarify that the proposed rear and interior side yard setbacks do not apply to below-grade structures.

Request for Future Incorporation of 607 Hansen and 811 Hansen Way Properties into El Camino Real Focus Area
Lastly, as the City continues to consider expansion of the El Camino Real Focus Area in a future study, SHP requests that the properties immediately adjacent to and south of the 3300 El Camino Real site at 607 and 811 Hansen Way be included in the Focus Area to facilitate development of housing on these sites.

Given that these sites are contiguous with 3300 ECR and are located at similar distances from El Camino Real as other sites already included in the Focus Area, it would be appropriate to include both additional sites. While these sites are located adjacent to R-1 zones, those lower density residential sites are already proximate to existing office development and the transition to mixed- use or higher density residential would be an appropriate land use transition in these locations.

However, to allow for existing housing proposals, including 3300 El Camino Real, to proceed at this time, SHP supports staff’s suggestion that the further El Camino Real Focus Area expansion be considered separately from the current proposed Ordinance to allow for any necessary CEQA review to proceed on a separate timeline.
* * *
Thank you for your time and attention to these issues. We look forward to continuing to work with Planning staff and decisionmakers to implement these refinements to the El Camino Real Focus Area development standards, all in the aim of creating a more vibrant, diverse and sustainable El Camino Real corridor.

Sincerely,
Laura Bowser
Director, Development
Sand Hill Property Company

From: Leslie Hsu
To: Council, City
Subject: California Avenue
Date: Thursday, May 22, 2025 3:43:30 PM
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Hello,
I am a long-time patron of businesses on California Avenue. The diversity of retail offerings, the fact they’re all small businesses, the sense it’s a community of hard-working “regular people” without pretension have combined to make it a treasured neighborhood.

The pandemic shutdown necessitated drastic measures, which included closing the street off from El Camino and prohibiting vehicle traffic. The current vibe of pedestrians and cyclists is pleasant, but I sense it as a neighborhood in sad decline. I think the small businesses have suffered from the loss of access and visibility, and many are on the brink. It would be a real loss for many of us if that commercial district dies. Pretty restaurants on a pedestrian street have a definite appeal, but we’d lose the vitality of services supporting real life. Is there a way to support those businesses in the next incarnation of the street? Perhaps California Avenue could be one way, open from El Camino, with signs indicating parking off California.

Cities are now limiting airbnb’s because catering to tourism and entertainment has turned out to displace residents’ real lives. I’d hate for California Avenue to do the same.

Thank you for your consideration,
Leslie Hsu
318 Miramontes Road
Woodside CA 94062
From: Lois Fowkes
To: Council, City
Subject: New units at the Commons, rezoning along El Camino Date: Thursday, May 22, 2025 8:47:43 AM
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i
Dear City Council,
I do not usually attend Council meetings, nor write letters, but the housing issue in Palo Alto should not be opposed at every turn. Palo Alto, with its aging population, needs to do its fair share.

So I attended the May 5 Council meeting, and here I am, writing a letter. I presently live at Channing House, but lived in south Palo Alto from 1962-2019. When we first moved in, I heard the train at night—for about a week. I would guess that also to be true of the Wilkie Way opponents of the Channing House expansion, so it is hard to understand their opposition to the 16 new units proposed by the Commons, which will be considerably quieter than trains. (The residents there are not known for all-night carousing!) My mother lived at the Commons for four years, and we found them to be caring and considerate of neighbors in every way. I was given my mother's spot in the basement garage so I wouldn't add to the parking problem. The Commons has already made significant adjustments to their building plans, and I believe they should be allowed to go ahead.

The residents on Wilkie Way, whom I listened to carefully, did not always state how long they have lived in that neighborhood, but I believe they knew it was a busy one when they moved in. I also believe their arguments to be classic NIMBY ones.

I urge Council to give the Commons the go-ahead, and also to approve the rezoning along El Camino to accommodate the great housing need in our city.

Thank you for your consideration,
Lois Fowkes
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From: Michael Terndrup
To: Council, City
Subject: ECR Housing - 5/27
Date: Wednesday, May 21, 2025 10:14:28 AM
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i
Hello,
My name is Michael. I've lived in the peninsula for almost my entire life and I've lived in Palo Alto with my wife and children for 10 years. I strongly support the proposal to lessen the restrictions on housing along El Camino. The city needs more housing and locating it on/near El Camino close to transit and within walking distance of Palo Alto's many amenities as other local cities have done is essential for us to do as well. I hope that the following goals of Palo Alto Forward will be strongly considered and approved at the upcoming hearing (below).

I hope you have a wonderful day and I look forward to the Council hearing.

Expand the proposed development standards to all the Tier 1 areas that can be accommodated within the current Environmental Impact Report.

Remove the Hansen Way special setback for all projects, not just for hotels. A sidewalk, trees, and a protected bike lane already exist. This area should be made vibrant and useful.

Provide direction to staff to further study the remainder of the corridor (i.e., the rest of Tier 2, 3, and 4 parcels and 470 Olive).

Michael Terndrup, AIA
Architect and Principal

PLANNING

FACEBOOK INSTAGRAM VIMEO HOUZZ
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From: Elan Loeb
To: Council, City
Subject: housing
Date: Wednesday, May 21, 2025 8:14:44 AM
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i
I'm writing in support of zoning changes. Housing is so important, please do not water down the rezoning with additional design requirements (like parking or percentage low income housing) that make building housing infeasible. We need to move away from cars & building high density housing near transit is the key. More housing now! I grew up in Palo Alto, but it is hard for me to live here.
--
Thanks,
Elan Loeb
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From: Michelle Oberman
To: Council, City
Subject: Better zoning
Date: Wednesday, May 21, 2025 8:07:41 AM
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i
Hi there,
I'm writing to express my support for the rezoning of several parcels of land along El Camino Real to permit the creation of affordable housing. As a long-time Palo Alto resident, I've been alarmed at the decline in affordable housing for those wishing to work at local businesses, whose jobs pay too little to permit them to rent homes in this area. New housing is needed, and will benefit all of us in a wide range of ways.

Please do not limit the potential reach and impact of this rezoning by adding additional design requirements that make housing financially infeasible. we need to build, asap. It is my top priority.

Thank you,
Michelle
--
Michelle Oberman | Katharine and George Alexander Professor of Law Santa Clara University School of Law | 500 El Camino Real, Santa Clara, CA 95050 tel: 408-551-7104 | pronouns: she, her, hers
articles | ssrn
My recent articles: Recalibrating Risk Under Dobbs; Doctors' Duty to Share Abortion Information; How Abortion Laws Do & Don't Work
My book: Her Body, Our Laws: On the Front Lines of the Abortion War from El Salvador to Oklahoma
“It’s not hard to imagine future generations one day asking: ‘When there was so much at stake for our country, what did you do?’ The only acceptable answer is: ‘Everything we could.’” --Cecile Richards
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From: Annette Isaacson
To: Council, City
Subject: More affordable housing, please
Date: Wednesday, May 21, 2025 7:39:52 AM
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Dear City Council Members,
I know Palo Alto can't solve the nation's problems, but we have so many people living in their vehicles or having to commute from far places like Los Banos or Pittsburg just to work here that we need to build affordable housing for them.

Since the 1950s and 1960s institutional racism created barriers to home ownership for people of color, and then cities put restrictions on multi-family units, creating a shortage of housing. It is our duty to make more housing available to try to ameliorate this housing shortage that we have created.

Please rezone the parcels on El Camino for housing and not just say we want more housing. We need to make it less difficult to actually build affordable housing.

Sincerely,
Annette Isaacson
2550 Webster St.
(Midtown)
From: Susan Setterholm
To: Council, City
Subject: Housing on El Camino Real
Date: Wednesday, May 21, 2025 5:25:29 AM
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Council Members,
I lived and worked in Palo Alto for years in the ‘70s and ‘80s. I even played soccer on a women’s team there. I appreciated the opportunities to contribute to the community.

But even then I was impacted by the housing shortage. I had to leave the community I loved to move southward in Santa Clara County.

Please help build more housing, especially along ECR with its public transportation.

New residents will be customers for the businesses along ECR and in the city of Palo Alto.

Please do not water down zoning with extra design requirements.

With respect,
Susan Setterholm
From: Sarah Levine
To: Council, City
Subject: More housing in Palo Alto
Date: Tuesday, May 20, 2025 11:58:52 PM
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i
To the City Council:

I am a Palo Alto resident. I am writing to encourage you to build more housing in Palo Alto to make housing affordable for teachers, public service workers, and all who wish to make their home here.

I support housing near jobs, shopping, and transit--that's what Palo Alto residents need. More housing in Palo Alto will make for more customers, more workers, and more students for PA schools currently experiencing declining enrollments.

Please do not add more requirements to EL Camino Housing area, or anywhere else. Palo Alto will be twice as wonderful when it offers more housing so that people can live and work locally.

Thank you
--
Sarah Levine
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'Stop the Red Tape' Protest in L.A.

For the first anniversary of the U.S. Supreme Court oral arguments in the Grants From: Mary Gallagher
To: Council, City
Subject: Housing for All
Date: Tuesday, May 20, 2025 1:00:15 PM
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i
Dear Council Members:

I listened to a discussion by the council meeting about leasing to folks who have been incarcerated.

Of course, this is a concern with multiple stakeholders and points of view.

As a renter and former resident property manager, sometimes the felon is the landlord. In 2006, I served a landlord who had been incarcerated for laundering HUD money.

Our real estate system is broken. Job security or a minimum wage is not guaranteed. Rents are more often driven by greed not need.

How can we as a society fulfill the need for housing as a human right? It’s a complex problem with no one answer, but we must house humans and meet their basic needs one by one.

Respectfully,
Mary Gallagher, B.Sc.

Long term Resident of Palo Alto, CA
650-683-7102
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Pass case, which allowed for the criminalization of the unhoused community, Housing Is A Human Right and the Los Angeles office of the National Coalition for the Homeless will take part in a national day of action on April 22 to demand “Housing Now” for unhoused communities across the country by surrounding L.A. City Hall in red tape ribbon.

The red tape represents the years of delayed construction of permanent housing for homeless and low-income communities caused by L.A. government bureaucracy. HHR and NCH will be joined by more than 100 advocates.

For more details, click on this link
. If you're in L.A., feel free to join us! Please
share and like this post to spread the word.

Alert: Call Your Congress Member Now!
The New York Times has reported that the Trump administration may replace the crucial Section 8 voucher program with block grants to states, rather than directly funding housing agencies. Section 8 helps low-income individuals and families to pay sky-rocketing rents -- and keeps people out of homelessness.

This harmful policy change goes along with the 48 percent reduction of staff in the federal Housing and Urban Development (HUD) Public Housing branch, which administers Section 8 vouchers to local housing authorities. The block grants and reduced workforce will cause serious, life-altering problems for low- income people struggling to pay excessive, unfair rents. Please call your Congress member now, telling him or her to protect the Section 8 voucher program and to stop the reduction of HUD's workforce. Click on this link to find your federal representative and that person's contact information. Thanks! Fighting the Oligarchs in L.A.

Last Saturday, Housing Is A Human Right took part in the "Fight the Oligarchy" rally in Downtown Los Angeles. Billionaire corporate landlords are part of that dangerous oligarchy, so we showed up to represent housing justice activists and inform people about our issues. More than ever, Americans need rent regulations to protect them against corporate landlords' predatory greed. Share and like our post to show your support.

About
Housing Is A Human Right is the housing advocacy division of AIDS Healthcare Foundation — the world’s largest HIV/AIDS medical-care nonprofit, serving more than two million patients in 47 countries.

Throughout the U.S., AHF clients have been negatively impacted by rising housing costs and gentrification, which threaten their health. HHR advocates for the "3 Ps": protect tenants, preserve existing affordable housing, and produce new affordable and homeless housing.

To learn more about AHF's history, go to the AHF Timeline. Watch the short documentary "The People's Hope" about AHF's life-saving work in South Africa.

Mary Gallagher
From: Diana O"Dell
To: Council, City
Cc: Nose, Kiely; Frick, Coleman; Tiffany Griego; Kelly Kline; Ramya Subramanian; Shweta Bhatnagar; Armer, Jennifer; Lait, Jonathan
Subject: May 27, 2025 Palo Alto Council Meeting - #7 El Camino Real Focus Areas (Stanford Comment) Date: Monday, May 19, 2025 1:56:19 PM
Attachments: 2025-05-19__Stanford Comment Letter on ECR Focus Area Update.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Good afternoon,
Please see the attached comment letter regarding El Camino Real Focus Areas (Agenda Item #7) at the upcoming City Council meeting of May 27, 2025.

We are happy to answer any questions you might have.

Diana O’Dell
Director, Land Use Planning
Stanford | Land, Buildings & Real Estate
408.839.9135

May 19, 2025
City of Palo Alto
City Council of City of Palo Alto
285 Hamilton Avenue, Suite 100,
Palo Alto, CA 94301

VIA EMAIL DELIVERY

Re: City Council Consideration of El Camino Focus Areas at their May 27th meeting

Dear Members of the City Council,

As a landowner of Stanford Research Park sites that are along the El Camino Real corridor, Stanford University is in support of increasing housing and mixed-use opportunities to advance the City’s intention to provide additional density on El Camino Real Focus Area sites.

Stanford supports the removal of the 50-foot Hansen Way special setback under the current El Camino Real Focus Area update. Reducing this restrictive setback now will increase buildable area and create more opportunities for additional housing. Changing this setback now will increase the feasibility of future development that supports city goals.

In addition to the removal of the Hansen Way Special Setback, we also support Sand Hill Properties’ request to remove the below grade setbacks, add the option of paying a housing impact in-lieu fee, and incorporate 607 Hansen and 811 Hansen Way properties into a future El Camino Focus Area, as noted in their most recent letter to the City Council

We appreciate the City Council’s thoughtful consideration of our comments. Please reach out to our team with any questions.

Sincerely,

Tiffany Griego,
Senior Managing Director, Commercial Real Estate Team
Stanford Real Estate, Stanford University
[email protected]

cc: Jonathan Lait, Director of Planning and Development Services Jennifer Armer, Assistant Director, Planning and Development Services Coleman Frick, Long Range Planning Manager, Planning and Development Services

Palo Alto City CouncilMay 27, 2025

Palo Alto City Council
May 27, 2025