Attachment H - Public Comments — Palo Alto City Council, November 10, 2025 (part 1 of 2)

1 Kallas, Emily
From: Kinsey haffner <[email protected]>
Sent: Thursday, October 30, 2025 12:23 AM
To: Yang, Albert; Kallas, Emily
Subject: 680 University, the alternative to 660 University, Does Not Qualify For Builder’s Remedy CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

I request that this email and its companion previous email communications on this topic be considered and made a part of the official records and deliberations for the 660 University project (660 Project). The threat of the 680 University project (680 Project) as a Builder’s Remedy (BR) alternative heavily and overtly influenced the PTC decision to approve the 660 University project (660 Project), as the public record of the Commissioner’s questions, comments and concerns makes obvious. Some even went so far as to say that although they had serious concerns and issues about the 660 Project, they voted to advance it because a BR would be worse.

Although the 660 Project is independent of the 680 Project, whether or not the 680 Project has BR status has a powerful effect on the considerations and decisions applicable to the 660 Project.

This email examines whether the 680 Project qualifies for BR. The correct conclusion is that (1) the 680 Project has lost its status as, and currently is not, a BR application and (2) due to the intervening certification of Palo Alto’s housing element by the State, the defects that cause that outcome cannot be corrected in a way that restores its BR status.

With regard to the 680 Project:
 The 680 Project’s Section 69541.1(a) preliminary application (CL_680_University_APPLY4) specified 110 residential units but its Section 69541.1(e)(1) full application (24-LN-00239) reduced the number of residential units to 88 (a 20% change).  CL_680_University_APPLY4 was filed before the date the State certified the housing element for Palo Alto (City). 24-LN-00239 was filed after the certification date.  Subsection 69541.1(d) provides: “After submittal of all of the information required by subdivision (a), if the development proponent revises the project such that the number of residential units or square footage of construction changes by 20 percent or more…the housing development project shall not be deemed to have submitted a preliminary application that satisfies this section until the development proponent resubmits the information required by subdivision (a) so that it reflects the revisions.” This means that CL_680_University APPLY4 may be relied on only for a BR project with 89 to 129 residential units, inclusive.
 The 88 residential units specified by 24PLN-00239 is outside this required range, so the 680 Project, automatically and by operation of law, does not have either the complete prerequisite preliminary application per subsection (d) or a deemed completion date per Subsection 65589.5(h)(5). Therefore, the 680 Project currently does not qualify for BR status or treatment. From Assistant City Attorney’s email attached below, the City does not dispute this point.
2  The sole remaining question is whether the defect caused by 24PLN-00239 can be remedied in a way that reestablishes BR status for the 680 Project. The answer, as is explained below, is no. BR status of the 680 Project cannot be restored or resurrected.

The City and the developer entered into a Tolling Agreement (TA) purportedly relating the 680 Project. It is not clear that the TA actually applies to this situation. The TA recites that “Applicant submitted a preliminary application (“the BR Preliminary Application”)…for development of a mixed-use building include [sic] 88 residential units…(the “BR Project”) and thereafter submitted a formal development permit application…. (the “BR Application”). The Applicant maintains that the BR Preliminary Application vested the then-existing Municipal Code requirements and Housing Element status pursuant to SB 330, specifically including the ability to pursue use of the Builder’s Remedy for the BR Project.” This wording creates the following problem:
 The pertinent obligations in the TA (its Section 2) are specifically limited to the “BR Project.” However, the BR Project as defined in the TA is not the project described by CL_680_University_APPLY4, and a “BR Preliminary Application” for an 88 residential unit project (I.e., as that term is defined in the TA) actually does not exist. The scope of the TA, by its terms, is limited to 24LPN-00239, and CL_680_University_APPLY4 is neither referenced or covered by the TA.
 Subsection 69541.1(d), discussed below, does not allow an application for a project with only 88 residential units to link back to CL_680_University_APPLY4 for BR purposes .  24PLN-00239 needs to be amended to be an 89 residential unit project or to disappear and be replaced by a new 89 residential unit project, to avoid the adverse effects of Subsection (d). If it is amended, then it is outside the TA because it no longer is the “BR Project” as defined. If it disappears, the TA disappears with it.
 Note neither of the above effects would happen if the TA defined “BR Project” in terms of CL_680_University_APPLY4.

Assistant City Attorney Yang, ignoring the drafting problems of the TA, makes a two pronged argument:
(1) the Tolling Agreement creates a window of opportunity for the developer to make a further filing file under Subsection 69541.1(e)(1) and (2) the Subsection 69541.1(d) problem can be resolved via that mechanism. Unfortunately for preserving the BR for the 680 Project, the second prong of Yang’s argument is not correct.

The first problem with Yang’s argument is that the developer actually already has made the required subsection (e)(1) filing and the City timely responded with a list of deficiencies per subsection (e)(2). The only open time window obligation still remaining under Section 69541.1 is the developer’s obligation to respond to the City’s list of deficiencies per subsection (e)(2). Additional changes to 24PLN00239 also can be made, but that is true whether or not the TA exists.

Assuming the Tolling Agreement actually has application to a filing obligation that already has been timely met and that Yang’s first prong argument about subsection (e)(1) is valid, there are only two ways to correct the Subsection 69541.1(d) problem per his second prong: (1) 24PLN-00239 is amended to change the number of residential units to 89 or (2) 24PLN-00239 is superseded or replaced by a new application for 89 residential units.
3  The wording of Subsection 69541.1(d) expressly and explicitly provides both that filiing 24PLN- 00239 with 88 residential units caused CL_680_University_APPLY4 to be incomplete as a preliminary application BR filing and that this incompleteness persists unless and until a appropriately revised preliminary application is resubmitted. This statutory wording does not refer to or authorize any other method of resolving the disconnect in number of residential units caused by the 20% change. In particular, subsection (d) does not mention or authorize the alternative to resubmission that makes up the second prong of Yang’s argument. A resubmission will create an application completion date per Subsection 65589.5(h)(5) that is after the date of certification of the City’s housing element (barring BR as an option for the 680 Project).  The Legislature extensively revised the BR statute (Section 65589.5), effective 1/1/2025. As part of that revision, the Legislature added a new provision to Section 65589.5 that relates specifically to Subsection 69541.1(d) in ways not applicable to these facts. The Legislature also revised the parts of Section 69541.1 relating the payment of fees. Most importantly, no changes were made to the text of either Subsection 65589.5(d) or Subsection 65589.5(h)(5). This legislative history is a powerful statement that the Legislature did not have any intention to modify those two pertinent provisions.
 The TA only allows/forgives a “late’” filing; it’s only legal effect is to eliminate a claim of invalidity due to lateness. Thus the TA permits and makes timely an action that otherwise would be barred by the passage of time, but that permission does not change the legal effects and consequences that result from its occurrence.
 Amending 24PLN-00239 to change it to 89 residential units is permissible without regard to the TA. However, a resubmission still is required per the express wording of subsection (d) or the amendment to 24PLN-00239 is deemed to be, or to obviate the need for, the required resubmission because the amendment eliminates the need for CL_680_University_APPLY4 to be revised. Either way, CL_680_University_AAPLY4 is deemed an incomplete preliminary application per subsection (d) until that corrective action occurs. The result is a new deemed completion date per Subsection 65589.5((h)(5) that is after the certification of the City’s housing element.  Superseding or replacing 24PLN-00239, as opposed to amending it, does not produce a different result. CL_680_University_APPLY4 is deemed incomplete until that corrective action occurs, same as in the amendment alternative, and that date is after the certification of the City’s housing element.

A variation is to argue that withdrawing or abandoning 24PLN-00239 has the effect of leaving CL_680_University_APPLY4 standing alone with its original effective date. This argument also fails.  This outcome is not reconcilable with subsection (d), which expressly states that the CL_680_University_APPLY4 continues to exist as an incomplete pending resolution of discontinuity in the number of residential units.
 In addition, Subsection 65589.5(o)(2)(E) demonstrates that this result is not the Legislature’s intention. That subsection provides that the 680 Project can be made subject to ordinances, policies, and standards adopted after the preliminary application was submitted pursuant to Section 65941.1 in a variety of circumstances, specifically including if “…the housing development project is revised following submittal of a preliminary application pursuant to Section 65941.1 such that the number of residential units or square footage of construction changes by 20 percent or more….” Subsection (o)(2)(E) supports and validates the notion that subsection (d) puts a preliminary application in suspension by subsection 65941.1(d) until the reason subsection (d) applies is resolved. If that were not the case, the application would not be subject to changes in the law enacted after the date the preliminary application was filed. 4  It is settled law that a valid and continuing Subsection 69541.1(a) preliminary application creates a “vested right” to BR as of its deemed completion date. This vested right must also shift forward in time, if subsection 69541.1(d) applies, to the date the relevant residential unit discontinuity is resolved. In other words, resolving that discontinuity results in a new, later, vesting date. Any other result puts the “vested right” and Subsection (o)(2)(E) in a conceptual conflict that is irreconcilable.

Kinsey Haffner

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From: Kinsey haffner <[email protected]>
Sent: Thursday, October 9, 2025 11:24 AM
To: Yang, Albert <[email protected]>
Cc: Kallas, Emily <[email protected]>
Subject: Re: 680 University Does Not Qualify For Builder’s Remedy

Thank you, Albert, for taking the time last night to reply to my email.

First, some clarifications. I actually agree with your description of the process state of the 680 applications and the “correction path” the developer probably will take (both already are in my email, though not very overtly). The difference is that we reach opposite conclusions as to the outcome. While I doubt the developer actually relied on the Tolling Agreement for reasons I can explain, but I too am positive that they will claim they did. Your comment (very politely expressed!) about my perhaps misconception isn’t correct, though I understand why you might conclude so from the way my email is written.

Unfortunately, the issue at hand is nuanced and not simple and the required analysis is complex.

Procedure/process needs to be considered separately from its outcome, the preliminary application needs to be considered separately from the formal application, and the two applications need to be considered separately from the proposed project itself. Then each of the above needs to be matched up against the statutory schema, taking into account the actual phrasing of relevant provisions looked at in the context of a non-obvious aspect of the relevant statutory history.

Successfully navigating the above is necessary because the correct answer to the BR status of 660/680 University is pivotal, as last night’s Commissioner questions and comments made obvious. Our doing so via an email exchange will be difficult and time consuming, and a collegial phone call or F2F meeting will be faster with a better outcome. I hasten to add, and it goes without saying, that “better outcome” does not mean we end up in agreement. Doing so will be excellent, regardless of whose view prevails, but correctly understanding the other’s positions and conclusions will suffice.

A long way, for which I apologize, to request some dates and times when we can speak by phone or meet. I presume sooner is better than later. My calendar is open with a few exceptions next week every day excluding 10/12. I am unavailable all of the week following due to travel plans. After that, only phone would work, as I will be in Idaho.

Best regards, Kinsey

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From: Yang, Albert <[email protected]>
Sent: Wednesday, October 8, 2025 10:49 PM
To: Kinsey haffner <[email protected]>
Cc: Kallas, Emily <[email protected]>
Subject: RE: 680 University Does Not Qualify For Builder’s Remedy

Mr. Haffner,

Thanks for your email and your comments to the PTC. My response to the PTC was based in Government Code section 65941.1, subdivision (e), which grants an applicant 180 days to submit a formal application consistent with a preliminary application containing the information in subdivision (a). For the 680 University “Builder’s Remedy” project, a preliminary application was submitted on June 11, 2024. Therefore, the applicant had until December 8, 2024 to submit a formal application that is consistent with the June 11, 2024 preliminary application.

The City and the applicant entered into a tolling agreement on December 4, 2024 that tolls any and all submittal deadlines related to the Builder’s Remedy project, which includes the 180 day deadline for the applicant to submit a formal application. The fact that the applicant submitted an 88-unit formal application in September 2024 does not preclude them from submitting another formal application for 89-131 units within the 180 day timeline (as extended by the tolling agreement). I expect the applicant would assert that their failure to submit such an application was in reliance on the tolling agreement.

I believe your analysis may misconstrue the impact of changes to a development proposal on a preliminary application. If an applicant submits a preliminary application for 100 units and subsequently submits a formal application for 50 units, this does not have any effect on the 100-unit preliminary application. It simply means that the 50-unit project cannot claim the benefits of the 100-unit preliminary application. Under subdivision (d), the 50-unit project “shall not be deemed to have submitted a preliminary application” until a new preliminary application for 50 units is submitted. But the applicant could still, within 180 days of the 100-unit preliminary application, submit another formal application for 81 units or 119 units and take advantage of its protections.

Best,

Albert S. Yang | Assistant City Attorney
250 Hamilton Avenue | Palo Alto, CA 94301
P: 650.329.2171 | E: [email protected]

This message contains information that may be confidential and privileged. Unless you are the addressee, you may not use, copy or disclose the message or any information contained in the message. If you received the message in error, please notify the sender and delete the message.

From: Kinsey haffner <[email protected]>
Sent: Wednesday, October 8, 2025 8:46 PM
To: Yang, Albert <[email protected]>
6 Cc: Kallas, Emily <[email protected]>
Subject: Fw: 680 University Does Not Qualify For Builder’s Remedy

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hello Albert,

I spoke tonight about the Builder's Remedy for 680 University. Attached below is my detailed analysis of this issue, which I suspect you have not yet seen. My belief is that your quick legal advice is not entirely right.

If you want to, and are allowed to, discuss this with me. I will be happy to do so.

Your answer in public forum to the question posed to you included that the BR defect identified can be remedied. The answer is no in my view, but even if yes, any corrective action at this point (even an amendment to the formal application if it is deemed a resubmission) at this point would create a deemed completed date after, not before, the certification of the City's housing element.. The reason is that Gov.

Code Section 69541.1(d) specifically both requires the preliminary application to be resubmitted and provides the deemed effective date for the preliminary application is the date of the resubmission. The defect cannot be remedied by amending the formal full application, because the wording of subsection (d) does not recognize that as an allowable way to remedy the defect.

You also referred to the Tolling Agreement. However, the Tolling Agreement does not apply. First, the defect is caused by what was filed and not by a failure to make a timely filing, which makes the Tolling Agreement inapplicable. Second, all of the pertinent events occurred before the Tolling Agreement was signed, and that agreement is not retroactive. Third, the Tolling Agreement states it applies to non- submissions, etc. made "in reliance on" the Tolling Agreement, a predicate event that is not in play here because the necessary reliance did not happen. Finally, the defect arose by the filing of the formal application, which occurred after the certification.

Regards (and fellow Stanford Law grad), Kinsey Haffner

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From: Kinsey haffner <[email protected]>
Sent: Wednesday, October 8, 2025 3:11 PM
To: Kallas, Emily <[email protected]>;
[email protected] <[email protected]> Cc: Raybould, Claire <[email protected]>; Christopher Ream <[email protected]>; The Hamilton Sharon Fees <[email protected]>; [email protected] <[email protected]> Subject: Re: 680 University Does Not Qualify For Builder’s Remedy

Resend of my 7/7/2025memail addressed to Emily Kallas, with typos corrected. No substantive changes.

Hi Emily,

7 This email examines the current Builder’s Remedy (BR) status of the pending application for the 680 University project (680 Project). I apologize for its length, but the issue is involved and complex.

Also, thank you in advance for including this email in the official records for 680 Project. I also request it become part of the official records for the companion 660 University project application, as a matter of creating notice. Although 660 University is a standalone project independent of the 680 Project, whether or not the 680 Project has BR status has an indirect effect on the considerations and decisions applicable to 660 University.

If the City Attorney has any opinion, reaction or response to this email, please communicate the same to me so that I may reply.

Question posed: Is the 680 Project and its application entitled to Builder's Remedy (BR) treatment under Gov. Code Section 65589.5?

Answer: The answer to the question posed is no (more precisely, no because of, and from and after the filing date of, 24PLN-00239).

Timelines and facts: Document C1_680_University_APPLY4 was filed on 6/11/2024 as the informational preliminary application under Gov. Code Section 69541.1(a). Document 24PLN-00239 was filed on 9/3/2024 as the formal full BR application for the 680 Project under Section 69541.1(e). In the interim between those two filings (on 8/3/2024), HCD certified the City's housing element. In October 2024, City issued comments on 24PLN-00239. Applicant has not responded to those comments and has not made any additional filings with respect to the 680 Project. City and the applicant entered into a Tolling Agreement on 12/2/2024, which put the 680 Project on hold from a time deadline/passage of time perspective.

C1_680_University_APPLY4, which meet the requirements of Section 65541.1(a), specified 110 residential units for the 680 Project. However, 24PLN-00239 specified only 88 residential units, exactly a 20% decrease from the 110 residential units specified by C1_680_University_APPLY4.

Reasoning and analysis:

A complete, filed preapplication complying with Section 69541.1(a) (and, if applicable, Section 69541.1(d)) plus a complete, filed formal full application based on the preapplication complying with Section 69541.1(e) are prerequisites for BR treatment of the 680 Project under Gov. Code Section 65589.5.

The version of Section 65589.5 in effect when C1_680_University_APPLY4 and 24PLN-00239 were filed (the 2024 Version) was significantly amended by a new version that went into effect on January 1, 2025 (the 2025 Version). Section 69541.1 also was amended effective January 1, 2025, but not in ways that are pertinent to the BR status of the 680 Project.

Per both the 2024 Version and the 2025 Version, BR is not available for the 680 Project unless its preliminary application under Section 65941.1(a) has a “deemed completion date” that is prior to the date of certification of the City’s housing element. Section 65589.5(h)(5), which also is the same in both the 2024 Version and the 2025 Version, provides a two alternative definitions of "deemed complete": "'deemed complete' means [1st alternative] the applicant has submitted a preliminary 8 application pursuant to Section 65941.1 or [2nd alternative], if the applicant has not submitted a preliminary application, has submitted a complete application pursuant to Section 65943." In the case of the 680 Project, operation of Section 65589.5(h)(5) turns on the effect on the 680 Project application of Section 69541.1(d).

Section 69541.1(d) requires an applicant to resubmit the informational preliminary application under Gov. Code Section 69541.1(a) if the overall size of the preapplication project (measured by the number of residential units in this case) “changes by 20% or more” . Section 69541.1(d) further provides “the housing development project shall not be deemed to have submitted a preliminary application that satisfies this section until the development proponent resubmits the information required by subdivision (a) so that it reflects the [excessive] revision.” Another way to look at how subsection (d) applies to the 680 Project is that, in effect, the 680 Project may relate back to and rely on CL_680_University_APPLY4 only if the number of residential units in 24PLN-00239 is within 89 to 121 units, inclusive. The 20% decrease in the number of residential units in the 680 Project made by 24PLN-00239 as filed (110 units down to 88 units) is outside this range.

Turning back to Section 65589.5(h)(5):
 The 1st alternative definition of “deemed complete” is not met by the 680 Project because the resubmission requirement of Section 69541.1(d) means, CL_680_University_APPLY4 notwithstanding, applicant has not submitted a complete preliminary application in compliance with Section 65941.1(a). In that regard, amending or replacing 24PLN-00239 to achieve the requisite minimum of 89 residential units does not satisfy Section 65941.1(d) since that subsection explicitly requires a Section 65491.1(a) resubmission, not a conforming change to the application to bring it within the allowed range of residential units. Also, 24PLN-00239 itself, even if so amended, would not meet the informational requirements of Section 69541.1(a).  The 2nd alternative definition is not met by Project 680 either, since 24PLN-00239 is not a complete application under Section 65941.1.
 Wthdrawing and replacing 24PLAN-00239 with a new application for 89 residential units that responds to all of City’s comments is not a viable solution. First, the new filing would not be allowed by the 180-day filing requirement under Section 69541.1(e)(1) (plus, the Tolling Agreement does not apply here; see the discussion below). Second, even if legally possible, the resulting deemed completion date would be after the date that City’s housing element was certified by HCD. Amending 24PLN-00239 to respond as needed to the City’s comments and increase the number of residential units to 89 also would be a moot point, for the same reason.  In any event, any action taken now to meet either definition of "deemed complete" would result in a deemed completion date that is after the date City's housing element was certified by HCD.

The combined effect of Sections 65941.1(a), 69541.1(d) and 65589.5(h)(5) can be summarized as follows:
 C1_680_University_APPLY4 satisfied the filing requirements of Section 69541.1(a), thereby initially creating a vested right to BR status for the 680 Project with a deemed complete date of 6/11/2024.
 The number of residential units for the 680 University Project was changed by 24PLN-00239, effective as of its filing date, from 110 units to 88 units (a 20% reduction). Per Section 69541.1(d), this 20% change rendered C1_680_University_APPLY4 incomplete for purposes of Section 69541.1(a), automatically by operation of law and not as a discretionary matter. As a result, the vested right to BR status for the 680 Project was lost, also automatically, upon the filing of 24PLN- 00239.
9  Per Section 69541.1(d), the preliminary application under Section 69541.1(a) for the 680 Project could be reinstated by a resubmission (and potentially perhaps in other ways, as discussed above), but the deemed complete date for the reinstated preapplication would be when that outcome was accomplished, not C1_680_Univerity_APPLY4’s original filing date of 6/11/2024, which renders that stratagem moot. In any event the resubmission or reinstatement did not occur.
 Although neither the 680 Project nor its application is entitled to BR status or treatment under Section 65589.5, 24PLN-00239 probably still survives and can be processed, as a "regular" (i.e., non-BR) application. However, the Tolling Agreement would not apply to that re-constituted application, since the Tolling Agreement is limited by its terms to BR issues.

The inevitable conclusion, and the singularly important fact, is that there is no completed preliminary BR application for the 680 Project under Section 69541.1(a) with a deemed completion date before the date the City’s housing element (or, for that matter, before 1/1/2025). Therefore, no BR vested right or status exists for the 680 Project and the 2025 Version does not apply.

Supplemental points:

Tolling Agreement: The Tolling Agreement has no effect on the above discussion or its outcome. The purpose and subject matter of the Tolling Agreement is pausing, for BR application purposes, the running of all filing and/or submittal and review deadlines applicable to the 680 Project. Application of Section 69541(d) discussed above was triggered by a status event (change in the number of residential units) not a timing event (failure to meet a filing, submission, or review deadline requirement). Also, the Tolling Agreement is inapplicable to any failure or omission to make a timely filing or submission with respect to Section 69541.1, since the Tolling Agreement requires reliance on the Agreement to excuse any such failure or omission — which is impossible since all the events and acts here relevant to that Section occurred before the Tolling Agreement was signed.

Definitional requirements: C1_680_University_APPLY4 specifies sufficient low-income units to satisfy the definition of a BR project under the 2024 Version but not the 2025 Version. 24PLN-00239, on the other hand, fails to designate sufficient low-income units to meet the definition of a BR project under either the 2024 Version or the 2025 Version. The reason is that 24PLN-00239 counted/included BMR units for moderate income, which is compliant with PAMC BMR requirements but irrelevant to satisfying the statutory BR requirements. Although 24PLN-00239 can be amended to correct this error, given the resubmission requirement applicable to C1_680_University_APPLY4, the change would not requalify the 680 Project for BR treatment with a deemed effective date before the date the City's housing element was certified by HCD.

Section 65589.5(f)(7)(B): As discussed above, the 2025 Version does not apply to the 680 Project. Even if it did, Section 65589.5(f)(7)(B) of the 2025 Version may not be relied upon to resurrect BR treatment of the 680 Project. First, by its terms, this Section is available only for a "housing development project [application] deemed complete before January 1, 2025" and the 680 Project does not meet this threshold requirement. Second, the provision only permits applicants "to revise their application so that the project is a builder’s remedy project, without being required to resubmit a preliminary application, even if the revision results in the number of residential units or square footage of construction changing by 20 percent or more." In this case, the “revise the application” wording of the subsection is blocking, since the problem stems from the application (24PLN-00239) itself, not a revision to an application that creates the 20% change. In addition, the wording of subsection (f)(7)(B) explicitly refers to changing an existing application that is not for BR project to convert it into one that is for a BR project. Any change in 10 reliance on this subsection with respect to the 680 Project would create a BR application whose deemed effective date is after the date City's housing element was certified by HCD.

Kinsey Haffner
555 Byron Street #210, Palo Alto, CA

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1 Kallas, Emily
From: Tina Frisco <[email protected]>
Sent: Tuesday, October 14, 2025 11:33 AM
To: Council, City
Cc: Kallas, Emily
Subject: 660 Universty Avenue
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To: Palo Alto City Counsel
From: Tina Frisco, RN, PA Resident
Re: Proposed Apt. Complex at 660 University
Date: October 14, 2025
I am a resident at Lytton Gardens, 649 University Avenue. I have serious concerns regarding the proposed apartment complex at 660 University.

My balcony and windows face University Avenue, as do those of many other residents residing here. We won’t be able to open our windows during construction (which will take months, if not years) due not only to exceedingly loud noise, but also to the amount of dust and dirt that will enter.

Keeping the windows closed will keep out only some of the dust and dirt, which can enter even when windows are closed. I know this because when I lived by the train station, soot built up on my windowsills even though the windows were closed.

I have asthma, and daily exposure to dust over an extended period of time will negatively impact my health. I could very well end up being hospitalized and requiring IV medication to assist me in breathing, which in turn could lead to intubation for a respirator, which in turn could lead to death.

Aside from health concerns, there also are traffic issues. University Avenue is already congested most of the time, especially since it’s a direct thoroughfare to Stanford Hospital. We must contend with myriad traffic noises daily: ambulances, fire trucks, buses, recycling and garbage pickup, street cleaning, loud (VERY LOUD) motorcycles, and much more. Adding at least 66 more vehicles to this area will impose severe if not dangerous risks on our community.

I think it’s commendable that the city is pursuing affordable housing projects. However, 660 University is not the place for this. My health will take a nosedive both during and after construction, as will that of many other residents here.

Please let me know when this issue will be placed on your agenda and opened to the public for discussion.

Thank you.
2 Tina Frisco, RN
649 University Avenue
Palo Alto, CA 94301

1 Kallas, Emily
From: Steven Atneosen <[email protected]>
Sent: Wednesday, October 8, 2025 1:51 PM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
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Hello Palo Alto PTC, we are Steven Atneosen and Caroline Dahllof, and we live in the Crescent Park neighborhood.

Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation, especially the 14 affordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community.

We hope the PTC will allow this project to move forward to council without further delay or modification.

Thank you for your leadership to support homes for all in our community,

Steven Atneosen
Caroline Dahllof
[email protected]
1 Kallas, Emily
From: Rob Schreiber <[email protected]>
Sent: Wednesday, October 8, 2025 1:13 PM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
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Dear members of the commission,

I support the 660 University project. While I live at the other end of Palo Alto, I am a frequent visitor to and patron of business in downtown. I appreciate the pressures from various directions and quarters concerning its evolution.

Downtown Palo Alto clearly needs to change with the times. The pace is too slow. The need for housing near jobs and transit, housing for people who can not buy at the price levels of current Palo Alto housing, and additional people of a range of ages and income brackets -- these are overwhelming, and they are made more so by the dramatic changes in the area's economy which contrasts to the slow pace of change in Palo Alto's plan, goals, vision, and processes. As a dear friend and long-time Greenmeadow neighbor and leader said to me, "It's a city, not a museum."

Our views, policies, and imagination must change with the deep and dramatic changes to the economics and demographics of the area. They have not. Put simply, we remain stuck, or nearly so, despite some changes that the city has instituted.

By the way, as a southerner I want to point out that the situation along El Camino in south Palo Alto remains dismal. On the southwest side of the road, between Page Mill and Arastradero, one still finds ancient decrepit one story commercial spaces, quonset huts, and at least four weed covered vacant properties. At $10 million per acre, this is a mind-boggling waste. Seventy years ago, builders and developers built the south Palo Alto that we live in to meet the needs of that time. That 1950s cityscape no longer meets the social needs. We have to let the market, developers and buyers, have a say in how to take these invaluable but underutilized spaces and put them to viable use. We have to do better.

Despite my desire to see changes happen faster, I remain grateful to you for your work and service to the community,
2 Rob Schreiber

1 Kallas, Emily
From: Rachel Miller <[email protected]>
Sent: Wednesday, October 8, 2025 4:24 PM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
CAUTION: This email originated from outside of the organizaƟon. Be cauƟous of opening aƩachments and clicking on links.

Hello Palo Alto PTC, my name is Rachel Miller and I live in Miranda Green.

Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportaƟon, especially the 14 aﬀordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing opƟons to our community.

I hope the PTC will allow this project to move forward to council without further delay or modiﬁcaƟon.

Thank you for your leadership to support homes for all in our community, Rachel Miller

Sent from my iPhone

1 Kallas, Emily
From: Owen Byrd <[email protected]>
Sent: Wednesday, October 8, 2025 11:48 AM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
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Hello Palo Alto PTC, my name is Owen Byrd and I live in Downtown North.

I am also a former member of the PTC.

Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community.

I am disappointed by opposition to the project from some residents of The Hamilton and hope you will not be swayed by it.

I remember when The Hamilton was proposed in the 1990s and was vigorously opposed by neighbors. I supported its development then, just as I support 660 University now, for the same reason -- we need more multi-family housing, especially downtown.

I hope the PTC will enable this project to move forward to the City Council without further delay or modification.

Thank you for your leadership to support homes for all in our community,

Owen Byrd
1 Kallas, Emily
From: Mert Dikmen <[email protected]>
Sent: Wednesday, October 8, 2025 11:29 AM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
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Hello Palo Alto PTC, my name is Mert Dikmen and I live in Crescent Park.

Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation.This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community.

As an owner of a home within three blocks of this development, I eagerly await its completion. It will anchor the downtown, increase retail foot traffic and will add to the vibrant character of the neighborhood. I hope the PTC will allow this project to move forward to council without further delay or modification.

Thank you for your leadership to support homes for all in our community, Mert Dikmen
1 Kallas, Emily
From: Mary Beth Train <[email protected]>
Sent: Wednesday, October 8, 2025 4:59 PM
To: Planning Commission
Cc: Council, City; Co-Presidents Lisa Ratner and Hannah Lu; Steve Levy; [email protected]
Subject: 660 University mixed-use project - YES
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I am writing to support the staff recommendation to move the 660 University mixed-use project forward to Council. The project proposes 70 residential units, including 14 BMR units.

As noted in a letter from Lisa Ratner and Hannah Lu, Co-Presidents, LWV Palo Alto, .."This proposal maintains the city's base requirement of 20% allocation to BMR units, with 2 very low income, 5 low income, and 7 moderate income units (studio, one and two bedrooms.) The downtown location close to shopping, dining, services, jobs and transit allows many residents to take downtown trips by walking and biking--a plus for the environment. Building 100% affordable units in Palo Alto by a non-profit developer would cost nearly $1million per unit and likely take more than 4 years. Building mixed income housing, as this project does following the city's inclusionary requirements, is currently the fastest way to increase BMR units."

This looks like the best iteration of this project yet, and I urge your support and action of the City Council to go forward with it. Palo Alto needs diversity in housing stock and in demographics. This project is a step in that direction. With downtown so close, residents will liven up the downtown as they use its businesses.

Thank you for your consideration, Mary Beth Train
Resident - 850 Webster Street, Apt. 420. Property owner - 3305 Middlefield Road

Mary Beth Train - Home office phone 650-324-7346 *voice only, not text* - [email protected]

1 Kallas, Emily
From: Kinsey haffner <[email protected]>
Sent: Wednesday, October 8, 2025 3:12 PM
To: Kallas, Emily; Planning Commission
Cc: Raybould, Claire; Christopher Ream; The Hamilton Sharon Fees; [email protected]
Subject: Re: 680 University Does Not Qualify For Builder’s Remedy CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Resend of my 7/7/2025memail addressed to Emily Kallas, with typos corrected. No substantive changes.

Hi Emily,

This email examines the current Builder’s Remedy (BR) status of the pending application for the 680 University project (680 Project). I apologize for its length, but the issue is involved and complex.

If the City Attorney has any opinion, reaction or response to this email, please communicate the same to me so that I may reply.

Question posed: Is the 680 Project and its application entitled to Builder's Remedy (BR) treatment under Gov. Code Section 65589.5?

Answer: The answer to the question posed is no (more precisely, no because of, and from and after the filing date of, 24PLN-00239).

Per both the 2024 Version and the 2025 Version, BR is not available for the 680 Project unless its preliminary application under Section 65941.1(a) has a “deemed completion date” that is prior to the date of certification of the City’s housing element. Section 65589.5(h)(5), which also is the same in both the 2024 Version and the 2025 Version, provides a two alternative definitions of "deemed complete": "'deemed complete' means [1st alternative] the applicant has submitted a preliminary application pursuant to Section 65941.1 or [2nd alternative], if the applicant has not submitted a preliminary application, has submitted a complete application pursuant to Section 65943." In the case of the 680 Project, operation of Section 65589.5(h)(5) turns on the effect on the 680 Project application of Section 69541.1(d).

Turning back to Section 65589.5(h)(5):
 The 1st alternative definition of “deemed complete” is not met by the 680 Project because the resubmission requirement of Section 69541.1(d) means, CL_680_University_APPLY4 notwithstanding, applicant has not submitted a complete preliminary application in compliance with Section 65941.1(a). In that regard, amending or replacing 24PLN-00239 to achieve the requisite minimum of 89 residential units does not satisfy Section 65941.1(d) since that subsection explicitly requires a Section 65491.1(a) resubmission, not a conforming change to the application to bring it within the allowed range of residential units. Also, 24PLN-00239 itself, even if so amended, would not meet the informational requirements of Section 69541.1(a).  The 2nd alternative definition is not met by Project 680 either, since 24PLN-00239 is not a complete application under Section 65941.1.
 Wthdrawing and replacing 24PLAN-00239 with a new application for 89 residential units that responds to all of City’s comments is not a viable solution. First, the new filing would not be 3 allowed by the 180-day filing requirement under Section 69541.1(e)(1) (plus, the Tolling Agreement does not apply here; see the discussion below). Second, even if legally possible, the resulting deemed completion date would be after the date that City’s housing element was certified by HCD. Amending 24PLN-00239 to respond as needed to the City’s comments and increase the number of residential units to 89 also would be a moot point, for the same reason.  In any event, any action taken now to meet either definition of "deemed complete" would result in a deemed completion date that is after the date City's housing element was certified by HCD.

The combined effect of Sections 65941.1(a), 69541.1(d) and 65589.5(h)(5) can be summarized as follows:
 C1_680_University_APPLY4 satisfied the filing requirements of Section 69541.1(a), thereby initially creating a vested right to BR status for the 680 Project with a deemed complete date of 6/11/2024.
 The number of residential units for the 680 University Project was changed by 24PLN-00239, effective as of its filing date, from 110 units to 88 units (a 20% reduction). Per Section 69541.1(d), this 20% change rendered C1_680_University_APPLY4 incomplete for purposes of Section 69541.1(a), automatically by operation of law and not as a discretionary matter. As a result, the vested right to BR status for the 680 Project was lost, also automatically, upon the filing of 24PLN- 00239.
 Per Section 69541.1(d), the preliminary application under Section 69541.1(a) for the 680 Project could be reinstated by a resubmission (and potentially perhaps in other ways, as discussed above), but the deemed complete date for the reinstated preapplication would be when that outcome was accomplished, not C1_680_Univerity_APPLY4’s original filing date of 6/11/2024, which renders that stratagem moot. In any event the resubmission or reinstatement did not occur.
 Although neither the 680 Project nor its application is entitled to BR status or treatment under Section 65589.5, 24PLN-00239 probably still survives and can be processed, as a "regular" (i.e., non-BR) application. However, the Tolling Agreement would not apply to that re-constituted application, since the Tolling Agreement is limited by its terms to BR issues.

Supplemental points:

4 Definitional requirements: C1_680_University_APPLY4 specifies sufficient low-income units to satisfy the definition of a BR project under the 2024 Version but not the 2025 Version. 24PLN-00239, on the other hand, fails to designate sufficient low-income units to meet the definition of a BR project under either the 2024 Version or the 2025 Version. The reason is that 24PLN-00239 counted/included BMR units for moderate income, which is compliant with PAMC BMR requirements but irrelevant to satisfying the statutory BR requirements. Although 24PLN-00239 can be amended to correct this error, given the resubmission requirement applicable to C1_680_University_APPLY4, the change would not requalify the 680 Project for BR treatment with a deemed effective date before the date the City's housing element was certified by HCD.

Section 65589.5(f)(7)(B): As discussed above, the 2025 Version does not apply to the 680 Project. Even if it did, Section 65589.5(f)(7)(B) of the 2025 Version may not be relied upon to resurrect BR treatment of the 680 Project. First, by its terms, this Section is available only for a "housing development project [application] deemed complete before January 1, 2025" and the 680 Project does not meet this threshold requirement. Second, the provision only permits applicants "to revise their application so that the project is a builder’s remedy project, without being required to resubmit a preliminary application, even if the revision results in the number of residential units or square footage of construction changing by 20 percent or more." In this case, the “revise the application” wording of the subsection is blocking, since the problem stems from the application (24PLN-00239) itself, not a revision to an application that creates the 20% change. In addition, the wording of subsection (f)(7)(B) explicitly refers to changing an existing application that is not for BR project to convert it into one that is for a BR project. Any change in reliance on this subsection with respect to the 680 Project would create a BR application whose deemed effective date is after the date City's housing element was certified by HCD.

Kinsey Haffner
555 Byron Street #210, Palo Alto, CA

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1 Kallas, Emily
From: Hillary Thagard <[email protected]>
Sent: Wednesday, October 8, 2025 1:52 PM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
CAUTION: This email originated from outside of the organizaƟon. Be cauƟous of opening aƩachments and clicking on links.

Hello Palo Alto PTC, my name is Hillary Thagard and I live in Midtown.

This project was introduced in 2021. It is Ɵme to act and end the delays. I hope the PTC will allow this project to move forward to council without further delay or modiﬁcaƟon.

Thank you for your leadership to support homes for all in our community, Hillary Thagard

1 Kallas, Emily
From: Heather Stewart-Bhardwaj <[email protected]> Sent: Wednesday, October 8, 2025 4:39 PM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
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Hello Palo Alto PTC, my name is Heather Stewart and I live in Crescent Park.

Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation, especially the 14 affordable homes.

This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community.

In the last year, I’ve talked to 4 childcare workers who care for my kids at the Ross road YMCA, my nanny, my son’s preschool, and Duveneck Elementary and they were struggling to find housing, live 30 miles away, or were rent burdened. This is a real problem and they work in our community. Just yesterday the person I spoke with at Duveneck Elementary PACCC told me he drives in from Dublin which takes him TWO HOURS one way on a workday. He can’t afford rent around here. The man who handles permits for city parks and rec lives in Pleasanton and drives in. If Palo Alto is actually serious about reducing carbon emissions and cares about people who work in our community and who want to be our neighbors, permit more housing.

I know many more people than childcare workers struggle with rent and this is ethically wrong. We need to make Palo Alto more inclusive and offer more housing for all income levels and stages of life, from college kids to affluent tech workers to middle income workers to elderly people who have to downsize. I welcome neighbors of all stripes and support adding affordable housing, irrespective of location and height. It’s the ethical, economically smart, and environmentally friendly thing to do for the long term health of our community.

I hope the PTC will allow this project to move forward to council without further delay or modification. It is imperative to build more housing and I am not sympathetic to complaints about housing being in the wrong context or too tall. We need it and it must happen regardless of neighbor concerns.

2 Please permit more and more housing so I don’t have to go through the heartbreak of trying to help my favorite ~65 year old childcare worker at the PA YMCA find an affordable apartment again.

Thank you for your leadership to support homes for all in our community,

Heather Stewart
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1 Kallas, Emily
From: Angela He <[email protected]>
Sent: Wednesday, October 8, 2025 12:00 PM
To: Planning Commission
Cc: Council, City
Subject: Support for Housing at 660 University
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Hello Palo Alto PTC,

My name is Angela He, and I am a resident of Palo Alto.

I hope the PTC will allow this project to move forward to council without further delay or modification.

Thank you for your leadership to support homes for all in our community, Angela He
1 Kallas, Emily
From: Christopher Ream <[email protected]>
Sent: Tuesday, October 7, 2025 12:53 PM
To: Kallas, Emily
Subject: 660 University - PowerPoint Slide Show
Attachments: 660 University - Ream - 20251006.pptx
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Emily,

Attached is a copy of my PowerPoint presentation for tomorrow’s PTC Hearing.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]

10/27/2025
1 Save the magnificent Coast Live Oak Tree
The Tree is defined by CPA as a PROTECTED TREE.It has a 50-inch diameter trunk, is around 60 feet tall, and has a mostly balanced canopy spreading nearly 90 feet across.Applicant’s Tree Protection Report, filed March 3, 2025, page 3 90 ft Diameter
Canopy is at the full 45 feet from the tree trunk
The CPA’s Tree Protection Zone (“TPZ”) standard is 41 feet for the Tree. 123
456
10/27/2025
2 Canopy if it were sliced off at the 41-foot TPZHowever, Applicant has arbitrarily decidedto pretend that 30 feet, not 41 feet, is a TPZ for this project.Applicant will cut back the canopy to 30 feet from the trunk, which will leave it touching the face of the building.

If Canopy is sliced off at 30 feet from the trunk to meet the face of the building Applicant won’t stop there.They will slice back another 6 feet to make room to install 6-foot deep balconies for every apartment.

If Canopy is sliced back another 6 feet to clear the balconies – now 24 feet from the trunkAnd the residents will demand that the canopy be cut back further to give clearance so that the residents and their guests can enjoy them without getting poked by branches.Assume another 5 feet of pruning. 789
101112
10/27/2025
3 Trim back another 5 feet to give clearance for the residents on their balconiesCount them –30 feet to the face of the buildingminus6 feetfor balconies and constructionminus5 feet clearance for people on the balconiesbrings us to only 19 feet of canopy from the Tree trunk remaining –-compared to the 45 feetwe started withThe Tree trunk, the small dark circle in the middle of the canopy, holds the limbs in place; in return each limb exerts a force trying to pull the Tree over. How strong those forces are depends on how much leverage each half of the canopy has –Leverage = weight x distance from trunk I will mention North and South frequently.North is the top of plan drawings, while South is the bottom.Moving North is going toward University Avenue.Moving South is going toward Hamilton Avenue and The Hamilton.The canopy extending over the property for the proposed project is all on the North side of the Tree. All of the canopy removal will be from the canopy on the North side of the Tree.The canopy on the South side of the Tree is all on the property of the neighboring dental office.There will be no removal at all from the canopy on the South side. There is general agreement by the project’s arborist and the arborist retained by The Hamilton that 25% of the whole canopy will be removed.But that 25% will all be removed from the canopy extending over the project’s property on the North side of the Tree. 131415
161718
10/27/2025
4 As you can see, there will be a major imbalance in the canopy trying very hard to tip the Tree over to the South, towards The Hamilton. Will the Tree be held up by its roots on the North side ? . Arborist OnSite® Horticultural Consulting, Inc. ISA Certified Arborist Report Submitted To: Rincon Consultants, Inc. 449 15th Street, Suite 303 Oakland, California 94612 Project Location: 660 University Avenue Palo Alto, California Submitted By: Robert Booty, Registered Member # 487 ISA Qualified Tree Risk Assessor The American Society of Consulting Arborists ISA Certified Arborist WC-4286 May 23, 2022 102030405060708090
102030405060708090TYP.17'-8 1/2"TYP.30'-0" OFFSETTREE PROTECTION ZONE9'-0TYP3 STALLSEVSE(INDEPENDENT PUZZLE)5 STALLS(INDEPENDENTPUZZLE)FUTUEVSR15'-0"15' MIN. / 30' MAX.) 192021
222324
10/27/2025
5 It gets worse –Applicant has said that for ground intrusions, it is okay to attack roots as close as only 20 feet from the Tree.“RootsThe 20-foot setback from #10's trunk for ground disturbance applies to any soil compaction, grading, subexcavation, overexcavation, trenching, drilling/auguring, storm drains, swales, etc. ”Applicant’sTree Protection Report, filed March 3, 2025, page 10 102030405060708090TYP.17'-8 1/2"TYP.30'-0" OFFSETTREE PROTECTION ZONE9'-0TYP3 STALLSEVSE(INDEPENDENT PUZZLE)5 STALLS(INDEPENDENTPUZZLE)FUTUEVSR15'-0"15' MIN. / 30' MAX.) 102030405060708090
203040506070809010050
5060708090100102030405060708090100FeetRoots now. 51 ft radius.Actually, the roots extend out well beyond the 51 feet recorded.Roots after construction.20 ft radiusArea is a direct function of the square of the radius.51 x 51 = 260120 x 20 = 400400 / 2601 = 15.4% 252627
282930
10/27/2025
6 Moving on to other concerns we have about this project.

Parking –89 stalls required– 69 stalls actually provided20cars roaming around looking for parking RED FLAG –NOTEALL INTERIOR DEMISING AND PARTITION WALL SUBJECT TO CHANGE PRIOR TO PERMIT SUBMITTAL AND APPROVAL29 more cars roaming after office space adjustment.Applicant’s plans for the First Floor appear to grant Applicant the option to configure 7,131 sq ft of more office space in the future after receiving approval of its plans without that additional office space.In other words, Applicant gets the high rental office space without providing the 29 parking spaces to go with it.A GRAVE, UNNECESSARY,INEXCUSABLE* * DANGER * * 36 BALCONIES OVER THE UNIVERSITY AVENUE SIDEWALK 313233
343536
10/27/2025
7 As David Hirsch so succinctly stated at the December 1, 2022 Architectural Review Board Hearing on this project:“This is too much building in too small of a space.”37 1 Kallas, Emily
From: Christopher Ream <[email protected]>
Sent: Sunday, October 5, 2025 10:08 PM
To: Planning Commission; Kallas, Emily
Subject: Re: 660 University - SECOND LETTER re Other than Tree Attachments: Ream Letter re Other Than Tree - 20251005.pdf Importance: High
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Commissioners and Emily Kallas,

Attached is my 6-page comment letter regarding concerns about the proposed development at 660 University Avenue where Smith Development proposes to build a development much too big for that small lot.

This is a second letter from me after my letter two days ago regarding the magnificent Coast Oak Tree.

Emily, could you please ensure that all the Commissioners are provided with this sufficiently before the PTC Hearing on Wednesday that they have adequate time to review it.

Thank you.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]

THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] October 5, 2025 Commissioners Planning and Transportation Commission City of Palo Alto, California Via: [email protected] [email protected] Re: PTC Meeting on October 8, 2025 660 University Project SECOND LETTER – Comments on Other than the Tree Commissioners, The Hamilton is a senior living (55+) condominium development which shares a small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all our neighbors. • Balconies over University Avenue • Byron Street Jammed – Traffic Congestion • Parking Basic Count Mechanical Lifts Parking for Office Size Adjustment ? No Parking for Fitness Center • Setbacks • Daylight Plane Ream – More Comments re the 660 University Project October 5, 2025 Page 2 of 6 Balconies over University Avenue Applicant shows 6-foot to 7-foot setbacks for the above-ground building along University Avenue. There are 36 balconies from the Second Floor to the Sixth Floor sticking out six feet into that “setback” so they come right to the edge of the public sidewalk or within one foot of it. They will have a clear glass railing set 3½ feet off the deck, with a clear glass sheet between the railing and the deck of the balcony. On warm, sunny Friday or weekend afternoons and evenings, there are going to be young people socializing on these balconies. The 3½ foot railing is an inviting place to rest your forearm as you hold a soft drink, a beer or a glass of wine. Geometry dictates that the drink is now another 6 -12 inches closer to the sidewalk floors below. Many residents in The Hamilton get some exercise by walking around our small block and their walk will pass under these balconies. I frequently see seniors from other parts of “Senior Corner” including this sidewalk as part of their walk. Please don’t drop a glass – you may kill someone. This is a grave, inexcusable, unnecessary danger. Those balconies must be removed or the building moved back away from the sidewalk. Byron Street Jammed – Traffic Congestion There is no parking on either University Avenue or Middlefield Road near the project. The Hamilton is on the short block of Byron between University and Hamilton and sees the parking problem every day. It is a narrow street to start with, but on every workday, every single parking spot on both sides of the street is filled all day long. This narrows the drivable room so that two cars going in opposite directions cannot pass. Every time a delivery vehicle stops on Byron Street during the day, it clogs and backs up Byron. The project does not provide any short-term parking for delivery vehicles, and with 70 rental units in the project’s building, most of which are 1BR or Studio, there are going to be a lot of deliveries, so Byron is going to get clogged and backed up many times a day. When The Hamilton was built in the 1990’s, they foresaw this problem and moved the front of the building back away from Byron Street and constructed a circular driveway that is wide enough and deep enough that a delivery van or Uber/Lyft car can park on the driveway, and then a second vehicle can park behind it or drive past it; the whole time leaving Byron Street free and clear.

Byron Street Building on the right is where project would be.

Ream – More Comments re the 660 University Project October 5, 2025 Page 3 of 6 Parking Basic Count Parking in downtown Palo Alto is a problem the City has been dealing with for years and continues to deal with. Applicant calculates that according to PAMC 18.52.040 a total of 81 parking stalls are required to serve the residents of the 70 residential units and 8 parking stalls to serve the workers in the non-residential office space on the ground floor, for a total of 89 stalls. But then Applicant invokes several arguments to reduce the number of stalls it is required to provide, starting with a 13% reduction claimed by TDM, down to only 69 actual parking stalls. Has the city staff carefully reviewed the TDM Applicant has submitted? Will it actually reduce the need for parking or is it only designed to reduce the daily use of cars: Is it designed to reduce the number of daily automotive commutes a person takes, while that person still owns a car to be used for weekend activity. Even though it may reduce daily congestion, that car still needs a place to park. Bottom Line – Applicant has cleverly eliminated 20 parking stalls (89 – 69 = 20). Those 20 stalls may have been eliminated in the project’s garage, but the cars have not been eliminated and the 20 cars that can’t find an empty stall in the project’s garage will be driving around downtown, commercial and residential, looking for a parking space and causing congestion that the TDM was supposed to reduce. My granddaughters and other family members might not come to visit me because of the inability to park nearby and friends will not want to come over as much as they used to. Mechanical Lifts Of the 69 actual stalls Applicant intends to provide, 54 of them are mechanical lifts where raising or lowering your car, or someone else’s car, is required. Now, 46 of those 54 lifts are “Stackers” on the second (bottom) floor of the underground garage. They are reasonably straight forward, but there is potential for operator error, and the likelihood of mechanical failure from time to time. Sheet A2.PO-C in Applicant’s PLAN 2 dated 08.08.2025 describes the system. The other 8 stalls come from a five-car “Puzzle” and a three-car “Puzzle” on the first floor. These are complex mechanical structures in which cars, your car and other people’s cars, are lifted and lowered, shifted to the left and shifted to the right. It seems almost inevitable that there will be operator error and somebody’s car will be damaged, probably not the then temporary operator’s car. And mechanical failure is almost certain. Interestingly, Applicant has not included any description of these “Puzzles.” Parking for Office Size Adjustment ? Applicant has shown only 1,984 ft2 of non-residential office space on the First Floor (see Sheet A2.1) and has calculated that the code requirement for that is the 8 parking stalls I referred to in the above section. Last year, up until Applicant added a Fifth and a Sixth Floor in October 2024, Ream – More Comments re the 660 University Project October 5, 2025 Page 4 of 6 the non-residential office space on the First Floor was 9,115 ft2 which calculated to a code requirement of 37 parking stalls, 29 more stalls than the current plans call for (37–8 = 29). I accept Applicant’s calculation of only 8 parking stalls as the First Floor is configured now.

Last Year – 9,115 ft2 Light blue is office space
Current – 1,984 ft2 Light blue is office space But, there is a warning flag – Applicant has inserted a notice on Sheet A2.1: ALL INTERIOR DEMISING AND PARTITION WALLS SUBJECT TO CHANGE PRIOR TO PERMIT SUBMITTAL AND APPROVAL If Applicant’s plans get approved, will Applicant then go back to the configuration of the First Floor it had last year and collect a lot of monthly rent on the additional 7,131 ft2 of office space without incurring the obligation for the additional 29 parking stalls? It will be tempting to Applicant. Emily Kallas, the City Planner on this project has informally told me that Applicant could only make minor adjustments not to exceed a total of 100 ft2. If this project is going to be approved, I strongly urge that the City Attorney get a binding written contract that limits Applicant to Ms. Kallas’s understanding of a maximum of 100 ft2 in adjustments. Without such a contract, we might have another 29 cars wandering around in addition to the 20 cars in the Basic Count section above.

Ream – More Comments re the 660 University Project October 5, 2025 Page 5 of 6 No Parking for Fitness Center Applicant has said that the 1,829 ft2 Fitness Center on the First Floor will be exclusively for use by tenants in the building (residential and office), and thus no need to calculate any additional parking stalls. So, while the City Attorney is at it, get a written contract affirming that the Fitness Center will remain exclusive to tenants. Setbacks At the April 18, 2024 and again at the December 5, 2024 ARB meetings on this project, there was a lot of discussion about the lack of proper setback along Middlefield Road. Applicant has moved the above grade portion of the building back to form a 25-foot setback along Middlefield as requested, but the underground garage still extends right up to the property line with ZERO setback and a minimal amount of soil fill above the garage structure. (See Sheet A3.3A.) Will the City of Palo Alto be able to make improvements to Middlefield Road in the future with this garage flush up against the road? Not likely. Applicant has offered to provide a small area at the Middlefield/University corner of the property as an “accommodation” if the City were to want to make improvements along Middlefield Road. Any improvement would most likely be to improve travel along Middlefield Road. But Applicant’s offer is only for 27 feet along Middlefield Road from the corner, leaving 46.5 feet still obstructed by the garage. (See Sheet A1.1A.) Applicant needs to make the offer to the City for the entire length of the property along Middlefield. This brings out the fact that the garage also abuts both University Avenue and Byron Street under ground with zero setbacks. Is this standard and acceptable? Daylight Plane There is a single family, one-story residence zoned RM-20 at 524 Middlefield Road adjacent to the project. Upon a 1/21/2022 review of Applicant’s initial filing, Samuel Gutierrez advised Applicant of the requirement to observe a 45° daylight plane. Applicant complied, and in the next submission of plans, cut back the portion of the Fourth Floor next to the neighboring house. The Fourth Floor has remained cut back and compliant with the daylight plane in all subsequent plans submitted by Applicant including the current submission. But Applicant has now added two additional stories onto the building raising the height up to 82 feet and disregarded the fact that these additional floors egregiously violate the daylight plane.

Ream – More Comments re the 660 University Project October 5, 2025 Page 6 of 6 The following is from Applicant’s submission. I have enhanced it to make the line of the daylight plane and the location of the neighboring house more visible.

Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Commission to require action to correct. Thank you for your consideration, Christopher Ream 3/32"=1'-0"
PLPLOFFICE LOBBYSPEED RAMP DOWNTO P2 LEVELUNIVERSITY AVE. 10'-0"
10'-6"OFFICE PARKINGRESIDENTIAL PARKING
STAIRBEYOND7'-9" TYP.45.0°55'-0"LINE OF DAYLIGHT PLANE3'-6" 3'-6"
9'-9"13'-6"10'-6"14'-6"7'-0"FENCE7'-0"9'-9"EL. -1'-6" (NAVD 88 EL. 45.5')NEIGHBORINGPROPERTY GRADEP1 LEVELP2 LEVELLIFT PIT SECOND FLOOREL. 14'-8"THIRD FLOORFOURTH FLOOREL. 24'-5"EL. 34'-2"FIRST FLOOREL. 1'-2" (NAVD 88 EL. 48.16')BASE FLOOD ELEV.EL. 0'-0" (NAVD 88 EL. 47')1'-2"12'-8 1/2" ± 8'-4 1/4"7'-6" MIN.EL. -12'-1 1/8" ±EL. -26'-7 1/8" ±EL. -33'-7 1/8" ± CORR.TYP.
9'-9"12'-3"55'-5"1'-6"FIFTH FLOOREL. 43'-11"SIXTH FLOOREL. 56'-2"T.O. ROOF SLABEL. 70'-2"14'-0"T.O. PARAPET / ELEV.EL. 71'-8"OVERRUN / STAIRST.O. RAILINGEL. 73'-8"T.O. MECH. SCREENEL. 80'-2"3'-6"6'-6"MECHANICALSCREEN 54'-6" +/-
3'-6"
2'-2"SHORING/SOLDIER BREAMS
1/32"=1'-0"
3/-UNIVERSITY AVE

MIDDLEFIELD ROAD
BYRON STREET64G CARTCOMPOST64G CARTCOMPOSTRC64G CARTCOMPOST 64G CARTCOMPOST96G CARTWASTE96G CARTRECYCLING96G CARTWASTE96G CARTRECYCLING

ARCHITECTSKORTH SUNSERI HAGEY

SHEET NUMBERSCALEPROJECT NUMBERSHEET TITLE
DATENO.ISSUES AND REVISIONSDESCRIPTION

ARCHITECTSKORTH SUNSERI HAGEY
21003PLANNING SUBMITTAL12.01.22PLANNING RESUBMITTAL #105.13.22PLANNING RESUBMITTAL #208.15.22PLANNING RESUBMITTAL #408.28.23PLANNING RESUBMITTAL #510.31.23PLANNING RESUBMITTAL #612.20.23PLANNING RESUBMITTAL #702.07.24AD HOC REVISIONS05.02.24PLANNING RESUBMIITTAL #809.30.24

524 MIDDLEFIELD A3.3B ENHANCEMENT OF VISIBILITY OF LINE OF DAYLIGHT PLANE AND 524 MIDDLEFIELD MADE BY CHRISTOPHER REAM

1 Kallas, Emily
From: Christopher Ream <[email protected]>
Sent: Saturday, October 4, 2025 4:47 PM
To: Planning Commission; Kallas, Emily
Subject: 660 University - "Protect the Coast Live Oak"
Attachments: Ream Letter re Tree - 20251003.pdf
Importance: High
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Commissioners and Emily Kallas,

Attached is my 5-page comment letter regarding the magnificent Coast Live Oak next to the property on which Smith Development proposes to build a development much too big for that small lot. There are three attachment to the letter; all together with the letter totaling 33 pages.

Emily, could you please ensure that all the Commissioners are provided with this sufficiently before the PTC Hearing on Wednesday that they have adequate time to review it.

Thank you.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]
THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] October 3, 2025 Commissioners Via: [email protected] Planning and Transportation Commission [email protected] City of Palo Alto, California Re: PTC Meeting on October 8, 2025 660 University Project Protect the Coast Live Oak Commissioners, My wife Anne and I have been Palo Alto residents for more than 54 years and have been residents of The Hamilton for the past seven years. The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (“HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block. David Babby, Applicant’s arborist, correctly reports the Tree’s trunk is 50 inches in diameter and its mostly uniform canopy stretches out 90 feet in diameter and is approximately 60 feet high. The Tree is on 517 Byron Street but abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is much larger. The Tree is several hundred years old and is deemed a protected tree by the City of Palo Alto. The Tree brings shade and joy to us and everyone else on the block. Applicant’s proposal to build a large building close to the Tree will put it in grave danger, and we need to protect it. There are three Attachments to this letter: A – Impact Analysis of Proposed 660 University Project, dated September 25, 2025, by Walter Levison Consulting Arborist (hereinafter referred to as “Levison Analysis”). B – Selected pages from Robert Booty’s GRP Scan, May 23, 2022 C – Mathematical Calculations of Circle Segments 660 University Project Protect the Coast Live Oak October 3, 2025 Page 2 of 5 TPZ – Tree Protection Zone Applicant’s arborist David Babby prepared a “Tree Protection Report” dated November 19, 2021 which was filed with Applicant’s original application in December 2021, and was updated with an updated version dated February 7, 2024 which Applicant has included with all subsequent sets of plans filed with the City. (I will refer to that report as “Babby Report”.) The Babby Report acknowledges that the Tree is a “protected tree” under PAMC 8.10 because of its 50-inch trunk and discusses the Tree repeatedly. The Palo Alto Tree Technical Manual, Section 1.36 requires a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Applicant acknowledges this 41-foot TPZ requirement (Babby Report, p. 9), but notwithstanding that, Applicant has gone ahead and arbitrarily drawn a deficient TPZ of only 30 feet on its plans and positioned its proposed building right next to that 30 feet. That is 11 feet less than the protection required by the City of Palo Alto. Canopy The Tree has a beautiful canopy that stretches over the site, a mostly balanced canopy spreading nearly 90 feet across. Babby Report, p.3. With a 90-foot diameter, the canopy has a radius of 45 feet and because the Tree abuts the property line, its canopy stretches that 45 feet over the proposed site. The TPZ applies to the canopy as well as the root structure, but Applicant has used its fake 30-foot TPZ to bring the exterior wall of the building up to 30 feet from the trunk of the Tree, slicing off 15 feet of canopy. But then Applicant’s plans show that every apartment has at least one balcony sticking out six feet from the exterior wall. First, Applicant will need to slice off another 6 feet of the canopy to make room for those balconies. Then, the building’s residents are not going to tolerate the Tree intruding their balconies, so the Tree will be pruned back to provide airspace clearance to maintain a free and clear space around the balcony, and you can be sure the Applicant will cut the Tree back so that there is at least 5 feet of clearance between those balconies and the Tree. The result – Tree’s beautiful canopy now stretching 45 feet over Applicant’s property will be cut back 26 feet or more (15 + 6 + 5) and will then extend only 19 feet towards the proposed building. Applicant says it will cut back 15% of the canopy to clear the proposed building and then another 10% to allow room for construction, for a total of 25%. Babby Report, p.10. Walter Levison Consulting Arborist retained by the Hamilton Homeowners Association estimates 20% to 30% of the canopy will be removed. See Attachment A, the “Impact Analysis of Proposed 660 University Project,” dated September 25, 2025, by Walter Levison Consulting Arborist, p. 8 (hereinafter referred to as “Levison Analysis”). So, we have a basic agreement that the proposed project will cause an estimated 25% of the canopy to be lost. 660 University Project Protect the Coast Live Oak October 3, 2025 Page 3 of 5 Applicant admits it will have to cut off many limbs and branches, a 17-inch diameter limb, an 8-inch diameter limb, a dozen or so smaller branches ranging in size from 1 to 6 inches in diameter. Babby Report, p.10. This will raise a serious risk of infection. “Internodal cuts performed on the subject oak will have a severe negative effect on the tree’s overall health and structure, since relatively large diameter internodal cuts are subject to decay and dieback over time, with pests and pathogens able to enter into the pruning cut faces whereby wood decay progresses downward and into the remaining stem cross sectional area, further reducing tree stability and health (vigor).” Levison Analysis, p.8 Root Structure Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reported that his GPR (ground penetrating radar) root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment B). This is consistent with the general assumption that a tree’s roots extend out 2x to 3x the drip line of its canopy (Levison Analysis, p.3) which would mean the Tree’s roots are going on out to 90 feet to 135 feet. But the Tree’s root structure on the north side, the side facing the proposed project, will be boxed in and severely cut back by the proposed two-story underground garage: auto ramp 32 feet to the west, subterranean exterior wall of the garage 36 feet to the north, and another auto ramp 30 feet to the east. See Sheet A2.P1 of Applicant’s plans. In addition, notwithstanding Applicant drawing a 30-foot radius circle on its plans, the Babby Report discloses that Applicant intends to disregard even that fake TPZ and there will be only a 20-foot setback from the Tree’s trunk for any “ground disturbance and that applies to any soil compaction, grading, subexcavation, overexcavation, drenching, and drilling/auguring.” Babby Report, p.10. In other words, if a construction crew is at least 20 feet from the Tree, they will be free to rip out as many roots as they like notwithstanding the deadly effect on the Tree. The most optimistically possible outcome for Applicant would be they end up with a semicircle of roots on the north side of the Tree with a radius of 25 feet (though nothing is stopping them from cutting that radius down to 20 feet, the 20-foot setback.). Even if we pretend that the Tree’s roots all stopped at 51 feet rather than extending out to the normal 90 feet or 135 feet, the root structure on the north side of the Tree would be reduced to only 25% of what it is now, a loss of 75% of those roots. ((∏x25x25)/(∏x51x51) = 24%) And those numbers are based upon the current root structure stopping at 51 feet; it would be much worse if we used the more likely 90 to 135 feet. 660 University Project Protect the Coast Live Oak October 3, 2025 Page 4 of 5 Tree Failure “It is WLCA’s [Walter Levison Consulting Arborist] professional opinion that the tree’s vigor would be negatively impacted to a “severe” degree as a direct result of proposed site work as currently described on the June and August 2025 sets of plan sheets, resulting in tree #10 potentially falling into a spiral of condition decline from which it cannot recover.” Levison Analysis, p.13. Levison’s prediction of a spiral of condition decline comes from the significant reduction of the water, minerals and sunlight the Tree needs. I also see a possibility of a sudden, radical failure – the Tree toppling over in a windstorm. As Applicant’s arborist reports, the Tree now has a balanced canopy. Babby Report, p.3. That balance will be completely lost if 25% of the canopy is sliced off. That is 25% of the whole canopy, but all of the removal is going to be from the north half of the canopy. Simple math tells you that 25% of the whole will be 50% of the north half. With the south half of the canopy now twice as large as the north, the Tree will want to tip over to the south towards The Hamilton. It gets worse: Leverage. The force effect of the weight of the canopy is a straight function of how far out that weight is from the Tree trunk: the further away from the trunk, the more force it will be exerting. You remember playing on a seesaw as kid: you could balance with your friend who weighed more or less than you by the heavier one sliding in towards the fulcrum (pivot point) and/or the lighter one sliding back away from it. Or if you don’t remember that, reach out and grab that water glass. When your arm is out straight away from your body it feels heavy, but when you pull your arm back in close to your body it feels much lighter. Applicant cutting back the canopy on the north side results in the canopy that is left there being close to the Tree’s trunk. The lighter kid has slid towards the fulcrum, not away from it. The dominance of the south side force over the north side force is even greater. I did some calculations of south side vs. north side and the results are in the table on the next page. “25% Agreement” is both arborists estimating a 25% cutback, and “Cutback to give balcony clearance” is my explanation on page 2 above of the need to maintain a free and clear space around each balcony. 660 University Project Protect the Coast Live Oak October 3, 2025 Page 5 of 5 See Attachment C for the details of how I calculated this. How could the Tree possibly survivor such radical, unbalanced decimation of its canopy? Maybe, just maybe, nature gave it a strong root structure on the north side to hold up the against the force trying to tip it over to the south. We know from Robert Booty’s GRP Scan (Attachment B) that there is a strong root structure on the north side extending out to at least 51 feet and probably more to maybe 90 feet or even 135 feet. But wait, Applicant plans to cut off those roots, none to survive past 30 feet, many cut off at 20 feet. That will reduce the root structure down to 25% of what it is now, probably less. See page 3 above. There is no way the Tree will survive if Applicant is allowed to go forward with its plans. Conclusion If Applicant’s plans are approved and it goes forward, how soon will the Tree topple over and crash into The Hamilton and others? It would destroy the Cardinal Dental office next to it and badly injure and maybe kill anyone in those offices at the time. The Hamilton community strongly opposes this application for over-excessive development on our small block and urges the Commission to require action to correct Thank you for your consideration, Christopher Ream Ratio of South’s Unbalanced Tipping Force To North’s Partial CounterBalance Force South North 25% Agreement Area of remaining canopy after segment is cut off 3,181 1,591 Distance from center of remaining canopy to tree trunk 18.18 8.9 FORCE (Area x Distance) 59,803 14,155 4.2 : 1 Cutback to give balconies clearance Area of remaining canopy after segment is cut off 3,181 1,658 Distance from center of remaining canopy to tree trunk 18.18 9.3 FORCE (Area x Distance) 59,803 15,419 3.9 : 1

660 University Project Ream – Protect the Coast Live Oak October 3, 2025 A"achment A Walter Levison Consul0ng Arborist Impact Analysis of Proposed 660 University Project September 25, 2025

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

1 of 19
Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Date: 12/15/2023
Revised: 9/25/2025

Impact Analysis of Proposed 660 University, Palo Alto Site Plan Project Work on One (1) Off-Site Coast Live Oak (Quercus agrifolia) Specimen (Project Tree #10, Palo Alto City Tree Tag #1572)
at
517 Byron
Palo Alto, CA
Mr. Chris Ream, President
The Hamilton Homeowners Association
555 Byron
Palo Alto, CA
[email protected]

Dear Mr. Ream,

The following written letter report is the single deliverable prepared by Walter Levison, Consulting Arborist (WLCA) per your request as an association with members residing immediately adjacent to the proposed multi-story 660 University project.

The original letter report submitted by WLCA was dated 12/15/2023 as noted on this page.

The following reported information has been updated as of 9/25/2025, after WLCA’s thorough review of the most currently available plan sheets that are public record, accessible via City of Palo Alto’s official download site, such as June and August 2025 iterations of the applicant’s plan sheets:
https://aca-
prod.accela.com/paloalto/Cap/CapDetail.aspx?Module=Planning&TabName=Planning&capID1=21PLN&capID2=00000&capID3=00 341&agencyCode=PALOALTO&IsToShowInspection=no

(Record 21PLN-00341)

WLCA also reviewed:

A. City of Palo Alto Urban Forestry Staff Catherine Mondkar’s testimony via Youtube, available as public record, from a formal hearing that occurred on 4/18/2024.

B. David Babby Consulting Arborist’s most current arborist report iteration 2/07/2024, noted in this report as the “DB” report.

C. Robert Booty arborist report dated 5/23/2022 which analyzed woody root extent using ground penetrating radar (GPR) machine, noted in this report as the “RB” report.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

2 of 19
Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Background and Assignment

The proposed private development project stated above proposes to demolish various existing office buildings and parking lot areas, and build an underground parking facility with residential facility direction over the garage footprint.

WLCA’s assignment was to determine whether the site work as currently proposed per the set of plan sheets (dated 2025) would cause severe or otherwise irreversible injury to the subject oak specimen to such as degree that it would be expected to fall into a spiral of decline from which it could not recover, as a direct result of the proposed site redevelopment work. WLCA visited the site on 12/13/2023 to archive digital images, create a tree map markup showing actual site-verified canopy dimensions (rough approx.), and confirm existing site conditions. A written report was originally submitted in 2023.

The project encompasses three lots, 660 University, 680 University, and 511 Byron. An adjacent lot at 517 Byron just south of the proposed work area exhibits a relatively very large “veteran tree” coast live oak (Quercus agrifolia) referenced by David Babby (the DB report) as tree #10 (City tag #1572), a specimen in good overall condition (62% out of 100% possible) as visually assessed by WLCA, with a canopy spread that is equal to the largest coast live oak specimens ever assessed in the author’s entire 25 year professional consulting career (see digital images below in this report showing the +/- 90 foot diameter spread canopy).

WLCA originally reviewed the private development proposed plan sheets dated 10/31/2023 (planning resubmittal #5) which were downloaded from the City of Palo Alto website, and an arborist report by DB dated 11/19/2021, which does not actually contain any site plan sheets (DB used a topographic survey sheet for his initial site tree map markup).

WLCA subsequently reviewed 2025 iterations of the project plans downloaded from the City of Palo Alto, as noted above in this letter report, as well as an updated DB Consulting Arborist report dated 2/07/2024, which I will refer to as the “DB” report. That DB report includes the City-required tree protection plan sheets often referred to as the “T” set of sheets, that detail project arborist recommendations as well as City standard tree protection methods required to be implemented as project conditions of approval (PCOA), which are legally binding conditions required to be performed by applicant project teams applying for site entitlements.

Digital images archived by WLCA in December 2023 are included in this report for reference of pre-project conditions.

Basic Data

Diameter: Assume 50 inches, per DB report. (+/- 4 feet).

Spread: Approximately 90 feet total diameter, per DB and WLCA reporting.

Health (Vigor): 70% per DB, 80% per WLCA.

Structure: 40% per DB, 50% per WLCA.

Overall Condition Rating: 50% (fair) per DB, 62% (good) per WLCA.

Live Twig Density and Live Foliar Density: Good.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

3 of 19
Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Additional Tree Information per WLCA’s Visual Tree Assessment (VTA) 12/13/2023 and Research

Foliage hangs down to 15 to 25 feet above grade at 45 feet radius north of mainstem edge.

Multiple mainstems exhibit wide angle saddle shaped (i.e.”normal”) attachment forks between 10 and 15 feet elevation above grade. These stems are somewhat upward oriented.

Buttress root flares at root crown appear normal, though root system extent and condition are essentially unknowable due to hardscape presence over a large percentage of actual root zone. It is hypothesized that the actual extent of root zone is at least 2x to 3x the 45 foot canopy radius in terms of lateral distance in most directions out from trunk 1, based
on both Arboriculture 4th Edition (2004), and on WLCA’s past 25 years of construction site consulting experience with coast live oak specimens on older sites with older less-compacted root zone conditions, where historical building foundations and parking lot baserock base sections were constructed to far less strict standards than modern engineer specifications.

There may be extensive rooting occurring out through various private lots that adjoin the 517 Byron lot on which tree #10 stands, with lateral woody roots extending from tree #10 underneath various retaining wall footings and building footings, out to underneath existing asphalt parking lot surfacing, etc. (Refer to the RB report detailing roots mapped via use of a ground penetrating radar GPR machine).

This Palo Alto site probably has one of the best soils in the entire Bay Area in terms of allowing for fast growth of native oaks. See the digital images section of this report for an overlay map created by WLCA using various online sources and the USGS soil map shows how groundwater at this location is relatively high in elevation (25 foot groundwater contour), and shows existing roads, historical streams, and red dot plots where a past survey by others indicated locations of extremely old native valley oak specimens for reference.

What this all means is that the proposed project site has very good growing conditions for native oaks with a high groundwater table elevation contour and gravelly alluvium soil associated with historical waterways which drains relatively quickly and may also exhibit relatively good aeration related to the larger material components of the soil.

Expected Construction-Related Tree Root Zone Impact and Canopy Impact Analysis Based on the most current 2025 Set of Proposed Plan Sheets

• Canopy:

Expect 20% to 30% of canopy live wood and foliage to be removed to clear southward-extended balcony construction, garage vertical wall construction, foundation footing construction for main building structure, vertical exterior walls along the south side of the residential structure, and an additional +/- 10 feet of horizontal width required to be totally cleared up to roof peak elevations as a “construction corridor” airspace for exterior work, scaffold erection, and bucket lift machinery use (based on WLCA’s past projects to date, which required between 6 feet and 15 feet of horizontal clearance as construction corridors around building exterior walls, between soil surface grade and the roof peaks).

1 Per Harris et. al. 2004. Arboriculture 4th Edition. Prentice Hall. Upper Saddle River, New Jersey, USA.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

4 of 19
Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Note that the curvilinear section of garage entry ramp, although it is below grade elevation, may actually require tall vertical machinery clearance directly above the proposed retaining wall excavation cut locations, resulting in further clearance pruning of the tree #10 northwest corner of canopy (not verified). This is based on past projects overseen by WLCA involving underground parking garage retaining wall construction in the Bay Area.

Total expected canopy loss will likely result in a remnant canopy with 20 to 25 feet of north, northeast, and northwest extension from mainstem base, whereas existing canopy is +/- 45 feet radial extension in those directions. This is a loss of roughly 50% from those sections of the canopy, and a loss of roughly 25% to 30% of the overall canopy biomass.

The DB 2024 arborist report notes an expected loss of some 15% of the existing canopy (assumedly referring to a 15% loss of the total canopy biomass as a whole), though it is not clear if the DB report is also accounting for loss of canopy due to pruning to clear airspace related to an unknown width “construction corridor” between the tree #10 protection zone fencing, and the proposed two balconies that will extend toward the tree. Construction corridor airspace clearance typically requires full clearance to unlimited height, in order to allow for use of lift machines to perform exterior finishing work such as window installations, balconies, painting, etc. In WLCA’s experience, the width of a construction corridor can range anywhere from 5 feet to 20 feet in horizontal width, depending on the types of machinery required to complete the exterior finish work. In some cases, a construction elevator is required to be installed along the exterior of a new building, which may require up to 20 feet horizontal width.

The DB report notes there will be significant pruning involved during the airspace clearance work, including a 17 inch diameter stem, an 8 inch diameter stem, and a dozen or so stems ranging from 1 to 6 inches diameter each. Again, this appears to only account for pruning to clear the new proposed building and balconies, but is assumedly not accounting for any construction corridor width airspace clearance tree pruning that may require an additional 5 to 20 feet in horizontal width to be completely cleared to unlimited vertical elevation (not verified).

• Roots:

Expected subgrade work will encroach to within the City of Palo Alto “10 times diameter” tree protection zone on the north side of tree, inside which special methods/materials/monitoring is required for site construction work.

Extent of root zone compromised by the various elements of proposed work (garage wall excavation using vertical shoring, landscape decking, landscape irrigation, landscape plant and tree installation, etc. is expected to be moderate to severe, depending on actual cut depths and depending on whether machinery and personnel are allowed to enter into the TPZ and compact the root zone in the north area of TPZ.

Note that the actual extent of roots may or may not be 2x to 3x the tree canopy dripline radius distance northward from trunk (e.g. 90 feet to 135 feet radius), and is currently obscured by hardscape and not able to be verified in terms of lateral distance of growth. The RB ground penetrating radar report root maps suggest that this is the case.

See the 2022 RB report root map pages reproduced below in this WLCA report body for reference.

Critical Root Zone (i.e. “CRZ”) in terms of structural root plate retention during work on a single side of a tree, is typically recommended as a so-called “tree protection zone” (TPZ) per 2016 BMP booklet “Managing Trees During Construction, 2
nd Edition” of at least 6x, 8x, or 10x2 the diameter as a lateral offset from edge of mainstem, which in the case of tree #10, calculates to roughly 24 feet, 32 feet, or 40 feet radius, depending on which standard is used.

Per the BMP book, coast live oak has a good tolerance of construction damage, but as a mature specimen, the TPZ multiplication factor that is most appropriate for use for tree #10 is either the 8x or the 10x factor (i.e. a TPZ radius of 32 feet radius, or 40 feet).

2 The applicant’s sheet L4.2 does indicate that the standard City-required tree protection zone (TPZ) is 10x trunk diameter, which equates to 41 feet offset radius, per the DB report.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Cumulative Impact vs. Root or Canopy Impact Alone

Note that in the case of the 660 University project, the severe extent of clearance pruning creates a cumulative impact in terms of loss of tree condition rating, such that the combined root zone impact plus tree live canopy loss impact is relatively severe, even though the majority of the work would occur north of the so-called “Tree Protection Zone” of 32 feet offset radius (see WLCA markup showing hard construction related impact to 30 feet offset radius from trunk edge, which is slightly within a TPZ of 8x diameter offset).

The DB report does not address cumulative impacts, and instead considers “roots” and “canopy” to be separate and distinct from one another, with a +/- 15% loss expected to each of roots and canopy per the DB report. In WLCA’s experience, construction related impacts to roots and canopy are neither separate nor distinct, and should instead be added together as a combined cumulative impact to the tree, bringing the actual impact to somewhere in the range of 30% to 40% or greater “cumulative impact”, which is “severe”. 3 TPZ Radius / Multiple Distances Cited

It is not clear why the DB 2024 arborist report continues to reference various different tree protection zone (TPZ) offset radius distances out from the trunk edge of oak #10.

The actual required TPZ per City of Palo Alto, established in the City tree technical manual, is 10x diameter offset from mainstem, which equates to +/- 41 feet offset radius from mainstem edge of oak #10.

However, per the DB 2024 report, the project as proposed per current plan iterations provides only some 30 feet offset from oak #10 mainstem as a horizontal separation between the tree mainstem edge and the new building footprint plus garage, and only a 20 foot radius protection offset from tree mainstem edge for limit of “ground disturbances” beneath the existing asphalt surfacing materials.

This multi-tier TPZ setup will not be in compliance with City of Palo Alto’s TPZ standards, unless very significant tree impact mitigation measures are adhered to with robust arborist site monitoring throughout the entire planned project buildout from start to finish, for all work that occurs within zero to 41 feet offset radius from the oak #10 mainstem edge.

Note also that the proposed terrace/garden element of the project does not comply with even the shortest of the three (3) TPZ radii (i.e. the 20 foot offset radius TPZ), given that the proposed terrace will encroach to within just a few feet of the oak #10 mainstem edge, violating even this minimal 20 foot TPZ offset.

Soil Compaction within the Critical Root Zone (CRZ) / Tree Protection Zone (TPZ)

3 This form of cumulative tree impact analysis was used by WLCA during contract consulting work for Barrie D. Coate and Associates of Saratoga, CA, under direction from firm Staff. Barrie D. Coate and Associates was considered at that time to be the preeminent arboriculture consulting firm in the Bay Area, and cumulative tree impacts were routinely determined in this manner.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Byron and the underground parking garage wall, etc.). Therefore, it is expected that soil compaction of a high degree will likely occur in the north section of the tree #10 root zone, within the CRZ/TPZ offset radius, causing additional reduction in overall tree health and structural condition as soil oxygen pore space is compacted and root zone root growing conditions end up suffering as a result of loss of oxygen pore spaces within the tree root growth section of the soil profile (i.e. mainly the uppermost two feet of the soil profile, but potentially down to 4 or 5 feet or more below soil surface grade elevation in native Palo Alto area historical riparian cobble type soils).

From a read of the RB ground penetrating radar report, one might think that the root system of the tree is only growing lateral woody roots at great depth (the report maps roots at highest density at distances some 5 to 7 feet below grade). However, trees do have extensively branches root systems with fine absorbing roots 1/32 inch to 1/16 inch diameter each, for example, which would assumedly not show up on the GPR root maps. The fact that the existing asphaltic surface parking lot over which the GPR testing was performed is considered a fill soil pad of great depth above the original tree #10 root system grade elevations, this does not mean that woody roots and/or fine absorbing roots are only present at great depth.

In WLCA’s 27 years of consulting experience, the layer of older baserock base section just beneath older parking lot asphalt (especially very old parking lots from the early to mid 20 th century) is a layer with conditions favorable to tree root extension and expansion growth in general. WLCA assumes that the root system of oak #10 extends up into the uppermost elevation of the soil profile, just beneath the asphaltic layer, where soil compaction is lowest, and oxygenation is highest.

• TRAQ Risk:

The removal of +/-25% to 30% of the overall canopy biomass of tree #10 for airspace clearance as noted above, will cause southward lopsidedness of the currently-symmetrical canopy tree specimen of extremely large spread radius (45 feet radius), resulting in increased load forces acting on the north side (“tension” side) of the root system. The root system will have been compromised to an unknown degree during site work (underground parking garage wall excavation, building foundation footing excavation, landscape development, and possible adjustments to or demolition of the existing brick retaining wall that separates 517 Byron from the proposed 660 University project site.

Risk of whole tree failure mode and impact with targets to the south of the mainstem location will be necessarily increased and elevated due to these site plan work activities.

Risk of individual stem failure and impact with various ground targets will over time be increased and elevated, due to the required clearance pruning through the north side of the canopy to clear scaffolding, bucket lift machinery, balconies, and the new building exterior wall plus underground parking retaining wall work that requires vertical machinery airspace clearance.

Very large diameter pruning cuts will be made to accomplish the work, ranging from a few inches diameter each, to as much as 17 inches diameter or more, on some stems that extend northward into the proposed project airspace area.

Pruning cuts of this relatively large diameter will allow for fungal wood decay-causing pathogen entrance into the stems via these open cut wounds, resulting in extensive decay column formation over time that progresses down into the stems from the cut wounds.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

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2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (6/20/2025, 8/08/2025).

1. EXTERIOR: The proposed exterior of the building (solid lines) will be approximately 30 feet west of the subject oak tree mainstem edge per sheet A0.2A.

2. BALCONIES: The proposed edge of two new multi-story balconies (gray dashed line rectangles extending map- downward from the building exterior on this sheet) will be approximately 24 feet and 26 feet west of the subject oak mainstem edge, per sheet A0.2A.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (CONTINUED)

3. CONSTRUCTION CORRIDORS ETC.: An additional minimum 5 horizontal feet of airspace clearance (or possibly far greater) is expected to be required to be able to build the proposed balconies, build other exterior features per plan and maintain a free and clear space around the balconies over time. This means the actual extent of pruning will be to a distance of 17 feet west of the mainstem edge of the subject oak specimen, removing at least 20 or more horizontal feet of the existing live canopy biomass, which is a loss of approximately 54% (or more) of the west quadrant of the canopy.

Note that the pruning cuts are likely going to consist of “non-ANSI A300 conforming cuts”, since there are few if any remaining stem forks at which to cut back to at that location of 17 feet west of the mainstem, which means that the cuts will then have to be made using “internodal cuts”, performed at locations between branch forks: a poor pruning technique which is often referred to as shearing, topping, or shaving, hedging, etc. when performed on shrubs. See the WLCA markup at right, showing approximately where these cuts might be performed (shown to non-accurate scale, arrows point to locations that are “roughly” 17 feet west or so of the subject oak mainstem edge).

Internodal cuts performed on the subject oak will have a severe negative effect on the tree’s overall health and structure, since relatively large diameter internodal cuts are subject to decay and dieback over time, with pests and pathogens able to enter into the pruning cut faces whereby wood decay progresses downward and into the remaining stem cross sectional area, further reducing tree stability and health (vigor).

The canopy will be suddenly susceptible to sunscald/sunburn as sunlight will be able to penetrate deeply into the west side of the canopy once clearance pruning is performed to +/- 17 feet west of the mainstem edge, likely resulting in additional decline/death of remaining residual live wood and foliage in that west quadrant of the canopy.

Coast live oaks as a species do tend to response relatively well to pruning and root pruning impacts during construction projects, but this degree of pruning is considered “severe”, even though it will only be impacting a single side of the symmetrical canopy.

The City of Palo Alto notes that the expected pruning will be considered to be +/-15% of canopy loss overall for the entire tree canopy. However, it is WLCA’s opinion that the City and the project design team may not have actually considered the requirement that a construction corridor, of minimum 5 feet width (or far greater width) as noted above, will be cleared completely in terms of vertical airspace pruning of tree canopy live wood and foliage, and that the pruning cuts are likely going to be performed as shearing-type cuts at internodal locations, which is equivalent to topping pruning in that the tree’s long term response is going to be a profusion of epicormic shoots growing from near the pruning cut wounds, increased sunscald/sunburn, and long term progression of internal wood decay by fungi species that will progress inward and downward through the remaining stems from the large diameter pruning cut wounds made during project airspace clearance pruning.

Also of note is the fact that the remaining canopy will be severely lopsided, and that TRAQ risk of whole tree failure and impact with various high value targets will be increased to some degree (as discussed elsewhere in this letter report per WLCA’s 2023 analysis).

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

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2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN

SHEETS (CONTINUED)

4. UNDERGROUND PARKING: Sheet A2.P2 dated
8/08/2025 shows a proposed new underground parking
curvilinear access road that will require deep excavation at approximately 29 to 30 horizontal feet offset from the mainstem edge of the subject oak. This position of the
curvilinear underground driveway is relatively closer to the tree than shown in previous 2023 plan sheet
iterations.

See WLCA’s markup at right showing the gray driveway
cut (deep excavation) and a vector of 29-30 feet true
north of the tree mainstem edge.

Note that in this image, the light gray dashed line is NOT the tree canopy dripline, and is instead a 30 foot radius demarcation by the project team on the plan sheet
renderings. The actual tree canopy extends at least
37 feet north as indicated on the applicant’s plan sheets, (and extends some 45 feet radius northward per WLCA’s estimation in 2023 using a forestry tape).

A tree protection zone of 10x calculates to 10 x 50” = 500 inches = approximately 41 feet radius offset from mainstem edge, for new construction. This means that the proposed underground driveway will encroach to far within the 41 foot protection zone.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

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2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN

SHEETS (CONTINUED)

OVER-EXCAVATION

There may or may not be additional “over-excavation”
(industry terminology: “over-ex”) required to be performed beyond the limit of excavation shown in this applicant plan sheet in gray coloration on plan sheet A2.P1 reproduced above on page 9 of this WLCA letter report.

This is a subject for further research or discussion.

Example: if the proposed retaining wall is to be located at the edge of the shown gray area on sheet A2.P1, then there may be a French drain or other type of drainage corridor that needs to be installed behind the wall, requiring over-excavation of some unknown number of horizontal feet, in order to accommodate a thin diameter or a thick diameter drainage curtain (e.g. thin Mirafi “drain core”, or traditional thick gravel-filled French drain system, etc.) that allows for water to drain vertically downward behind the retaining wall, and into a PVC piped drainage system from which water is pumped out in some manner.

The thickness of a drainage area behind an underground parking garage retaining wall may be as thick as 3 feet or more (see image above for an example of how a traditional thick type French drain system appears behind a retaining wall). The “overex” or “over-excavation” required for this item is typically not shown and not understood by laypersons to even exist, until the detailed design set of plans (aka “DD” set of plans) are rendered by a project team of professionals.

A 3-foot width French drain system would bring the final excavation cut to within approximately 26-27 feet of the subject oak tree mainstem edge.

Use of the more narrow “Miradrain” drainage curtain product, or similar, may reduce this required thickness to as little as 6 inches diameter.

During his 27 years of construction project consulting experience, WLCA has worked on Bay Area projects where “over- excavation” was not indicated on rendered plans during the pre-project design stage, resulting in horizontal excavation that extended multiple feet farther than the limits of proposed new underground parking garage retaining wall excavation cuts as shown on birds eye view plan sheets. Nearby trees being protected in place ended up with significant unavoidable root loss due to this oversight by the project engineering teams.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

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2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN

SHEETS (CONTINUED)

At right is a snippet from Robert Booty
arborist report dated 5/23/2022, which is
public record as part of the applicant’s
background documentation. Mr. Booty
used ground penetrating radar (GPR) to
determine an approximation of the root
extent far below asphalt surface grade
elevation, on the side of oak tree #10
facing proposed new building foundation
excavation for both the building and
underground parking garage retaining
walls.

Not shown on this image is the curvilinear
underground parking garage work which
will cut far more root mass than shown by
Mr. Booty’s vector black line in the image
at right. One of the parking garage
roadways below ground is shown in a
snippet above on page 8 of this WLCA
arborist letter report.

From the image at right from Booty arborist
report dated 2022, and from the curvilinear
below grade parking garage and driveway
work shown on page 8 above, we can
clearly see that the percentage of the root
system to be removed will be very
significant: possibly as much as 40-50% of
the root system on the northwest side of
the tree, not including damage from the
proposed terrace/garden buildout area,
which is discussed in item #5 below.

We should assume from the Booty ground penetrating radar examination of the tree #10 root system that lateral woody roots continue to extend outward in all directions much farther than were recorded by Mr. Booty’s GPR machine, which means that an even greater percentage of the tree #10 root system will be damaged and destroyed during development of the proposed property per plans, since the tree’s structural and vigor life support system literally depends on this woody root system and the fine absorbing root mass attached to it, which is apparently far greater in extent than might have otherwise been known prior to the 2022 arborist report graphic root representations having been provided with scale bars by the applicant’s arborist Robert Booty.

Note also that the RB report root maps indicate roots present at varying depths of between +/- 30 inches depth (2.5 feet below parking lot surface grade elevation) and the 7 foot depth limit of the GPR machine setting used by RB for his analysis.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

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2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN

SHEETS (CONTINUED)

TREE PROTECTION ZONE FENCING AND MONITORING BY ARBORISTS:

It is not clear to WLCA as to the exact location of the official tree protection zone fencing, with an apparent 41 foot TPZ offset alignment indicated by the City of Palo Alto.

Actual distance of construction-related impacts to both root system (soil pore space compaction by machinery driving, etc.) and canopy (pruning for vertical and/or horizontal airspace clearance of building, balconies, and an additional “construction corridor” east of the balconies of unknown required width), will necessarily mean that airspace work and some driving of lift vehicles will be occurring at locations between 17 feet west of mainstem edge and 30 feet west of mainstem edge.

Additionally, the terrace/garden construction will occur at between 3 feet west of mainstem edge and 30 feet west of mainstem edge as an end-of-project end-phase landscape element of the design that has yet to be detailed in the proposed plan sheets.

The conditions of project approval (COPA), set forth by City of Palo planning division and public works division as legally binding conditions, should ideally include specific wordage that indicates a tiered system of root zone protection (i.e. ground protection) for tree #10, such as:

• GROUND PROTECTION:

Robust ground protection of 6 to 12 inches thickness for the area between the oak tree mainstem edge and out to 30 feet west of mainstem edge, with frequent arborist consultant on- site monitoring on a weekly or twice-monthly basis to verify compliance by the project build team.

See image at right showing this type of protection on a WLCA project in the past in Menlo Park, CA, which was a layer of 6 inches of coarse wood chips overlaid with
exterior grade 1.0 inch “actual thickness” (or greater) plywood boards screwed together with steel screw
plates.

• ZERO IMPACT VS. PARTIAL IMPACT AREAS:

If City Urban Forestry is recommending zero impact zone of 20 feet radius, then that area between 0 and 20 feet west of the mainstem will need to be hard-fenced at all times, with no access to the ground, which then sets up a problem for the final landscape buildout portion phase of the project when that protection will be required to be removed to allow for the proposed 735 sq ft terrace/garden element of the project to be built out.

• MONITORING BY A PROJECT ARBORIST:

The scheduling of project consulting arborist monitoring will potentially need to include daily or weekly on-site monitoring of a much more frequent basis than on a typical construction project, if the oak #10 root system and canopy is to be preserved and protected to the best possible extent on sides facing proposed new site construction work. The project arborist will likely need to be present on site during relatively long periods of the tree canopy pruning work as well as the garage retaining wall excavation work.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Conclusion & Recommendations

If the proposed 660 University site plan project were built out as currently proposed per the June and August 2025 planning resubmittal versions of the plan sheets, WLCA expects that tree #10 would experience a relatively severe degree of below-ground live lateral woody root loss, and a relatively severe degree of above-ground live canopy pruning likely at internodal locations randomly dispersed along large diameter stems to within 17 feet of the mainstem edge, which, when combined as a cumulative below-ground and above-ground negative impact, would necessarily result in loss of tree vigor (health) and tree structure to a “severe” degree over the long term. The applicant’s Robert Booty ground penetrating radar report from 2022 substantiates the presence of oak #10 rooting out to distances far greater in radius than shown on the report root map images, suggesting that actual tree root loss caused by proposed construction as currently shown on the 2025 set of plan sheets may be far greater than the +/-15% loss of root system noted in the David Babby consulting arborist report.

The tree’s safe and useful life expectancy in its current condition rating of “good” (+/- 62% overall condition rating) may be significantly to severely reduced as a result of site plan project work from (EXISTING: no-construction scenario) 50 to 100 years remaining, to (PROPOSED: post-construction scenario) 10 to 20 years remaining, or less, depending on the tree’s response to very significant project clearance canopy and root pruning as described above in this letter report.

It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a “severe” degree as a direct result of proposed site work as currently described on the June and August 2025 sets of plan sheets, resulting in tree #10 potentially falling into a spiral of condition decline from which it cannot recover.

Project airspace clearance pruning of large diameter stems at internodal locations along the stems to clear the building, the balconies, and a construction corridor of unverified additional width, is expected to result in increased activity by pest and/or wood decay causing fungi species progressing inward and downward through the cross sectional areas of the stems, starting at the pruning cut wound faces at approximately 17 horizontal feet west of the mainstem edge, potentially causing an increase in risk of stem failure over time, with ever-increasing “fungal load” within the cross sectional areas of remaining cut stems.

Due to wood decay-causing fungi colonization of the cross sections of various clearance-pruned stems at the west side of the subject tree as noted above, there would necessarily be a corresponding increase in severity of the TRAQ risk rating(s) in terms of risk of whole tree and/or tree part failure and impact with various static and moving targets with moderate to high occupancy ratings within the target zone and a reasonable time frame such as 12 to 24 months, starting as of the proposed site construction completion date (note that this would need to be assessed at a future time, and is outside the scope of WLCA’s initial pre-project tree impact analysis assignment).

The tree is located in the an area known to have high water table elevations and gravelly (gravel-laden) riparian type alluvium soil that tends to support excellent native oak tree root growth in terms of both rooting depth and root lateral extension.

RECOMMENDATIONS

See WLCA’s partial set of recommendations above on page 12 of this letter report.

Note that even if all of the above recommendations indicated on page 12 of this WLCA letter report were to be strictly adhered to by the applicant build team and their team of professional consultants, this will not change the fact that at least +/- 50% or more of the tree’s west side of canopy live biomass will be removed to clear the proposed new building exterior, balconies, and a construction corridor of unknown required width with unlimited vertical clear airspace to the southeast of the balconies.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Digital Images by WLCA 12/13/2023 / Tree #10 Coast live oak (Quercus agrifolia)

View looking eastward while standing on 517 Byron. Note the excellent buttress root flaring at the root crown of tree #10 which is considered normal and desirable.

View of the relatively wide angle fork attachments between 10 and 15 feet elevation above grade at which the tree
#10 codominant mainstems arise. These saddle shaped
forms are normal and desirable from a structural stability standpoint. Although it is not “optimal” to have codominant mainstems forking in a tree, the best case scenario would be for all of the forks to exhibit wide saddle-shaped
attachments like this tree. It is actually extremely unusual for a coast live oak to exhibit saddle-shaped forks at every bifurcation of the codominant mainstems.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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View of subject oak #10 looking northward from 517 Byron.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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View of oak #10 lower 50% of canopy/mainstem architecture, with the adjoining asphalt parking lot area west of 517 Byron visible at left half of the image. The root system is assumed to be extended through most or all adjoining lots surrounding 517 Byron (not verified), as is assumed to reach as much as 2x to 3x the 45 foot canopy radius (again, not verified, but very possible, per WLCA’s past experience with older oaks in Palo Alto and Menlo Park area, especially if the soil is a historical cobble-based riparian soil profile with fast drainage (not verified).

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

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Per WLCA’s multi-layer mockup created for a valley oak location comparison with groundwater depths and soil types, the tree #10 location has a 25 foot depth groundwater table, and nearby Palo Alto study-noted red dots which indicate very large older valley oak specimens surveyed in the past and included on internet maps for reference.

The Qoa soil type at the 660 University site is defined as “older alluvium” (hence the “oa” designation): a Pleistocene soil of gravels, sand, and silt that is unconsolidated to consolidated, interspersed with alluvial materials from stream action.

See next page of this report for the United States Geological Survey legend pertaining to this soil unit, clipped from the local Palo Alto soil map, obtained from USGS Menlo Park headquarters.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

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Above was excerpted from the USGS Quadrangle (soil unit map) which includes the City of Palo Alto area.

Assumptions and Limiting Conditions

Any legal description provided to the consultant/appraiser is assumed to be correct. Any titles and ownership to any property are assumed to be good and marketable. No responsibility is assumed for matters legal in character. Any and all property is appraised and evaluated as through free and clean, under responsible ownership and competent management.

It is assumed that any property is not in violation of any applicable codes, ordinance, statutes, or other government regulations.

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ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

19 of 19
Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

drawings or other documents does not constitute a representation by Walter Levison to the sufficiency or accuracy of said information.

Unless expressed otherwise:
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Arborist cannot guarantee that a tree will be healthy or safe under all circumstances, or for a specified period of time.

Likewise, remedial treatments, like any medicine, cannot be guaranteed.

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660 University Project Ream – Protect the Coast Live Oak October 3, 2025 A"achment B Selected pages from Robert Booty’s GRP Scan May 23, 2022 .

Arborist OnSite®
Horticultural Consulting, Inc.

ISA Certified Arborist Report

Submitted To:

Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612

Project Location:

660 University Avenue
Palo Alto, California

Submitted By:

Robert Booty, Registered Member # 487
ISA Qualified Tree Risk Assessor
The American Society of Consulting Arborists
ISA Certified Arborist WC-4286
May 23, 2022

Copied from page 10 of the report. Adjusted so the “y” scale is the same as the “x” scale. 660 University Project Ream – Protect the Coast Live Oak October 3, 2025 A"achment C Mathema0cal Calcula0ons of Circle Segments

Page 1 of 4 ends

Calcula&ons Related to a Circle Segment Christopher Ream October 3, 2025 When a straight line is drawn across a circle, the two shapes produced are “segments” of that circle, a major segment and the smaller minor segment. I am dealing today only with the minor segment, the segment which is a semicircle or smaller. If you know the radius of the circle and the height of the segment, you can ﬁnd the segment area from the formula below. where: r is the radius of the circle of which the segment is a part. h is the height of the segment. Note: The result of the cos-1 func2on in the formula is in radians. The foregoing was copied oﬀ the web at hKps://www.mathopenref.com/segmentareaht.html This same website as a very easy to use calculator which I use to enter the radius (r = 45) and the height (“h”), and it produces the Area. And then if I already know the Area and want to ﬁnd the height (“h”), I can again enter r=45 and then make mulSple entries for height (“h”) unSl the calculator gives me the same Area which I already know. I used this technique to arrive at all the numbers in the table on page 5 of my October 3, 2025 letter “Protect the Coast Live Oak” and here is what I did.

Area of a Circular Segment given its height
Definition: The number of square units it takes to fill a segment of a circle Try this Drag one of the orange dot that defines an endpoint of the segment. Adjust the segment height. Note the number of square units it takes to fill it and the calculation.

If you know the radius of the circle and the height of the segment, you can find the segment area from the formula below. The result will vary from zero when the height is zero, to the full area of the circle when the height is equal to the diameter. where:
r is the radius of the circle of which the segment is a part. h is the height of the segment.

Note: The result of the cos-1 function in the formula is in radians.

Another method
If you know the central angle of the segment (the angle subtended by the segment at the center of the circle) you can use the method Area of a circular segment given the central angle.

Applications
Area=42cos−1 4−3.0
4 −(4−3.0)√2·4·3.0−3.02=17.2
area=r2cos−1 r−h
r −(r−h)√2rh−h2

r = 45’
h
The area of the circle cut oﬀ is a “segment.”

Page 2 of 4 ends

Start with the entries for the South side of the Tree, the semicircle of canopy facing south towards The Hamilton. 25% Agreement There will have been no cuYng back of the canopy on this side of the Tree, so the “Area of the remaining canopy” is the area of the untouched semicircle, by the simple formula A = 0.5 x ∏r2 = 0.5 x ∏ x 45 x 45 = 3,181. As with a seesaw, or a crowbar, or any other kind of lever, you mulSple the weight applied by the length of the lever from the fulcrum. In our case, the weight of the remaining canopy is a direct funcSon of the area of the remaining canopy, and that weight can be considered applied at the center of the remaining canopy. The center of the remaining canopy is where the area of canopy outboard of that spot is equal to the area inboard. To ﬁnd the “Distance from the center of the remaining canopy to tree trunk,” I needed to ﬁnd what value of “h” will give me a segment area equal to 0.5 x 3181 = 1,590.5, one half of the “Area of the remaining canopy.” I used the calculator on the website at hKps://www.mathopenref.com/segmentareaht.html; entered r = 45, and tried mulSple entries for “h” unSl I got 1,590.5 for the Area. I did it and got “h” = 26.82. This was the distance from the perimeter of the circle to the “center” of the remaining canopy; but I wanted the distance from the “center” to the tree trunk, so I took the radius (“r”) of 45 and subtracted the “h” of 26.82 to give me 18.18 as the length of the Lever. Now to get the Unbalanced Tipping Force, I mulSplied remaining canopy of 3,181 by the Lever of 18.18, and got 59,803. Cutback to give balconies clearance Since no canopy is to be removed on the South side of the Tree, the numbers for the Cutback are the same as those for the 25% Agreement.

Page 3 of 4 ends

Move on to the entries for the North side of the Tree, the semicircle of canopy facing north towards Applicant’s proposed building. This will be a liKle more complicated 25% Agreement Both arborists esSmate that 25% of the enSre canopy will be sliced oﬀ, but all of the removal is going to be from the North half of the canopy. Simple math tells you that 25% of the whole will be 50% of the North semicircle. The North semicircle is the same size as the South semicircle, or 3,181, and 50% of that is 1,590.5, and with that 1,590.5 removed, the remaining canopy is 1,590.5. Similar to the South side, I now needed to ﬁnd the center of the remaining canopy, from where half of the remaining canopy, 0.5 x 1590.5 = 795.25, would be inboard and the other half, 795.25 would be outboard. SSll dealing with circle segments, I wanted to visualize a new segment that would account for both the outboard half of the remaining canopy (795.25) and the 50% to be sliced oﬀ (1,590.5) or a total of 2,385.75. (Note that 2,385.75 is 75% of the 3,181 semicircle.) To ﬁnd that, I looked for the “h” value that, with “r” sSll at 45, would produce an area of 2385.75, and found h = 36.1. As with the South side above, this was the distance from the perimeter of the circle to the “center” of the remaining canopy; but I wanted the distance from the “center” to the tree trunk, so I took the radius (“r”) of 45 and subtracted the “h” of 36.1 to give me 8.9 as the length of the Lever. Now to get the Par=al CounterBalance Force, I mulSplied remaining canopy of 1,590.5 by the Lever of 8.9, and got 14,155. Cutback to give balconies clearance This is again a liKle diﬀerent because don’t have simple calculaSons of areas, rather we have height of the segment sliced oﬀ and needed to use that to ﬁnd the area of the canopy sliced oﬀ and thus the area of the remaining canopy. The radius of the canopy is 45 feet but the face of the proposed building is only 30 feet from the Tree trunk; therefore, Applicant must slice oﬀ a segment with an “h” of 15 feet. The face of the proposed building it is going to covered with mulSple balconies sScking out 6 feet beyond that face; therefore, another 6 feet of canopy would have to be sliced oﬀ. And ﬁnally, Applicant must provide clearance around the balconies so the residents can use them; therefore, another 6 feet of canopy would have to be sliced oﬀ. “h” = 15 + 6 + 5 = 26. I went to the online calculator at hKps://www.mathopenref.com/segmentareaht.html, entered r = 45 and h = 26, and got an Area of 1523 for the sliced oﬀ canopy. SubtracSng that from the 3,181 area of the semicircle and got 1,658 for the Area of the remaining canopy on the North side (3181 – 1523 = 1,658).

Page 4 of 4 ends

Noted that this area number is a li<le more than the 1,590.5 es?mate of the two arborists. That is likely due to the arborists accoun?ng for some addi?onal pruning required for construc?on which I did not take into account. Similar to the explanaSon above of how I found the “Lever” under the “25% Agreement on the North side, I now needed to ﬁnd the center of the remaining canopy, from where half of the remaining canopy, 0.5 x 1,658 = 829, would be inboard and the other half, 829 would be outboard. SSll dealing with circle segments, I wanted to visualize a new segment that would account for both the outboard half of the remaining canopy (829) and the 1,523 to be sliced oﬀ or a total of 2,352. To ﬁnd that, I looked for the “h” value that, with “r” sSll at 45, would produce an area of 2352, and found h = 35.7. As with the South side above, this was the distance from the perimeter of the circle to the “center” of the remaining canopy; but I wanted the distance from the “center” to the tree trunk, so I took the radius (“r”) of 45 and subtracted the “h” of 35.7 to give me 9.3 as the length of the Lever. Now to get the Par=al CounterBalance Force, I mulSplied remaining canopy of 1,658 by the Lever of 9.3, and got 15,419. 1 Kallas, Emily
From: [email protected]
Sent: Friday, October 3, 2025 2:46 PM
To: Kallas, Emily
Subject: Slides for me on Oct 8th
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These are the few slides I would like to show when I talk at the Wed., October. 8th Planning and Transportation meeting.

Slide 1

2 3

Slide 2

4 5

Slide 3

Carol Gilbert
555 Byron St.

Palo Alto, CA 94301
650-323-2862
6 1
Kallas, Emily
From: Faith Brigel <[email protected]>
Sent: Tuesday, September 30, 2025 8:13 PM
To: Kallas, Emily
Subject: Re: Planning and Transportation Committee: 660 University Ave.

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi Emily,
Thanks for your informative response. I am sorry that I did not realize that you were at that meeting. I came a few minutes late and so I missed the introductions. And I am sorry it took me this long to get back to you. I have been very busy the past few months.

Several months ago after living beside a house for 4 years that was demolished and a large, new 2 story house with a large basement and large ADU constructed; I decided to move out of Palo Alto. The last 4 years have been filled with construction right beside my living quarters: the noise, the dust, the trucks, the constant building and builders there all day yelling to each other, 6 days a week. I had been in that house for 25 years, and I loved it. I had not planned on moving out. But the construction next door, made it impossible for me to have a good quality of life. They started that project in December, 2021. Almost 4 years ago! And they are not near finished. My main objection was that they built their house only about

1.5 feet from the property line. But speaking several times to the City I was told that it is according to code.

So realizing that construction will now start all over again with another very large project, right across from my office building is very disconcerting. And again, I feel that no one in the City is showing any consideration for the neighbors. This building will be the most massive building in the area. It will be 6 stories with balconies, and insufficient parking spots. It will totally change the ambiance of this area. I appreciated our first talk when I felt that you had some understanding of my feelings. I wish that this project would go back to 4 stories!
I just shared my situation with you for you to maybe understand my feelings a bit more.

I assume that the City Council has already addressed this project?

Thanks,
Faith
Faith W. Brigel

> On Aug 21, 2025, at 5:23 PM, Kallas, Emily <[email protected]> wrote:
>
> Hi Faith,
> I do not know why you think I was not there. I introduced myself, gave the staff presentation, and answered most of the Board members’ questions.
> Construction activity is regulated through the City Code consistently for all projects. As such, this project will include a Construction Logistics Plan, reviewed and approved by the Public Works Department as a part of the Building Permit review. The standard condition states:
> CONSTRUCTION LOGISTICS PLAN. A construction logistics plan shall be provided addressing all 2 impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit.
> I cannot guarantee that there will never be a temporary road closure at any point during the construction. However, if it does occur, notice will be provided and it will be done following procedures and regulations set by the Public Works Department. Sincerely, > Emily
> <image001.png>Emily Kallas, AICP
> Senior Planner
> Planning and Development Services Department
> (650) 617-3125 | [email protected]
> www.cityofpaloalto.org
> <image002.png> Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped
> From: Faith Brigel <[email protected]>
> Sent: Thursday, August 21, 2025 1:17 PM
> To: Kallas, Emily <[email protected]>
> Cc: Council, City <[email protected]>
> Subject: Re: Planning and Transportation Committee: 660 University Ave. > CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
>
> Hello Emily,
> I attended the Architectural Review Board meeting this morning re the project at 660 University. I assume that you were not there. I spoke and several other neighbors made comments as well. > There are a couple of other points that I want to add. There were several comments made about guarding the tree that is adjacent to the construction. And that is good- but what about the people, the neighbors such as myself? This construction project is massive. And it will overwhelm my one story building.
> I have owned that house across the street for 37 years. And it is more than 120 years old, and it is in good condition- there was no mention of respect or consideration to it as a neighbor. I need to know that this development will not adversely affect my building- both during the construction and once it is complete.
> One of the members at the end mentioned that when the construction begins the neighbors should be given notice re closing the street, etc;
>
> It is absolutely not acceptable that Byron Street be closed for any amount of time due to their construction. This construct will take what? About 4 years?! > I have tenants who work there and have clients there daily. They need to have access to my building in order to do their work. And they need it quiet.
> If they cannot enter Byron Street for any amount of time, or if construction trucks block access to my driveway, and if any of my tenants leave that
> will effect my income. And the construction company will be responsible. > They need to find ways to contain the construction to their own property. And as I have mentioned before and other people have as well - this building is much too large for the space- and we the neighbors 3 in that area are relying on the Architectural Review Board and the City Council to protect the integrity of Palo Alto, and not to allow construction companies coming in to Palo Alto from other locations and building structures that are way out of proportion to the area as this one is. >
> Emily can you pls forward this email to the Architectural Review Board? >
> Thanks,
>
> Faith W. Brigel
>
>
> > On Apr 30, 2025, at 3:46 PM, Kallas, Emily <[email protected]> wrote:
> >
> > Hi Faith,
> >
> > Thank you for your comments. This agenda item has been cancelled at the request of the applicant.

You will receive another notice when it has been rescheduled. > >
> > Thanks,
> > Emily
> >
> >
> > Emily Kallas, AICP
> > Senior Planner
> > Planning and Development Services Department
> > (650) 617-3125 | [email protected]
> > www.paloalto.gov
> >
> >
> >
> > Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped
> >
> > -----Original Message-----
> > From: Faith Brigel <[email protected]>
> > Sent: Wednesday, April 30, 2025 1:58 PM
> > To: Kallas, Emily <[email protected]>
> > Subject: Planning and Transportation Committee: 660 University Ave. > >
> > CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
> >
> > Hello Emily,
> > I received a notice that there will be a public hearing tonight at City Hall re the construction project at 660 University Ave.
> > Unfortunately, I will not be able to attend. So I am writing this email to you in the hopes that you and the members of this committee will see it.
> > I cannot state strongly enough how out of place, and cumbersome this huge building will be on 4 University Ave and Byron Street.
> > I have been on Byron St. for thirty years and so I feel that I have some knowledge of that area. > > It will be out of place in that no other buildings in that area are that large, that dense, nor that high. No other buildings are 6 stories high.
> > Initially weren’t they describing it as 4 stories, which is still very high? > > I call it cumbersome in that there will be many people living there, and many people working there and most of them will need parking spots.
> > And as they explained at one of the meetings though they will have a 2 level underground parking lot- there still will NOT be enough parking sports for all of their people. > > There is very little parking on University Ave, , and rarely are there any available parking spots on Byron Street. Similarly, finding parking on Middlefield is close to impossible. > > This lack of parking for their tenants, and clients or customers will be a serious problem once the construction is complete. I am quite sure that they are not yet aware of this. > > The fact that they are planning to build 6 stories is of a great concern to me. My building at 518 Byron Street is as I have explained a one story, and it has been there for more than 120 years. Having this construction 6 stories high right across the street will effect the light plan. It will be ominous. And it will detrimentally affect the quality of life of my tenants. > > I am hoping and would expect that the City Staff would help protect the Palo Alto community of already established buildings., like mine, from new developments coming in and overwhelming the area. > >
> > I hope that you will not just focus on building more houses for Palo Alto, but also protect the character that older, Victorian buildings such as mine offer to our City. > >
> > Thank you,
> >
> > Faith W. Brigel
> >
> >
> >
From: Armer, Jennifer
To: Kallas, Emily; Raybould, Claire
Cc: Tavera, Samuel
Subject: Fw: HAC support for 660 University Ave.

Date: Thursday, September 18, 2025 8:18:22 AM
Attachments: 660 University Ave Letter of Support-7.pdf Outlook-Logo__Desc.png
Outlook-h2w13w1h.png
FYI
Sincerely,
Jennifer

JENNIFER ARMER, AICP
Assistant Director
Planning and Development
Services Department
(650) 329-2191 | [email protected]
www.paloalto.gov

From: Ali Sapirman <[email protected]>
Sent: Wednesday, September 17, 2025 6:37 PM
To: Planning Commission <[email protected]>; Armer, Jennifer <[email protected]>
Cc: [email protected] <[email protected]>; [email protected] <[email protected]>; Coy, Melinda@HCD <[email protected]>; Witt Turner <[email protected]>; Brianna Morales <[email protected]> Subject: HAC support for 660 University Ave.

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Commissioners, Staff, and HCD:

Please see the attached letter of support on behalf of The Housing Action Coalition. Please note HCD is copied on this email due to the history of delays the project has faced. Feel free to reach out with any questions or concerns.

In solidarity,
--
Ali Sapirman | Pronouns: They/Them
Advocacy & Policy Manager| Housing Action Coalition
555 Montgomery St, San Francisco, CA 94111
Cell: (407) 739-8818 | Email: [email protected] To opt out of all HAC emails, respond to this email with "unsubscribe all".

September 8, 2025
Dear Commissioners,
The Housing Action Coalition is a member-supported nonprofit that advocates for creating more housing

for

residents

all

income

levels

help

alleviate

the

Bay

Area

and

California’s

housing

shortage,

displacement,

and

affordability

crisis.

Our endorsement committee had the opportunity to review Smith Development’s proposal at 660

University,

and

proudly

endorsed

the

project.

Smith Development’s proposal would bring 66 much-needed new units to Palo Alto. We were impressed

with

the

project's

dedication

affordable

housing,

with

20 percent

the

units

for

lower-tiered

affordable

housing,

which

high
especially considering current economic
conditions.

By prioritizing affordable housing and urban development, we can create more sustainable

and

inclusive

communities

for

everyone.

In terms of Land Use and Density, the project site's central location with its proximity to essential downtown

amenities,

including

the

Caltrain

station,

and

the

inclusion

ample

bike

parking

facilities

underscore

commitment

promoting

environmental

sustainability

and

reducing

reliance

automobiles.

In terms of parking, our committee would like to see a reduction on the amount

parking

provided

for

the

project,

and

have

the

project

redirect

those

costs

increasing

the

overall

density

the

project.

terms

overall

design,
we commend the steps
Smith

Development

has

taken
to preserve the Oak tree on site, and even incorporated it into the design.

This project will be critical to support Palo Alto, and the Bay Area’s housing needs. Please move this

project

forward

without

delay.

Corey Smith , Executive Director Housing Action Coalition (HAC) Ali Sapirman, Advocacy and Policy Manager Housing Action Coalition (HAC)

From: Tran, Vickie
To: Kallas, Emily; Raybould, Claire
Cc: Lait, Jonathan; Armer, Jennifer
Subject: FW: 660 University Ave., Palo Alto
Date: Monday, August 25, 2025 8:36:23 AM
Hi Emily and Claire,
Please see below for public comment on 660 University.

Vickie
-----Original Message-----
From: Velasquez, Ingrid <[email protected]> Sent: Monday, August 25, 2025 8:23 AM
To: Lait, Jonathan <[email protected]>; Armer, Jennifer <[email protected]>; Tran, Vickie <[email protected]>
Cc: Nose, Kiely <[email protected]>; Gaines, Chantal <[email protected]>; City Mgr <[email protected]>
Subject: FW: 660 University Ave., Palo Alto
Good morning,
Forwarding the comment below for awareness.

Thanks,
Ingrid
Ingrid Velásquez
Administrative Assistant
Office of the City Manager
(650) 329-2354| [email protected] www.PaloAlto.gov -----Original Message-----
From: Faith Brigel <[email protected]>
Sent: Saturday, August 23, 2025 9:05 PM
To: [email protected]; Council, City <[email protected]> Cc: Faith Brigel <[email protected]>
Subject: 660 University Ave., Palo Alto
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear City Council of Palo Alto,
Re 660 University Ave. Construction Project
I sent an email regarding 660 University Ave, a few days ago, but I would like to express a few more objections to this project that I hope you will consider. I have great concern that the size and a few other issues related to this construction will detrimentally affect my property, and several of the other neighbors. 1- I understand that the State is mandating that housing be increased in California. But we have several new projects being considered already, not just 660 University, and several of those other areas do not have as many serious problems that this one has. There is the 17 story building on Mollie Stones, there is the project just 2 blocks up from 660 University on University Ave, one on San Antonio I believe it is 197 apartments, and I think one on El Camino Real. And probably more will be submitted.
2-At the Architectural Board Review Thurs. Aug. 21 several of the members of this Board questioned such issues as the lack of parking, and the high-level of congested traffic in that area, and other issues. When questioned the responses that the developer gave were rather disappointing. Such as, when asked about parking and traffic congestion- he said that they assume that a lot of the residents will not drive cars. But that is an assumption not based on any facts or analysis! It is very possible on the other hand, that most, or many of the residents will have cars. Public transit is quite scarce in this area, and the train is not close at all to this project. 3- This construction was initially submitted for 4 stories. But when they were asked to increase the setback - they said fine they will do that but they will increase the height to 6 stories! If 6 stories is allowed this building will be the highest in that location. It will take of course longer to build, and it will permanently overwhelm, and possibly negatively affect the light plan of my building that has been there for about 120 years, and other neighbors. 4- The traffic in that area is very dense most of the day. The location is at the corner of University Ave., and Middlefield which is the entrance to the downtown of Palo Alto. The City has not had an official traffic analysis done. Only the developer of this project had one done. It would be important for the City to hire a neutral party to do one.
5-They will only be providing 78 parking spots for the whole building in a 2 level parking garage. This is to accommodate 70 multi-family residential units, plus 1900 sq. ft of offices, where tenants, and outsiders also will be coming and going and certainly needing parking spaces.
6-There are rarely parking spots available on Byron, University or Middlefield, any time of day. And it has been like this for the 37 years that I have frequented that area. In fact, on 8/21 right after attending most of the ARB meeting I went over to my property on 518 Byron Street and there was a car parked blocking my driveway. When she came out of the dentist’s office she said she didn’t realize it was a driveway( it is very clear) and she was in a hurry. I hope this is not a prediction of things to come. 7-There has been a great deal of discussion about protecting a tree that would be adjacent to the building. That is very good. However, I would like equal attention to the neighboring houses. 8- As one of the ARB members expressed -this large building will only have 2 common spots in the front ( on Byron Street). With various delivery trucks coming by - that is- Amazon, Door Dash, etc ., there will not be enough parking spots for them. So will they park in the middle of the street and block it for the neighbors? He suggested that this building of this size needs more spots for this type of parking. Very true. But will there be any follow up on this and other issues mentioned since the vote was 3-2 and passed by the ARB members. 9- Apparently, recently the developer has added more balconies to the residential units. He said: “Everybody loves balconies.” But what about the neighbors? Since I have been there that area has been dominated by professionals:
dentists, attorneys, and therapists: that is, Psychiatrists, Psychologists, and Clinical Social Workers. This location is east of downtown. Byron is not quite in the downtown area. It is a quieter area. That very large building of offices and residents, and balconies will change the atmosphere. 10- It is my understanding that the developers of this project have not built in Palo Alto before. These developers are from San Francisco or Sacramento. Palo Alto is unique. Please help hold onto some of its character. 11- Please if no other changes are required, please do not allow 6 stories. They themselves at first submitted 4 stories. Pls go back to the 4 stories. It will take less time to build, and it will be less overwhelming for houses such as mine, which is a beautiful Victorian style that has been there for 120 years. Once this huge construction project is built the developer will leave -but this very tall and massive building will be there forever. It will be permanent.

Please show consideration, respect and appreciation for the already established Palo Alto buildings by not voting in this mammoth structure as it is.

I much appreciate your time to read my email and consider my points.

Thank you,
Faith
Faith W. Brigel
518 Byron Street
From: Christopher Ream
To: Kallas, Emily; Architectural Review Board
Subject: 660 University- SECOND LETTER other than Tree
Date: Monday, August 18, 2025 4:07:42 PM
Attachments: Ream - SECOND LETTER - Comments on Other Than Tree - 20250308.pdf Importance: High
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Emily,
Attached is my letter “SECOND LETTER – Comments on Other than the Tree”. Please distribute it to the Members of the Architectual Review Board, and to others as may be appropriate, in time for their review before the ARB Meeting this coming Thursday morning.

Thank you.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]

THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] August 18, 2025 Members Architectural Review Board City of Palo Alto, California Via: [email protected] [email protected] Re: ARB Meeting on August 21, 2025 660 University Project SECOND LETTER – Comments on Other than the Tree Board Members, The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all our neighbors. • Balconies over University Avenue • Parking • Parking for Office Size Adjustment ? • No Parking for Fitness Center • Balconies in the Canopy • Setbacks • Daylight Plane Balconies over University Avenue Applicant shows 6-foot to 7-foot setbacks for the above-ground building along University Avenue. There are 36 balconies from the Second Floor to the Sixth Floor sticking out six feet into that “setback” so they come right to the edge of the public sidewalk or within one foot of it. They will have a clear glass railing set 3½ feet off the deck, with a clear glass sheet between the railing and the deck of the balcony.

Ream – More Comments re the 660 University Project August 18, 2025 Page 2 of 5 On warm, sunny Friday or weekend afternoons and evenings, there are going to be young people socializing on these balconies. The 3½ foot railing is an inviting place to rest your forearm as you hold a soft drink, a beer or a glass of wine. Geometry dictates that the drink is now another 6 -12 inches closer to the sidewalk floors below. Many residents in The Hamilton get some exercise by walking around our small block and their walk will pass under these balconies. I frequently see seniors from other parts of “Senior Corner” including this sidewalk as part of their walk. Please don’t drop a glass – you may kill someone. This is a grave, inexcusable, unnecessary danger. Those balconies must be removed. Parking Parking in downtown Palo Alto is a problem the City has been dealing with for years and continues to deal with. There is no parking on either University Avenue or Middlefield Road near the project. The Hamilton is on the short block of Byron between University and Hamilton and sees the parking problem every day. It is a narrow street to start with, but on every workday, every single parking spot on both sides of the street is filled all day long. This narrows the drivable room so that two cars going in opposite directions cannot pass; one must slowly pull into a driveway to make room for the other to pass. Every time a delivery vehicle stops on Byron Street during the day, it clogs and backs up Byron. The project does not provide any short-term parking for delivery vehicles, so Byron is going to get backed up many times a day. Applicant calculates that according to PAMC 18.52.040 a total of 81 parking stalls are required to serve the residents of the 70 residential units and 8 parking stalls to serve the workers in the non-residential office space on the ground floor, for a total of 89 stalls. But then Applicant invokes several arguments to reduce the number of stalls it is required to provide, starting with a 13% reduction claimed by TDM, down to only 69 actual parking stalls. Has the city staff carefully reviewed the TDM Applicant has submitted? Will it actually reduce the need for parking or is it only designed to reduce the daily use of cars: Is it designed to reduce the number of daily automotive commutes a person takes, while that person still owns a car to be used for weekend activity. Even though it may reduce daily congestion, that car still needs a place to park. Bottom Line – Applicant has cleverly eliminated 20 parking stalls (89 – 69 = 20). Those 20 stalls may have been eliminated in the project’s garage, but the cars have not been eliminated and the 20 cars that can’t find an empty stall in the project’s garage will be driving around downtown, commercial and residential, looking for a parking space and causing congestion that the TDM was supposed to reduce. My granddaughters and other family members might not come to visit me because of the inability to park nearby and friends will not want to come over as much as they used to.

Ream – More Comments re the 660 University Project August 18, 2025 Page 3 of 5 Parking for Office Size Adjustment ? Applicant has shown only 1,984 ft2 of non-residential office space on the First Floor (see Sheet A2.1) and has calculated that the code requirement for that is the 8 parking stalls I referred to in the above section. Last year, up until Applicant added a Fifth and a Sixth Floor in October 2024, the non-residential office space on the First Floor was 9,115 ft2 which calculated to a code requirement of 37 parking stalls, 29 more stalls than the current plans call for (37–8 = 29). I accept Applicant’s calculation of only 8 parking stalls as the First Floor is configured now.

Ream – More Comments re the 660 University Project August 18, 2025 Page 4 of 5 Emily Kallas, the City Planner on this project has informally told me that Applicant could only make minor adjustments not to exceed a total of 100 ft2. If this project is going to be approved, I strongly urge that the City Attorney get a binding written contract that limits Applicant to Ms. Kallas’s understanding of a maximum of 100 ft2 in adjustments. Without such a contract, we might have another 29 cars wandering around in addition to the 20 cars in the prior section above. No Parking for Fitness Center Applicant has said that the 1,829 ft2 Fitness Center on the First Floor will be exclusively for use by tenants in the building (residential and office), and thus no need to calculate any additional parking stalls. So, while the City Attorney is at it, get a written contract affirming that the Fitness Center will remain exclusive to tenants. Balconies in the Canopy The approval of the Architectural Review Board at its December 5, 2024 meeting was subject to several conditions being met. The first condition was “Remove balconies from within the Oak tree canopy.” (This can be found in the Staff Report for the upcoming August 21, 2025 Meeting, Item No. 2. Page 5 of 9.). Applicant has ignored this for its plans show 31 balconies including 5-foot clearance would intrude into the canopy (45-foot radius), and none have been removed. They need to be removed. Setbacks At the April 18, 2024 and again at the December 5, 2024 ARB meetings on this project, there was a lot of discussion about the lack of proper setback along Middlefield Road. Applicant has moved the above grade portion of the building back to form a 25-foot setback along Middlefield as requested, but the underground garage still extends right up to the property line with ZERO setback and a minimal amount of soil fill above the garage structure. (See Sheet A3.3A.) Will the City of Palo Alto be able to make improvements to Middlefield Road in the future with this garage flush up against the road? Not likely. Applicant has offered to provide a small area at the Middlefield/University corner of the property as an “accommodation” if the City were to want to make improvements along Middlefield Road. Any improvement would most likely be to improve travel along Middlefield Road. But Applicant’s offer is only for 27 feet down Middlefield from the corner, leaving 46.5 feet still obstructed by the garage. (See Sheet A1.1A.) Applicant needs to make the offer to the City for the entire length of the property along Middlefield. This brings out the fact that the garage also abuts both University Avenue and Byron Street with zero setbacks. Is this standard and acceptable? Ream – More Comments re the 660 University Project August 18, 2025 Page 5 of 5 Daylight Plane There is a single family, one-story residence zoned RM-20 at 524 Middlefield Road adjacent to the project. Upon a 1/21/2022 review of Applicant’s initial filing, Samuel Gutierrez advised Applicant of the requirement to observe a 45° daylight plane. Applicant complied, and in the next submission of plans, cut back the portion of the Fourth Floor next to the neighboring house. The Fourth Floor has remained cut back and compliant with the daylight plane in all subsequent plans submitted by Applicant including the current submission; but Applicant has now added two additional stories onto the building raising the height up to 82 feet and disregarded the fact that these additional floors egregiously violate the daylight plane. The following is from Applicant’s submission. I have enhanced it to make the line of the daylight plane and the location of the neighboring house more visible.

Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Board to require action to correct. Thank you for your consideration, Christopher Ream 3/32"=1'-0"
PLPLOFFICE LOBBYSPEED RAMP DOWNTO P2 LEVELUNIVERSITY AVE. 10'-0"
10'-6"OFFICE PARKINGRESIDENTIAL PARKING
STAIRBEYOND7'-9" TYP.45.0°55'-0"LINE OF DAYLIGHT PLANE3'-6" 3'-6"
9'-9"13'-6"10'-6"14'-6"7'-0"FENCE7'-0"9'-9"EL. -1'-6" (NAVD 88 EL. 45.5')NEIGHBORINGPROPERTY GRADEP1 LEVELP2 LEVELLIFT PIT SECOND FLOOREL. 14'-8"THIRD FLOORFOURTH FLOOREL. 24'-5"EL. 34'-2"FIRST FLOOREL. 1'-2" (NAVD 88 EL. 48.16')BASE FLOOD ELEV.EL. 0'-0" (NAVD 88 EL. 47')1'-2"12'-8 1/2" ± 8'-4 1/4"7'-6" MIN.EL. -12'-1 1/8" ±EL. -26'-7 1/8" ±EL. -33'-7 1/8" ± CORR.TYP.
9'-9"12'-3"55'-5"1'-6"FIFTH FLOOREL. 43'-11"SIXTH FLOOREL. 56'-2"T.O. ROOF SLABEL. 70'-2"14'-0"T.O. PARAPET / ELEV.EL. 71'-8"OVERRUN / STAIRST.O. RAILINGEL. 73'-8"T.O. MECH. SCREENEL. 80'-2"3'-6"6'-6"MECHANICALSCREEN 54'-6" +/-
3'-6"
2'-2"SHORING/SOLDIER BREAMS
1/32"=1'-0"
3/-UNIVERSITY AVE

MIDDLEFIELD ROAD
BYRON STREET64G CARTCOMPOST64G CARTCOMPOSTRC64G CARTCOMPOST 64G CARTCOMPOST96G CARTWASTE96G CARTRECYCLING96G CARTWASTE96G CARTRECYCLING

ARCHITECTSKORTH SUNSERI HAGEY

SHEET NUMBERSCALEPROJECT NUMBERSHEET TITLE
DATENO.ISSUES AND REVISIONSDESCRIPTION

524 MIDDLEFIELD A3.3B ENHANCEMENT OF VISIBILITY OF LINE OF DAYLIGHT PLANE AND 524 MIDDLEFIELD MADE BY CHRISTOPHER REAM

Please let me know if you have trouble opening either.

Thank you,
K Brown

Kay Brown

August 16, 2025

Emily Kallas Senior Planner
Planning and Development Dept. City of Palo Alto
250 Hamilton Ave Palo Alto, CA 94301

Dear Ms. Kallas,

I’m writing to you, once again, to express my concerns regarding traffic issues which will undoubtedly arise with the slated construction of 660 University. In my letter to you dated March 4, 2025, I outlined a number of already existing dangers on Byron St. as well as the potential for an exponential increase in traffic related accidents that will occur on Byron should 660 be given the go-ahead without a proper EIR traffic safety analysis and an in-depth mitigation plan to address said issues. (Below, I will attach my March 4th letter for reference).

As you (inclusive of planning department) must be aware, a thorough traffic EIR analysis must include the potential for both pedestrian and vehicle accidents. Unless, I have missed some interaction at meetings or documentation in follow-up reports, I have not seen (within the constructs of the EIR report) any reference to this aspect of 660’s scheduled demolition and construction project. Nor, have I seen an analysis of how an increase in population and autos might impact the safety of existing residents, patients, church-goers and nursery school attendees.

I was made aware at the last planning meeting that a few representatives from the planning commission visited the site one day to get a sense of the traffic situation. One representative stated that the lack of space on the narrow street, did present an issue.

However, no mitigating solutions were presented that evening nor later in any documentation.

A thorough EIR Traffic Safety Report encompasses multi-day and multi-time observations before an adequate analysis can me generated. Repeating, there is no formal EIR traffic safety analysis that has been completed that I can locate for 660. And, after such report has been submitted, there need be mitigating solutions to address said

hazards. The developer must provide in advance adequate alternatives (mitigating solutions ) for parking during construction. The City of Palo Alto Planning Commission must in good conscience provide adequate mitigating traffic solutions, as well, to address increased population/traffic upon project completion.

1. Again, where will the large construction vehicles park for demolition and building erection? Will they be parking on Byron, University or Middlefield?

2. When completed, where will all the new tenants of 660 park? According to the expected population of 660, 74 parking spaces are required. Yet, there’s a 30% reduction allowed under TDM. Only 52 stalls will be available. Clearly, the excess spaces required will overpopulate parking on Byron, University and adjacent streets. (While the TDM has a lofty ambition to encourage mass transportation, a 22 slot reduction in parking will undoubtedly exacerbate an already precarious narrow street scenario.)

3. Please take into consideration multimodal conflict points with the challenged population that exists in a 2 block radius of 660. There are 3 large elderly communities that surround 660. During the day, pedestrians with walkers, wheelchairs and canes regularly cross University to attend meals and activities at the Methodist Church across Byron from 660.

4. With, the increased residents and office workers at 660, what will be the impact on an already dangerous traffic situation? (Must be included in a formal EIR traffic safety report). And, appropriate mitigation steps need to be outlined by either developer or the City of Palo Alto Planning Commission in advance of a go-ahead for construction.

A transportation analysis was completed by Hexagon Transportation, a private consultant corporation hired by the developer. Hexagon addresses safety transiently.

Briefly, it states that Byron is a quiet street (ie. No danger factor ). The study does not address the width of the street, the traffic patterns on Byron, University nor the pedestrian population that traverses the streets. A legitimate EIR traffic safety analysis according to California codes) must be completed by a public agency, not a private corporation paid by the developer with a vested interest. Hexagon’s report is primarily an overview of traffic patterns in Santa Clara County. Where is the EIR traffic safety analysis that is required by the State of California?

Appreciate your time and attention.

Sincerely,

Kay Brown

March 4, 2025

Emily Kallas
Senior Planner
Planning and Development Dept.

City of Palo Alto
250 Hamilton Ave Palo Alto, CA 94301

Dear Ms. Kallas,

I’m writing to express my concerns regarding the intended project slated to be built at 660 University. This large apartment/multi-use facility is scheduled to come before you for determination on March 12, 2025. I would like to familiarize you with the current traffic issues on the 500 block of Byron St.

As it stands today, senior residents of 555 Byron as well as nursery school parents, church-goers and dental office patients encounter frequent near-misses entering and exiting their respective parking lots.

1. Currently parallel parking is permitted on both sides of the street, and the narrow residual allotment for 2-way traffic becomes unwieldy with one car needing to pull over to allow on-coming traffic to pass.

2. Byron is utilized frequently as an auto pass-through for traffic wanting to avoid the traffic light at University and Middlefield. Residents and patients in cars must to pull-over and brake to avoid the on-coming traffic. The cars travel swiftly without regard to elderly residents that are with walkers and wheelchairs as they attempt to cross the street.

3. Large commercial vehicles deliver food, linen, packages, etc or service plumbing, electrical, wifi tele-communication issues at the various facilities.

When these large trucks park on Byron, the danger factor is exacerbated. It is difficult to see or maneuver safely around the commercial vans, etc.

4. There are currently 3 large senior facilities within the 2 block radius.

Concern for Emergency Response Vehicles ability to access the streets at all times should be paramount

It is my understanding that the developer of 660 University intends to situate the ingress and egress to the underground parking directly on Byron St? With the dense apartment units and office spaces allotted to the new complex, accidents can be anticipated.

Also, please consider the situation that will arise during construction of the new complex. At any given time, there will be large construction vehicles needed to demolish existing structures and erect the final facility. Where will they park so as not to worsen an already dangerous situation…on University, on Middlefield?

I am under the impression that the developers are anticipating that many of the 660 University dwellers will not own cars and will be utilizing mass transport.

At the previous City Council meetings, a study initiated on the developers behalf stated that a majority of the tenants will not be coming and going in automobiles by a computer generated (formulation) pie in the sky scenario? If this is an accurate analysis, I am asking the city of Palo Alto to verify this information and stand by it’s assessment.

Thank you for your attention to this matter.

Appreciatively,

From: Christopher Ream
To: Kallas, Emily; Architectural Review Board
Subject: 660 University - Letter re Tree
Date: Monday, August 18, 2025 1:51:14 AM
Attachments: Ream Letter re Tree - 20250818 w Attachments.pdf Importance: High
Emily,
Attached is my letter “Protect the Coast Live Oak”. Please distribute it to the Members of the Architectual Review Board, and to others as may be appropriate, in time for their review before the ARB Meeting this coming Thursday morning.

Thank you.

Chris
_________________________
Christopher Ream

660 University Project
Protect the Coast Live Oak
August 18, 2025

Page 2 of 3 ends

The Palo Alto Tree Technical Manual, Section 1.36 requires a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. In the most recent Tree Protection Report, Applicant acknowledges this 41-foot TPZ requirement on page 9 of David Babby’s February 4, 2024 Tree Protection Report it filed with its plans; but notwithstanding that, Applicant has gone ahead and arbitrarily drawn a deficient TPZ of only 30 feet on its plans and positioned its proposed building right next to that 30 feet. That is 11 feet less than the protection required by the City of Palo Alto.

Notwithstanding Applicant drawing a 30-foot radius circle on its plans, its Tree Protection Report, pages 9 & 10 discloses that Applicant intends to disregard even that fake TPZ by reporting that there will be a 20-foot setback from the Tree’s trunk for any ground disturbance and that applies to any soil compaction, grading, subexcavation, overexcavation, drenching, and drilling/auguring.

In other words, if the construction crew is at least 20 feet from the Tree, they are free to rip out as many roots as they like notwithstanding the deadly effect on the Tree.

Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment A). But those roots are going to cut off by the garage and ramps at 30 feet and still much closer to the trunk by the 20-foot rule during construction.

Canopy

The Tree has a beautiful canopy that stretches 45 feet over the site. The TPZ applies to the canopy as well as the root structure, but Applicant has used its fake 30-foot TPZ to bring the exterior wall of the building up to 30 feet from the trunk of the Tree, slicing off 15 feet of canopy.

But then there are a large number of balconies sticking out six feet from the exterior wall. First, Applicant will need to slice off another 6 feet of the canopy to make room for those balconies.

Then, the building’s residents are not going to tolerate the Tree intruding their balconies, so the Tree will be pruned back to provide a little fresh air to those enjoying the balconies and you can be sure the Applicant will prune the Tree back so that there is at least 5 feet of clearance between those balconies and the Tree. The result – Tree’s beautiful canopy stretching 45 feet over Applicant’s property will be cut back 26 feet or more (15 + 6 + 5) and will now be only 19 feet.

It should be noted that you, the Architectural Review Board, held at your December 5, 2024 Meeting that your approval was conditioned upon “Remove balconies from within the Oak tree canopy.” Staff Report for the upcoming August 21, 2025 Meeting, Item No. 2. Page 5 of 9.

660 University Project
Protect the Coast Live Oak
August 18, 2025

Page 3 of 3 ends

Tree Failure

It gets worse – Page 4 of the current Tree Protection Report discloses that the canopy “does unfavorably displace limb and branch weight towards the canopy's edges.” This me ans that the loss of 26 feet of canopy will be the loss of a disproportionate, huge majority of the canopy’s weight on the side of the Tree closest to the proposed building. And what weight there will be remaining on that side of Tree will be centered much closer to the Tree than the canopy weight on opposite side and thus will have much less leverage to counter-balance the full, heavy canopy on the opposite side. There will be a huge force on one side of the Tree. A tree’s roots do more than just feed and water a tree, the roots stabilize the tree and hold it upright. As the weight and leverage of the canopy on the opposite side of the Tree strains to tip it over the next-door dental office at 517 Byron Street and onto The Hamilton, it is the job of the roots to fight back and hold the Tree up. But, these roots are going to be sliced off under where the canopy is going to be cut back and the roots will not be able to do their job after they have been sliced off.

The Hamilton has retained an independent arborist to analyze the possible danger to the Tree.

After extensive investigation and the preparation of a detailed analysis, it was that arborist’s professional opinion that the Tree’s vigor would be negatively impacted to a severe degree as a direct result of the proposed work at the 660 University site as described on Applicant’s plans, resulting in the Tree falling into a spiral of condition decline from which it cannot recover.

Please review the Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023 (See Attachment B).

Notwithstanding that this report had been made public to Applicant well almost two years ago, Applicant has done nothing to minimize this serious danger. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy that dental office and badly injure and maybe kill anyone in those offices at the time.

Conclusion

The Hamilton community strongly opposes this application for excessive development on our small block and urges the Commission to require action to correct

Thank you for your consideration,

Christopher Ream

660 University Project
Ream – Protect the Coast Live Oak
March 4, 2025

A"achment A

660 University Project
Ream – Protect the Coast Live Oak
March 4, 2025

A"achment B

From: Admin
To: Architectural Review Board
Subject: Re: 660 University Project
Date: Sunday, August 17, 2025 3:47:25 PM
Attachments: Letter to ARB Aug 17, 2025.pdf

From: Kallas, Emily
To: Christopher Ream
Cc: Gilbert, Carol
Subject: Re: 660 University
Date: Monday, July 21, 2025 4:28:11 PM
Attachments: Outlook-Logo__Desc.png
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Outlook-Logo__Desc.png
Outlook-tkzgy4nh.png
Hi Chris,
Thank you for letting me know you did not receive my email on July 14th. The revised plans are also available on the project webpage:
https://www.paloalto.gov/Departments/Planning-Development-Services/Current- Planning/Projects/660-University-Ave
You are correct that the plans have been reuploaded with the changes you identified.

They also made changes to how the BMR units are distributed, and minor changes to the Middlefield setback area.

We are currently targeting ARB on August 21, PTC on September 24, and Council on October 20 or November 3 depending on agenda availability.

Thanks,
Emily

Emily Kallas, AICP
Planner
Planning and Development Services Department
(650) 617-3125 | [email protected]
www.cityofpaloalto.org

Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped

From: Kallas, Emily <[email protected]>
Sent: Monday, July 21, 2025 4:18 PM
To: Christopher Ream <[email protected]>
Cc: Gilbert, Carol <[email protected]>
Subject: Re: 660 University

Hi Chris,
Yes, we discussed this on July 14th. Please let me know if you did not receive my email that day.

That information is correct.

Thanks,
Emily

Emily Kallas, AICP
Planner
Planning and Development Services Department
(650) 617-3125 | [email protected]
www.cityofpaloalto.org

Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped

From: Christopher Ream <[email protected]>
Sent: Monday, July 21, 2025 4:16 PM
To: Kallas, Emily <[email protected]>
Cc: Gilbert, Carol <[email protected]>
Subject: 660 University

Emily,

Please give me an update on the status of the 660 University Project.

It is my understanding that the developer is moving forward with its original application 21PLN-00341. Two new sets of plans and supporting documents were filed on 6/23/2025, C12_660 University Ave_PLAN1.pdf, C12_660 University Ave_PLAN2.pdf, and C12_660 University Ave_DOCS.pdf. My brief review of these plans reveals a major change: The top floor (sixth) is no longer office space but has been changed to 12 new residential units, and the total number of residential units has increased from 66 to 70.

I am assuming that these new plans and documents supersede the prior filings.

Am I correct in my understanding?
Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]
From: Faith Brigel
To: Kallas, Emily
Subject: Planning and Transportation Committee: 660 University Ave.

Date: Wednesday, April 30, 2025 1:58:05 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hello Emily,
I received a notice that there will be a public hearing tonight at City Hall re the construction project at 660 University Ave.

Unfortunately, I will not be able to attend. So I am writing this email to you in the hopes that you and the members of this committee will see it.

I cannot state strongly enough how out of place, and cumbersome this huge building will be on University Ave and Byron Street.

I have been on Byron St. for thirty years and so I feel that I have some knowledge of that area.

It will be out of place in that no other buildings in that area are that large, that dense, nor that high. No other buildings are 6 stories high.

Initially weren’t they describing it as 4 stories, which is still very high? I call it cumbersome in that there will be many people living there, and many people working there and most of them will need parking spots.

And as they explained at one of the meetings though they will have a 2 level underground parking lot- there still will NOT be enough parking sports for all of their people.

There is very little parking on University Ave, , and rarely are there any available parking spots on Byron Street.

Similarly, finding parking on Middlefield is close to impossible.

This lack of parking for their tenants, and clients or customers will be a serious problem once the construction is complete. I am quite sure that they are not yet aware of this.

The fact that they are planning to build 6 stories is of a great concern to me. My building at 518 Byron Street is as I have explained a one story, and it has been there for more than 120 years. Having this construction 6 stories high right across the street will effect the light plan. It will be ominous. And it will detrimentally affect the quality of life of my tenants.

I am hoping and would expect that the City Staff would help protect the Palo Alto community of already established buildings., like mine, from new developments coming in and overwhelming the area.

I hope that you will not just focus on building more houses for Palo Alto, but also protect the character that older, Victorian buildings such as mine offer to our City.

Thank you,
Faith W. Brigel
From: Faith Brigel
To: Planning Commission
Cc: Kallas, Emily
Subject: Re: The 511 Byron St., 660 University Ave. 680 University Ave., 500 Middlefield Ave.Complex Date: Friday, March 14, 2025 6:35:17 PM
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ATT00001.txt
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ATT00002.txt
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Hello Panning Commission,
I do not know if you got the email that I sent to you on March 12 right before the meeting. I am sorry that it was so late.

I read some of what happened in the meeting and I would like to make a few comments.

Firstly, I realize that these developers initially submitted their plans for this project in 2021.

And I think that
there may be the concern that since it has been such a long time- you should be more empathic to them, and just approve it.

I would like to make the point that had their initial draft been different it may have gone through much faster and more smoothly.

By different I mean more in line with the other buildings in this area. From the first draft this building has been mammoth, massive, and very out of character with this neighborhood. For several reasons this construction is wrong for that location. All the changes that they have made over the past few years have not brought it down in scale or size. In fact, it has gotten larger! When they were told that they need more setback- they said fine we will just add another story- so it went from four stories up to six stories! And so due to their own insistence that it remain massive in size - this process has lingered. And they have taken up your time.

Secondly, I read that at least one of you believe that the final decision that was made at your meeting was wrong. And that you should have approved their current design.

I want to say that you did the right thing. I am thrilled that their design was not approved. It is so wrong. I was fearing that only once it is built will you see how wrong it is. And by then of course it is too late.

Thirdly, to mention several of the reasons why it is wrong:
1- It will be huge, gigantic, massive and totally out of scale with the neighbor’s buildings.

There are NO 6 story buildings here. The highest is 4 stories. 2- That intersection of University and Middlefield is the gateway to downtown Palo Alto, and it is always congested. To accept this current design will add more congestion and traffic than it can bear. It will be a constant nightmare. 3- At one of the meetings the developer himself stated that they will have a two level parking garage in their new basement. But he added, there will NOT be enough parking spots for them. There will be 66 apartments. And only 78 spaces. What about the parking needs of their offices? That is not near enough what they will need. So where will they park? They will not be able to park on Byron Street which is a small, narrow street and as I wrote 3/12 it is always full. Rarely are there available spots. There will be very few spots on University, and very few on Middlefield. So this will become a serious and ongoing problem. 4- This area mostly consists of office buildings with professionals, attorneys, dentists, and therapists. Aside from the traffic, it is a quiet area. Allowing this gigantic construction with 66 studio apartments that will have balconies, plus offices will effect the ambiance negatively. We have no restaurants, nor bars in our area. It is quiet. 5- By allowing this development company to build a 6 story, complex sets a precedent for others to build that high in this area. A bad decision. 6- Personally, I have owned the small, one-story, beautiful, well maintained, 120 year old Victorian building across the street. This massive development will totally overshadow my building, which will negatively affect the quality of living of my tenants. One tenant has already told me that she might move out. And I think it might affect my daylight plane. 7- I understand that due to some contract not being signed by Palo Alto the developers can now build at their own discretion. But it seems that these developers realize the benefits of trying to get the Planning Commission and the City Council’s approval. But still this is not a reason to approve such a phenomenally mammoth building.

Pease continue to use your discretion, and integrity as you did at that last meeting, and do not let a developer destroy what has been a tasteful, professional area just for their own greed.

Thank you for your consideration.

I would be happy to meet any of you on Byron Street to discuss this further. I have spent a lot of time on Byron since 1987, which is 38 years.

Best regards,
Faith
Faith W. Brigel
518 Byron St.
> On Mar 12, 2025, at 5:35 PM, Faith Brigel <[email protected]> wrote:
>
>
>
>> Dear Planning Commission,
>> I am not able to get to the meeting tonight. And I was not able to write any sooner. >> I hope that you see this email prior to the meeting. I have attended a couple of the other meetings on the construction on University Ave. and Byron. I own the building across the street. It is a single story Victorian house. I have been there since 1987. >> The construction submitted that is being discussed is much too large for this area. And I understand that now they are asking for it to be six stories. This is much too tall for this area.

No other buildings here are that high. There is also a lot of traffic at that corner. The 2 level underground parking will not be large enough for their needs. So their parking needs will spill out onto Byron that is already completely taken every day, all day, except maybe Sunday. >> Please consider the quality of life that will be detrimentally affected by the neighbors by allowing that project to be so massive. Please have them scale it back to a more moderate size. >> Thank you for your consideration.
>>
>> Faith W. Brigel
>>
>>> On Mar 6, 2025, at 2:01 PM, Kallas, Emily <[email protected]> wrote:
>>>
>>> Hello,
>>> You are receiving this email because you have expressed interest in the Planned Home Zoning (PHZ) project proposed at 511 Byron St, 660 University Ave, and 680 University Ave/500 Middlefield Rd (aka 660 University). This project. is being presented to the Planning and Transportation Commission on March 12, 2025 at 6pm. >>> The agenda, staff report, and attachments are available here:
>>> https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16498 >>> The project plans, Draft EIR, Final EIR, and other project documents are available here:
>>> https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Current- Planning/Projects/660-University-Ave
>>> If you have any comments, please email them to
[email protected]. There will also be the opportunity for public comments during the hearing. If you have any questions about the project you would like assistance with prior to the hearing, please email me at [email protected]. >>> Thanks, and see you next week,
>>> Emily
From: [email protected]
To: Planning Commission
Cc: Kallas, Emily
Subject: 660 University
Date: Monday, March 10, 2025 4:23:11 PM
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!
Dear Commissioners,
Please add your comments and forward to the City Council.

This application is now in its 4th year of review. They deserve a decision by council.

I attended all the ARB hearings in which opponents made their objections after which the ARB approved the project.

The applicant has worked hard to meet concerns while preserving feasibility and choosing a compliant not builder's remedy application.

This to my knowledge is the only housing proposal downtown of any significant size.

Also it brings with it BMR units that the applicant was able to weight toward lower income residents.

Housing downtown is a major city goal in our HE and approval of this project will be a promising start and\
bring the many benefits of downtown living to residents (I am one), to local businesses and to the environment.

I look forward to seeing this application approved and see the new housing in my neighborhood.

Stephen Levy
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1 Kallas, Emily
From: Preparata, Franco <[email protected]>
Sent: Wednesday, March 5, 2025 8:25 AM
To: Planning Commission
Cc: [email protected]; Kallas, Emily
Subject: 660 University Ave
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Byrne Chang (Chair)
Allen Akin (Vice Chair)
Doria Summa (Commissioner)
Bart Hechtman (Commissioner)
Carolyn Templeton (Commissioner)

Dear Honorable City Commissioners:

As residents of The Hamilton, the 55+ retirement community located next to this proposed site, this proposed project is deeply concerning for us.

The increased density of a 6‐story
building would substantially alter what is currently a quiet and safe street; It would not only change the character of this neighborhood block but it would also create a hazard for many of The Hamilton's residents. As elderly pedestrians, increased congestion is a significant safety issue. This is particularly the case given that the vehicular entry to the proposed building’s parking garage would be on Byron Street, next to The Hamilton’s entrance.

Additionally, Byron Street is a narrow street. As it stands, two cars cannot pass one another on the street. The setback of the proposed building on the Byron street side would need to be comparable to the setback of The Hamilton complex in order to permit the safe parking of firetrucks or other emergency vehicles.

We urge you to seriously reconsider the project.

Franco P.
and Rosa Maria Preparata
‐‐
Franco Preparata
An Wang Professor of Computer Science, Emeritus
Brown University
1 Kallas, Emily
From: Christopher Ream <[email protected]>
Sent: Wednesday, March 5, 2025 2:31 AM
To: Kallas, Emily
Subject: 660 University - SECOND letter
Attachments: Ream Letter re Other Than Tree - 20250305.pdf Importance: High
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Emily,

Please find attached a SECOND letter from me regarding other concerns with the 660 University project. This is in addtion to the letter concerning the Tree which I had just sent to you.

Please include include this SECOND letter as well in the packet for the March 12 PTC hearing.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1‐650‐424‐0821
[email protected]

THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] March 5, 2025 Commissioners Planning and Transportation Commission City of Palo Alto, California Via: [email protected] Re: 660 University Project SECOND LETTER – More Comments Commissioners, The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all of our neighbors. Parking Parking in downtown Palo Alto is a problem the City has been dealing with for years and continues to deal with. There is no parking on either University Avenue or Middlefield Road near the project. The Hamilton is on the short block of Byron between University and Hamilton and sees the parking problem every day. It is a narrow street to start with, but on every workday, every single parking spot on both sides of the street is filled all day long. This narrows the drivable room so that two cars going in opposite directions cannot pass; one has to slowly pull into a driveway to make room for the other to pass. Every time a delivery vehicle stops on Byron Street during the day, it clogs and backs up Byron. The project does not provide short-term parking for delivery vehicles, so Byron is going to get backed up many times a day. Applicant calculates that according to PAMC 18.52.040 a total of 111 parking stalls are required to serve the residents of the 66 residential units and the workers in all the office space. But then Applicant invokes several arguments to reduce the number of stalls it has to provide, starting with a 30% reduction claimed by TDM, down to only 69 actual parking stalls. I have seen 20% reductions claimed for TDM, but never 30%. Is Applicant’s claim of 30% proper? Has the city staff carefully reviewed the TDM Applicant has submitted? Will it actually reduce the need for parking or is it only designed to reduce the daily use of cars: Is it designed to reduce the number of daily automotive commutes a person takes, while that person still owns a car to be used for weekend activity. Even though it may reduce daily congestion, that car still needs a place to park.

Ream – More Comments re the 660 University Project November 26, 2024 Page 2 of 4 Bottom Line – Applicant has cleverly eliminated 42 parking stalls (111 – 69 = 42). Those 42 stalls may have been eliminated, but the cars have not been eliminated, and the 42 cars that can’t find an empty stall in the project’s garage will be driving around downtown, commercial and residential, looking for a parking space and causing congestion that the TDM was supposed to reduce. My granddaughter and other family members may not come to visit me because of the inability to park nearby; friends will not want to come over as much as they used to. Setbacks At the April 18, 2024 ARB meeting on this project, there was a lot of discussion about the lack of proper setback along Middlefield Road. Applicant has moved the above grade portion of the building back to form a 24’ setback along Middlefield as requested, but the underground garage extends right up to the property line with ZERO setback and a minimal amount of soil fill above the garage structure. (See Sheet A3.3A.) Will the City of Palo Alto be able to make improvements to Middlefield Road in the future with this garage flush up against the road? This brings out the fact that the garage also abuts both University Avenue and Byron Street with zero setbacks. Is this standard and acceptable?

Ream – More Comments re the 660 University Project November 26, 2024 Page 3 of 4 Daylight Plane There is a single family, one-story residence zoned RM-20 at 524 Middlefield Road, adjacent to the project. Upon a 1/21/2022 review of the initial filing by Applicant, Samuel Gutierrez advised Applicant of the requirement to observe a 45° daylight plane. Applicant complied, and in the next submission of plans, cut back the portion of the fourth floor next to the neighboring house. The fourth floor has remained cut back and compliant with the daylight plane in all subsequent plans submitted by Applicant including the current submission; but Applicant has now added two additional stories onto the building raising the height up to 82 feet, and disregarded the fact that these additional floors egregiously violate the daylight plane. The following is from Applicant’s submission. I have enhanced it to make the line of the daylight plane and the location of the neighboring house more visible.

Balconies in the Canopy The approval of the Architectural Review Board at its December 5, 2024 meeting was subject to several conditions being met. The first condition was “Remove balconies from within the Oak tree canopy.” (This can be found at the top of the fifth page of the document filed on 3/3/2025 under the name “C11_660 University Ave_DOCS_Revised for PTC.pdf”). Applicant’s plans show 24 balconies would intrude into the canopy (45-foot radius), and none have been removed. 3/32"=1'-0"
PLPL
OFFICE LOBBYSPEED RAMP DOWNTO P2 LEVELUNIVERSITY AVE.
10'-0"
10'-6"OFFICE PARKINGRESIDENTIAL PARKING
STAIRBEYOND7'-9" TYP.45.0°55'-0"LINE OF DAYLIGHT PLANE3'-6" 3'-6"
9'-9"13'-6"10'-6"14'-6"7'-0"FENCE7'-0"9'-9"EL. -1'-6" (NAVD 88 EL. 45.5')NEIGHBORINGPROPERTY GRADEP1 LEVELP2 LEVELLIFT PIT SECOND FLOOREL. 14'-8"THIRD FLOORFOURTH FLOOREL. 24'-5"EL. 34'-2"FIRST FLOOREL. 1'-2" (NAVD 88 EL. 48.16')BASE FLOOD ELEV.EL. 0'-0" (NAVD 88 EL. 47')1'-2"12'-8 1/2" ± 8'-4 1/4"7'-6" MIN.EL. -12'-1 1/8" ±EL. -26'-7 1/8" ±EL. -33'-7 1/8" ± CORR.TYP.
9'-9"12'-3"55'-5"1'-6"FIFTH FLOOREL. 43'-11"SIXTH FLOOREL. 56'-2"T.O. ROOF SLABEL. 70'-2"14'-0"T.O. PARAPET / ELEV.EL. 71'-8"OVERRUN / STAIRST.O. RAILINGEL. 73'-8"T.O. MECH. SCREENEL. 80'-2"3'-6"6'-6"MECHANICALSCREEN 54'-6" +/-
3'-6"
2'-2"SHORING/SOLDIER BREAMS
1/32"=1'-0"
3/-UNIVERSITY AVE

MIDDLEFIELD ROAD
BYRON STREET64G CARTCOMPOST64G CARTCOMPOST
RC64G CARTCOMPOST 64G CARTCOMPOST96G CARTWASTE96G CARTRECYCLING96G CARTWASTE 96G CARTRECYCLING

ARCHITECTSKORTH SUNSERI HAGEY

SHEET NUMBERSCALEPROJECT NUMBERSHEET TITLE
DATENO.ISSUES AND REVISIONSDESCRIPTION

524 MIDDLEFIELD A3.3B ENHANCEMENT OF VISIBILITY OF LINE OF DAYLIGHT PLANE AND 524 MIDDLEFIELD MADE BY CHRISTOPHER REAM Ream – More Comments re the 660 University Project November 26, 2024 Page 4 of 4 Balconies over University Avenue Applicant shows six to seven foot setback for the above-ground building along University Avenue. There are 29 balconies from the second to the fifth floor sticking out six feet into that “setback” so they come right to the edge of the public sidewalk or within one foot of it. They will have a clear glass railing set 3½ feet off the deck, with a clear glass sheet between the railing and the deck of the balcony. The majority of these balconies are part of small studio apartments. On warm, sunny Friday or weekend afternoons, there are going to be young people socializing on these balconies. The 3½ foot railing is an inviting place to rest your forearm as you hold a soft drink, a beer or a glass of wine. Geometry dictates that the drink is now another 6 -12 inches closer to the sidewalk floors below. Many residents in The Hamilton get some exercise by walking around our small block and their walk will pass under these balconies. I frequently see seniors from other parts of “Senior Corner” including this sidewalk as part of their walk. Please don’t drop a glass – you may kill someone. Those balconies need to be removed. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Board to require action to correct. Thank you for your consideration, Christopher Ream 1 Kallas, Emily
From: Christopher Ream <[email protected]>
Sent: Wednesday, March 5, 2025 2:26 AM
To: Kallas, Emily
Subject: 660 University - Letter t for PTC hearing
Attachments: Ream Letter re Tree - 20250304.pdf
Importance: High
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Emily,

Please find attached a letter from me regarding the Tree next to the 660 University Project, together with two attachments. Please include this in the packet being prepared for the hearing on March 12.

Thank you.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1‐650‐424‐0821
[email protected]

THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] March 4, 2025 Commissioners Planning and Transportation Commission City of Palo Alto, California Via: [email protected] Re: 660 University Project Protect the Coast Live Oak Commissioners, My wife Anne and I have been Palo Alto residents for more than 53 years and have been residents of The Hamilton for the past six years. The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (“HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block. David Babby, Applicant’s arborist, reports the Tree’s trunk is 50 inches in diameter and its mostly uniform canopy stretches out 90 feet in diameter and is approximately 60 feet high. The Tree abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is much larger. The Tree is several hundred years old and is deemed a protected tree by the City of Palo Alto. The Tree brings shade and joy to us and everyone else on the block. Applicant’s proposal to build a large building close to the Tree will put it in grave danger, and we need to protect it. TPZ – Tree Protection Zone The Palo Alto Tree Technical Manual requires a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Applicant acknowledges this 41-foot TPZ requirement in the Tree Protection Report it has filed with its plans, but then it has arbitrarily drawn a TPZ of only 30 feet on its plans and positions this building right next to that 30 feet. That is 11 feet less than required by the City of Palo Alto. 660 University Project Protect the Coast Live Oak March 4, 2025 Page 2 of 3 Notwithstanding Applicant drawing a 30-foot radius circle on its plans, its Tree Protection Report discloses that Applicant intends to disregard even that fake TPZ by reporting that there will be a 20-foot setback from the Tree’s trunk for any ground disturbance and that applies to any soil compaction, grading, subexcavation, overexcavation, drenching, and drilling/auguring. In other words, if the construction crew is at least 20 feet from the Tree, they are free to rip out as many roots as they like notwithstanding the deadly effect on the Tree. Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment A). But those roots are going to cut off by the garage and ramps at 30 feet and much closer to the trunk by the 20-foot rule during construction. Canopy The Tree has a beautiful canopy that stretches 45 feet over the site. The TPZ applies to the canopy as well as the root structure, but Applicant has used its fake 30-foot TPZ to bring the exterior wall of the building up to 30 feet from the trunk of the Tree, slicing off 15 feet of canopy. But then there are a large number of balconies sticking out six feet from the exterior wall. Applicant will need to slice off another 6 feet of the canopy to make room for those balconies. The building’s residents are not going to tolerate the Tree intruding their balconies, so the Tree will be pruned back to provide a little fresh air to those enjoying the balconies and you can be sure the Applicant will prune the Tree back so that there is at least 5 feet of clearance between those balconies and the Tree. The Tree’s beautiful canopy stretching 45 feet over Applicant’s property will be cut back 26 feet or more (15 + 6 + 5) and will now be only 19 feet. Tree Failure A tree’s roots do more than just feed and water a tree, the roots stabilize the tree and hold it upright. These roots are going to be sliced off under where the canopy is going to be cut back. As the weight and leverage of the canopy on the opposite side of the Tree strains to tip it over the dental office and onto The Hamilton, it is the job of the roots to fight back and hold the Tree up. But the roots will not be able to do that after they have been sliced off. The Hamilton retained an independent arborist to analyze the possible danger to the Tree. After extensive investigation and the preparation of a detailed analysis, it was that arborist’s professional opinion that the Tree’s vigor would be negatively impacted to a severe degree as a 660 University Project Protect the Coast Live Oak March 4, 2025 Page 3 of 3 direct result of the proposed work at the 660 University site as described on Applicant’s plans, resulting in the Tree falling into a spiral of condition decline from which it cannot recover. Please review the Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023 (See Attachment B). Notwithstanding that this report had been made public to Applicant over a year ago, Applicant has done nothing to minimize this serious danger. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy the dental offices and badly injure and maybe kill anyone in those offices at the time. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Commission to require action to correct As David Hirsch so succinctly stated on December 1, 2022 at the first Architectural Review Board Meeting to consider this application: “This is too much building in too small of a space.” Thank you for your consideration, Christopher Ream

660 University Project Ream – Protect the Coast Live Oak March 4, 2025 A"achment A

660 University Project Ream – Protect the Coast Live Oak March 4, 2025 A"achment B

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

1 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Date: 12/18/2023

Dear Mr. Ream,

The following written letter report is the single deliverable prepared by Walter Levison, Consulting Arborist (WLCA) per your request as an association with members residing at The Hamilton, in close proximity to the proposed multi-story 660 University project.

Background and Assignment

The proposed private development project stated above proposes to demolish various existing office buildings and parking lot areas, and build an underground parking garage, with residential and commercial office facility directly over the garage footprint. WLCA’s assignment was to determine whether the site work as currently proposed per the set of plan sheets (dated October 2023) would cause severe or otherwise irreversible injury to the subject oak specimen to such as degree that it would be expected to fall into a spiral of decline from which it could not recover, as a direct result of the site work. WLCA visited the site on 12/13/2023 to archive digital images, create a tree map markup showing actual site-verified canopy dimensions (rough approx.), and confirm existing site conditions.

The project encompasses three lots, 660 University, 680 University, and 511 Byron. An adjacent lot at 517 Byron just south of the proposed work area exhibits a relatively very large “veteran tree” coast live oak (Quercus agrifolia) referenced by David L. Babby, author of the Tree Protection Report filed by the developer, as tree #10 (City tag #1572), a specimen in good overall condition (62% out of 100% possible) as visually assessed by WLCA, with a canopy spread that is equal to the largest coast live oak specimens ever assessed in the author’s entire 25 year professional consulting career (see digital images below in this report showing the 90 foot diameter canopy).

WLCA reviewed the private development proposed plan sheets dated 10/31/2023 (planning resubmittal #5) which were downloaded from the City of Palo Alto website, and an arborist report by David Babby dated 11/19/2021, which does not actually contain any site plan sheets (Mr. Babby used a topographic survey sheet for his site tree map markup).

Multiple marked-up tree location maps, color-coded by WLCA, show expected construction-related impacts in relation to the tree #10 existing canopy dripline and in relation to the standard tree protection zone (TPZ) of 10 x diameter as an offset radius from mainstem edge. These markups are attached to the end of this letter report for reference (view document using Adobe Pro, Adobe CS, or other paid form of Adobe Acrobat, to maintain the visibility of the color-coded markups).

Digital images archived by WLCA in December 2023 are also included in this report for reference of pre-project conditions.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

2 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Basic Data

Diameter: 50 inches, per Babby report.

Spread: Approximately 90 feet total diameter, per David Babby report and WLCA.

Health (Vigor): 70% per Babby, 80% per WLCA.

Structure: 40% per Babby, 50% per WLCA.

Overall Condition Rating: 50% (fair) per Babby, 62% (good) per WLCA.

Live Twig Density and Live Foliar Density: Good.

Additional Tree Information per WLCA’s Visual Tree Assessment (VTA) 12/13/2023 and Research

Foliage hangs down to 15 to 25 feet above grade at 45 feet radius north of mainstem edge.

Multiple mainstems exhibit wide angle saddle shaped (i.e.”normal”) attachment forks between 10 and 15 feet elevation above grade. These stems are somewhat upward oriented.

Per USGS local quadrangle soils map, tree #10 is growing in the “Qoa” unit, which is defined as an older alluvium (oa):
a gravelly riparian soil that is derived from stream associated movements, and typically contains smooth rocky material that drains relatively well, and is excellent for development of deep, elongated native oak tree root systems (based on WLCA’s professional experience and research). This Palo Alto site probably has one of the best soils in the entire Bay Area in terms of allowing for fast growth of native oaks. See the digital images section of this report for an overlay map created by WLCA using various online sources and the USGS soil map shows how groundwater at this location is relatively high in elevation (25 foot groundwater contour), and shows existing roads, historical streams, and red dot plots where a past survey by others indicated locations of extremely old native valley oak specimens for reference. What this all means is that the proposed project site has very good growing conditions for native oaks with a high groundwater table elevation contour and gravelly alluvium soil associated with historical waterways which drains relatively quickly and may also exhibit relatively good aeration related to the larger material components of the soil.

1 Per Harris et. al. 2004. Arboriculture 4th Edition. Prentice Hall. Upper Saddle River, New Jersey, USA.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

3 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Expected Tree Root Zone and Canopy Impact Analysis / Based on October 2023 Set of Proposed Plan Sheets

• Canopy:

Expect 20 to 30% of canopy live wood and foliage to be removed to clear southward-extended balcony construction, garage vertical wall construction, foundation footing construction for main building structure, vertical exterior walls along the south side of the residential structure, and an additional +/- 10 feet of horizontal width required to be totally cleared up to roof peak elevations as a “construction corridor” airspace for exterior work, scaffold erection, and bucket lift machinery use (based on WLCA’s past projects to date, which required between 6 feet and 15 feet of horizontal clearance as construction corridors around building exterior walls, between soil surface grade and the roof peaks).

Note that the curvilinear section of garage entry ramp, although it is below grade elevation, may actually require tall vertical machinery clearance directly above the proposed wall cut locations, resulting in further clearance pruning of the tree #10 northwest corner of canopy (not verified). This information is based on past projects overseen by WLCA involving underground parking garage retaining wall construction in the Bay Area.

Total expected canopy loss will likely result in a remnant canopy with 20 to 25 feet of north, northeast, and northwest extension from mainstem base, whereas existing canopy is +/- 45 feet radial extension in those directions. Refer to the attached WLCA tree map markup for a graphic representation of the various impacts indicated as color-coded lines.

• Roots:

Note that the actual extent of roots may or may not be 2x to 3x the tree canopy dripline radius distance northward from trunk, and is currently obscured by hardscape and not able to be verified in terms of lateral distance of growth.

Critical Root Zone (i.e. “CRZ”) or “Tree Protection Zone”, in terms of structural root plate, lateral woody roots, and absorbing root mass retention during work on one or more sides of a tree, is ten times the diameter of trunk (10 x 50 inch diameter as noted in the David Babby report). Therefore, it is WLCA’s understanding that the required TPZ work offset radius for tree #10 is approximately 10 x 50 inches = 41.6 feet radius 2), unless site work at offset
distances less than 10 x diameter is specifically authorized by City Urban Forestry Staff. Note that in the case of the 660 University project, the severe extent of clearance pruning creates a cumulative impact in terms of loss of tree condition, such that the combined root zone and canopy impacts are relatively severe or extremely severe (see attached WLCA markups showing deep excavation work impacts, for example, expected to within 30 feet offset from trunk, which is far less than the 41.6 foot official TPZ offset).

2 Reference the developer’s Tree Disclosure Statement, which notes that the official TPZ is 10 x diameter of trunk, per City of Palo Alto Tree Technical Manual (TTM) standards. Blue link to full TTM below shows up erroneously as a hyperlink to “Appendix A”, but is actually the full TTM document:

APPENDIX A (cityofpaloalto.org)

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

4 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Note also that there is no guarantee that site work will be performed by the developer in a manner consistent with specific conditions of project approval as set forth by Palo Alto Urban Forestry Staff, even if those special conditions were mandated by the City. There is no way for an arborist monitoring site work, for instance, to be on site during every stage of the work. The arborist monitor, if retained to inspect site work near to tree #10 during the development phase of the project, would only be able to visibly inspect the site once a month or so, leaving him/her with a limited snapshot of what below-ground impacts occurred in relation to the tree #10 root zone.

Soil Compaction within the CRZ/TPZ:

Note that proposed driving of machinery, foot traffic, extensive landscape footing development, and extensive planting and (possibly also) extensive irrigation pipe trenching are expected to occur within the CRZ/TPZ of 41.6 feet radius from trunk edge of tree #10. Consulting Arborists will typically specify use of robust “ground protection” in these cases, covering the ground with a thick mat of geotextile overlaid with 6 or more inches of wood chips, and finally covered with steel trench plates or full sheets of exterior grade plywood strapped together with steel strap plates to create a soil buffer. But given that there is planned intense landscaping and decking, etc. to be developed in the area between the garage retaining wall and the south property line abutted up against the 517 Byron lot, WLCA expects that it would be virtually impossible for the developer to actually implement use of robust ground protection and maintain it for any length of time, without causing a major problem in terms of ground logistics (staging, storage, movement of tools and materials, performance of landscape related development between 517 Byron and the underground parking garage wall, etc.). Therefore, it is expected that soil compaction of a high degree will likely occur in the north section of the tree #10 root zone, within the CRZ/TPZ offset radius, causing additional reduction in overall tree health and structural condition as soil oxygen pore space is compacted and root zone root growing conditions end up suffering as a result of loss of oxygen pore spaces within the tree root growth section of the soil profile (i.e. mainly the uppermost two feet of the soil profile, but potentially down to 4 or 5 feet or more below soil surface grade elevation in native Palo Alto area historical riparian cobble type soils).

• TRAQ Risk:

The removal of 20% to 30% of the canopy of tree #10 for clearance as noted above, will cause southward lopsidedness of the currently-symmetrical canopy tree specimen of extremely large spread radius (45 feet radius), resulting in increased load forces acting on the north side (“tension” side) of the root system. The root system will have been compromised to an unknown degree during site work (underground parking garage wall excavation, landscape development, and possible adjustments to or demolition of the existing brick retaining wall that separates 517 Byron from the proposed 660 University project site.

Risk of whole tree failure mode and impact with targets to the south of the mainstem location will be necessarily increased and elevated due to these site plan work activities.

Risk of stem failure and impact with various ground targets will over time be increased and elevated, due to the required clearance pruning through the north side of the canopy to clear scaffolding, bucket lift machinery, balconies, and the new building exterior wall plus underground parking retaining wall work that requires vertical machinery airspace clearance. Very large diameter pruning cuts will be made to accomplish the work, ranging from a few inches diameter each, up to 17 or more inches diameter each 3, on some stems that extend northward into the
proposed project airspace area.

3 David Babby’s arborist report notes that a 14” and a 17” diameter stem will require pruning.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

5 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

• Heritage Tree Designation in City of Palo Alto

There are currently +/- eight (8) trees listed on the City heritage tree list maintained by the City. Per the following information, trees are apparently not required to meet any specific “approval criteria” in terms of species, size, condition, or other relevant parameters, to be selected as formal heritage tree specimens in City of Palo Alto, other than that the trees are native oak species or redwoods located on private property:

(Excerpt from a City Staff Report Online):
“In 1996, Council enacted the Tree Preservation Ordinance, Chapter 8.10 of the Palo Alto Municipal Code, to preserve and maintain specified native oaks, redwoods, and heritage trees on private property, and to protect them from disfigurement or removal, except in certain circumstances. Section 8.10.090 of the ordinance allows persons to nominate a tree on their property forheritage tree status. After Council approval of such designation, the tree is added to the heritage tree listing, which includes specific location, overall size, and canopy spread. The list is maintained by the Department of Public Works and available to the public on the City’s Urban Forestry website.

Once designated, a heritage tree is protected by the provisions of the Tree Preservation and Management Regulations, unless removed from the heritage tree list by subsequent Council action at the request of the property owner.”

Per the above information, protected size tree #10 (City tree tag #1572) appears to be an excellent candidate for inclusion in the City’s heritage tree designation program which protects native oaks on private properties. It is a specimen in good overall condition, with exceptional size in terms of both mainstem diameter (est. 50 inches), and canopy spread (90 feet total diameter), with good vigor, good buttress root flares, and good saddle-shaped wide angle forks of mainstem attachment.

• David Babby Report 11/19/2021 Page 6

Per page 6 of the developer’s arborist report by David Babby, tree #10 exhibits a “high” rating in terms of suitability for preservation (see below excerpt from page 6 of Babby report):

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

6 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Conclusion

If the proposed 660 University site plan project were built out as currently proposed per the 10/31/2023 planning resubmittal #5 versions of the plan sheets, WLCA expects that tree #10 would experience relatively moderate to severe root loss, and relatively severe pruning, which combined as a cumulative below-ground and above-ground negative impact would necessarily result in loss of vigor (health) and structure to a severe degree.

The tree’s safe and useful life expectancy in its current condition rating of “good” (+/- 62% overall condition rating) may be reduced as a result of site plan project work from (EXISTING: no-construction scenario) 50 to 100 years remaining, to (PROPOSED: post-construction scenario) 10 to 20 years remaining, or less, depending on the tree’s response to very significant project clearance canopy and root pruning as described above in this letter report.

It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover.

There would also necessarily be a corresponding elevation of the TRAQ risk rating in terms of risk of whole tree and/or tree part failure and impact with various static and moving targets with moderate to high occupancy ratings within the target zone and a reasonable time frame such as 12 to 24 months, starting as of the proposed site construction completion date (this would need to be assessed at a future time, and is outside the scope of WLCA’s initial pre-project assignment).

It is highly recommended that this exceptionally large native oak specimen in good overall condition be designated by the City Council as a City of Palo Alto Heritage Tree on private land, and formally added to the list maintained by the City on their official website, with the added tree protection guarantees that this tree special protection status includes (tree specimens are typically nominated for such designation by the owner of the property on which the tree stands).

Refer also to David Babby’s arborist report dated 11/19/202, page 6, which notes that tree #10 is rated as “high” suitability for preservation, appearing healthy and structurally stable per his assessment, presenting “good potential for contributing long-term to the site”.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

7 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Digital Images by WLCA 12/13/2023 / Tree #10 Coast live oak (Quercus agrifolia)

View looking eastward while standing on 517 Byron. Note the excellent buttress root flaring at the root crown of tree #10 which is considered normal and desirable.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

8 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

View of subject oak #10 looking northward from 517 Byron.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

9 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

10 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

See next page of this report for the United States Geological Survey legend pertaining to this soil unit, clipped from the local Palo Alto soil map, obtained from USGS Menlo Park headquarters.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

11 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

Above was excerpted from the USGS Quadrangle (soil unit map) which includes the City of Palo Alto area.

Assumptions and Limiting Conditions

It is assumed that any property is not in violation of any applicable codes, ordinance, statutes, or other government regulations.

ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email [email protected]

12 of 12
Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved

Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture

drawings or other documents does not constitute a representation by Walter Levison to the sufficiency or accuracy of said information.

Loss or alteration of any part of this report invalidates the entire report.

Arborist Disclosure Statement:

Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice.

Arborist cannot guarantee that a tree will be healthy or safe under all circumstances, or for a specified period of time.

Likewise, remedial treatments, like any medicine, cannot be guaranteed.

Trees can be managed, but they cannot be controlled. To live near trees is to accept some degree of risk. The only way to eliminate all risk associated with trees is to eliminate the trees.

Certification

I hereby certify that all the statements of fact in this report are true, complete, and correct to the best of my knowledge and belief, and are made in good faith.

Signature of Consultant

DIGITAL BADGES:

ISA CERTIFIED ARBORIST CREDENTIAL:
https://certificates.isa-arbor.com/f1918723-df46-48cc-ace2-c12625530fec#gs.v54om6

(Renewed through June, 2026)

ISA TREE RISK ASSESSMENT QUALIFIED (TRAQ):
https://certificates.isa-arbor.com/d180515f-ab75-440b-9c66-106005e3cf10?record_view=true#gs.hpb30w

(Renewed through March, 2028)

Attached: Tree Map Markups by WLCA 12/18/2023
(View Using Adobe or Adobe CS in Order to Allow for Full Visibility of the Markups Created Using Adobe Pro Software).
1 Kallas, Emily
From: Kay Brown <[email protected]>
Sent: Tuesday, March 4, 2025 9:59 AM
To: Kallas, Emily
Subject: 21 PLN-00341/660 University Ave
Attachments: City of Palo Alto Letter to Planning.pages CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Kay Brown
555 Byron St Apt 101
Palo Alto, CA 94301
[email protected]
650-269-1985

March 4, 2025

Emily Kallas
Senior Planner
Planning and Development Dept.

City of Palo Alto
250 Hamilton Ave Palo Alto, CA 94301

Re: 660 University/21 PLN‐00341

Dear Ms. Kallas,

I’m writing to express my concerns regarding the intended project slated to be built at 660 University. This large apartment/multi‐use facility is scheduled to come before you for determination on March 12, 2025. I would like to familiarize you with the current traffic issues on the 500 block of Byron St.

As it stands today, senior residents of 555 Byron as well as nursery school parents, church goers and dental office patients encounter frequent near‐misses entering and exiting their respective parking lots.

1. Currently parallel parking is permitted on both sides of the street, and the narrow residual allotment for 2‐way traffic becomes unwieldy with one car needing to pull over to allow on‐coming traffic to pass.

2. Byron is utilized by random drivers as pass‐through wanting to avoid the traffic light at University and Middlefield. Residents and patients in cars must to pull‐over and brake to avoid the on‐coming traffic. The cars travel swiftly without regard to elderly residents that are with walkers and wheelchairs as they attempt to cross the street.

3. Large commercial vehicles deliver food, linen, packages, etc or service plumbing, electrical, wifi tele‐ communication issues at the various facilities. When these large trucks park on Byron, the danger factor is exacerbated. It is difficult to see or maneuver safely around the commercial vans, etc.

4. There are currently 3 large senior facilities within the 2 block radius. Concern for Emergency Response Vehicles ability to access the streets at all times should be paramount. And, keep in mind that the majority of the population in this vicinity is elderly (ie. walkers, wheelchairs, and slow physically impaired amblers). Residents of Lytton Gardens regularly come for lunch at the church on foot with assisted devices. They traverse both Byron and University.
2 It is my understanding that the developer of 660 University intends to situate the ingress and egress to the underground parking directly on Byron St? With the dense apartment units and office spaces anticipated in the new complex, accidents can be anticipated.

Also, please consider the situation that will arise during construction of the new complex. At any given time, there will be large construction vehicles needed to demolish existing structures and erect the final facility. Where will the construction vehicles park so as not to worsen an already dangerous situation…on University, on Middlefield?

I am under the impression that the developers are anticipating that many of the 660 University dwellers will not own cars and will be utilizing mass transport. At the previous City Council meetings, a study initiated on the developers behalf stated that a majority of the tenants will not be coming and going in automobiles by a computer generated (formulation) pie in the sky scenario? If this is an accurate analysis, I am asking the city of Palo Alto to verify this information and stand by it’s assessment.

Thank you for your attention to this matter.

Appreciatively,
Kay Brown
Letter Attached:
1 Kallas, Emily
From: Leroy Barnes <[email protected]>
Sent: Tuesday, March 4, 2025 12:56 PM
To: Kallas, Emily
Subject: 660 University Avenue
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

To the Palo Alto Planning and Transportation Committee

I am a resident of what is known as “seniors corner”, at University and Hamilton in Palo Alto. Lytton Gardens, the Webster, and the
Hamilton together house hundreds of elderly Palo Alto citizens at this corner. The addition of about 88 new cars in this small area would result from building the proposed 660 University high rise, assuming one car for each living unit. Slow‐walking citizens with poor eyesight and impaired hearing walk on Byron St., University, and Webster all day, every day. One of the cars belonging to the proposed building will surely run over one or more of our citizens within months or years of its completion. Help us live a long life by rejecting this proposal.

In addition, aesthetically, the building
is a poor fit for downtown Palo Alto. Since it would be built on University at the east entrance to downtown, they might as well put up a sign that says, “Welcome to Downtown Palo Alto. We’re trying to look like Redwood City.”

This building may some day serve a great
purpose to Palo Alto, but not in the proposed location. We energetically request that you deny the proposal as it has been presented.

Leroy Barnes
555 Byron Street Resident

1 Kallas, Emily
From: Leroy Barnes <[email protected]>
Sent: Tuesday, March 4, 2025 12:54 PM
To: Kallas, Emily
Subject: 660 University
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Palo Alto Planning and Transportation Commission:

We respect the developer’s desire to add housing units to the Byron/University/Middlefield neighborhood. However, we are confident that the completion of this project will be an irreversible mistake that mars Palo Alto’s downtown
skyline and endangers hundred of senior citizens who live and walk in this three block area.

The traffic congestion that would result from this development would suffocate Byron Street between University and Hamilton, a street on which delivery trucks, moving trucks, ambulances and parents dropping off preschool children at
First School all compete for space on the single two‐way lane between cars parked on both sides of the street. The additional cars that would belong to the residents of 660 University would overwhelm this area.

Please reject the proposed location for this development.

We support additional housing in Palo Alto, but are confident that this would be a disaster that would be forever blamed on the members of your Commission.

Thank you.

Linda Chin
555 Byron Street Resident

1 Kallas, Emily
From: Admin <[email protected]>
Sent: Tuesday, March 4, 2025 12:45 PM
To: Transportation; Planning Commission
Cc: Kallas, Emily; Gilbert, Carol
Subject: 660 University Ave.

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

To: Planning and Transportation Commission March 4, 2025 Subject: 660 University
The building proposed at 660 University will create a dangerous situation for those of us who live or do business on the 500 block of Byron between University and Hamilton. Lund Development proposes to create 60+ living units plus a floor of office space. The proposal only provides for 78 parking stalls. There are no parking spaces surrounding that building on University or Middlefield, so that only leaves Byron or other nearby streets with 2-hour limited parking available to those occupants, a traffic nightmare.

This photograph shows Byron on a delivery-impacted day. Imagine adding the truck, auto, emergency, and garbage truck traffic for the occupancy that will be added. As an area of senior residences with pedestrians on walkers and canes and frequent Paramedic vehicles needed, I wish to propose that you strongly consider reconfiguring the length of 500 Byron St. so that all cars, rescue vehicles, pedestrians, and trash removal can safely turn onto or cross or exit our street.

At the forthcoming meeting on March 12, I wish to propose this reconfiguration:

Sincerely,
Carol Gilbert
555 Byron St. #209
Palo Alto, CA 94301

From: Austin Traver
To: Kallas, Emily
Subject: Neighbor, Opposed to 680 University Avenue
Date: Friday, December 6, 2024 7:03:43 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hello Emily,
My name is Austin, I own a home on Fulton St in downtown Palo Alto. I noticed that a developer has proposed to construct a massive building right next to my little condo. https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Current- Planning/Projects/680-University-Avenue
I live one building away, in a 10-unit complex. Our condo is already pretty cramped as it is, in terms of parking spaces, density, etc.,
This project seems like it will be very disruptive to the character of the nearby neighborhood community.

Can you help me understand how I, as a resident of Palo Alto, can participate in our city’s decision on whether to allow this to go forward? I want my voice to be heard by my representatives.

Sincerely,
Austin Traver
Sent from my iPhone
1 Kallas, Emily
From: Yingxi Chen <[email protected]>
Sent: Thursday, December 5, 2024 8:26 PM
To: Kallas, Emily
Subject: 660 University Ave- Structure Feasibility for Future Transportation Improvements CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi Emily,
I would like to share some additional thoughts regarding the special setbacks for the 660 University Ave project following today's ARB meeting.

One of the key reasons for establishing these special setbacks is to accommodate future transportation improvements, which may include bike lanes, street parking/loading zones, left‐turn lanes, and other enhancements. Given the rapid growth of the city, with over 6,000 new units planned, Middlefield Road will inevitably face increased traffic congestion and safety concerns. At some point, the road will require modifications to address these challenges.

The design team for 660 University Ave has made significant efforts to meet the required 24‐foot setback, but it would be shortsighted if, years down the line, we discover that these necessary roadway improvements cannot be implemented due to potential structural issues with underground parking.

In fact, the applicant could benefit from these future improvements. For instance, if the street is widened to allow for street parking, it could help alleviate parking issues. Similarly, the expanded roadway could provide space for a loading zone or designated trash collection area, preventing disruptions to traffic flow while meeting the building’s operational needs.

I understand that further studies, surveys, and community engagement will be conducted before any changes are made.

However, buildings are permanent commitments, and their design will shape the city for decades. The ongoing wave of new housing projects means that transportation infrastructure improvements will need to keep pace with growth. I urge the applicant to consider the structural feasibility of accommodating these future transportation needs in their design, in addition to provisions for landscaping and utilities.

Thank you for your consideration of these points, and I hope you have a wonderful holiday season.

Sincerely,
Yingxi

Yingxi Chen, AIA
Y. Chen Architect
From: [email protected]
To: Architectural Review Board
Cc: Kallas, Emily; Lait, Jonathan
Subject: 660 Univeristy project
Date: Saturday, November 30, 2024 10:57:53 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Chair Rosenberg and committee members,
I hope you are having a joyful Thanksgiving holiday.

Please move this application forward with your comments and any remaining concerns.

As the housing project on this site enters its fourth year of review, I believe the applicant and community deserve a hearing before the city council and timely decision.

My comments below are as a DTN resident and economist with experience in housing economics and more than a dozen HCD advisory committee member meetings. As I always clarify before you, I have no expertise as an architect or arborist and will not comment on these issues.
1) I believe this is the only housing proposal of any significant size in DTN, an area identified as important for additional housing in our Housing Element and by you in previous meetings.
2) As with 3265 and 3150 ECR, this current application is the result of collaboration between the applicant and staff to respond to ARB comments and concerns while preserving the financial feasibility of the application. I have been pleased by the recognition and appreciation by ARB members of these twin objectives.

As with 3265, the applicant has responded to concerns by adding height and other configuration changes.

And, as the chair noted at the last meeting, the alternative to successful resolution of issues could be no project or in this case a builder's remedy application that the applicant has shelved for now in favor of this smaller project.
3) The applicant is proposing a large majority (10) of the 14 BMR units for low income residents including 6 for very and extremely low income residents. I am pleased the applicant i able to co this in the context of a feasible proposal. 4) This site has additional benefits as it will allow some/many trips to be done without driving and the residents will make a small but positive addition as customers for DTN businesses.

I look forward to hearing council's review asap as we begin the process of adding housing in appropriate DTN locations.

Stephen Levy
From: Greg Welch
To: Architectural Review Board; Kallas, Emily
Cc: Ann Lewnes
Subject: Public Feedback on the proposed project "660 University Ave" project [21PLN-00341] Date: Wednesday, December 4, 2024 7:58:11 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

My wife and I are writing as we will be unable to attend the ARB meeting at 8:30am on 12-5- 24 due to work conflicts. We own a unit on the north side, third floor of the Hamilton building ( at 555 Byron St.) just to the south of the proposed project. My house-bound, elderly mother-in-law occupies the unit and the sunlight through her windows and on her balcony represent most of her experience of the outdoors. We are very concerned that the proposed project could cut off all direct sunlight and require her to have to draw her blinds to have any sort of privacy.
1) the six-story height suggests a size and mass completely out of keeping with the surrounding neighborhood
2) at that height, the project threatens to loom over and literally overshadow the buildings around it.
3) Throughout Palo Alto, building standards preserve privacy by preventing neighbors from building structures that look down into backyards, or directly into windows in existing structures. How will that be accomplished on this project? Greg Welch
Ann Lewnes
560 Center Drive
Palo Alto, CA
December 3, 2024
Dear CommitteeMembers,
TheHousingActionCoalitionisamember-supportednonprofit that advocatesfor creatingmorehousingfor residentsof all incomelevelstohelpalleviatetheBayAreaandCalifornia’shousingshortage, displacement, andaffordabilitycrisis.

Our endorsement committeehadtheopportunitytoreviewSmithDevelopment’sproposal at660University, andweproudlyendorsedtheproject.

SmithDevelopment’sproposal wouldbring66much-needednewunitstoPaloAlto. Wewereimpressedwiththeproject'sdedicationtoaffordablehousing, with20percent of theunitsforlower-tieredaffordablehousing, whichishighespeciallyconsideringcurrent economicconditions. Byprioritizingaffordablehousingandurbandevelopment, wecancreatemoresustainableandinclusivecommunitiesfor everyone.

Intermsof LandUseandDensity, theproject site'scentral locationwithitsproximitytoessentialdowntownamenities, includingtheCaltrainstation, andtheinclusionof amplebikeparkingfacilitiesunderscoreacommitment topromotingenvironmental sustainabilityandreducingrelianceonautomobiles. Intermsof parking, our committeewouldliketoseeareductionontheamount of parkingprovidedfor theproject, andhavetheproject redirect thosecoststoincreasingtheoverall densityof theproject. Intermsof overall design, wecommendthestepsSmithDevelopment hastakentopreservetheOaktreeonsite, andevenincorporatedit intothedesign.

Thisproject will becritical tosupport PaloAlto, andtheBayArea’shousingneeds. Pleasemovethisproject forwardwithout delay.

CoreySmith, ExecutiveDirectorHousingActionCoalition(HAC) AliSapirman,AdvocacyandPolicyManagerHousingActionCoalition(HAC)

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December 1, 2024
SUBJECT: Agenda Item #3 - 660 University Avenue Mixed-Use Project Dear Chair Rosenberg and Board Members,
We urge quick action on the proposed mixed-use project at 660 University Avenue. The project has been positively modified based on previous Architectural Review Board comments. We are excited to see an additional floor has been added to the project for a total of 66 residential units as part of this mixed-use project
We support this project because it is walking distance to downtown businesses, retail, and services . It is 0.6 mile from Caltrain and adjacent to major transit stops, thus reducing residents' climate emissions because they can drive less. In furtherance of our affordable housing goals, the project will provide 66 homes and 20% will be affordable (where normally 15% is required).

We hear often from tenants in Palo Alto that there is not enough bike parking in their multi-family developments. This is especially true as more residents are adopting e-bikes and cargo bikes.

We are excited to see accessible and plentiful bicycle parking being provided as part of the project – a huge bonus to future residents and office tenants. The proposed vehicle parking ratio is adequate based on recent development trends and given the project’s location near transit and retail.

This modest 66-unit project has been through a long (but sadly typical) PHZ process since 2021, including an exhaustive Environmental Impact Report that is normally reserved for significantly larger projects. Please provide substantive comments so that the project can move towards approval.

Palo Alto Forward has been working to strengthen community support for housing projects to end our housing crisis and strengthen our city. As such, we have included 100 pages of support letters written by residents on behalf of this project.

Thank you for your service to our community!
Amie Ashton
Executive Director, and on behalf of the Board of Palo Alto Forward ATTACHMENT A: 100 Pages of Public Comment Comments Supporting the Project

ATTACHMENT A: 100 Pages of Public Comments Supporting the Project (link) /0/1/2/3/4/4/5
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YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]

12/02/2024

City of Palo Alto
Architectural Review Board
250 Hamilton Ave
Palo Alto, CA 94301

[email protected]
Via Email

Re: 660 University Avenue Proposal

Dear Palo Alto Architectural Review Board,

YIMBY Law is a 501(c)3 non-profit corporation, whose mission is to increase the accessibility and affordability of housing in California. YIMBY Law sues municipalities when they fail to comply with state housing laws, including the Housing Accountability Act (HAA). As you know, the City Council has an obligation to abide by all relevant state housing laws when evaluating the above captioned proposal, including the HAA. Should the City fail to follow the law, YIMBY Law will not hesitate to file suit to ensure that the law is enforced.

This proposal consists of a mixed-use development with 66 units and a top-floor office and two levels of below-ground parking. The proposal was submitted under Palo Alto’s Planned Home Zoning community plan in an area zoned for multi -family residential use. Though it requests zoning changes, this proposal is compliant with the City’s General Plan. Under California Government Code § 65589.5 in cases where the general plan and zoning ordinance do not match, a project is only required to comply with the general plan.

YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]

(j)...(4) For purposes of this section, a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the project site is inconsistent with the general plan. If the local agency has complied with paragraph (2), the local agency may require the proposed housing development project to comply with the objective standards and criteria of the zoning which is consistent with the general plan, however, the standards and criteria shall be applied to facilitate and accommodate development at the density allowed on the site by the general plan and proposed by the pro posed housing development project.

In the case of this particular project, the zoning ordinance has a more restrictive density limit than the general plan and no density minimum. The general plan on the other hand requires a minimum density for new development in this area that is not present in the zoning ordinance.

Applied to this project state law clearly mandates that the project comply with the city’s general plan in cases where the zoning ordinance differs. This includes all objective general plan standards or criteria, including the density minimum. This is all noted in the staff report for this project, which accurately describes the proper application of state law, regarding unit count, to this project.

Therefore, you must approve the application, or else make findings to the effect that the proposed project would have an adverse impact on public health and safety, as described above. Should the City fail to comply with the law, YIMBY Law will not hesitate to take legal action to ensure that the law is enforced.

YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]

I am signing this letter both in my capacity as the Executive Director of YIMBY Law, and as a resident of California who is affected by the shortage of housing in our state.

Sincerely,

Sonja Trauss

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/126/102/109/113/111/121/111/122/124/143/118/109/102/110/103/132/127/104/109 /101/102/103/104/i255/106/103/107/104/115/i255/108/102/103/110/123/104/114/112/110/102/i255/144/145/146/129/128 1 660 University Avenue Development Issues An Executive Summary for ARB Meeting December 5, 2024 Need to consider the following: 1. Inadequacy of 78 stalls for 66 units plus businesses. 2. How brochures and passes get people out of their cars. 3. If we don’t know compliance for 2 years, there is no going back. 4. Insist on two-year data from previous TDM Specialists, Inc. to prove effectiveness. 5. History of This Project Nearby residents of the proposed 660 University development have been opposed to several aspects of the development and have made our objections known to every city committee that held a hearing. It started with shoe-horning in too much building on too small a property which was 4 stories tall with 70 units and size remains an issue. October 25, 2021 Council held a prescreening to review a conceptual plan for the proposed project on October 25, 2021. The formal PHZ application was submitted on December 21, 2021. Following staff’s initial review and subsequent resubmittal, the PTC reviewed the project on November 16, 2022 and recommended that the project be forward to the ARB for review in accordance with the PC rezoning process. December 1, 2022 The ARB reviewed the same plan set on December 1, 2022. Since this time, the applicant made significant modifications to the project, including changing the parking garage driveway entry from Middlefield Road to Byron Street, as well as removing residential uses from the ground floor to meet FEMA flood zone requirements and address ARB comments related to privacy for ground floor units. This submittal was received on September 1, 2023, ten months after the last public hearing. The plans have been further refined over three rounds of staff review in the last seven months to address various staff comments. Key comments from Board members and the applicant’s response to those comments are summarized in the Exhibit file found separately. Dec. 1, 2022 ARB Meeting A previous Architecture Review Board hearing listened to our objections and sent Smith Development away to make some amendments that would be more suitable for your board and nearby residents on Dec. 1, 2022. Key comments from Board members and the applicant’s response to those comments were summarized. Only change was drive-way moved to Byron St. all others were left alone. You can see Exhibit results separately. April 18, 2024 ARB Meeting Further recommendations by 3 Board members were adjustments be made to the plans. 1. Remove extended balconies from units B1, B1, and A2 from Historic Oak tree. 2. 6 foot screening on 4th floor roof deck to reduce noise and maintain privacy. 3. Inadequate parking remained an issue. 4. Consider the Draft Environmental Impact Report The purpose of this report is to restate the comments made by the Board and detail the applicant’s response to those comments. The analysis section below builds upon the information contained in the earlier report and has been modified to reflect recent project changes. Following the ARB’s recommendation, the project will return to the Planning and Transportation Commission (PTC) for a formal recommendation of a Planned Community Ordinance. Both of these recommendations will be forwarded to Council for a final decision. At that point the number of units was 63. 2 Builder’s Remedy May 2024 6 stories and initially 110 units. The revised application that Smith Development submitted last month for its planned project 660 University Ave. calls for a six-story building with office space on the lowest and highest floors and then 66 apartments in between. The proposal is just the latest iteration of a downtown project that has already gone through multiple revisions since Smith first applied in 2021 under the “planned home zoning” process, which allows residential builders to negotiate with the city over zoning exemptions. The four-story project that the company had previously proposed was narrowly approved by the Architectural Review Board in April. While both the builder’s remedy and the PHZ applications are currently on file, the applicant has requested that the City place the Builder’s Remedy application on hold while the City continues to process the PHZ application November 26, 2024 ARB Meeting re: TDM Plan The Transportation Demand Management (TDM) plan includes measures and programs to achieve a reduction in single-occupancy vehicle trips to the site by a minimum of 45%. New residents will have to sign an acknowledgment that they are aware there is a goal to reduce commuter trips and maximize use of all other sources. This is not a legal pledge. The TDM plan includes an annual monitoring plan to document their traffic. The first data will not be known until 2 years hence. In summary, a TDM plan sounds great, but it only works for Smith Development who will make too few parking places available for residents. With no adjacent streets permitting parking and limited parking on Byron, do you really think this will work? In TDM’s own words, “We have a proven track record of getting employees out of their cars. As projects are built and occupied, TDM Specialists can develop the, outreach, and campaigns necessary to implement and manage employee Commute Programs or parking management programs. The initial start-up, implementation, and ongoing management of the Commute Program are designed to meet employee benefits for businesses.” It is incumbent on this board to request some proven results that TDM has been able to achieve after two years before making any decision on this project. Exhibit Follows which shows various ARB directions with applicant’s responses.

3 Exhibit File

From: Kathleen Rotow
To: Kallas, Emily
Subject: Re: 660 University Draft EIR - Now Circulating Date: Wednesday, April 3, 2024 11:52:55 AM
Attachments: image001.png
image002.png
Thanks Emily. I'm glad the review concluded that the Byron Ave entry and exit for this project made more sense than further slowing down Middlefield and University. It also keeps some of the inevitable noise from this project from disturbing the senior project across the street on University.

On Wed, Apr 3, 2024 at 8:28 AM Kallas, Emily <[email protected] > wrote:

Hi Kathleen,

After the initial ARB review, the driveway was relocated to the Byron frontage, to reduce potential conflict on Middlefield.

Thanks,
Emily

Emily Kallas, AICP
Planner
Planning and Development Services Department
(650) 617-3125 | [email protected]
www.cityofpaloalto.org

Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped

From: Kathleen Rotow <[email protected]>
Sent: Wednesday, April 3, 2024 4:46 AM
To: Kallas, Emily <[email protected]>
Subject: Re: 660 University Draft EIR - Now Circulating

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Good Morning Emily,
I have an initial question that you may be able to answer quickly. Given that I live within two blocks from the project on University Avenue, one of my concerns is the amount of additional traffic this project will generate on an already very congested corner. Probable additional traffic backups on both University Ave and Middlefield Ave. Will the entry and exits for parking be on University or Middlefield? Will there be any left turn entry into the parking for the project while heading west on University?

Thank you,
Kathleen Rotow
Sent from my iPhone
On Apr 2, 2024, at 5:58 PM, Kallas, Emily <[email protected] >
wrote:

Good afternoon,

This e-mail is to inform you that the Draft EIR for the 660 University project is now available here on our Planning Department website. The Notice of Availability is attached and has further information regarding the proposed project. The comment period for the Draft EIR begins today, Tuesday, April 2nd and will end on May 17, 2024. This e-mail is being provided to you because you are a neighboring jurisdiction, your agency has expressed an interest in the proposed project or because your agency may have an interest in the proposed project, or because you have been requested to be contacted regarding any project within the City of Palo Alto’s jurisdiction. Please feel free to contact me if you have any questions or to send comments.

Regards,
Emily

<image001.png> Emily Kallas, AICP
Planner
Planning and Development Services Department
(650) 617-3125 | [email protected]
www.cityofpaloalto.org

<image002.png>

Parcel Report
| Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped

<660_University_NOA signed.pdf>
From: Christopher Ream
To: Kallas, Emily
Subject: 660 University Project
Date: Wednesday, April 10, 2024 3:38:35 PM
Importance: High
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Emily,

Chris Ream here, the President of the Hamilton Homeowners Association.

I intend to prepare a letter to the Architectural Review Board outlining The Hamilton’s objections to the planned project at 660 University, and I also intend to attend and comment at the ARB Hearing new week on April 18.

I have done a quick review of the Draft EIR. The Draft EIR addresses many of the points I had previously brought up to the ARB along with some new points, including in particular, the danger of killing Tree #10 (the protected coastal oak) and the alternative of adding a fifth above-ground story to the building, and the alternative of eliminating the second floor of the underground garage. These are not shown in the developer’s current plans, but are obviously issues that need to be addressed at some point.

My question is: Would it be proper for me to address in my letter to the ARB and at the Hearing points raised in the Draft EIR but not yet appearing in the developer’s plans.

I will call you to have a brief discussion on this.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]

From: Mimi and Eric Carlson
To: Christopher Ream; Kallas, Emily
Subject: Re: 660 University Project
Date: Thursday, April 11, 2024 11:02:35 AM
You don't often get email from [email protected]. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Chris et al.

Please note that the proposed project will create a traffic nightmare, espesciallly if the entrance is on Byron.- which is effectively a one wao street during the day.

Eric Carlson
From: Christopher Ream <[email protected]>
Sent: Wednesday, April 10, 2024 3:38 PM
To: Kallas, Emily <[email protected]>
Subject: 660 University Project

Emily,

Chris Ream here, the President of the Hamilton Homeowners Association.

My question is: Would it be proper for me to address in my letter to the ARB and at the Hearing points raised in the Draft EIR but not yet appearing in the developer’s plans.

I will call you to have a brief discussion on this.

Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]

THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] April 16, 2024 Via email: [email protected] Re: 660 University Project Architectural Review Board Hearing on April 18, 2024 Draft EIR April 2024 Comments re Protection of the Coast Live Oak Tree Dear Emily, Please consider the comments in this letter as you continue to work on the Draft EIR for the 660 University Project and pass on these comments to members of the Architectural Review Board and to others where appropriate. There is an Attachment A and an Attachment B to this letter. The Hamilton is a senior living (55+) condominium development with 36 residential units and the average age of the residents in The Hamilton is mid-80’s. The Hamilton shares the same small block with the proposed development at 660 University Avenue. Lytton Gardens, Webster House and Webster House Health Center are within a block and directly across the street from the proposed development. Channing House is two blocks away. Because of this concentration of elderly citizens, the area is frequently referred to as “Senior Corner.” I am Christopher Ream. My wife Anne and I have been Palo Alto residents for 53 years and have been residents of The Hamilton for the past five years. The Hamilton community strongly opposes the proposed development at 660 University, and the Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its members/residents, has resolved to fight against the proposed development. I am the President of the HHA and am personally committed to significantly revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block and is listed as Tree #10 on Applicant’s plans. Applicant’s arborist reports that the Tree’s trunk is 50 inches in diameter and its limbs stretch out 90 feet in diameter “in a mostly balanced canopy.” The Tree abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is larger than that. The Tree brings shade and joy to us and everyone else on the block. The Tree is several hundred 660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 2 of 4 years old and is deemed a Protected Heritage Tree by the City of Palo Alto. Applicant’s arborist rates the Tree “High” for suitability for preservation. This proposed project puts this beautiful Tree in grave danger: “It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover.” Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023, p.6 Please see Attachment A to this letter for the full Impact Analysis by Walter Levison Consulting Arborist. Tree Protection Zone Applicant’s plans recite that the City’s Tree Technical Manual (TTM) ¶1.36 specifies a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Another rule is that the TPZ should be equal to the foliage, so here that would be a radius of 45 feet based upon the arborist’s report of a 90-foot canopy spread. I am not an arborist, but I am told that one common rule of thumb is that a tree’s roots are one and a half to three times wider than the canopy. For the Tree’s 45-foot limbs, that would be 67 to 135 feet of roots out under the parking lot where the new building would go. Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment B.) Applicant has drawn a TPZ of only 30 feet on its plans and has the new building right next to and touching that 30 feet. That is 11 to 15 feet less than required. And the 30 feet is just what the building is supposed to look like – you don’t have to be an experienced contractor to know that there will be plenty of damaging construction work done on the exterior side of the two-story underground garage walls, and that will be much closer than 30 feet to the Tree. Robert Booty’s report points out that the roots are going to be sliced off at his scan of 31 feet. (See Attachment B.) Now, look up at the 2nd, 3rd and 4th floors, there are residential units with balconies sticking out 6 feet into the TPZ. Applicant’s arborist admits that pruning will be required, including a 17-inch limb. The Tree has to be pruned back to clear those balconies. Then be realistic: Applicant is going to prune the Tree even further back so that there is at least 5 feet of clearance between those balconies and the Tree. We are now cutting the Tree back to only 19 feet of foliage left. 660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 3 of 4 If 660 University is allowed to be built as now proposed, the Tree’s canopy will be severed on one side, disrupting the Tree’s balance, potentially allowing strong gravitational forces to push the Tree over. In addition, the roots needed to hold the Tree back from tipping over will have been cut and lost their gripping force. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy the dental offices at 517 Byron, and badly injure and maybe kill anyone in those offices at the time. The neighborhood will lose this beautiful tree. The privacy of the seniors in the sixteen apartments in The Hamilton on that side of our development will be exposed to the 36 units with balconies on our side of the 660 University building as well as the noisy crowds on the roof top party deck. Security The Staff Report for the Architectural Review Board Hearing to be held April 18, 2024 reported that the Urban Forestry Section has requested that any building permit be conditioned upon the Applicant obtaining an appraisal of the replacement value of the Tree and posting security for that amount. What does that mean in this situation? It will be completely impossible to replace the Tree, thus how can anyone come up with a replacement value. And, if the Tree “dies” within three years of the completion of the project, then the money from the security will go into the Forestry Fund to plant trees elsewhere. So much for the owner of 517 Byron and thus the person who was the owner of the Tree and the one most damaged by its death. This might make sense if the permit was conditioned upon obtain an appraisal value using the Trunk Formula Method (TTM 6.45B) rather than the Replacement Cost Method (TTM 6.45A). Solution At the Architectural Review Board hearing in December 2022, everyone, including the Applicant’s architect and its landscaper actively agreed that the Tree had to be protected; but the Applicant did not suggest that a 41-45 foot TPZ should be observed. No, their answer was that they knew of a tree in Mountain View that has so far survived a small TPZ (although they did not say how long it has survived). One tree surviving for an unknown time is not a valid argument to ignore the universally accepted rule of a TPZ equal to 10 times the trunk’s diameter or the extent of the canopy. The only solution here to save this Protected Heritage Tree is that the proper 41-foot TPZ must be imposed and complied by both the proposed building and its construction. This is not an unfair burden on the Applicant: They have known all along that their 30-foot TPZ was in violation of TTM regulations, and that the building could not be constructed without violating even that reduced TPZ because of the necessity to have construction closer to the Tree than that artificial 30 feet. The first time they showed a TPZ on their plans was their C3 filing on October 6, 2022 when they showed a TPZ with a radius of 29’11-½” (strange number for a TPZ). C3_660 University Ave_PLAN1.pdf, p.24. This was later updated to the 30 feet we see now. 660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 4 of 4 Applicant’s arborist David L. Babby discusses the size of the TPZ in §5.3 of his Tree Protection Report, 660 University Avenue, February 7, 2024: “The CPA's Tree Protection Zone (TPZ) standard is a radial distance from the trunk equal to 10 times its diameter, which for oak #10, identifies a TPZ of 41 feet from the trunk. The proposed project establishes the TPZ to be 30 feet from the trunk, which equates to a multiplier of 7 times the trunk diameter (and 11 feet inside).” He then goes on to say that the small 30-foot TPZ only applies to the finished building and garage, and sets up an even smaller, undisclosed zone where all sorts of construction work can tear up the ground and destroy the Tree’s roots: “The architectural design substantially conforms to my recommendations provided in January 2021, which stipulates a minimum 30-foot setback from the oak's trunk to construct the future building and parking garage, and a minimum setback of 20 feet from the trunk for all ground disturbance beneath the existing asphalt surface. “Roots The 20-foot setback from #10's trunk for ground disturbance applies to any soil compaction, grading, subexcavation, overexcavation, trenching, drilling/auguring, storm drains, swales, etc.” In other words, once you are 20 feet or more from the Tree, you can go at it, tear up the ground and destroy the Tree’s roots anyway and as much as you want. It appears to me that the Applicant didn’t have a thought when they started about Palo Alto’s desire to protect its beautiful Heritage Trees. They just saw some land, put together plans to fill that land with rental opportunities, and moved forward. When they discovered that Palo Alto wanted to protect the Tree, they drew a TPZ to accommodate their plans, rather than drawing their plans to accommodate the Tree. As Chair David Hirsch so succinctly stated at the December, 2022 Architectural Review Board Hearing on this project: “This is too much building in too small of a space.” Thank you for your consideration, Christopher Ream Christopher Ream