City Council
Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: September 15, 2025
Report #:2508-5040
TITLE
QUASI-JUDICIAL. 400 Mitchell Lane [25PLN-00006]: Recommendation From the Planning and Transportation Commission to Uphold the Director’s Decision to Approve a Conditional Use Permit Allowing a Private University Educational Use Within an Existing Building. CEQA Status:
Exempt in accordance with CEQA Guidelines Section 15301 (Existing Facilities). Zone District: PF.
RECOMMENDATION
The Planning and Transportation Commission (PTC) recommends that Council take the following action:
1. Uphold the Director’s Decision to approve the proposed Conditional Use Permit based on findings and subject to conditions of approval set forth in the Record of Land Use Action in Attachment B.
EXECUTIVE SUMMARY
On June 9, 2025 the Director of Planning and Development Services (Director) tentatively approved a Conditional Use Permit (CUP) to allow a Private University Education Use within an existing building at 400 Mitchell Lane. A request for hearing was filed pursuant to PAMC Section
18.77.060 on July 17, 2025, within the 14-day period allowed for such requests following the tentative decision. In accordance with the standard review process, the project went before the Planning and Transportation Commission for a recommendation and is now presented to the City Council for a final decision.
The Planning and Transportation Commission recommended that Council uphold the Director’s decision to approve the project. In accordance with PAMC Section 18.77.060, this item is placed on the consent agenda within 45 days of the PTC’s recommendation. If Council chooses to remove the recommendation from the consent calendar, three votes are required. If pulled, the application shall be set for a new noticed hearing before the City Council.
BACKGROUND
The request for public hearing did not specify any concerns with the project. Despite repeated requests to provide a reason for the appeal, the requestor has not responded to provide a specific reason, nor did the requestor attend the PTC hearing.
However, a separate e-mail sent by the requestor the day prior to filing a request for hearing expressed concerns that there were two separate applications on file for the same site, the subject application and a request for a hazardous tree removal. The requester stated that the two projects should be processed together and asserted that processing these separately is a violation of the California Environmental Quality Act (CEQA). As detailed in the City’s response to this e-mail (Attachment E), these two applications are unrelated and have independent utility. Therefore, staff disagrees that processing these two permits separately is a violation of CEQA.
Additional background information is provided in the PTC report for the proposed project.1 Project Description
The project is a request from Stanford University for a CUP for a private University educational use for the Doeer School of Sustainability at 400 Mitchell Lane. Stanford proposes to utilize the existing building and construct interior tenant improvements to accommodate the use. The site would offer working and training spaces and a field trip resource for students near transit. The facility is also intended to host a portion of the Geoscience Specimen Collection that includes geological and paleo samples to support a wide range of courses. The project plans are included in Attachment H. Physical improvements are limited to ADA improvements (e.g. for restrooms), replacement of existing HVAC, electrical and lighting improvements, and plumbing/fire safety improvements.
Neighborhood Setting and Character
The project site is located on a 0.551-acre portion of land on the same parcel as El Camino Park.
The property is owned by Stanford University, and the City has had a long-term lease on a portion of the parcel for the park since 1915. The property abuts the downtown Caltrain Station and the Palo Alto transit center with connections to the Dumbarton Express, SamTrans, VTA, and Marguerite Shuttles. The site is bordered by El Camino Real to the west, Alma Street/Caltrain train tracks to the east, Palo Alto Avenue to the north, and the University Avenue Caltrain bus transfer station to the south. The existing structure previously housed the American Red Cross and Urban Ministry of Palo Alto, that has been unoccupied for several years.
Planning and Transportation Commission Recommendation
On July 30, 2025, the Planning and Transportation Commission (PTC) conducted a public 1 The July 30, 2025, Planning and Transportation Commission Report is available online at:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16561 hearing2 and unanimously recommended that Council uphold the Director’s decision to approve the Conditional Use Permit application with modifications to add the word “University” to the CUP findings to further clarify the proposed use, revised language in Condition of Approval #13 to clearly indicate the duration of the CUP, and staff’s review of Conditions of Approval #22-33 to determine their applicability with removing any that do not apply to the project. The individual requesting the hearing did not attend the PTC hearing.3
ANALYSIS
Staff and the PTC have reviewed the proposed project and find that the project is in conformance with applicable plans, policies, regulations, and the CUP findings.
Consistency with the Comprehensive Plan, Area Plans, and Guidelines4 The Comprehensive Plan land use designation for the project site is Public Park (P) as it is located on the same parcel as El Camino Park. This land use designation is defined as “Open lands whose primary purpose is public access for active recreation and whose character is essentially urban.” The existing building is situated on a 0.551-acre area of the larger parcel and is not part of the park dedication. The City subleases the portion of the larger parcel that is dedicated as parkland. The proposed use would not impact park services or conflict with public access to the site and is a conditionally permitted use of the site. Therefore, the proposed use is consistent with the Comprehensive Plan land use designation.
Further, the project supports Comprehensive Plan Policy L-2.9 through the reuse of an existing building. The proposed use by the Standford Doeer School of Sustainability also aligns with Comprehensive Plan Policy C-1.5 by expanding access to nearby resources and fostering student engagement with its proximity to public transportation.
Zoning Compliance5
Staff has reviewed the proposed project’s consistency with the Public Facilities (PF) and applicable zoning standards. In the PF district, a Private University Education use is listed as a conditionally permitted use. The proposed project would not increase the existing floor area of the structure. No site plan changes are planned with the associated project beyond the replacement of a wooden accessibility ramp with a concrete replacement ramp. As part of the PTC recommendation, Condition of Approval #13 was revised to clearly indicate the duration of the CUP as provided by PAMC Section 18.77.100 – Duration of Permits. Staff also reviewed Conditions of Approval #22-33 to ensure their applicability to the project and removed one condition that did not apply to the project as reflected in Attachment B. Staff has concluded that the proposed use and renovation, as conditioned, comply with the City’s Zoning Code. 2 The July 30, 2025, Planning and Transportation Commission Report is available online at:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16561 3 The July 30, 2025, Planning and Transportation Commission meeting can be viewed online at:
https://youtube.com/watch?v=Yn2dywjPd4Q?feature=share
4 The Palo Alto Comprehensive Plan is available online: bit.ly/PACompPlan2030 5 The Palo Alto Zoning Code is available online: bit.ly/PAZoningCode Multi-Modal Access & Parking
Per Assembly Bill (AB) 20976 which “prohibits public agencies from enforcing minimum automobile parking requirements for developments located close to public transit,” no parking is required on sites located within 0.5 miles of a public transit station, such as the downtown Caltrain Station. There will be no reduction in parking spaces with the project. Currently, there are 17 parking stalls provided with 1 accessible parking stall.
Williamson Act
The California Land Conservation Act of 1965, commonly known as the Williamson Act, is a State program that discourages agricultural lands from being converted to urban uses, preserves open space, and promotes efficient urban growth patterns. In 1973, The City of Palo Alto and Stanford University entered into a Williamson Act Contract that included the subject property (Attachment F). Compatible uses with the governing contract are listed as the uses permitted by the regulations in the PF zoning district. Because a private educational use is a conditionally permitted use within the PF zoning district and the project will utilize an existing building, the proposed use is consistent with the existing Contract.
Consistency with Application Findings
The CUP findings for approval are set forth in PAMC Section 18.76.010 and are detailed in the June 9, 2025, tentative approval letter (Attachment C). However, staff notes that there are minor changes in text to the CUP findings to clarify the proposed use. Specifically, the Record of Land Use Action has been refined based on comments from the PTC to clearly indicate the proposed use as a Private University Educational use, which is differentiated from a private education use in the code. The findings were also modified to correct a minor factual error in reference to the age of the building and the age of the El Camino Park. These modifications are reflected in Attachment B. The proposed use is consistent with the Comprehensive Plan and is a conditionally permitted use set forth in the Zoning Code. Staff finds that the project would not be detrimental to the public health, safety, general welfare, or convenience.
POLICY IMPLICATIONS
Regional actions emphasize liveliness and activation at the Palo Alto Transit Center. VTA’s ad hoc subcommittee intends to transform the historic depot into an active, transit-friendly hub that enhances visitor experience, supports community engagement, and ensures long-term sustainability, with potential public-facing elements such as shared micromobility, limited retail/services, nonprofit space, and digital wayfinding/history kiosks. While MTC has funded near-term access work (Quarry Road Connection), that action does not set depot programming.
The application before the Planning Director, the Planning and Transportation Commission, and now the City Council is a Conditional Use Permit for a private university educational use within an existing Stanford-owned building in the PF district, where such use is conditionally 6 The text for Assembly Bill 2097 is available online:
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB2097 permitted. Approval requires findings that the use “will not be detrimental or injurious to property or improvements in the vicinity, and will not be detrimental to the public health, safety, general welfare, or convenience,” and that it “will be located and conducted in a manner in accord with the Palo Alto Comprehensive Plan and the purposes of the Zoning Ordinance.” Given the subcommittee’s activation focus on public-oriented, energizing uses at the depot, one could find that the private university use may not, by itself, fully advance that vision. Others may note the site has been long vacant and the proposal reuses an existing building on Stanford property; on that basis, the use may be viewed as not detrimental, even if it does not fully deliver the activation outcomes envisioned by VTA. If three or more City Councilmembers wish to study this further, the item can be removed from the Consent Calendar and scheduled for a future hearing.
FISCAL/RESOURCE IMPACT
The recommendation in this report has no significant budget or fiscal impacts. The proposed project is a private development that is subject to cost recovery; therefore, processing of this application does not directly impact City resources. The proposed private university use would utilize a vacant building.
STAKEHOLDER ENGAGEMENT
As part of the standard CUP review process, information about the application and about the proposed decision was mailed to owners and occupants of property within 600 feet of the subject property following the filing of the application and following the director’s decision. No comments were received from any members of the public prior to the issuance of the tentative decision. Following the tentative decision, the City received the request for hearing, which did not cite any specific concerns related to the Project. The PTC held a public hearing to consider the request for public hearing on June 30, 2025. Notice of that hearing was published in the Daily Post and mailed to property owners and tenants within a 600-foot radius at least 10 days prior to the public hearing. The requestor did not show up to the public hearing. One member of the public spoke at the hearing and expressed concerns with the separate tree removal permit citing that the tree removal information was difficult to find and should not be considered separate from the CUP. The request for a tree removal application letter (25PLN- 00131) is included in Attachment G.
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. In accordance with Section 15301 (Existing Facilities), the project is exempt as the proposed activity will involve negligible or no expansion of the existing facilities.
As detailed in the City’s response to the appellant on June 17, 2025 (Attachment E), although there are two separate applications on file, one for the subject CUP and one for the removal of two Bay laurel (Laurus nobilis) trees (as hazardous tree removals), processing these applications separately is not a violation of CEQA. The CUP includes interior improvements and the change in use. The hazardous tree removals are not required to accommodate the proposed use and therefore the two projects have independent utility. Moreover, even if the two tree removals (and required replacement planting) were included in the subject application, the project would continue to be exempt from CEQA in accordance with CEQA Guidelines Section 15301.
Therefore, processing these projects separately does not change the conclusions of the environmental review under either application.
ATTACHMENTS
Attachment A: Location Map
Attachment B: Draft Record of Land Use Action
Attachment C: June 9, 2025, Tentative Approval Letter
Attachment D: Request for Hearing Letter
Attachment E: Email Correspondence Regarding CEQA Compliance Attachment F: Applicant’s Project Request Letter
Attachment G: Request for Tree Removal Application Letter (25PLN-00131) Attachment H: Project Plans
APPROVED BY:
Jonathan Lait, Planning and Development Services Director