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Item 13 Staff Report

Palo Alto City Council
August 11, 2025

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Item 13 Staff Report
Meeting
August 11, 2025
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Palo Alto City Council
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City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: August 11, 2025
Report #:2506-4848
TITLE
QUASI-JUDICIAL. 3150 El Camino Real [24PLN-00231]: Approval of a Vesting Tentative Map to Merge Five Parcels Together to Create One 111,030-Square-Foot Parcel to Facilitate Construction of 368 New Residential Rental Units. CEQA Status: Streamlined CEQA Review in Accordance with Section 15183. Zoning District: CS (Service Commercial).

RECOMMENDATION
Staff recommends the City Council take the following actions:

1. Find the project consistent with the CEQA Guidelines section 15183 analysis previously approved by the Director of Planning and Development Services (Attachment C); and

2. Approve the Record of Land Use Action (RLUA) in Attachment B, approving the Vesting Tentative Map based on findings and subject to conditions of approval.

EXECUTIVE SUMMARY
The applicant requests approval of a Vesting Tentative Map to merge five parcels to create one 111,030-square-foot parcel located at 3128 and 3150-3160 El Camino Real. Through a separate, Streamlined Housing Development Review Process, the applicant proposed, and the Director of Planning and Development Services approved, construction of a 368-unit residential apartment project. The development application included 74 units provided at below market rate and made affordable to low-income households (50%-80% of Area Median Income).

The Vesting Tentative Map also includes necessary utility easements in accordance with the City of Palo Alto Municipal Code and City of Palo Alto Utilities standards, which would be formally accepted by the City as part of the Final Map process.

A location map is included in Attachment A. The proposed Vesting Tentative Map is linked in Attachment C.

BACKGROUND
On August 27, 2024, Acclaim Properties filed a Vesting Tentative Map application concurrently with a Streamlined Housing Development Review application. In accordance with the Vesting

Tentative Map Palo Alto Municipal Code (PAMC) Sections 21.13, approval of the map application was deferred until all other entitlements were approved. For this application the associated entitlements for the planned improvements were approved on July 11, 2025, following a study session with the Architectural Review Board on November 7, 2024,1 and completion of the environmental analysis.

The project includes a request for approval of a Vesting Tentative Map to merge five parcels into one 111,030-square-foot parcel located at 3150 El Camino Real, to develop a 368-unit apartment building. Approval of the map also includes acceptance of proposed public utility easements which are required per City of Palo Alto Utility.

The process for evaluating this type of application is set forth in Title 21 of the PAMC and California Government Code 66474. The process for approval of a Vesting Tentative Map is outlined in PAMC Sections 21.13.020. Vesting Tentative maps require PTC review. The PTC reviews whether the proposed subdivision is consistent with the Subdivision Map Act (in particular, Government Code 66474), Title 21 of the Palo Alto Municipal Code, the Palo Alto Comprehensive Plan, and other applicable provisions of the Palo Alto Municipal Code and State Law. The PTC’s recommendation is forwarded to the City Council for final approval.

The PTC reviewed the project on May 14, 2025, and voted unanimously to recommend that Council approve the Vesting Tentative Map.2 Commissioner Hechtman also identified three minor inconsistencies in the Draft Record of Land Use Action, which have been corrected.

Following the completion of this Vesting Tentative Map, the applicant is required to file an application for a Final Map. The Final Map would be placed on the City Council consent agenda and must be in substantial conformance with the Vesting Tentative Map.

ANALYSIS
The proposed project and relevant discussion and findings herein reflect the Vesting Tentative Map. The Director previously approved the proposed site improvements associated with this lot merger as part of a streamlined housing development review application. The map also includes dedication of relevant public utility easements associated with the new site improvements.

Neighborhood Setting and Character
This property is located adjacent to Palo Alto Square to the north; the Parmani Hotel and the entry to the Stanford Research Park on Hansen Way to the south; the Clocktower Square Office Park to the west; and a mix of commercial and proposed residential uses to the east within the 1 Link to the November 7, 2024 ARB Staff Report:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13926 Video: https://www.youtube.com/watch?v=GXNKd9VWddc
2 Link to the September 19, 2024 ARB Staff Report:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13926 Video: https://www.youtube.com/watch?v=GXNKd9VWddc
North Ventura neighborhood across El Camino Real. Palo Alto Square is comprised of two 10- story towers with four two-story structures, while the adjacent Parmani Hotel and Clocktower Square Office Park properties are comprised of two-story structures. Across El Camino Real is a variety of one- and two-story personal service businesses (private gyms). A five-story affordable housing project has been approved across El Camino Real at 3001/3017 El Camino Real but has not yet been constructed. City-wide, the character of El Camino Real is continuing to transition from commercial uses to multi-family residential and mixed uses and continues to be an appropriate location to place high density housing.

Consistency with the Comprehensive Plan, Area Plans, and Guidelines3 Staff’s analysis finds that the proposed Vesting Tentative Map is consistent with the Comprehensive Plan, in that the site is designated as the “Commercial Service” land use designation, which allows for multi-family residential uses. The site is also identified as a Housing Inventory Site in the Housing Element; therefore, development of the site with multifamily residential use is appropriate and consistent with the Housing Element, as discussed further below. The map facilitates the redevelopment of a parcel within the City’s urban service area which is consistent with Policy L-1.2 of the Comprehensive Plan. The associated development to be constructed on the lot would add new residential units that contribute to the housing inventory including 74 affordable housing units, consistent with Goal 2 of the Housing Element, which states “assist in the provision of safe, attainable, and sustainable housing, especially affordable housing, to meet the needs of all economic segments of the community.” Consistencies with other Comprehensive Plan policies are included in Attachment B.

Housing Element
All parcels included in this proposed lot merger are Housing Inventory Sites in the City’s adopted Housing Element. The five properties have a projected capacity of 29, 16, 179, 113, and 44 units, resulting in a consolidated capacity of 381 units for the site with a projected capacity of 77 low-income units. The 368-unit proposal with 74 inclusionary below market rate units (BMR) is 13 units below the anticipated capacity for the five sites combined and three below the anticipated capacity for low-income units. In preparing the Housing Element to meet the City’s required Regional Housing Needs Allocation (RHNA) of 6,086 units, the City planned for and analyzed a buffer, meaning that in identifying Housing Inventory Sites, the City planned for an additional 727 units, including a buffer of an additional 261 low and very low income units because actual development of housing projects across the City are dependent on numerous factors. In addition, the City will be able to count all housing developments, even ones not included in the Housing Element, toward fulfillment of the required RHNA. Therefore, although the project does not build to the full identified capacity for the site, the project still proposes a housing development project on a Housing Inventory Site and includes 74 3 The Palo Alto Comprehensive Plan is available online: bit.ly/PACompPlan2030 inclusionary below market rate units on site, consistent with the City’s goals of providing housing, and particularly providing below market rate units. The difference in the number of units identified in the Housing Element and the units proposed in this project does not result in a Housing Element capacity below the required RHNA, therefore, re-designation of another Housing Inventory Site to accommodate this difference is not required. The proposed project and relevant discussion and findings herein reflect the Vesting Tentative Map. The Director previously approved the proposed site improvements associated with this lot merger as part of a streamlined housing development review application. The map also includes dedication of relevant public utility easements associated with the new site improvements.

Zoning Compliance4
All of the subject parcels are zoned Service Commercial (CS) and are located within the El Camino Real Focus Area. The project complies with the applicable development standards set forth in PAMC Chapter 18.14, except as modified in accordance with the El Camino Real Focus Area standards, and the Objective Design Standards in PAMC 18.24. The five parcels will be merged into one parcel and that final parcel is consistent with the code requirements for the zoning district, which has no minimum or maximum lot size requirements. Likewise, CS-zoned parcels have no maximum density and is consistent with height and floor area allowed under the El Camino Real Focus Area, which sets forth the allowed density when no maximum is identified. Therefore, the proposed 144 du/ac is consistent with the zoning. Accordingly, staff finds that the proposed Vesting Tentative Map is consistent with the zoning code.

Consistency with Application Findings
As detailed in Attachment B, staff finds that this project meets all required findings for a Vesting Tentative Map and facilitates development of a housing development project that is consistent with the City’s regulations, goals, and policies.

FISCAL/RESOURCE IMPACT
Processing of this application has limited fiscal impact. Applicants are responsible for staff and consultant costs of processing this application through payment of applicable fees per the City’s deposit-based cost recovery program. It is anticipated that the project will result in a change in local tax revenues that the site generates, specifically in the sales tax and property tax categories. These impacts will be reflected in the City’s tax revenue forecasts.

The project would be required to pay Development Impact Fees, which are currently estimated at $20,674,685.30.

STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at 4 The Palo Alto Zoning Code is available online: bit.ly/PAZoningCode least ten days in advance of the hearing. Notice of a public hearing for this project was published in the Daily Post and postcard mailing occurred on July 25, 2025, which is 10 days in advance of the meeting.

Public Comments
The owners of the Parmani Hotel next door raised a concern regarding access to the existing utilities (a transformer and an electric meter) along the shared property line between these two sites. The current transformer straddles the property line and serves the Fish Market and Parmani Hotel properties. Although the neighboring property owners have stated their intent to propose modifications to their property that could resolve this issue, no project has yet been proposed. To address the neighbor’s comments and City of Palo Alto Utilities requirements the applicant has proposed to replace the existing transformer on the 3150 El Camino Real property in their utility yard along El Camino Real. This will eliminate the existing non-complying issue with the transformer straddling property line while ensuring the Parmani Hotel has continued access to City services.

During the May 14, 2025 PTC hearing, a public speaker raised concerns about the traffic analysis, availability of parks/open space, and the number of parking spaces provided for the project. Regarding the traffic analysis, the speaker suggested that the analysis did not analyze intersection traffic flow at University Avenue and Arastradero Road, which are two and one mile from the project site, respectively. While the City’s intersection study in Attachment H of the CEQA document looked at all intersections within 0.5 miles of the project site, the cumulative background conditions of existing traffic patterns for El Camino Real were also incorporated to evaluate the Level of Service (LOS) impact created by the project. It is important to note, however, that LOS analysis is not a CEQA threshold for determining impacts from a project on the environment.

The commenter suggested that this project should be responsible for increasing the available parkland within the City. However, PAMC 21.50 does not require land to be dedicated unless the project includes a subdivision which creates 50 or more parcels. Because the project does not create 50 or more parcels, the applicant will instead pay fees. These fees are used toward development of parkland within the vicinity.

Lastly, the commenter suggested that the ARB project is under parked. However, per Table 3 of PAMC 18.14.020, the requirement for parking for residential projects in the El Camino Real Focus Area is one vehicle parking space per unit. For the 368-unit development the developer is proposing 455 parking stalls, all of which are below-grade.

ENVIRONMENTAL REVIEW
The subject project has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. Specifically, the proposed Vesting Tentative Map has been reviewed under a streamlined CEQA review in accordance with CEQA Guidelines Section 15183. A link to the exemption documentation is available in Attachment C.

ATTACHMENTS
Attachment A: Location Map
Attachment B: Draft Record of Land Use Action
Attachment C: Link to Project Plans and CEQA Analysis
APPROVED BY:

Jonathan Lait, Planning and Development Services Director

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