From: Clerk, City
To: Council, City
Subject: FW: Public Comment for City Council, Item 6
Date: Monday, November 10, 2025 8:05:42 AM
Attachments: 660 University Ave - City Council 11_10_25.docx image001.png
image002.png
image004.png
Dear City Council,
Please see the attached letter regarding Item #6.
Thank you,
Christine Prior
Assistant City Clerk
Office of the City Clerk
(650) 329-2159 |
[email protected]
www.PaloAlto.gov
From:
Jack Farrell <[email protected]>
Sent: Monday, November 10, 2025 5:24 AM
To: Clerk, City <[email protected]>
Subject: Public Comment for City Council, Item 6
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Good morning, Please find attached correspondence from YIMBY Law regarding item 6 on the agenda for tonight's meeting of City Council. Sincerely, Jack Farrell he/himResearch Attorney 267-218-1147 Check out everything we achieved in 2024!
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Good morning,
Please find attached correspondence from YIMBY Law regarding item 6 on the agenda for tonight's meeting of City Council.
Sincerely,
Jack Farrell he/him
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Research Attorney
267-218-1147
Check out everything we achieved in 2024!
YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]
11/10/2025
City of Palo Alto
City Council
250 Hamilton Ave
Palo Alto, CA 94301
[email protected]
Via Email
Re: 660 University Avenue Proposal, Agenda Item 6
Dear Palo Alto Planning and Transportation Commission,
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.
This proposal consists of a mixed -use development with a ground floor office, 66 residential units and two below -ground parking levels. 13 units will be reserved for moderate income tenants, 1 for low income, and 1 for very low income. The proposal
YIMBY Law
2261 Market Street STE 10416
San Francisco, CA 94114
[email protected]
was submitted under Palo Alto’s Planned Home Zoning community plan in an area zoned for multi-family residential use.
As confirmed by previous committees and recommended by staff, this project complies with the Palo Alto Comprehensive Plan, awning code, coordinated area plans, and design guides. The Revised EIR found no significant and unavoidable environmental impacts. T his project has gone through four years of successive review and modification to reach this stage, where it is consistent with all necessary local conditions.
Given these consistencies, this Commission 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. 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
From: Christopher Ream
To: Christopher Ream; Lauing, Ed; Veenker, Vicki; Burt, Patrick; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Council, City; Kallas, Emily
Cc: Kinsey Haffner; Carol Gilbert; Kay Brown; Peggy Forbes Subject: WITH LETTER ATTACHED - Re: City Council – Agenda 6: 660 University Avenue - Last Letter, Comment on Builder"s Remedy
Date: Sunday, November 9, 2025 10:18:34 PM
Attachments: Ream Letter re SB330 - 20251108.pdf
Importance: High
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Councilmembers,
Sorry I failed to attach my letter. I hope I have done so now.
Chris
From: Christopher Ream <[email protected]>
Date: Sunday, November 9, 2025 at 7:31 PM
To: Mayor Ed Lauing <[email protected]>, Vice Mayor Vicki Veenker <[email protected]>, Councilmember Patrick Burt <[email protected]>, Councilmember George Lu <[email protected]>, Councilmember Julie Lythcott-Haims <[email protected]>, Councilmember Keith Reckdahl <[email protected]>, Councilmember Greer Stone <[email protected]>, City Council <[email protected]>, Kallas, Emily <[email protected]> Cc: Kinsey Haffner <[email protected]>, Carol Gilbert <[email protected]>, Kay Brown <[email protected]>, Peggy Forbes <[email protected]> Subject: City Council – Agenda 6: 660 University Avenue - Last Letter, Comment on Builder's Remedy
Councilmembers,
Please find attached my 2-page comment letter regarding the threat of Builder’s Remedy stepping in to take over the 660 University project. I hope you are able to review this prior to the meeting tomorrow evening.
This is the last of my comment letters for tomorrow evening’s City Council meeting. Thank you for bearing with me.
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] November 8, 2025 Mayor Ed Lauing Vice Mayor Vicki Veenker Councilmember Patrick Burt Councilmember George Lu Councilmember Julie Lythcott-Haims Councilmember Keith Reckdahl Councilmember Greer Stone City Council City of Palo Alto, California [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Re: City Council MeeOng on November 10, 2025 660 University Avenue Project – Agenda Item 6 THIRD LETTER –There is NO Valid Threat of Builder’s Remedy Council Members, When the 660 University project was before the Architectural Review Board (“ARB”) and then the Planning and TransportaOon Commission (“PTC”), there were repeated comments by Members and Commissioners that this was not an a_racOve project, that it was too big on too small a lot, that it was going to cause serious traffic congesOon, and other negaOves; but they felt they had to approve it because Applicant had a Builder’s Remedy project standing by to replace it, and the Builder’s Remedy would be much worse. That threat is NOT valid. As my neighbor Kinsey Haffner has explained to you in his comments, Applicant made incurable mistakes in filing the applicaOon for the Builder’s Remedy resulOng in it no longer being a valid Builder’s Remedy applicaOon. I will go a step further and point out that Applicant’s enOre pre-applicaOon and applicaOon process was not valid because the City of Palo Alto had already adopted a Housing Element before Applicant filed any of its Builder’s Remedy applicaOons. The City of Palo Alto adopted a 6th Cycle (2023-2031) Housing Element on May 8, 2023. On August 3, 2023, the California Department of Housing and Community Development (“HCD”) sent Palo Alto a le_er with a 6-page detailed appendix poinOng out substanOal defects to be corrected. Palo Alto worked hard on it, and on April 15, 2024 a joint meeOng of the PTC and City Council adopted a substanOally revised Housing Element, which was then submi_ed to the Ream – There is NO Valid Threat of Builder’s Remedy November 8, 2025 Page 2 of 2 HCD. On August 20, 2024, the HCD approved that April 15, 2024 Housing Element with some technical modificaOons: “Thank you for submihng the City of Palo Alto’s (City) housing element that was adopted April 15, 2024 . . . .HCD is pleased to find the adopted housing element, including all technical modificaOons, in substanOal compliance with State Housing Element Law (Gov. Code, § 65580 et seq) as of the date of this le_er.” HCD letter to City of Palo Alto, August 20, 2024, page 1. The law provides that an applicant cannot use Builder’s Remedy if the jurisdicOon [City of Palo Alto] had adopted a Housing Element in substanOal compliance with the State Housing Element Law (Gov. Code, § 65580 et seq). “(5) On the date an application for the housing development project or emergency shelter was deemed complete, the jurisdicOon had adopted a revised housing element that was in substanOal compliance with this arOcle [Government Code §§65580 - 65589.11].” Government Code §65589.5(d)(5) HCD’s August 20, 2024 le_er confirms that the Housing Element adopted by the City of Palo Alto on April 15, 2024 is in substanOal compliance. “SubstanOal compliance” means not necessarily 100% compliance but close to it and that leaves room for the technical modificaOons. April 15, 2024 is the date to be dealt with. Applicant cannot argue that its applicaOon for a Builder’s Remedy project on the land pre-dated the Housing Element because Applicant’s earliest filing for Builder’s Remedy was a pre-applicaOon filed on May 8, 2024, together with other filings stretching out to September 3, 2024. They are all aoer Housing Element’s April 15 date and thus do not confer any rights to Builder’s Remedy. The Hamilton community strongly opposes this applicaOon for excessive development on our small block. Please make clear that Builder’s Remedy is not applicable here so that you can consider the regular applicaOon for the 660 University Avenue project without fear of a threat of Builder’s Remedy. Thank you for your consideraOon, Christopher Ream P .S.: Last of my three comment le_ers.
From: Christopher Ream
To: Lauing, Ed; Veenker, Vicki; Councilmember Patrick Burt; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Council, City; Kallas, Emily
Cc: Kinsey Haffner; Carol Gilbert; Kay Brown; Peggy Forbes Subject: City Council – Agenda 6: 660 University Avenue - Last Letter, Comment on Builder"s Remedy Date: Sunday, November 9, 2025 7:31:47 PM
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Councilmembers,
Please find attached my 2-page comment letter regarding the threat of Builder’s Remedy stepping in to take over the 660 University project. I hope you are able to review this prior to the meeting tomorrow evening.
This is the last of my comment letters for tomorrow evening’s City Council meeting. Thank you for bearing with me.
Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]
From: Christopher Ream
To: Lauing, Ed; Veenker, Vicki; Councilmember Patrick Burt; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Council, City; Kallas, Emily
Cc: Kinsey Haffner; Carol Gilbert; Kay Brown; Peggy Forbes Subject: City Council – Agenda 6: 660 University Avenue - Comments Other than the Tree Date: Sunday, November 9, 2025 7:18:43 PM
Attachments: Ream Letter re Other Than Tree - 20251108.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
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Councilmembers,
Please find attached my 6-page comment letter regarding several problems with the 660 University project other than the Tree. I hope you are able to review this prior to the meeting tomorrow evening.
I am working on one more, short comment letter which I hope to be able to get to you later today.
Chris
_________________________
Christopher Ream
555 Byron Street, #409
Palo Alto, CA 94301
1-650-424-0821
[email protected]
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THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: [email protected] November 8, 2025 Mayor Ed Lauing Vice Mayor Vicki Veenker Councilmember Patrick Burt Councilmember George Lu Councilmember Julie Lythcott-Haims Councilmember Keith Reckdahl Councilmember Greer Stone City Council City of Palo Alto, California [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Re: City Council Meeting on November 10, 2025 660 University Avenue Project – Agenda Item 6 SECOND LETTER – Comments on Other than the Tree Councilmembers, 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. At the ARB and the PTC hearings, the assumed threat of a Builder’s Remedy was brought up by some of the members and commissioners at those hearings. Please don’t let that happen at your hearing. As I explain in a subsequent letter to you, and my neighbor Kinsey Haffner has explained in his own letter to you, Builder’s Remedy is not a valid threat and should be ignored by you. I will address the following concerns in this letter: • Byron Street Jammed – Traffic Congestion • Parking Mechanical Lifts Parking for Office Size Adjustment ? No Parking for Fitness Center • Setbacks • Daylight Plane Ream – More Comments re the 660 University Project November 8, 2025 Page 2 of 6 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 we see the parking problem every day. Across the street is the First United Methodist Church which has activities going on most days and evenings of the week, including La Comida lunch service and a pre-school with many small children.
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 66 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. How in the world are they going to build this six-story building? Where will construction equipment be located? There is no room; the building will cover almost the entire lot. When The Hamilton was built in the late 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 November 8, 2025 Page 3 of 6 Parking 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 filed 10/21/2025 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” notwithstanding that I have repeatedly raised this concern. 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. 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.
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
Ream – More Comments re the 660 University Project November 8, 2025 Page 4 of 6 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.
Last Year – 9,115 ft2 Light blue is office space 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 . 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
Ream – More Comments re the 660 University Project November 8, 2025 Page 5 of 6 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 underground 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. 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.
Too Much Time Several times in ARB & PTC hearings, a member or commissioner has said that they have spent too much time on this project, so let’s just vote to move it along. Yes, they have seen this project repeatedly and they have spent a lot of time on it. But the reason is that there are a lot 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 Ream – More Comments re the 660 University Project November 8, 2025 Page 6 of 6 of problems with it as has also been expressed by members and commissioners at those hearings. 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 PS: This is the second comment letter I have sent you today; the earlier one dealt with the Magnificent Coast Live Oak Tree. I am preparing a third comment letter about the faux threat of Builder’s Remedy raised at the ARB and PTC hearings and will send that to you shortly.
From: Kay Brown
To: Council, City
Subject: 660 University Project /Agenda date: Nov. 10
Date: Sunday, November 9, 2025 5:13:30 PM
Attachments: March 4th letter to Palo Altowstudy request.docx Letter to Emily kallas (follow-up).docx
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Dear City Council Members,
I sent the 2 attached letters below to Emily
1). March 4 letter sent to ARB
2). August 16 letter sent to PTC
Local
traffic safety issues described in these letters were ultimately ignored.
The 2 commissions OK’d the 660 project without alternatives or mitigations being explored.
The project was passed onto you (The City Council) for final approval.
I’m asking that you take the time to read my 3 letters (the 3rd letter came to you on March 6).
Thank you for your time and attention to these concerns.
Kay Brown
650-269-1985
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Kay Brown
555 Byron St Apt 101
Palo Alto, CA 94301
[email protected]
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 par- ents, church goers and dental office patients encounter frequent near-misses en- tering 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. Con- cern 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 accu- rate 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
650-269-1985
Kay Brown
555 Byron St Apt 101
Palo Alto, CA 94301
[email protected]
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
650-269-1985
From: Christopher Ream
To: Lauing, Ed; Veenker, Vicki; Councilmember Patrick Burt; Lu, George; Councilmember Julie Lythcott-Haims; Reckdahl, Keith; Stone, Greer; Council, City; Kallas, Emily Cc: Kinsey Haffner; Carol Gilbert; Kay Brown; Peggy Forbes Subject: City Council – Agenda 6: 660 University Avenue - Save the Tree Date: Sunday, November 9, 2025 4:29:48 PM
Attachments: Ream Letter re Tree - 20251108.pdf
Councilmembers,
Please find attached my 5-page comment letter focused on the need to protect the magnificent coastal live oak tree that is in grave danger if the 660 University project goes forward as presently planned. I hope you are able to review this prior to the meeting tomorrow evening.
I am working on two more comment letters which I hope to be able to get to you later today.
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] November 8, 2025 Mayor Ed Lauing Vice Mayor Vicki Veenker Councilmember Patrick Burt Councilmember George Lu Councilmember Julie Lythcott-Haims Councilmember Keith Reckdahl Councilmember Greer Stone City Council City of Palo Alto, California [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Re: City Council Meeting on November 10, 2025 660 University Avenue Project – Agenda Item 6 Protect the Magnificent Coast Live Oak Councilmembers, The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. 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 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 would 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 is close to 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 two 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 660 University Project Protect the Magnificent Coast Live Oak November 8, 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 is close to 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 faux 30-foot TPZ to bring the exterior wall of the proposed building up to 30 feet from the trunk of the Tree. 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 “Levison Analysis,” p.3. So, we have a basic agreement that the proposed project will cause an estimated 25% of the canopy to be lost. 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.8 660 University Project Protect the Magnificent Coast Live Oak November 8, 2025 Page 3 of 5 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 northern 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 24% of what it is now, a loss of 76% of those roots. ((0.5 x ∏ x 25 x 25) / (0.5 x ∏ x 51 x 51) = 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. 1 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. In addition to that slow death for the Tree, there is the substantial probability of a sudden failure – the Tree toppling over in a windstorm, if not sooner during construction. 1 If we use the shorter normal of 90 feet, the reduction in roots would be a loss of 92% of the roots. ((0.5 x ∏ x 25 x 25) / (0.5 x ∏ x 90 x 90) = 8%) 660 University Project Protect the Magnificent Coast Live Oak November 8, 2025 Page 4 of 5 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 cut off. That is 25% of the whole canopy, but all of the removal will be from the northern half of the canopy, none from the southern half.2 Simple math tells you that 25% of the whole will be 50% of the northern half. With the southern half of the canopy now twice as large as the northern, 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. 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 they go forward, how soon will the Tree topple over and crash into The Hamilton and others? It would destroy the Cardinal Dental office on the property next to it and badly injure and maybe kill anyone in those offices at the time. The top of this 60-foot Tree will also reach and hit The Hamilton. Pray that none of our senior residents get hit. 2 The Tree is outside the southern property line of the project’s property. Only the canopy on the northern side of the Tree stretches over the project property (what I have been referring to as the “northern half”) and that is where Applicant intents to cut back the canopy. Applicant has no reason to cut canopy in the southern half, and indeed it would not be allowed to since that is land owned by a different person. 660 University Project Protect the Magnificent Coast Live Oak November 8, 2025 Page 5 of 5 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 PS: I am preparing two more comment letters on this 660 University Avenue project which I expect to be able to send to you over the weekend. One about other problems and concerns we have about the proposed large building, and the other about the faux threat of Builder’s Remedy raised at the ARB and PTC hearings.
660 University Project Ream – Protect the Magnificent Coast Live Oak November 8, 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]
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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]
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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]
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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).
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.
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]
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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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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
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)
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 32 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
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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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
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
Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture
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]
8 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
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]
9 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
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]
10 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
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]
11 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
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]
12 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
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]
13 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
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]
14 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
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]
15 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
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]
16 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
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]
17 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
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]
18 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
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.
Care has been taken to obtain all information from reliable sources. All data has been verified insofar as possible; however, the consultant/appraiser can neither guarantee nor be responsible for the accuracy of information provided by others.
The consultant/appraiser shall not be required to give testimony or to attend court by reason of this report unless subsequent contractual arrangements are made, including payment of an additional fee for such services as described in the fee schedule and contract of engagement.
Unless required by law otherwise, the possession of this report or a copy thereof does not imply right of publication or use for any other purpose by any other than the person to whom it is addressed, without the prior expressed written or verbal consent of the consultant/appraiser.
Unless required by law otherwise, neither all nor any part of the contents of this report, nor copy thereof, shall be conveyed by anyone, including the client, to the public through advertising, public relations, news, sales, or other media, without the prior expressed conclusions, identity of the consultant/appraiser, or any reference to any professional society or institute or to any initiated designation conferred upon the consultant/appraiser as stated in his qualifications.
This report and any values expressed herein represent the opinion of the consultant/appraiser, and the consultant’s/appraiser’s fee is in no way contingent upon the reporting of a specified value, a stipulated result, the occurrence of a subsequent event, nor upon any finding to be reported.
Sketches, drawings, and photographs in this report, being intended for visual aids, are not necessarily to scale and should not be construed as engineering or architectural reports or surveys unless expressed otherwise. The reproduction of any information generated by engineers, architects, or other consultants on any sketches, drawings, or photographs is for the express purpose of coordination and ease of reference only. Inclusion of said information on any
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
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:
• information contained in this report covers only those items that were examined and reflects the conditions of those items at the time of inspection; and
• the inspection is limited to ground-based visual examination of accessible items without climbing, dissection, excavation, probing, or coring.
• There is no warranty or guarantee, expressed or implied, that problems or deficiencies of the plants or property in question may not arise in the future.
Loss or alteration of any part of this report invalidates the entire report.
Arborist Disclosure Statement:
Arborists are tree specialists who use their education, knowledge, training, and experience to examine trees, recommend measures to enhance the beauty and health of trees, and attempt to reduce the risk of living near trees.
Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice.
Arborists cannot detect every condition that could possibly lead to the structural failure of a tree. Tree are living organisms that fail in ways we do not fully understand. Conditions are often hidden within trees and below ground.
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.
Treatment, pruning, and removal of trees may involve considerations beyond the scope of the arborist’s services such as property boundaries, property ownership, site lines, disputes between neighbors, and other issues. Arborists cannot take such considerations into account unless complete and accurate information is disclosed to the arborist. An arborist should then be expected to reasonably rely upon the completeness and accuracy of the information provided.
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)
660 University Project Ream – Protect the Magnificent Coast Live Oak November 8, 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.
From: [email protected]
To: Council, City
Subject: 660 University Project/Agenda 11/10/25
Date: Sunday, November 9, 2025 4:07:23 PM
Attachments: Justine revise copy 4word.docx
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Please include attached letter for 660 University Project on 11/10/25 agenda Thank you,
Justine Forbes MD (retired)
Justine Forbes, MD (Retired)
555 Byron Street. #202
Palo Alto, CA, 94301
Resident 11/07/2025 The Hamilton
Speaking on behalf of pedestrians
I would like to make some comments on the 660 University Ave 6 story Builders Remedy Project.
Smith Developers rejected their 4 story building plans because of a requirement to maintain a 40 ft protection of an oak tree and a 10 foot Setback on Middlefield to accommodate a future bicycle lane.
The Smith Developers, instead, applied for State Senate Bill 330 for Builders Remedy.
The Smiths Builders Remedy will include several below city standards plans, including a 2-level below city standard parking garage and also below standard property set-backs especially on Byron St. Byron St becomes the garbage storage along with the noisy compacting and removal, the center of traffic for bike and possibly motorcycle storage and exit from parking garage.
Byron St has complicated traffic and parking problems for everyone at most times. These traffic and parking space availability problems include traffic from elder pedestrians. There are very few spaces to park in the entire area which leads to recirculation hoping there will be a parking space.
These traffic and parking space availability problems include traffic from pedestrians. This area could be designated Elder Care Hub at the end of the commercial part of the City of Palo Alto. All of this includes the Webster House and Lytton Gardens, very large elder care and rehab facilities (situated across University from 660). Pedestrians in this Elder Care environment also include their wheelchairs and walkers, and unsteady gait and slow reaction times, confusion when requiring multiple responses at the same time.
We all have a lot to manage. Cooperation for a safe environment is an enormous and essential necessity. Getting old is tough. One may have their functioning mind but the body is a different struggle to navigate, especially to be able to walk safely even with mobility devices.
We are grateful for the safe environment we have had here. We are also grateful for any opportunities to be heard.
Bottom LINE of importance for elder pedestrians is safety and environmental support.
Respectfully submitted, Justine Forbes, MD (retired)
From: Xenia Hammer
To: Council, City
Cc: [email protected]
Subject: 660 University Project
Date: Sunday, November 9, 2025 1:42:50 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear Palo Alto City Council,
I am very supportive of adding housing, and the location at 660 University is a good one for housing. However, there are significant problems with the project proposal before you, and I urge you to correct these problems before approving the project.
The project location at University and Middlefield is a crucial intersection and a gateway location at the entrance to downtown.
These problems with the current proposal include:
1. Lack of passenger loading space
2. Disregard for required setbacks on 3 sides of the building
3. Impact on traffic on surrounding streets and traffic safety
1. Need a loading space in front of main residential entrance on University Ave:
Section 18.52.040, chapter (d) of the Palo Alto Municipal Code clearly states:
“Residential and mixed use structures with fifty (50) or more dwelling units shall provide at least one (1) on-site, short-term loading space for passenger vehicles, to be used by taxicabs and similar transportation and delivery services.”
This requirement makes sense anywhere. In this location, on University Avenue immediately before Middlefield, this requirement is crucial. This is a This message needs your attention
This is a personal email address.
This is their first mail to some recipients.
Mark Safe Report
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gateway for traffic in and out of downtown and for through traffic connecting 101 and Stanford. Imagine food delivery and rideshares pick-ups stopping on that block and tying up University Ave traffic.
There is a bus stop on University before Middlefield in front of the proposed building. Without a loading space, any rideshare drop off or any food delivery will block the buses!
Also, the parking provided for this project is already reduced, so residents will be using more rideshares, making the loading space even more important.
All other buildings in that area have circular driveways with loading space.
The requirement for the loading space has been brought up by you in prior meetings, and yet, the current plans do not accommodate this reasonable and necessary requirement. Please insist on a loading space in front of the main entrance on University Avenue
2. Setbacks – this project as proposed encroaches on required setbacks:
University Ave: 7 feet vs required 16 feet
Byron Street: 12 feet vs required 16 feet
Side Yard garage ramp: 2 feet vs required 10 feet
Middlefield: above grade setback requirement is met
This is a gateway location to downtown, and setbacks are important for maintaining a welcoming feel with sidewalks that feel open and safe for everyone - including older people who live in nearby senior housing and families with strollers.
In addition, setbacks are important for traffic safety to ensure visibility for cars making turns to and from University Ave. Setbacks are also necessary for any future traffic improvements on University Ave! Please insist on required setbacks!
3. Traffic and Pedestrian Safety at street crossings:
Passenger loading space on University is crucial for smooth traffic flow in and out of downtown. In addition, it is important to provide for safe pedestrian crossing of University Ave at Byron – for example, there is a steady flow of senior citizens going to lunch from Lytton Gardens to First Methodist Church.
Byron is a narrow street; and the traffic on Byron needs to be addressed.
These concerns have been brought up at every stage and meeting on this project.
Please note that the Architectural Review Board and the Planning & Transportation Commission noted these issues as serious problems with the project, but they voted to advance this project because of the threat of a larger Builders Remedy project.
However, questions have been raised as to whether the Builders Remedy application is valid (see correspondence in the packet).
In summary, I urge you to work with the developer to provide required setbacks and a passenger loading space on University before approving this project.
Thank you very much,
Xenia Hammer
Palo Alto resident
From: Patty Irish
To: Council, City
Subject: Action Item 6 Public Hearing 660 University
Date: Friday, November 7, 2025 1:58:02 PM
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Dear Mayor Lauing and Council Members,
I write in support of the proposal for the new 6 story Mixed Use Building with 70 Multi-Family Residential Units at 660 University.
The Smith Family has worked for four years to get this approved.
They are a LOCAL family investing in their community. Something I think we want to value greatly.
The location is excellent for persons to live productively. They are in walking distance to schools, transportation, work sites, and many services.
I live in the general area myself and can do many things without a car.
Please realize that in many cases you will get pushback for any changes made to our neighborhoods. This limits our vision of what is possible and also what is needed by others.
Please think of the people who will benefit from living here - who may work here and drive long distances now.
Also you are probably aware that the schools need additional children to be at their best. This housing will give some children a chance to go to our excellent schools nearby.
Thank you for all your attention to housing at this time. It is an urgent need. And one you can help remedy.
Patty Irish
850 Webster St. #628
Palo Alto, CA 94301
--
Patty Irish
850 Webster St. #628
Palo Alto, CA 94301
650-324-7407
650-245-3906
cell
How do you tell a story that has been told the wrong way for so long? Virus-free.www.avast.com
From: Kinsey haffner
To: Kallas, Emily; Council, City
Cc: Yang, Albert
Subject: Development project for 660 University (660 University) Date: Friday, November 7, 2025 11:58:32 AM
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660 University is on the Council agenda for its meeting on 12/10. Please include and consider these comments in connection with that agenda item.
1. Builder's Remedy: The developer of 660 University filed a parallel application to develop a project for 680 University (680 University). The 660 University and 680 University are development alternatives for the same three combined parcels. 680 University was filed, and to date has been treated as, a Builder's Remedy (BR) project.
Analysis: There are two pivotal dates in this analysis. The first is the date a complete BR Preapplication is filed with the City (the project application’s “deemed complete date’” for BR purposes). The second is the date the State certified the City’s Housing Element (HE) was certified by the State. (HE Certification Date). To have BR status, 680mUnivrrsity must have a “deemed complete date” that is prior to the HE Certification Date (8/3/2024), which no longer is the case. The preapplication filed by the developer for 680 University met all the necessary BR criteria, so its filing date (5/14/2024) initially was the “deemed complete date” for the project. However, the formal application for 680 University filed by the developer on 9/3/2024 had technical defects (see other 660 University public comments by me) that made the BR Preapplication “deemed incomplete” (words from the relevant statute).
As a direct effect and consequence, and automatically and by operation of law, 680 University lost and ceased to have a “deemed complete date.” Those defects probably can be remedied, but the result would be a new “deemed complete date” (i.e., the date the correction occurs).
Since this correction has not yet happened, there is no complete BR Preapplication on file.
Also, any new “deemed complete date” would be after, not before certification of the HE.
However, 680 University continues to be treated by the City as if it is a BR application even though it does not qualify as such.
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Tellingly, I am informed that the developer has not submitted any rebuttal to the above analysis. This implicitly acknowledges its correctness.
Importance: We repeatedly heard at the past ARB and PTC hearings regarding 660 University that the Commissioner’s felt compelled to approve the project because, although they had very serious reservations and concerns, the BR alternative (680 University) would be worse.
Thus the prior determinations of the ARB and PTC are biased and do not reflect their true and fulsome evaluation of 660 University. Also, the faux existence of a BR possibility in the form of 680mUnivrrsity effectively prevented consideration of the very challenging questions and concerns expressed below.
Actions Required:
The 660 University project must be either disapproved by the Council or referred/sent back to both the ARB and the PTC for additional review and action. If the Council declines to act otherwise, then additional specific actions are required, as noted below.
2. Traffic Impacts: While I recognize the City’s mandate to address the housing crisis and acknowledge that the Final EIR may technically satisfy VMT requirements, I must formally object to the project based on three critical, unmitigated operational and legal deficiencies.
1. The Operational Failure of TDM and the Need for a Performance Guarantee
The City’s reliance on the TDM plan to achieve a 40% vehicle trip reduction is conceptually flawed. A legal mandate for success is not the same as guaranteed success. If the TDM measures—which include easily ignored or unused incentives like transit passes and bike parking —fail to achieve the target, the project, as currently proposed, will significantly worsen the existing traffic problems on Byron and surrounding major arterials by introducing the trip generation of 70 units and ground-floor office space. This has a further ripple effect out into the neighborhoods.
The proposed Conditions of Approval (COAs) for remedial TDM measures are a weak enforcement lever that triggers after the safety hazard has already manifested.
Recommendations for Strengthening: The City must demand strong TDM remediation efforts and a robust TDM Performance Bond from the developer. This bond should be equivalent to a substantial mitigation fee, held in escrow, and only released after the City confirms the 40% reduction target has been met for a minimum of three years of full occupancy. If the target is missed, the funds must be used by the City for punitive, enforceable mitigation measures (e.g., dedicated staff for traffic control or aggressive parking buyouts).
2. Unmitigated Public Safety Hazard on Byron Street
The decision to place the primary vehicular access and egress for 70 high-density units and an office component onto the single 500 block of Byron Street, which dead-ends on University and Hamilton, creates an operational conflict that is an unmitigable public safety hazard, regardless of TDM success.
Byron Street is narrow and serves as a high-vulnerability over-55 community (555 Byron). The inevitable queuing from the garage entrance onto Byron Street inevitably will create "nose-to- nose" and "plugged bottle" traffic congestion and traffic conflict on Byron and potentially on University and Hamilton, severely compromising both regular traffic in and out of, and emergency access to, both 555 Byron and 660 University. The problem here is that small incremental traffic additions to any already saturated situation can trigger significant problems.
This operational flaw cannot be resolved with signage or a stacking lane; it is a fundamental design conflict. The Council must find that this specific, localized unmitigated safety hazard is unacceptable.
On-demand stop lights at both ends of the 500 block of Byron would ease the ability of the new Byron traffic to merge into University and Hamilton, but the City must also evaluate (which it has not done) the broader impact of that possible solution.
The lack of adequate delivery vehicle and traffic loading/unloading zones in proximity to the building entrance substantially increases the chance of double-parked vehicles on University, which is equally bad.
3. The Requirement for Explicit Findings on Cumulative Housing Element Impacts
The Council is legally obligated under the Housing Accountability Act (HAA) to make explicit, deliberate findings justifying its approval. This cannot be an implicit finding.
We urge the Council to explicitly consider the systemic, cumulative risk the project poses to the entire Housing Element. If this project, due to its operational failure on Byron Street and related major and minor arterials, is allowed to possibly create severe, unmitigated gridlock, it will set a disastrous precedent. If and to the extent it will be legally and practically impossible to approve the surrounding MFA and Planned Unit sites that the City is mandated to develop, the "realistic achievability" of the entire Housing Element site inventory is in jeopardy.
For these reasons—the lack of guaranteed TDM performance, the unmitigable safety hazard on Byron Street, and the potential negative ripple effect on the Housing Element—I urge the Council to reject the project as currently conditioned and demand the PTC evaluate the traffic effects of 660 University in the broader context of the HE as a whole in addition to requiring significant design revisions or robust, financially-backed TDM performance enhancements and guarantees.
3. HE Impacts: The current design for 660 University fails to align with the core purpose and legal mandates of the City’s certified HE and the underlying state law requiring housing for diverse household types. This concern is distinct from the previously raised issues regarding traffic, VMT, and public safety.
1. Failure to Accommodate Diverse Household Needs
The California Housing Element law mandates that jurisdictions plan to accommodate "a variety of household sizes and types." The proposed unit mix at 660 University—comprising primarily of ~400 square foot studios, a small number of ~600 square foot 1-bedroom units, and minimal number of ~900 square foot 2-bedroom units—demonstrates a strategic effort to maximize density and revenue per square foot, at the expense of family and long-term residential needs.
Micro-Unit Functionality: A 400 square-foot studio, equivalent in size to a mid-range hotel room, is functionally constrained. Such units offer minimal storage, compacted kitchenettes (often with small refrigerators and limited cooking capacity), and lack the storage and living space necessary for a multi-year resident with standard possessions. This design effectively filters out couples, families, and individuals seeking long-term stability.
Constrained Family Housing: The proposed 1-bedroom and 2-bedroom units are only very marginally better in this regard and are also inadequate for comfortable family living.
The 1-bedroom is not significantly better than the studio, and the 2-bedroom square footage is more aligned with a generous 1-bedroom unit in the Bay Area. The designed bedrooms within this footprint leaves insufficient common living area for families with two or more children or even two unrelated long-term roommates.
The resulting building is architecturally structured to create a form of slightly more lengthy form of transient housing intended to serve almost exclusively single, highly mobile, high-income individuals—a specific niche that does not address the required "variety" of household types central to the HE mandate.
2. High Cost-Per-Square-Foot and Subversion of Purpose
Market analysis of comparable nearby developments (such as The Mia on nearby Everett Ave.) shows that this model of hyper-dense, small units commands an exceptionally high rent per square foot, often in the $8.00 to $10.00 range, significantly exceeding the general Palo Alto market average of $4.00 to $7.00 per square foot for significantly larger units.
This financial optimization suggests the project is designed for use as de-facto temporary but extended-stay lodging for Stanford students, corporate transferees, weekday "sleep only units" for workers whose permanent residences are far from Palo Alto, or temporary workers, in all instances other than, and rather than, permanent residential housing. When new housing development is overwhelmingly optimized for this transient, high-premium market, it raises serious policy questions:
1. Is this truly "housing" as envisioned by the HE, or is it a commercial lodging product designed to maximize revenue from corporate clients?
2. Does the creation of a building optimized for rapid resident turnover contribute to the stability and long-term community goals of the City?
A pattern of approving projects that function as transient corporate housing, renting at an extraordinary premium, risks subverting the underlying purpose of the Housing Element, which is to identify sites that meet the general, long-term residential needs of the entire community.
3. Risk to Housing Element Compliance (Realistic Achievability) While a single market-rate project may not violate the technical unit count of the HE, approving a project template that results in inadequate unit diversity and high turnover creates systemic risk.
The State's HCD reviews Housing Elements for “realistic achievability.” If the majority of the City’s new market-rate housing is characterized by these functionally constrained, premium-priced micro-units, HCD could credibly find that the City is failing to meet the diverse needs of its workforce, particularly families. This pattern could be cited as evidence that the HE is not realistically achieving the goal of accommodating all economic segments and household sizes, thereby making the entire HE vulnerable to a finding of non-compliance. Note, in this regard, the HE-related discussion with respect to traffic issues above. in this regard, note that the HE (Schedule D) does not allow more than 65 Toal Units for 660 University. In that regard, note that "maximum allowable amount" of units is not the same as "optimal amount" of units when 660 University is considered in its broader HE context.
Conclusion and Call to Action
I urge the City Council to utilize its discretionary authority to require addition ARB and PTC reviews of, and significant modifications, to 660 University. To align this project with the spirit and requirements of the Housing Element, the Council should demand a unit mix that includes:
1. A minimum required square footage for studio and 1-bedroom units to ensure basic livability for long-term residents.
2. An increase in the number and a substantial increase in the size of 1- and 2-, and possibly an addition of 3-, bedroom units to demonstrate a genuine commitment to accommodating family and non-single-person households.
Approving the current design without these changes risks setting a problematic precedent that prioritizes maximum developer profit over the genuine, diverse, and stable housing needs of the Palo Alto community.
Kinsey Haffner
traffic problems by introducing the trip generation of 70 units and ground-floor office space.
The proposed Conditions of Approval (COAs) for remedial TDM measures are a weak enforcement lever that triggers after the safety hazard has already manifested.
Recommendation for Strengthening: The City must demand a robust TDM Performance Bond from the developer. This bond should be equivalent to a substantial mitigation fee, held in escrow, and only released after the City confirms the 40% reduction target has been met for a minimum of three years of full occupancy. If the target is missed, the funds must be used by the City for punitive, enforceable mitigation measures (e.g., dedicated staff for traffic control or aggressive parking buyouts).
2. Unmitigated Public Safety Hazard on Byron Street
The decision to place the primary vehicular access and egress for 70 high-density units and an office component onto Byron Street creates an operational conflict that is an unmitigable public safety hazard, regardless of TDM success.
Byron Street is narrow and serves a high-density, high-vulnerability over-55 community (555 Byron). The inevitable queuing from the garage entrance onto Byron Street will create "nose-to-nose" traffic congestion and conflict, severely compromising emergency access to both 555 and 660 University. This operational flaw cannot be resolved with signage or a stacking lane; it is a fundamental design conflict. The Council must find that this specific, localized unmitigated safety hazard is unacceptable.
3. The Requirement for Explicit Findings on Cumulative Housing Element Impacts The Council is legally obligated under the Housing Accountability Act (HAA) to make explicit, deliberate findings justifying its approval. This cannot be an implicit finding.
We urge the Council to explicitly consider the systemic, cumulative risk the project poses to the entire Housing Element. If this project, due to its operational failure on Byron Street, is allowed to create severe, unmitigated gridlock, it will set a disastrous precedent. It will be legally and practically impossible to approve the surrounding MFA and Planned Unit sites that the City is mandated to develop, thereby jeopardizing the "realistic achievability" of the entire Housing Element site inventory.
For these reasons—the lack of guaranteed TDM performance, the unmitigable safety hazard on Byron Street, and the potential negative ripple effect on the Housing Element —I urge the Council to reject the project as currently conditioned and demand significant design revisions or robust, financially-backed TDM performance guarantees.
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From: [email protected]
To: Council, City
Cc: Yang, Albert; [email protected]; Boyd Smith; Lund Smith; Alysa Tibbitts Subject: Applicant"s Public Comment - 21PLN-00341 (November 10th Council hearing) Date: Friday, November 7, 2025 11:34:51 AM
Attachments: 660 Univ - Letter addressing Builder"s Remedy status 11-7-2025 FINAL.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Good morning Mayor Lauing and Councilmembers,
On behalf of our client the Smith Development Group, attached please find the applicant’s public comment ahead of your November 10
th hearing to consider approval of their PHZ Project at 511 Byron Street, 660 University Avenue, and 680 University Avenue (#21PLN-00341).
Thank you,
Genna Yarkin | Holland & Knight PRIDE
She/Her/Hers
Partner
Holland & Knight LLP
560 Mission Street, Suite 1900 | San Francisco, California 94105 Phone 415.743.6990 | Fax 415.743.6910
[email protected]
| www.hklaw.com
________________________________________________
Add to address book | View professional biography
NOTE: This e-mail is from a law firm, Holland & Knight LLP ("Holland & Knight"), and is intended solely for the use of the individual(s) to whom it is addressed. If you believe you received this e-mail in error, please notify the sender immediately, delete the e-mail from your computer and do not copy or disclose it to anyone else. If you are not an existing client of Holland & Knight, do not construe anything in this e-mail to make you a client unless it contains a specific statement to that effect and do not disclose anything to Holland & Knight in reply that you expect it to hold in confidence. If you properly received this e-mail as a client, co-counsel or retained expert of Holland & Knight, you should maintain its contents in confidence in order to preserve the attorney-client or work product privilege that may be available to protect confidentiality.
560 Mission Street, Suite 1900 | San Francisco, CA 94105 | T 415.743.6900 | F 415.743.6910 Holland & Knight LLP | www.hklaw.com
Genna Yarkin
+1 415-743-6990
[email protected]
Chelsea Maclean
+1 415-743-6979
[email protected]
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November 7, 2025
Via E-mail ([email protected])
City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 9430
Re: 511 Byron St, 660 University Avenue, 680 University Project - Builder’s Remedy Application Status (Application #21PLN-00341)
Dear Mayor Lauing and Councilmembers:
Holland & Knight LLP represents Smith Development Group (the "Applicant") in connection with its proposed residential development at 511 Byron St, 660 University Avenue, 680 University/500 Middlefield Rd in Palo Alto. The purpose of this letter is to clarify the status of the Applicant's Builder's Remedy application (which was also applied for under the protections of the Housing Crisis Act of 2019 or “SB 330”) , and which has been the subject of recent public comment suggesting it may have expired.
We note that it remains the Applicant’s strong preference to proceed with the 66-unit Planned Home Zoning (PHZ) version of the development (the “PHZ Project”) , which is before you for consideration of approval on November 10, 2025. By contrast, the current Builder’s Remedy application contains 88 units, and could be increased to up to 131 units. Over the course of several years, the Applicant team has worked closely with City staff and incorporated significant feedback from various City decisionmakers to ensure that the PHZ Project is a vibrant and successful addition to the community. While the Applicant does not currently intend to return to the Builder’s Remedy application given the strong momentum behind the PHZ Project, we reiterate here that it remains viable and can be reactivated if necessary.
Background and Timeline
The Applicant is currently pursuing approval of a 66-unit residential project through the City's PHZ process, which includes 20% affordable housing. The Applicant also submitted an alternative Builder's Remedy application, which is currently tolled while the PHZ application proceeds City Council
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through the approval process. The relevant timeline of the Builder’s Remedy application is as follows:
• May 14, 2024: The Applicant submitted an SB 330 preliminary application proposing 110 dwelling units pursuant to the Builder’s Remedy provision of the Housing Accountability Act (the “Builder’s Remedy Project”).
• June 11, 2024:
o The Applicant submitted a new/revised SB 330 preliminary application for the Builder’s Remedy Project, also proposing 110 dwelling units. o This submission established a new vesting date and created an obligation to submit a formal application within 180 days, or by December 8, 2024. (Gov. Code § 65941.1(e))
• August 20, 2024 : The California Department of Housing and Community Development (“HCD”) certified the City’s Housing Element, cutting off the ability for any new Builder’s Remedy projects to be proposed, but allowing any Builder’s Remedy projects that had previously submitted SB 330 preliminary applications, to proceed so long as they subsequently meet deadlines and maintain vesting.
• September 4, 2024: The Applicant submitted a formal application for development of the Builder's Remedy Project, proposing 88 dwelling units (an exactly 20% change from the previous 110 units).
• October 2, 2024: The City responded to the Builder's Remedy Project application without raising any concerns about the unit count change.
• December 2, 2024: The Applicant and the City executed a Tolling Agreement, pausing all deadlines related to the Builder's Remedy Project application while the PHZ Project application proceeds.
• December 8, 2024: As noted above, prior to the tolling of all processing deadlines for the Builder’s Remedy Project’s application, this would have been the deadline to submit a formal application for development, and still maintain the Builder’s Remedy Project’s SB 330 vesting and its ability to proceed under the non-compliant Housing Element status that existed as of its SB 330 preliminary application date.
The Builder's Remedy Application Remains Viable
At the Planning and Transportation Commission (“PTC”) hearing for consideration of the PHZ Project on October 8, 2025 , a member of the public argued that the Builder's Remedy Project application had expired because the formal application reduced the unit count by exactly 20% (from 110 to 88 units). Under Government Code Section 65941.1(d), if a development proponent City Council
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"revises the project such that the number of residential units... changes by 20 percent or more," the preliminary application's vesting protections may be lost.
However, as the City Attorney correctly noted during the PTC hearing and as the Staff Report for this hearing reiterates, this issue is readily curable . The Applicant retains the ability to submit a revised formal application for the Builder’s Remedy Project that adds one or more dwelling units, bringing it within the permissible change threshold. Specifically:
• The Applicant had a right to submit a new formal application for the Builder’s Remedy Project within the original 180-day deadline.
• When the Tolling Agreement was executed on December 2, 2024, the Applicant had 6 days remaining until the December 8, 2024 deadline.
• If the Applicant chooses to terminate the Tolling Agreement and reactivate the Builder's Remedy application, it can immediately submit a revised formal application adding one or more units (and even up to 131 units, which would be a 19% increase from the original 110 units).
In conclusion, the Builder's Remedy Project application remains a viable alternative should the PHZ Project application face any obstacles that are significant enough that the Applicant chooses to return to the Builder’s Remedy Project application . The unit count concern would be easily remedied, and it does not invalidate the Applicant's vesting rights under SB 330.
Mr. Haffner’s Written Public Comment dated October 30
Included in your hearing packet is public comment that Mr. Haffner provided via email on October 30, to which we provide the following responses.
We first wish to address the idea that the existence of the Builder’s Remedy application unduly influenced the PTC. It is important to note that the Applicant has been open to a significant amount of feedback from City staff, the public, and PTC members in multiple rounds of review. The version of the PHZ proposal that is coming before you has had the benefit of many changes to address that feedback, a nd the Applicant feels strongly that this process has been extensive, appropriate, and fair to all.
Second with regard to Mr. Haffner’s mentions of the Department of Housing and Community Development (“HCD”)’s certification of the City’s Housing Element, it is abundantly clear that regardless of the date of certification, the Builder’s Remedy Project gained vesting on the date of its SB 330 preliminary application. The date of the Builder’s Remedy Project’s formal application for development, is irrelevant for the purposes of establishing initial vesting (other than that it needed to occur within 180 days of the preliminary application to maintain such vesting). First, 2024’s AB 1886 established that a housing element is only "substantially compliant" for purposes City Council
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of the Builder's Remedy when either HCD or a court makes that determination.1 AB 1886 further clarified that a housing element’s “substantial compliance” status is pegged to the date that a Builder’s Remedy project submits an SB 330 preliminary application, regardless of whether a jurisdiction later achieves certification from HCD , whether that certification is before or after a formal application is submitted.2
Mr. Haffner also makes much of the Tolling Agreement’s mistaken reference to a certain number of units contained in the Builder’s Remedy Project. However, it is abundantly clear from the agreement that the proposal is meant to toll deadlines related to processing of the Builder’s Remedy Project. A mere typographical error in description of the application, does not nullify the agreement between two parties who intended to bind each other to certain commitments and mutually understand themselves to be so bound.
Finally, Mr. Haffner insists without adequate support that because the Applicant already submitted one formal application for development of the Builder’s Remedy Project, it may not substitute that application with a revised application. However, it is common practice for applicants to revise or replace proposals with new ones in the course of processing. Further, SB 330 simply does not indicate that a new or revised formal application may not been submitted within the 180 days following the submission of a preliminary application.
Conclusion
The Applicant remains committed to working with the City through the PHZ process to deliver housing, including affordable units, to Palo Alto. We believe this process offers benefits to both the City and the community, and we look forward to your consideration of the PHZ application when it comes before you on November 10.
Thank you for your time and consideration.
Sincerely,
HOLLAND & KNIGHT LLP
Genna Yarkin
Chelsea Maclean
1 Gov. Code § 65585.03 (as amended by AB 1886).
2 Gov. Code § 65589.55(a) (as amended by AB 1886).
From: Faith Brigel
To: Council, City
Cc: Kallas, Emily; Faith Brigel
Subject: 660 University Ave. Builders" Remedy, Separate delivery entrance, Four stories.
Date: Thursday, November 6, 2025 4:54:06 PM
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Hello Councilors of City Council,
At the last Planning and Transportation Meeting an attorney from Stanford spoke publicly and brought to our attention a very interesting point. He explained that the Builders' Remedy is not as applicable to the 660 University construction as was originally thought, and he gave several reasons. The City attorney present did not seem to have that information. I am hoping that he has contacted you, or you have heard about this. Several of the commissioners stated that though there were several codes that were not being adhered to, the building is very large, and a lot of traffic will be generated in that already busy location - due to the Builders' Remedy they felt obliged to vote it in.
However, if this is accurate and the Builders' Remedy cannot be enforced it seems that that would change how the commissioners ( and possibly yourselves) view this building.
Another concern, is that now that they are putting the front area on Byron Street, but I believe that there are only two parking spots for any and all of the delivery vans, trucks, cabs, and other cars coming and going, etc. for this massive mixed use building; would it be possible to require that they place a separate entrance for delivery vans and trucks on Middlefield or University to thin out a little of the traffic off of Byron Street? This narrow street does not have the capacity to deal with ALL of the traffic, and deliveries that will be coming and going on a daily basis just for this one building not even considering all of the traffic for the church, the Hamilton building, the other buildings on Byron, plus the large complexes across the street of Lytton Gardens and the Webster House. It is very possible that there will be cars backed up on University and on Hamilton and this will be a traffic nightmare.
My final concern, is the acceptance of this construction being six stories. There are no other buildings on Byron being that high. The Hamilton project is four stories high. And at four stories it looks very tall.This is an overly tall, compacted, dense building in an area that cannot contain it. I understand that the owner wants to increase his financial rewards, but he is not the only person to consider. I would like you to also consider the neighborhood.
Pls revisit the acceptance of four stories for this building, and most important pls find out if it is accurate that the Builders’ Remedy is not applicable.
Much appreciated,
Faith W. Brigel
518 Byron Street
From: Kay Brown
To: Council, City
Subject: Comment: 660 University Complex/Agenda 11/10/25 Date: Thursday, November 6, 2025 8:31:07 AM
Attachments: 660 letter to council--114.pdf
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Dear City Council Representative,
Please include the following attachment below (5 Pages ) in letters/ comments re 660 University Project.
The 660 development is slated to be on agenda this Monday November 10.
Thank you for your help.
Kay Brown
650-269-1985
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To: The Palo Alto City Council 11/4/25
From: Kay Brown
Chart Below from Final EIR Report Pg 103 660 University
The above chart appears in the Final EIR Report (Pg 103) completed by Rincon Consultants March 2025. I have searched through the Draft and Final EIR’s to locate mitigating measures for the above concerns. Reference to these issues are located in the Draft EIR 4.3 (pgs. 12-14). In the analysis compiled by Hexagon Transportation Consultants (hired by Smith Developers) which utilizes VMT to analyze traffic issues for the project, there is no mention of limitations of Byron Street, the intersection of Byron and University and safety issues regarding the popula- tion of the area. Smith Developers engaged Hexagon to respond to above potential impacts.
In Hexagon’s transit overview, statement below is the only mention of Byron St.
Byron Street is a north-south street that extends between University Avenue to the north and Hamilton Avenue to the south. Byron Street has a prima facie speed limit of 25 mph. Sidewalks are present on both sides of the street. There are no existing bike facilities on Byron Street. On- street parking is permitted on both sides of the street. Byron Street runs along the western boundary of the project site and provides direct access to the site via one full access driveway. 1). Hexagon’s conclusion (Draft EIR: 4.3 Pg 11), after giving a boiler plate analysis of Santa Clara transit, responds to Rincon’s concerns in chart above. “This impact would be less than significant without mitigation.
No mitigation measures are required.”
____________________________________________________________________________
2. Hexagon (Appendix E EIR) addresses Emergency Access (d. chart above).
Access to the project site would be provided via one full access driveway on Byron Street, which emergency response vehicles would be able to use. The TIA (traffic impact analysis) evaluated site access and circulation and concluded that the project’s driveways and internal roadway network would be designed to current City standards and would accommodate the access requirements for emergency and passenger vehicles. In addition, all roadway users must yield to the right-of-way of emergency vehicles when emergency sirens and lights are on. Therefore, the proposed project would not result in inadequate emergency access and this impact would be less than significant.
The above (answer to d. chart) addresses access only to 660 for emergency vehicles. It does not also take into consideration Emergency Response Vehicle access to senior communities that surround 660. This area is visited frequently by Emergency Response teams that arrive in mul- tiple vehicles. Hexagon’s analysis does not address the narrowness nor the limited parking that already exists on Byron. Even with siren’s blaring, it is very difficult for cars to pull over to allow Emergency Vehicle access.
__________________________________________________________________________
3). The initial draft EIR study ( page 78), also addresses Emergency response plans. “f. Would the project impair implementation of or physically interfere with an adopted emer- gency response plan or emergency evacuation plan?
The project would involve the demolition of existing buildings and the construction of a four-sto- ry mixed-use building. The new building would not obstruct existing roadways, require full road closures during construction, or require the construction of new roadways or access points.
Therefore, the proposed building would not block emergency response or evacuation routes or in- terfere with adopted emergency response and emergency evacuation plans. No impact would oc- cur and further analysis of this issue in an EIR is not warranted.” (NO IMP ACT) Where are demolition and constructions vehicles going to park? Again, there is no adequate parking on Byron. Will they park on University or on Middlefield? The set-backs have been minimized and cannot accommodate large vehicles. Emergency Access will certainly be im- pacted. (traffic safety alternatives/mitigations have been side-stepped). _____________________________________________________________________________ 4). On April 11, 2024, at a planning commission meeting, Eric Carlson, a Palo Alto resident, raised local traffic/safety concerns.
The commission’s response to Mr. Carlson’s concerns…
“As discussed in the Draft EIR, Byron Street is a local residential street that carries light traffic volumes throughout the day. Because the speed and volume of vehicular traffic would be low on Byron Street it is anticipated that traffic accessing the project site would not result in safety or operational impacts. In addition, the Transportation Impact Analysis prepared by Hexagon Transportation Consultants, Inc on February 15, 2024 (Appendix E to the DEIR)” No research consultants, no city entities mention the idiosyncrasy of Byron St, its narrowness, the elderly population that traverses it daily, nor the safety problems that currently exist.
There is no adequate study that addresses Rincon’s “potentially significant impact” chart above. Rincon concludes "impacts would be significantly impacted and would be further ana- lyzed in the EIR.” Where are local concerns further analyzed by the EIR? Where are the miti- gation measures?
___________________________________________________________________________ In previous letters (dated 3/4/25 and 8/17/25) I sent to Emily , The Planning Commission, and City Council, I outlined existing traffic safety issues which will be exacerbated by the densely populated 660 project. Situation as it exists now….
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.Delivery trucks, tele-communication repair trucks, food delivery trucks for the church, linen deliveries, plumbers, electricians, multiple nursery school transport vehicles are parked along Byron which obstruct an already congested street.
3.Drivers on University that choose not to wait for light on Middlefield use Byron in attempt to side-step the traffic light. They zoom through Byron. The cars travel swiftly without re- gard to elderly residents with walkers and wheelchairs attempting to cross University on their way to daily church lunches.
4.This is not a normal residential street. The church is an event venue. Several times a week music, dance, ethnic and religious events are held. Parking exceeds spaces in the lot which flows out to Hamilton, Byron and adjacent residential streets. At times, church attendees park in the existing dental bldgs (660-680 University) lots on weekends and will not be available after 660 is erected.
Architects of 660 were not required to provide a circular drive nor loading dock to accommo- date commercial vehicles. With the density of 660, there will be enumerable Amazon type de- liveries. The width of the driveway specified cannot accommodate commercial vehicles and also allow ingress and egress of occupants. Where will the garbage trucks pull up and not clog an already impacted Bryon St? The architects plan currently is for large vehicles to park along Byron (maybe 1 or 2 spots may fit on the Byron portion of 660. How will emergency vehicles access Byron efficiently?
___________________________________________________________________________
CEQA/EIR
CEQA requires an EIR to identify potential significant safety related impacts. Rincon did this in above chart. CEQA advises the necessity to offer feasible mitigation measures to minimize outlined impacts (none). CEQA requires the need to explore alternatives to address safety con- cerns (none). CEQA requires technical studies to address safety issues (none). A comment by a transportation commissioner at recent October meeting, “Studies are expensive.” Agreed, studies are expensive. When Palo Alto commissions costly studies, better oversight is needed to address local issues. The city cannot be satisfied with boiler plate VMT studies that regurgitate Santa Clara thoroughfares and skirt over EIR matters of significant con- cerns.
CEQA requires public input regarding safety concerns. Existing safety issues were dismissed outright by the Hexagon Study and no technical traffic safety studies were initiated. And, fi- nally…safety considerations must take into consideration the surrounding population (3 large elderly communities). Public comment re the safety configurations of University, Hamilton, and Byron were ignored.
Hexagon Conclusions
(Transportation Study 2024/ restated in revised final EIR pg 13 Appendix E) “The impacts of the proposed project were evaluated in accordance with the procedures and guidelines specified by the City of Palo Alto. The analysis resulted in the following key findings:
•Based on the City of Palo Alto VMT (Vehicle Miles Traveled) Policy, the project would have less- than-significant VMT impact for its residential and office components”. •The project would not create any impacts on pedestrian, bike, or transit facilities.” Developers cannot disregard public safety, including traffic concerns and cannot invoke Builders Remedy without providing some mitigations or modification to the project. In or- der to use Builders Remedy, they must provide alternative solutions to secure the safety of the population surrounding the planned development. A Builders Remedy project cannot be approved without considering local traffic safety. Palo Alto can impose conditions on a project requiring further studies, alternatives and mitigations if it poses a "specific adverse impact on public health and safety,” (Housing Accountability Act) The analyses offered by Hexagon have failed to take into consideration the cumulative impact on Byron and University. Hexagon has failed to conduct realistic local traffic assessments (only viewing it at off-hours?). This omission compromises the project's long-term viability, quality of life and safety for the surrounding community. And, lack of local data collection has skewed responses to Rincon’s EIR Chart of ‘Potentially Significant Impact’. Relying heavily on Santa Clara VMT requirements, Hexagon, the Developers and the Transportation Commission have leap-frogged over CEQA concerns / EIR consequential impacts (above chart) with the portent of potentially significant repercussions.
Appreciate your time and attention,
Kay Brown
650-269-1985
[email protected]
From: Alice Smith
To: Council, City
Subject: Item 6 on November 10th Agenda : Approval of 660 University Ave.
Date: Wednesday, November 5, 2025 4:47:30 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
RE: PUBLIC HEARING / QUASI-JUDICIAL. 660 University Ave [21PLN-00341]: Request for Approval of a Planned Home Zoning (PHZ) on Three Parcels (511 Byron Street, 660 University Avenue, 680 University Avenue/500 Middlefield Road), to Demolish Existing Buildings and Provide a New Six Story Mixed-Use Building with Approximately 1,900 Square Feet of Office, 70 Multi-Family Residential Units, and a Two Level Below-Grade Parking Garage. CEQA Status:
A Draft Environmental Impact Report Circulated for Public Review Beginning on April 2, 2024, and Ending on May 17, 2024. The City published a Final EIR in March 2025 and a revised Final EIR in October 2025. Zoning District: RM-20 (Multi-Family Residential).
To the City Council of Palo Alto,
I write to ask you to support the above-described New Six Story mixed use building to provide 70 multi-family residential units which I consider to be necessary and proper for the betterment of the future of the City of Palo Alto.
Consider the benefits to the merchants, the schools, the community generally. The location is near already in place businesses and services (schools, public transportation, fire station, parks, accessible shopping, library and so on), The height is reasonable and the parking appropriate with more available nearby.
As a nearby neighbor, I do support this new housing project in the Planned Home Zone and trust that you will vote yes.
Alice Schaffer Smith
Channing House
850 Webster Street #520
Palo Alto, CA
From: [email protected]
To: Tim Persyn
Cc: Council, City; Palo Alto Forward
Subject: Re: 660 University Ave.
Date: Wednesday, November 5, 2025 10:54:18 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
thanks!!!
On 2025-11-05 10:27, Tim Persyn wrote:
Dear City Council,
I'm writing today to support the proposed development at 660 University Ave and I respectfully ask the council to approve it.
As a Palo Alto resident for the past 10+ years, this housing proposal has been under review by the city for nearly one-third of the time that I've been a resident. Needless to say, it's been thoroughly reviewed and vetted.
There are many reasons to support this development. Its downtown location puts it within walking distance of retail and services. It's also near Caltrain and adjacent to transit.
Most importantly, 20% of the homes in this development will be affordable housing. This fact will help the city make progress on its fair housing goal. As we know, Palo Alto has developed a reputation as an exclusive city, but this proposed housing could help open up opportunity and change that direction.
For these reasons, I support the proposed development at 660 University, and I ask the city council to support it, also.
Sincerely, Tim Persyn
1 Dear Mayor Lauing and Council members,
I write in support of the staff recommendations to approve the application for the 660 University project.
I note that the site was adopted by council in the Housing Element site inventory for a project of this size.
In addition, the applicant has worked for four years in an open and transparent process that offered multiple opportunities for both supporters and opponents to make public comments.
The applicant has adopted many of the requests for modifying the application from both the ARB and PTC.
The staff notes that the project has no significant negative environmental impacts and conforms to the Comp Plan.
Adoption by the council will send a strong signal to other potential applicants that the City is serious about adding market-rate/mixed use housing downtown.
As the applicant enters the fifth year with this project, it is time to approve it and move forward.
Thank you
Stephen Levy
A suupportive downtown resident
From: Tim Persyn
To: Council, City
Cc: Palo Alto Forward; [email protected]
Subject: 660 University Ave.
Date: Wednesday, November 5, 2025 10:27:33 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear City Council,
I’m writing today to support the proposed development at 660 University Ave and I respectfully ask the council to approve it.
As a Palo Alto resident for the past 10+ years, this housing proposal has been under review by the city for nearly one-third of the time that I’ve been a resident. Needless to say, it’s been thoroughly reviewed and vetted.
There are many reasons to support this development. Its downtown location puts it within walking distance of retail and services. It’s also near Caltrain and adjacent to transit.
Most importantly, 20% of the homes in this development will be affordable housing.
This fact will help the city make progress on its fair housing goal. As we know, Palo Alto has developed a reputation as an exclusive city, but this proposed housing could help open up opportunity and change that direction.
For these reasons, I support the proposed development at 660 University, and I ask the city council to support it, also.
Sincerely, Tim Persyn
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From: [email protected]
To: Council, City; Kallas, Emily
Subject: 660 University Avenue application
Date: Wednesday, November 5, 2025 9:58:02 AM
Attachments: Aupport for the 660 University project.docx CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
!
letter of support for the staff recommendations
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