Attachment B - 2023-2031 Housing Element Implementation Programs, 2025

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2023-2031 HOUSING ELEMENT PROGRAM IMPLEMENTATION, 2025
Program
# Implementing Objective Time Frame Quantified Objective Current Status 2025 Status
PROGRAM 1: MAINTAIN SITES
Program 1.1: Adequate Site Program

1.1A Amend the Comprehensive Plan and zoning districts as needed for properties identified to meet the City’s
RHNA obligations. The amendments include changes to
allow increased residential densities shown in Appendix D in developments and relevant development
standards to accommodate increased density, and
modifications to allowable uses to permit multi-family
residential uses where it is not currently allowed.

Examples of possible changes include adjustments to
building height, lot coverage, floor area ratios, ground floor landscaping requirements, and parking, as
discussed in Chapter 4, Analysis of Land Use Controls.

This also includes zoning updates to create the El
Camino Real Focus Area, which would allow up to 4.0
FAR and 85 feet in height in exchange for the provision of 20 percent inclusionary housing on site. Located
between Page Mill Road and Matadero Avenue, this
location has excellent access to services, shopping,
California Avenue, jobs, Stanford, and transit.

The rezone/upzoning shall include the following
provisions of Government Code Section 65583.2(h) and
(i) for specified sites accommodating lower incomes: (1) By-right development of multi-family developments in
which 20 percent or more of units are affordable to
lower-income households; (2) Accommodation of at
least 16 units per site; (3) Minimum density of 20 units per acre; (4) Because 50 percent of the lower-income
need cannot be accommodated on sites designated for
residential use only, a portion shall be accommodated
on sites zoned for mixed uses that allow 100 percent
residential use and require that residential use occupy at least 50 percent of the total floor area of a mixed-use project.

The rezoning includes the following requirements for
these Stanford-owned properties:

Complete by January 31, 2024 The City will amend the Comprehensive Plan or zoning designation of 291
properties located in commercial,
industrial, or residential zoning districts,
which together will generate a realistic
yield of 4,063 housing units.

Complete Complete. Ordinance and
Comprehensive Plan update
were adopted by City
Council in November 2023.

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Program
# Implementing Objective Time Frame Quantified Objective Current Status 2025 Status

1.1A.i For the housing opportunity site located at the corner of Pasteur Drive and Sand Hill Road and the adjoining
property at 1100 Welch Road, as an alternative to the
State Density Bonus law, amend zoning regulations to
allow approximately net new 425 units up to 85 feet in
height; redevelopment of the Welch Road property
shall comply with the replacement housing provisions
of the Housing Crisis Act, which will substantially
protect tenants from displacement.

Complete Complete. Ordinance and
Comprehensive Plan update
were adopted by City
Council in November 2023.

1.1A.ii For the housing opportunity site located at 3128 El Camino Real (McDonald’s), as an alternative to the
State Density Bonus law and as part of the El Camino
Real Focus Area, amend zoning regulations to allow at
least 144 housing units with a maximum height of 85
feet; allow a minimum of 315 housing units if combined
with an adjacent property, and require 20 percent
inclusionary housing.

Complete Complete. Ordinance and
Comprehensive Plan update
were adopted by City
Council in November 2023.

1.1A.iii For the housing opportunity site located at 3300 El Camino Real, as an alternative to the State Density
Bonus law and as part of the El Camino Real Focus Area, allow up to 200 housing units, up to a 4:1 floor area
ratio (FAR) with a 20 percent inclusionary housing
requirement. Commercial office approved or permitted
on this property is inclusive of the total floor area
allowed for this site.

Complete Complete. Ordinance and
Comprehensive Plan update
were adopted by City
Council in November 2023.

1.1B Rezone ROLM and GM zoned properties to allow multi- family residential housing with a density of 90 dwelling units per acre for properties nearest Bayshore Freeway
and generally bounded by East Charleston Road and
Loma Verde Avenue. This action will require additional
changes to the related development standards to
accommodate higher-density development. Examples
of specific changes to development standards are
discussed in Chapter 4, Analysis of Land Use Controls.

Complete by January 31, 2024 The City will rezone approximately 146 sites in the designated area, including the
already identified housing inventory sites,
to allow for development at
approximately 90 dwelling units per acre.

Complete Complete. Ordinance and
Comprehensive Plan update
were adopted by City
Council in November 2023.

1.1C Maintain an updated inventory of housing sites and actively promote sites available for lower- and
moderate-income housing development to potential
developers, private and non-profit organizations, and
other interested persons. Post information on the City’s website and update as necessary to maintain accurate
information.

Post information on the City’s
website by June 2024 and
update annually, or more
often if needed.

Support the development of 1,556 units
for very-low income, 896 units for low
income, 1,013 units for moderate income,
and 2,621 above-moderate households
during the planning period.

Ongoing Ongoing/Standard
Operations. The City
maintains an updated
inventory of housing sites
and continues to
communicate availability of
site for lower- and
moderate-income housing
to potential partners.

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Program
# Implementing Objective Time Frame Quantified Objective Current Status 2025 Status

1.1D Provide technical assistance and information on parcels available for lower-income developments to private or
non-profit housing developers. Technical assistance
includes land development counseling by staff planners.

Develop technical assistance
program by December 2024
and set/publish regular hours
for assistance on the City’s
website.

Support the development of 1,556 units
for very-low income, 896 units for low-
income households during the planning
period.

Ongoing Ongoing/Standard
Operations. City staff
regularly provide technical
assistance to developers.

1.1E Engage owners of parcels owned by faith-based
institutions to educate them on legislation (SB 4) that streamlines the residential development process for
religious institutions, and funding opportunities for this type of development. Because the outreach,
engagement, and site design will take time, the City
anticipates that the majority of production will happen during the second half of the planning period. To track program implementation, monitor faith-based
community interest and production. By 2027, halfway
through the planning period, if less than 35 percent of the Quantified Objective (i.e., 48 affordable housing
units) has been entitled, update the Site Inventory to
identify new opportunities to achieve the Quantified
Objective in this program.

Initiate discussions in 2025
and then annually.

Support the development of 135 units on
sites owned by faith based institutions
during the planning period
In Progress In Progress. Staff has
initiated discussions with
interested faith-based
institutions about SB 4 and
potential development
opportunities
Program 1.2: Site Inventory Monitoring Program

1.2A Maintain an updated inventory of residential housing developments that have been submitted and acted
upon.

Update inventory annually
every April.

Management of site inventory through
the Annual Progress Report to HCD.

Ongoing Ongoing/Standard
Operations. The City
maintains a regularly
updated site inventory.

1.2B Maintain an updated inventory of residential housing developments that have been submitted and acted
upon.

Conduct review of sites
inventory annually and report
findings in housing element
progress report; correct any
deficiency within 180 days if
identified.

The City will maintain a sufficient number
of reserve housing inventory sites to
remain compliant with State law. In the
event the City falls short of that
requirement, it has committed to adding
or rezoning additional properties within
180 days of noticed shortfall of units.

Ongoing Ongoing/Standard
Operations. City staff
monitor the status of the
sites inventory to ensure a
sufficient number of reserve
sites.

1.2C Actively promote, through outreach and discussions, sites available for lower- and moderate-income housing
development to potential developers, private and non-
profit organizations, and other interested persons and
organizations.

Update inventory annually
every April.

Conduct a minimum of four (4) meetings
annually with potential developers about
lower- and moderate income housing
sites.

Ongoing Ongoing/Standard
Operations. City staff
continues to discuss housing
sites with interested parties.

Program 1.3: Site Used in Previous Housing Cycle

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Program
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1.3A The City shall rezone or amend its Municipal Code to allow by-right approval on non-vacant sites included in one previous housing element inventory and on vacant
sites included in two previous housing elements and
designated for lower-income housing, provided that the
proposed housing development consists of at least 20
percent lower-income housing units.

Complete by January 31, 2024 Complete rezoning and amend development standards for qualifying
sites to enable a projected realistic
housing yield of 390 housing units.

Complete Complete. Ordinance and
Comprehensive Plan update
were adopted by City
Council in November 2023.

Program 1.4: City-owned Land Lots and Downtown Housing Plan

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1.4A Any future project on the six City-owned surface
parking lots identified in Appendix D for redevelopment shall include replacement public parking and provide
100% affordable housing units serving households
earning up to 80% of the Area Median Income (AMI) or
for workforce housing for City employees and Palo Alto
Unified School District (PAUSD) employees. The City will prepare a request for proposals to solicit interest in a public/private partnership for redevelopment of one or
more sites in the City’s University Avenue Downtown
area. The City will comply with the provisions of the
Surplus Lands Act, ideally by using the streamlined
provisions for affordable housing dispositions under
Government Code Section 37364.

The City will take a phased
approach to developing these
lots. An RFI was issued in
2023 with the intent to select
a development partner in
2024 and solicit feedback
from community partners.

The City will assist its
development partner in
securing tax credits and other
financing, with the goal of
awarding construction
contracts on both the housing
project and replacement
public parking in 2026. Based
on the results of the initial
effort, the City will issue one
or more additional RFIs or
RFPs for any remaining units
no later than 2026, with the
goal of selecting development
partners in 2027. The City will
coordinate with development
partners and community
partners, to ensure units are
entitled during the planning
period. The City anticipates
that the majority of
production will happen during
the second half of the
planning period. The City will
monitor progress during the
planning period. If the City is
not on track to meet the
Quantified Objective by 2027,
halfway through the planning
period, the City will remove
these sites and identify
alternate sites with zoning
sufficient to accommodate
any shortfall of units, likely
resulting from the Downtown
Housing Plan by December
31, 2027. Any additional
selected sites will meet the
requirements of Government
Code Section 65583.2.

Develop 50 lower income units through
the initial RFI process, with the intent to
develop the remaining 240 units that can
be accommodated on City-owned sites
through one or more separate efforts to
follow during the planning period
In Progress In progress. The City entered
into an Exclusive Negotiating
Agreement with Alta
Housing in June 2025 and
anticipates a formal project
application submission in
2026.

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1.4B Upon completion of the Project Homekey project, the City anticipates that sufficient transitional housing
capacity to serve Palo Alto’s needs will be available. If additional capacity for interim or transitional housing is required, the City will examine City owned parcels and
other sites based on availability, size, access to services and related metrics. If additional parcel(s) are
identified, pursue partnerships and funding
opportunities to build interim or transitional housing.

If additional capacity is
needed, complete site
identification within 180 days
of identification of need.

Subject to identification of suitable sites
and formation of public/private
partnership; provide transitional housing
opportunities for 75 or more beds during
the planning cycle.

In Progress In progress, construction
completion anticipated early
2026. City staff are
monitoring progress.

Program 1.5: Stanford University Lands

1.5A Remove the Conditional Use requirement for
residential uses in the Research Park zone district,
which is specific for the Stanford Research Park, except for properties subject to or impacted by the City’s
hazardous materials ordinance. Sites included in
Appendix D will have the Conditional Use requirement
removed under Program 1.1.

Complete by January 31,
2025.

This will remove a governmental housing
constraint that may encourage greater
residential uses in the Stanford Research
Park.

Complete Complete. The ordinance
update to remove the CUP
for residential uses within
the RP and RP5 zones except
for sites that are subject to
or impacted by the City's
hazardous waste ordinance
was adopted by Council in
January 2025.

1.5B Engage Stanford University in a dialogue about future multi-family housing opportunities within the Stanford
Research Park, including consideration of a new
neighborhood along Foothill Expressway. Identify
locations suitable for housing and mixed-use
development and zoning modifications and housing
incentives as appropriate for consideration in the
Seventh Cycle Housing Element Update
Initiate conversations with
Stanford University, Simon
Properties, and other
stakeholders prior to
December 31, 2025.

If Stanford University and long-term lease
holder are receptive to future residential
development, establish a memorandum
of understanding with appropriate
stakeholders that identify the location and
amount of future housing at these
locations by the end of the planning
period.

In Progress In Progress. Staff has
initiated the conversation to
identify housing opportunity
sites in Stanford-owned
lands specifically in the
Research Park in fall 2025.

1.5C Engage Stanford University and long-term leaseholder Simon Properties for possible residential
redevelopment opportunities at the Stanford Shopping
Center for consideration in the Seventh Cycle Housing
Element Update.

Initiate conversations with
Stanford University, Simon
Properties, and other
stakeholders prior to
December 31, 2025.

In Progress In Progress. Staff has
initiated the conversation
with representatives from
Stanford on the possible
residential redevelopment
at the Stanford Shopping
Center in fall 2025.

PROGRAM 2: AFFORDABLE HOUSING
Program 2.1: Affordable Housing Development

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2.1A Use funds available through the City’s residential and commercial affordable housing fund to provide gap
funding for qualifying affordable housing projects.

Housing funds are derived from development impact
fees, in-lieu inclusionary fees and proceeds from a local business tax approved by the voters in November 2022.

The City will continue to seek funding sources, including supporting the ongoing development of the Bay Area
Housing Financing Authority (BAHFA).

Annually review fund
balances and if sufficient
funds warrant, prepare a
Notice of Funding Availability.

The fund balance will vary
over time based on
development activity and for
the business tax, first
collection is anticipated to
start no sooner than January
2024.

Over the planning period, the City
anticipates it would generate
approximately twenty million dollars ($20
M) for use toward affordable housing and
homelessness projects. Based on this
projection, the City would expect to be
able to support gap funding for the
production of 55 affordable housing units
during the planning cycle or support other
housing priorities.

Ongoing Ongoing/Standard
Operations. The City
regularly monitors available
funds and funding
opportunities.

2.1B Prepare an updated nexus and feasibility study and adjust the residential and commercial housing
development impact fee as appropriate, to support
affordable housing production, while ensuring that the
fee is set appropriately to maintain project feasibility.

As part of this study, the City will engage local
developers and building industry stakeholders to gain
feedback on impact fees and will incorporate feedback
into the study.

Initiate study prior to
December 31, 2025 with
implementation of adjusted
impact fees, if needed, by
January 2026.

Use the study to adjust impact fees as
necessary to support continued
contribution to the City’s affordable
housing fund without burdening housing
production with excessive fees that
cannot be supported by the City’s
development standards.

Pending Pending .The City issued an
RFP in May 2025 and
expects Council approval for
a consultant contract to
perform this work in
December 15, 2025.

2.1C Partner with qualified housing developers to identify affordable housing development opportunities with
emphasis on promoting housing choices that serve the
needs of special needs populations, including seniors,
homeless, female-headed households, large families,
low-income, and/or persons with disabilities.

Opportunities along Alma Street, Embarcadero Road
northeast of Highway 101, and the South Ventura
neighborhood should be prioritized to provide
additional opportunities where special needs
populations are located. Meet annually throughout the
housing cycle.

By December 2024 initiate
meetings with housing
developers to discuss
affordable housing
opportunities.

Through annual meetings, identify with
partners at least three affordable housing
opportunity sites and facilitate project
approval and permitting to realize
implementation.

Ongoing Ongoing/Standard
Operations. Staff meets
with interested parties to
identify affordable housing
opportunities which can
serve the needs of special
needs populations.

2.1D Research and identify additional State and federal funding opportunities for affordable housing projects.

Disseminate information on funding opportunities on
the City’s website and/or to potential developers during technical assistance meetings and meetings with
housing developers.

Ongoing task as part of
meetings with housing
developers.

Support the development of 1,556 units
for very-low income, and 896 units for
low-income households during the
planning period.

Ongoing Ongoing/Standard
Operations. The City
continually shares
information about
affordable housing funding
opportunities with
developers.

Program 2.2: Below Market Rate (BMR) Program

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2.2A Continue to require development of three or more net- new residential units to provide at least fifteen (15
percent) of those units as inclusionary units at below
market rates for ownership housing or pay a fee toward
the City’s affordable housing fund.

Ongoing 15 percent of the net new multi-family
ownership housing stock will be deed-
restricted to affordable housing (two-
thirds at 100 percent AMI and one-third at
120 percent AMI), except in instances
where an in-lieu payment may be
accepted. The City will collect in-lieu
payments for new multi-family rental
housing based on project floor area times
a dollar amount set by the City’s fee
schedule, currently $24.52; payments will
be used to support qualifying affordable
housing projects. Some rental home
builders may elect to provide inclusionary
units to qualify for the State Density
Bonus, in such instances no additional in-
lieu payment will be received.

Ongoing Ongoing/Standard
Operations. Per the Palo
Alto Municipal Code, the
City continues to require
developments of three or
more net-new residential
units to provide at least
fifteen percent of units as
BMR inclusionary units.

2.2B Update the City’s 2020 financial feasibility report prepared by Strategic Economics and research a tiered
inclusionary housing requirement for ownership and
rental housing where market conditions support a
higher inclusionary rate; establish requirements for
lower income units at a reduced inclusionary
requirement based on feasibility findings and discussion with developers and community members.

Complete study and
implement recommendations
by June 30, 2026.

Update study and present findings to the
City Council with options to modify the
City’s inclusionary requirements. If
supported, enact municipal code changes
to implement changes. Implementation of
this objective may have the effect of
modifying the quantified objective in A
above.

In Progress In Progress. This is included
in the scope of the fee study
project initiated at the end
of 2025. The project team
began work after the
consultant contract was
approved on December 15,
2025. The project includes
tasks to update the BMR
program report, perform
required research and, make
recommendations to Council
(as appropriate) by June 30,
2026.

2.2C Amend the City’s BMR program to ensure continued
affordability of income-restricted ownership units for
the life of the project (exempting certain affordable
projects taking advantage of tax credit financing). Once amended, conduct outreach with home builders and
other stakeholders regarding amended program.

Complete by December 31,
2028.

Conduct outreach with home builders and
other stakeholders and draft an ordinance
to extend income restrictions in
accordance with the implementing
objective.

Pending Pending/Not Started.

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2.2D Review the City's Below Market Rate rental procedures for households who exceed the maximum income limit
during their tenancy. Update rental procedures to
ensure reasonable transition time for households
whose incomes increase but end up disqualifying
households from deed restricted housing. [Note: this
can only apply to units in the City’s BMR program, 100
percent affordable projects may have other lender-
dictated requirements.]
Complete by December 31,
2025.

Update rental procedures to respond to
input from rental community to ensure
that affordable housing units are occupied
by qualified individuals.

In Progress In Progress. Options
identified in fall 2025 to
amend procedures. Review
in progress.

PROGRAM 3: CONSTRAINTS
Program 3.1: Fee Waivers and Adjustments

3.1A Amend the City’s municipal fee schedule to waive City staff costs associated with the processing of an
affordable housing planning application, except for
directly related consultant supported costs.

Amend fee schedule by
December 2024
Reduce application processing costs by
approximately $20,000 per affordable
housing application and processed for a
planning entitlement.

Complete Complete. The Palo Alto
Municipal Fee Schedule
outlines a Planning
Application Fee Waiver for
100% Affordable Housing
Projects.

3.1B Prepare an economic feasibility study to analyze
implications that the park fee, may have on housing
production; adjust fees as appropriate to enable a
reasonable return on investment and ensure sufficient
fee collection to support City services. Complete
additional study by December 2025. If study
demonstrates that park fees are acting as a constraint
on housing production, amend fee schedule by
September 2026.

Complete and implement
studies by September 2024.

Complete additional study by
2025. Amend fee schedule by
September 2026.

In Progress In Progress. City issued RFP
for this work in May 2025.

Work began at the end of
2025. Any recommended
changes to the park land
dedication fees will be
approved by City Council by
September 2026.

3.1C By September 2024, complete and implement studies
to convert existing park, community center, and library development impact fees that are applied on a per unit
basis to a per square foot basis. Complete additional
study by December 2025. If study demonstrates that
development impact fees are acting as a constraint on
housing production, amend fee schedule or modify
development standards by September 2026.

Complete and implement
studies by September 2024.

Complete additional study by
2025. Amend fee schedule by
September 2026.

In Progress In Progress. Initial update
completed in 2024. Project
team began work on
additional analysis as part of
a fee study and update
project initiated at the end
of 2025.

Program 3.2: Monitor Constraints to Housing

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3.2A Monitor new local policy initiatives for effectiveness in combatting identified constraints to housing
development.

Complete review and
implementation of required
edits once during the
planning period, by January
2027.

Ongoing Ongoing/Standard
Operations. The City
continually monitors policy
initiatives and their potential
impact on housing
development. Any
recommended changes to
the park land dedication
fees will be approved by City
Council by September 2026.

3.2B When new land use regulations, impact fees, or
procedural changes are being considered by the
Planning and Transportation Commission and City
Council, the City shall prepare an analysis in the
accompanying staff report detailing how the regulation
may impact housing production, if at all, and provide
recommended solutions to address those impacts.

Complete review and
implementation of required
edits once during the
planning period, by January
2027.

Ongoing Ongoing/Standard
Operations. An analysis on
the potential impact on
housing production is
included for relevant
Planning and Transportation
Commission and City Council
staff reports.

3.2C The City shall monitor the application of the Municipal Code standards for potential constraints to housing
projects and recommend changes annually, as
appropriate, to enhance the feasibility of affordable
housing.

Complete review and
implementation of required
edits once during the
planning period, by January
2027.

Ongoing Ongoing/Standard
Operations. The City
continually monitors the
application of the Municipal
Code to identify potential
constraints related to
affordable housing
feasibility.

Program 3.3: Affordable Housing Development Incentives

3.3A Amend the municipal code to extend the affordable
housing incentive program to apply to all housing
opportunity sites identified in the Housing Element and zoned for commercial, industrial or multi-family
residential use; research potential AHIP regulations for religious institution sites located in the R1 district with a reduced density provision.

Complete zoning changes by
December 31, 2024
Amend the zoning code and
comprehensive plan as necessary to
extend the provision of affordable
housing incentive program to sites in the
housing inventory and codify additional
incentives described herein.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

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3.3B Amend the affordable housing overlay (incentive
program) regulations to allow housing projects to
achieve a residential floor area ratio of 2.4:1.0 without requiring commercial floor area (except where required
on University and California Avenues). The City will
modify AHIP development and parking standards
commensurate with FAR increases, and, for housing
projects income restricted to 60 percent of the area
median income level or below, allow up to sixty (60)
feet in height on all opportunity sites
Complete zoning changes by
December 31, 2024
Amend the zoning code and
comprehensive plan as necessary to
extend the provision of affordable
housing incentive program to sites in the
housing inventory and codify additional
incentives described herein.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

3.3C Amend Zoning Code to incorporate all recent changes to State density bonus law and develop summary
materials to promote the use of density bonuses.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

3.3D Amend the PAMC to streamline all 100% affordable
housing development projects. Implement a procedure
that prioritizes affordable housing projects for staff
resources and, if applicable, hearing dates, above other projects, regardless of submission date.

Complete by December 2024 The timeframes associated with permit processing can be viewed as a constraint
to affordable development. The City aims
to complete the processing of planning
entitlements for affordable housing
projects exempt from environmental
review within 90 days from application
submittal.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

Program 3.4: Housing Incentive Program (HIP)

3.4A HIP qualifying projects that also comply with City approved objective standards shall be administratively
reviewed with one courtesy meeting before the
Architectural Review Board.

Revise review process
instructions by December
2024.

Monitor projects for compliance with
desired review schedule, track application
processing timelines and number of
applications appealed to Council; use data
to inform future modifications to the HIP
program.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

3.4B Amend the local Housing Incentive Program to include specific expanded development standards, as an
alternative to state density bonus provisions. Reduce
barriers by removing Planning Director discretion to
define applicable standards in each instance.

Complete Municipal Code
amendments by December
31, 2024.

Amend the municipal code and
comprehensive plan to codify
implementing objective with the goal of
encouraging the development of
approximately 550 units over the planning
period.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

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3.4C Allow for sites subject to the City’s retail preservation ordinance – except in the ground floor (GF) and retail
(R) combining districts and strategic locations generally depicted in the draft South El Camino Real Design
Guidelines – to have a reduction in the amount of retail replacement floor area needed for redevelopment and
waive the retail preservation requirement for identified housing opportunity sites.

Complete Municipal Code
amendments by December
31, 2024.

Amend the municipal code and
comprehensive plan to codify
implementing objective with the goal of
encouraging the development of
approximately 550 units over the planning
period.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

3.4D Extend the local Housing Incentive Program to the
multi-family residential districts (RM-20, RM-30, and R- 40).as well as the ROLM and GM district focus area The
Housing Incentive Program development standards
shall be amended to increase height and floor area
allowances for housing projects; reduce parking
requirements to match or improve upon state density
bonus, and adjustment to other development standards
to enable greater housing production.

Complete Municipal Code
amendments by December
31, 2024.

Amend the municipal code and
comprehensive plan to codify
implementing objective with the goal of
encouraging the development of
approximately 550 units over the planning
period.

Complete Complete. The Planning and
Transportation Commission
recommended approval of
the ordinance in December
2024. The City Council
adopted the ordinance in
March 2025.

3.4E Expand the geographic boundaries of the El Camino
Real Focus Area (adopted in 2023) to incentivize
housing production at appropriate locations. Increase
building height and floor area ratios and apply other
objective standards, such as transitional height
restrictions, to address single family zoning district
adjacencies. The proposed standards will be an
alternative to the state density bonus.

Complete municipal code
amendments by June 30,
2025.

Amend municipal code with the goal of
encouraging development of
approximately 500 units over the planning
period.

Complete The City Council adopted an
ordinance expanding the
boundaries of the El Camino
Real Focus Area and
amending the regulations on
May 27, 2025.

Program 3.5: Accessory Dwelling Unit (ADU) Facilitation

3.5A Develop, maintain and update a City Summary Guide to ADUs and JADUs to promote, educate, and assist
homeowners with developing ADUs/JADUs.

Complete by June 30, 2024
and maintain annually
thereafter.

Facilitate the development of 512 ADUs
over the planning period.

Ongoing Ongoing/Standard
Operations. An updated
version of the City Summary
Guide to ADUs and JADUs
was made available in 2025.

3.5B Provide informational workshop(s) and publish
resources on City’s website on building ADUs and
JADUs. Target outreach to property owners in
neighborhoods designated as racially concentrated
areas of affluence to promote housing mobility for
lower- and moderate-income households. Provide
workshops and materials in English, Spanish, and
Chinese.

Publish material on the City’s
website by December 2024
and facilitate one workshop
annually in multiple
languages.

Facilitate construction of 512 ADUs over
the planning period, with a goal of at least
128 (25%) of these to be in
neighborhoods with higher median
incomes.

Ongoing Ongoing/Standard
Operations. Resources on
building ADUs and JADUs
were published on the City's
website in 2025. Staff is
available to provide
information as needed.

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3.5C In accordance with AB 1332, and in coordination with Santa Clara County’s ongoing efforts, develop a
program for pre-approved standards for ADU
foundation plans or prefabricated plans.

Create program by January 1,
2025 and annually inform
residents and developers of
available plans.

Facilitate construction of 512 ADUs over
the planning period, with a goal of at least
128 (25%) of these to be in
neighborhoods with higher median
incomes.

Ongoing Ongoing. Website and City
review process are
completed.

3.5D Continue to monitor and publish information related to ADU production and application review timelines; meet
with ADU stakeholders and review application
processing performance to identify potential
impediments and make adjustments as needed.

Meet with ADU stakeholders
at least once every two years
starting in 2024; prepare
information reports bi-
annually.

Prepare bi-annual reports documenting
findings to facilitate construction of 512
ADUs over the planning period, with a
goal of at least 128 (25 percent) of these
to be in neighborhoods with higher
median incomes.

In Progress In progress.

3.5E Realign development impact fees for ADUs larger than 750 sq. ft. to utilize per-square-foot methodology, likely reducing fee applied to ADUs.

Adopt changes to fee
schedule by September 2024.

Eliminate variations in impact fees for
similarly sized ADUs to increase the supply
of affordable housing in higher
opportunity areas
Complete Complete. In September
2024, City Council adopted
an ordinance realigning
impact fees for ADUs to
utilize per-square-foot
methodology.

3.5F Amend ADU ordinance as required to comply with State law and submit to HCD
Amend ordinance by May
2023. If further amendments
are made to state ADU law,
amend ordinance within 6
months to ensure continued
compliance with ADU law.

Ensure that the City’s ADU ordinance
complies with State law.

Ongoing Ongoing. The latest
ordinance was approved and
adopted by the City Council
on June 17, 2025 and
became effective on July 17,
2025. Staff sent the final
ordinance to HCD on July 16,
2025.

3.5G Review ADU production and affordability levels every two years to determine if assumptions made in Housing
Element are accurate. Prepare and circulate survey of
ADUs to determine affordability levels and determine
where any improvements can be made to the process
and whether non-governmental constraints to
construction of ADUs, such as financing and
construction costs, are restricting development. If
assumptions are not met, and depending on the results
of the survey, take additional actions, which could
include additional public outreach efforts, modifications to process, pre-approved plans, additional zoning
flexibility, ADU incentives, financial assistance, and
identification of new sites.

Meet with ADU stakeholders
at least once every two years
starting in 2024. Review ADU
trends every two years
starting in January 2025. If
assumptions are not met,
take actions within six months
of receiving results to
increase ADU production and
ensure that the City continues
to have adequate housing
sites.

Undertake affordability survey and
prepare bi-annual report documenting
findings to promote income integration
and increase the supply of affordable
housing in higher opportunity areas
In Progress In Progress. Quarterly
reports are published
related to production and
review timelines.

Program 3.6: Expedited Project Review

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3.6A Amend the Municipal Code to exempt housing projects from Architectural Review to the extent they comply
with the City’s objective design standards, requiring
only one study session or courtesy review by the
Architectural Review Board. Clarify staff-level approval process for ministerial and by-right reviews.

Complete by January 31,
2024.

Complete Complete. City Council
adopted an ordinance
amending the Municipal
Code to exempt housing
projects from Architectural
Review to the extent that
they comply with the City's
objective design standards
in January 2024..

3.6B For projects subject to Architectural Review, develop process for early review by the ARB (within 45-60 days
of submittal), even if application is not yet complete.

Implement by December
2024.

The City aims to complete the processing
of planning entitlements for housing
projects exempt from environmental
review within 90 City-processing days
from application completeness.

In Progress In Progress. Where feasible,
projects subject to
Architectural Review are
reviewed within 45-60 days
by the ARB. As noted in
Programs 3.6(A) and (D), the
City has also developed
streamlining paths to limit
the number of Architectural
Review hearing to which
projects may be subject.

3.6C Formalize a procedure to offer no-cost pre-application consultation services for new housing developments.

Complete by July 1, 2024 Provide a no-cost pre-consultation meeting for up to 120 minutes for any
multi-family housing project.

Complete Complete. Process has been
implemented as of June 30,
2024.

3.6D For housing projects subject to the City’s Architectural Review Board, limit the number of hearings before the
ARB to a maximum of two meetings.

Complete by December 31,
2024
Amend the zoning code to limit multi-
family housing projects to two hearings
before the City’s ARB unless additional
review is agreed upon by the home
builder and City; document the City’s
performance.

Complete Complete. The ordinance
amendments was adopted
by the City Council in
January 2025.

Program 3.7: Objective Design Standards for SOFA

3.7A Develop Objective Design Standards for the SOFA Area to accommodate future residential development at
higher densities.

Complete and adopt objective
design standards by
December 31, 2026
Support additional residential
development proposed for the SOFA area.

In Progress In Progress. Project scoping
initiated in Q4 2025.

Program 3.8: Zoning Ordinance Monitoring

3.8A Amend the zoning code to ensure compliance with all provisions of current state law as specified in Program

6.5. Complete by December 31,
2023
Ensure that the zoning code is consistent
with state law.

Complete Complete. The zoning code
was amended in May of
2024 to ensure compliance
with current State law.

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3.8B Review future adopted changes in state law and adopt additional zoning ordinance changes as required to
comply with state law.

In addition, by December 31
of each year, review adopted
changes in state law effective
January 1 of the next year and
adopt additional ordinance
changes as required to
comply with state law. This
program would continue to
be implemented on an
ongoing basis through the
remainder of the planning
period as state law is
amended.

Ensure that the zoning code is consistent
with state law.

Ongoing Ongoing/Standard
Operations. Staff regularly
monitors changes in State
law.

Program 3.9: Conversion of Commercial Uses to Mixed-Use Development

3.9A Amend the City’s Municipal Code to reduce commercial floor area allowances or other commercial incentives at strategic locations to shift the economic benefit of
redevelopment toward home building.

Complete amendments to
Municipal Code by December
31, 2025
Support the development of 716 units on
sites with existing commercial uses.

In Progress In Progress. Staff will bring
options to the Policy &
Services Committee in
March 2026.

3.9B The City shall conduct outreach with home builders and other stakeholders to assess the feasibility of marketing different housing typologies without on-site parking
(paid through an in-lieu fee) and the implications for
City parking resources. Findings will be presented to the City Council along with options on how to proceed,
including the potential extension of the University
Avenue In-Lieu Parking program to residential projects
and the creation of an in-lieu parking program for the
California Avenue area.

Present findings to City
Council by December 31,
2025 with amendments to
municipal code by December
31, 2026.

Complete Complete. Report delivered
to City Council on December
15, 2025. No amendments
are required at this time.

PROGRAM 4: CONSERVATION
Program 4.1: Replacement Housing

4.1A Enforce replacement housing requirements as required by state law. Amend the City’s municipal code to
require all sites listed in the housing element, all
projects utilizing density bonuses, and all projects
demolishing residential dwelling units to meet the
replacement housing requirements of state law
contained in housing element law, density bonus law,
the Housing Crisis Act of 2019 as amended by AB 1218.

Continue to implement state
law for all development
projects subject to
replacement housing
requirements. Adopt
ordinance as part of planned
rezonings by January 31,
2025.

Amend the municipal code to implement
replacement housing obligations.

Complete Complete. The ordinance
amendments were adopted
by the City Council in
January 2025.

Program 4.2: Housing and Neighborhood Preservation

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4.2A Annually communicate with renters through direct
mailing to multi-family apartment buildings and
through the City’s website, resources available to
renters, including expectations for housing quality and steps to take for suspected substandard housing
conditions.

Initiate in 2025 and annually
thereafter.

Prepare relevant information, provide to
all renters by mail, and post online,
implement best outreach approaches to
communicate with renters.

Ongoing Ongoing. Website updated
with additional tenant
resources in December
2025. First mailers sent in
Winter 2025/2026.

4.2B In response to any complaint about substandard
housing received by the City’s Code Enforcement
Program, staff will provide information to the resident or homeowner about the City’s Rehabilitation Program
and conduct residential code inspections to determine
if the property is substandard in accordance with PAMC

16.40.020 and the state Housing Code. If the property is substandard, the City will begin code enforcement
action.

Ongoing. Staff will respond to any complaints
received, conduct code inspections of all
reported units, provide access to relevant
information, and, when necessary,
connect the complainant with mediation
services offered by the City through a
contract provider, or undertake
enforcement action, as appropriate.

Ongoing Ongoing/Standard
Operations. The City
responds to complaints
received as appropriate and
partners with a non-profit
service provider to offer
mediation services.

4.2C The City will conduct increased outreach to increase awareness of housing resources, fair housing
workshops, and tenant protection. Specifically, the City will conduct at least one fair housing workshop
annually for community-based organizations that serve
residents and housing providers in areas of the City
with the highest number of substandard housing
complaints to Code Enforcement. Non-profit partners
provide fair housing information and advice to
individual tenants.

Ongoing and annually, with
first workshop to occur by
December 2024.

Disseminate information to the public to
increase the awareness of support for
tenant protections with the goal of
reaching at least five new households
annually. The City will engage with
community-based organizations to gauge
the effectiveness of the workshops. If new
households are not reached, City will
increase outreach efforts.

Ongoing Ongoing/Standard
Operations. The City held an
Affordable Housing and
Housing Resources Fair on
May 17, 2025. The City also
held workshops to provide
housing resources
throughout the year, in part
through contract with non-
profit service providers.

4.2D The City will develop options for limiting short-term rentals in all areas of the City to ensure housing stock is used for long-term rentals. Strategies to evaluate
include prohibiting short-term rentals (no less than 30 days allowed), limiting the number of days the unit can be used for short-term rentals, prohibiting short-term
rentals in all multi-unit dwellings, allowing for short- term rentals only if the property is the owner’s primary residence, and benchmarking the number of short-term
rentals allowed to no more than a specific percentage
of the community’s rental housing stock
Initiate study of short-term
rentals in 2025 and determine
impact on City housing
supply. Adopt ordinance by
July 1, 2027 to limit short-
term rentals as required to
minimize impacts on
properties available for long-
term use.

In Progress In Progress. Project scoping
initiated in Q4 2025.

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4.2E The City will evaluate the feasibility of adding
regulations to incentivize the use of housing units for residential purposes to support retention of housing
stock.

Initiate study of short-term
rentals in 2025 and determine
impact on City housing
supply. Adopt ordinance by
July 1, 2027 to limit short-
term rentals as required to
minimize impacts on
properties available for long-
term use.

Amend the municipal code to codify
regulations limiting short-term rentals.

In Progress In Progress. Project scoping
initiated in Q4 2025.

Program 4.3: Home Rehabilitation

4.3A Continue to work with home rehabilitation
organizations to assist qualifying low-income
homeowners with home rehabilitation projects.

Ongoing Ongoing/Standard
Operations. The City
continues to partner with
home rehabilitation
organizations to support
home repair needs of low-
income homeowners.

4.3B Develop CDBG outreach program to educate residents about opportunities for services, such as RV parking and rental assistance regarding mediation.

Develop program by
December 2026. The City’s
partnership with home
rehabilitation organizations is
ongoing.

Disseminate information to the public to
increase the awareness of support for
home rehabilitation with the goal of
reaching at least five new households
annually.

Pending Pending/Not Started.

4.3C Annually dedicate CDBG funds as available to support the City’s Rehabilitation Program; seek additional
funding to supplement CDBG funding to expand the
program and recipients to households above low-
income levels.

Annually budget CDBG funds
for City’s Rehabilitation
Program.

Participate and remain in good standing
with the CBDG program, with the goal of
providing funding to support the
rehabilitation of at least five homes
annually
Ongoing Ongoing/Standard
Operations. The City
continues to partner with
home rehabilitation
organizations to support
home repair needs of low-
income Palo Alto
homeowners and monitors
availability of funds to
support households at other
income levels.

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4.3D City will conduct increased outreach to increase
awareness of CDBG funds and availability of said funds.

The City will conduct one CDBG workshop annually to
disseminate information regarding program
requirements and availability of funds. The City will also update their website annually with information on the
program.

Ongoing and annually, with
first workshop to occur by
December 2024 and website
updated after adoption of
each CDBG budget.

Disseminate information to the public to
increase the use of available CDBG funds
with the goal of supporting the
rehabilitation of at least 5 homes
annually. Market home rehabilitation
program opportunities as part of Housing
Resources Fair. Continue to update the
new Housing Portal on the City’s website.

Ongoing Ongoing/Standard
Operations. The City
conducts annual outreach
and workshops to increase
awareness of availability of
CDBG funds. A CDBG pre-
proposal conference
occurred on November 14,
2025 for those interested in
the notice of funding
availability issued by the
City..

Program 4.4: Seismic Retrofit

4.4A Amend the City’s seismic hazards identification
program to strengthen regulations and require seismic
upgrades of vulnerable housing stock through a
combination of mandatory provisions and voluntary
incentives.

Initiate effort in 2024 begin
outreach in 2025, complete
by 2026.

Amend the City’s seismic regulations to
advance implementation objective,
including a compliance schedule for
approximately 130 soft-story multi-family
buildings in Palo Alto located near
Downtown, Midtown and the Ventura
neighborhood, along California Avenue,
College Terrace, San Antonio Road, and
elsewhere.

In Progress In Progress. The project
team began work on
ordinance and program
update in May 2025. The
update is expected to be
completed in 2026, with
phased implementation.

Program 4.5: Encourage Local Hiring

4.5A Develop local labor program list. Establish and post a list of local labor unions and apprenticeship programs
on City’s website and encourage developers and
contractors to hire local labor.

Establish list by December 31,
2026.

Develop local labor program list. Pending Pending/Not Started.

PROGRAM 5: AT-RISK HOUSING
Program 5.1: Preservation of At-Risk Housing

5.1A Monitor the status of the 72 units at high risk of conversion to market rate units during the planning
period and seek to preserve these affordable units at
their existing affordability levels.

Monitor annually. Track the status of units with high risk of conversion to market-rate to preserve
affordability for extremely low and very
low income households.

Ongoing Ongoing/Standard
Operations. The City
continually monitors status
of units at high risk of
conversion.

5.1B Provide direct notification to property owners and tenants of low-income deed restricted housing units of
the state requirement to notify affected households
about the termination of the affordability restrictions at six and twelve months, and three years.

Twice during the reporting
period, once in 2024 and
again in 2028.

Mail requirements to qualifying property
owners as specified.

In Progress In Progress. First mailing
completed. Second mailing
scheduled for 2028.

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5.1C Inform property owners of their obligation to comply with noticing requirements stipulated under state law
to ensure that qualified nonprofit entities from the
State’s qualified entities list are informed of the
opportunity to acquire the affordable property and that tenants are informed about their rights and potential
resources.

Send notice to property
owner three years prior to
potential project conversion.

Provide follow-up with
contacts one years and six
months prior to conversion if
property owner fails to
comply.

Ensure qualified non-profit entities are
notified of acquisition opportunities and
to ensure tenants are aware of the
impending changes.

Ongoing Ongoing/Standard
Operations. Staff continually
monitors affordable units
that are at-risk of conversion
and will send notice as
necessary.

5.1D Contingent on funding availability, in the event that a property is scheduled for conversion, contact property
owner regarding funding availability. If the property
owner intends to sell the property encourage sale to a
qualified non-profit entity.

Inform property owner three
years prior to potential
project conversion whether
funding is available to
preserve the affordability
restrictions.

Incentivize the sale to a qualified non-
profit entity.

Ongoing Ongoing/Standard
Operations. Staff continually
monitors affordable units
that are at-risk of
conversion.

5.1E Continue to engage with HUD and the property owner of 4230 Terman Drive (Terman Apartments) with 72
affordable housing units at risk of conversion to market rate units during the housing cycle to explore
opportunities for continued affordability. At present,
the owners have no intention to sell the project or
transfer the affordable units out of the Section 8
contract, based on correspondence with a HUD
representative on September 14, 2022.

Initiate conversation in 2024. Preserve 72 affordable housing units that are at risk of conversion.

In Progress In Progress. Conversations
with HUD and property
owner were initiated in
2024.

Program 5.2: Water and Sewer Suppliers

5.2A Provide a copy of the adopted 2023-31 Housing
Element to the City’s Utility Department, which
provides water and sewer service to the City.

Within 30 days of adoption. Update Utilities Department Rules and Regulations.

Complete Complete. The certified
Housing Element has been
shared with the City's Utility
Department following HCD
certification in August 2024.

PROGRAM 6: FAIR HOUSING
Program 6.1: Housing for Persons with Special Needs

6.1A For extremely low-income housing units, update the City’s affordable housing guidelines to establish
preferences for populations with special needs in those units.

Adopt revised guidelines by
December 31, 2024.

Complete Complete. Affordable
housing guidelines have
been updated to include
preferences for populations
with special needs in
extremely low-income
housing units.

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6.1B Contract with and financially support non-profit
services providers through the Community
Development Block Grant program, such as the
Opportunity Center, that help meet the supportive
services needs of the City’s diverse community,
especially those with extremely low incomes.

Starting in 2023 and annually
thereafter, as funds are
available.

Support the Opportunity Center with the
goal of providing services to 50 low-
income households during the planning
period.

Ongoing Ongoing/Standard
Operations. The City
continues to contract with
multiple organizations
through the Community
Development Block Grant
program to provide
supportive services to
residents.

6.1C In order to assist in the housing needs for special needs populations, the City will facilitate the development of housing for persons with disabilities through incentives including streamlined processing, scoring priorities in future Notices of Funding Availability, and/or direct
subsidies drawing from City affordable housing funding
such as CDBG, HOME, Affordable Trust fund, and other
State/federal funding sources for affordable housing
development with services, resources, and assistance:
a) Establish procedures by June 2024 in Notice of Funds Available (NOFA) that create incentives for the
development of various types of housing units,
including units for persons with disabilities and seniors, such as bonus points or preference for special needs
housing. b) Annually engage with housing stakeholders
and housing providers, on the identification of needs
and new solutions, including lessons learned from the
operators of the City’s recently approved AB2162
housing project for persons with disabilities. c) Partner with the County and other agencies to pursue funding
sources, such as County Measure A funds, designated
for housing for special needs groups, including persons with disabilities.

Conduct outreach to housing
providers and County starting
in 2024 and annually
thereafter. Prepare a NOFA in
2024 and review annually
thereafter based on adequate
availability of funds.

Meet annually with housing service
providers and the Santa Clara County
representatives to identify opportunities
to further support special needs
populations. Develop at least 5 units
annually for a total of 40 housing units for
special needs households
Ongoing Ongoing/Standard
Operations. The 525 East
Charleston project, which
includes 50 affordable
housing units, including 25
dedicated to residents with
special needs is anticipated
to be operational in 2025.

The City is also actively
working with the County
Housing Authority on the
Buena Vista Redevelopment
Project. Charities Housing is
anticipated to begin
construction of the 3001 El
Camino Real affordable
housing project in winter
2025. The City committed $5
million in funding in
Janurary, 2025.

6.1D Continue to implement the Municipal Code and
facilitate requests for reasonable accommodation to
land use decisions and procedures regulating the siting, funding, development, and use of housing for people
with disabilities.

Annually report on
reasonable accommodation
requests received, and their
outcomes, in the Annual
Progress Report.

Support the development of additional
housing opportunities for those with
disabilities.

Ongoing Ongoing/Standard
Operations.

Program 6.2: Family Housing and Large Units

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6.2A Research and implement incentives to encourage larger units, such as FAR exemptions for three or more
bedroom units, and creation of family-friendly design
standards. Meet with housing stakeholders and
conduct public hearings before the Planning and
Transportation Commission to receive public and
commissioner input on ways to achieve stated
objective. Make recommendations to Council and
follow up with an ordinance to effect a change in local zoning regulations as directed.

Support additional
development of large housing
units in areas with larger
concentrations of
overcrowding (along
Embarcadero Road northeast
of Highway 101 and south of
Alma Street) through code
amendments that incentive
large family housing units and
family-friendly designs, with
the goal of a housing stock
where large units comprise 10
percent of all new rental
units.

Initiate study of possible incentives by
June 2025 and adopt recommended
actions by June 2026.

Complete Complete. In March 2025,
following staff analysis and
Planning and Transportation
Commission public hearings
and feedback, the City
Council approved
modifications to the Housing
Incentive Program
ordinance, including a
provision incentivizing larger
units that can accommodate
families by allowing
density/floor area ratio
increases for "family-friendly
units" consisting of three or
more bedrooms.

Program 6.3: Middle Housing Program

6.3A Increase the floor area limitation from 800 to 1,200 square feet per unit for SB 9 projects that result in
creation of three or more detached units on a single-
family lot. Refine objective design standards and
development standards based on experience with
project applications.

Initiate by 2025, complete by
December 2026.

Development of 40 net new units, other
than ADU development, on single-family
zoned lots in racially concentrated areas
of affluence during the planning period
Pending Pending.

6.3B Prioritize adoption of development standards that
support smaller-scale “missing middle” development
when implementing Programs 1.1, 3.4, 3.5, and 3.6
See timeframes for
referenced programs
Development of 40 net new units in
smaller-scale development projects in
racially concentrated areas of affluence.

Ongoing Ongoing/Standard
Operations.

Program 6.4: Homelessness Program

6.4A Expand geographic and service areas of the City’s Safe Parking Program. Research the feasibility and extend
the safe parking program to City parks, parking lots and commercial lots. Expand program services to include
case management and explore opportunities to provide
supervised access to City facilities.

Initiate by 2026, complete by
December 2028.

Support the City’s existing population
living in vehicles by annually moving 40
percent of individuals using Safe Parking
to housing as it becomes available.

Pending Pending/Not Started.

6.4B Create a social services directory and make it available to residents at public counters, on the City website, and at Safe Parking areas.

Complete by December 2023. Complete Complete. A Social Services directory was created in
2023 and has been widely
distributed.

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6.4C Expand the City’s homeless prevention program to
include renter protections, including security deposit
limits, eviction reductions and financial assistance for utilities. Identify funding sources, such as Human
Services Resource Allocation Process (HSRAP) funds to
support households at risk of homelessness; engage
with homelessness stakeholders, conduct hearings
before the Planning and Transportation and City
Council and make recommendations to support
objective; implement based on available funding.

Initiate code amendments in
2023 and complete by June
2024.

Adopt new renter protection ordinances
to advance objective.

In Progress In Progress. HSRAP's priority
of needs funding categories
continues to include
homeless services (including
prevention) and for the
FY26/27 RFP added Housing
Support Services as an
allowable funding category.

FY26/27 HSRAP funding was
provided to five
organizations servicing the
unhoused for a total HSRAP
investment of $289,865.

Complete (code
amendments). Ongoing
(funding source
identification).

6.4D Continue to pursue the Homekey Palo Alto at 1237 San Antonio Road for use as a temporary bridge housing
facility to provide accommodations for individuals who
are actively engaged in services leading to permanent
housing. Engage with stakeholders, including the State
Department of Housing and Community Development,
LifeMoves, Santa Clara County Office of Supportive
Housing, and the Santa Clara County Housing Authority.

Continue engagement efforts
on an ongoing basis
throughout the planning
period.

Advance the project and ensure robust
uptake by engaging in ongoing outreach
to the unhoused, ensuring support
services, connectivity, and transitional
housing for, at a minimum 88 households
annually.

In Progress In Progress. The City is
working with key
stakeholders and its
homeless outreach team to
develop an outreach plan to
ensure robust uptake of the
new facility when it opens in
2026.

6.4E Explore and implement, where feasible, additional
opportunities for Homekey funding or other similar
funding sources to convert hotels to permanent or
interim housing for persons experiencing homelessness
or at risk of homelessness. Work with stakeholders to
identify additional funding opportunities and locations to support homelessness population and those at risk
of homelessness.

Ongoing Ongoing Ongoing/Standard
Operations. The City
regularly accesses suitability
of new sources of funding to
support the homeless
population and those at risk
of homelessness.

Program 6.5: Alternate Housing

6.5A Coordinate with HIP Housing or similar house sharing services to provide shared housing arrangements.

Identify opportunities to extend home sharing services
to Palo Alto and promote on the City’s website as
appropriate
Initiate conversations in 2024. In Progress In Progress. Discussions have been initiated
regarding shared housing
arrangements in the City.

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6.5B Allow innovative housing structures, such as micro-unit housing and new shared and intergenerational housing
models, to help meet the housing needs of aging adults, students, and lower-income individuals citywide. Meet
with housing stakeholders and conduct public hearings
before the Planning and Transportation Commission to
receive public and commissioner input on ways to
achieve stated objective. To the extent that density
presents a constraint on development of alternative
housing types, identify sites where elimination of
maximum dwelling units per acre is appropriate.

Because impact fees assessed per unit inordinately
impact alternative housing types, adjust fees to apply to square footage. Make recommendations to Council and
follow up with an ordinance to effect a change in local zoning regulations as directed.

Initiate study of alternative
models in 2024 and present
initial findings in 2025 to
Commission, public, and
stakeholders. Adopt
ordinance revisions as
appropriate before December
31, 2026. Adjust fees to apply
by square footage, to
encourage alternative
housing types, in Fall 2024
In Progress In Progress. The project
team completed the existing
conditions analysis and
recommended alternatives
in December 2025. These
alternatives will be
presented to the Planning
and Transportation
Commission in early 2026.

6.5C Amend the PAMC to include group homes by right in all residential zones. Include a set of objective standards to provide certainty to applicants through the permitting
process.

Adopt ordinance
amendments by June 2025.

Complete Complete. The ordinance
amendments were adopted
by the City Council in
January 2025.

6.5D Amend the PAMC to be consistent with Government
Code Sections 65650 et seq., which require that
Supportive Housing meeting the standards in the
statute be treated as a by-right use where multifamily
and mixed uses are permitted, including nonresidential
zones permitting multifamily uses. Amendments will
also be made to allow transitional and supportive
housing, as defined in Government Code Section 65582,
to be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same
type in the same zone.

Adopt ordinance
amendments by January 2025
Complete Complete. The ordinance
amendments were adopted
by the City Council in
January 2025.

6.5E Amend the PAMC to be consistent with Government
Code sections 65660 et seq., which require a Low
Barrier Navigation center to be a use by-right in areas zoned for mixed-use and nonresidential zones
permitting multifamily uses, provided specific
requirements of the law are met.

Amend by January 2025 Complete Complete. The ordinance amendments were adopted
by the City Council in
January 2025.

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6.5F Amend the PAMC parking regulations for Homeless and Emergency Shelters and Navigation Centers to comply
with Government Code section 65583, subdivision
(a)(4)(A). Allow emergency shelters in the ROLM(E)
zone to be approved ministerially, without discretionary action, remove distance requirements, adjust length of
stay requirements, and ensure that the development
standards for shelters are in compliance with statutory requirements
Amend by January 2025 Complete Complete. The ordinance amendments were adopted
by the City Council in
January 2025.

6.5G Amend the PAMC zoning code to ensure compliance
with the Employee Housing Act (including California
Health and Safety Code sections 17021.5, 17021.6, and
17021.8) to state that farmworker housing up to 36
beds or 12 units are to be permitted as an agricultural use and therefore “by right” in the AC and OS zones and no discretionary permit would be required of employee
housing providing accommodation for six or fewer
employees if discretionary permits are not required of a family dwelling of the same type in the same zone.

Amend by January 2025 Complete Complete. The ordinance amendments were adopted
by the City Council in
January 2025.

Program 6.6: Fair Housing

6.6A Distribute educational materials to property owners, apartment managers, and tenants relative to fair
housing requirements, regulations, and services via
public counters, the City’s website, social media,
community announcements and in response to
telephone inquires. Provide materials in English,
Spanish, and Chinese.

Initiate first distribution by
May 31, 2024 and implement
annually thereafter.

Outreach to 100 residents, housing
providers, and housing professionals.

Prioritize neighborhoods with lower
income residents and cost burdened
renters, including at least 20 individuals in
South Ventura and North of Downtown,
adjacent to Menlo Park.

Ongoing Ongoing/Standard
Operations. The City has
contracted with a fair
housing services
organization to conduct
outreach and distribute
materials. The City also held
a Housing Fair on May 17,
2025 to provide housing
resources.

6.6B City will require affirmative marketing of all residential projects and will require developers to advertise to
under-represented, socio-economically sensitive
communities (as defined in Appendix C, AFFH Analysis)
along Alma Road to indicate the availability of housing units that meet affordable housing requirements.

Develop policy and initiate by
May 31, 2024.

Inclusion of marketing materials as a
condition of residential permit approvals
Citywide.

Complete Complete. Where
applicable, affirmative
marketing of affordable
housing units in residential
projects is required as a
condition of approval.

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6.6C Prepare an area plan for the San Antonio Road Corridor, including the ROLM/GM Focus Area. Collaborate with
local organizations and residents to facilitate
neighborhood planning that integrates housing with
safe multi-modal transportation and provides access to
amenities, parks and open space, placemaking
improvements, and mitigations for environmental
impacts.

Initiate work on area plan by
December 31, 2024.

Improve assets in areas of lower
opportunity and in areas projected for
growth in lower income housing, along
the San Antonio Road corridor.

In Progress In Progress. Phase 1 of
project wrapping up in
October 2025. Alternatives
will be presented to the
community in 2026. Plan
anticipated to be adopted in
early 2028.

6.6D Provide public announcements, via different media
(e.g., social media, newspaper ads, and public service
announcements at local radio and television channels)
related to fair housing programs and opportunities for
Palo Alto residents. Public announcement will be
provided in English, Spanish, and Chinese.

Initiate in January 2024 and
biannually thereafter.

Provide biannual announcements during
the planning period.

Ongoing Ongoing/Standard
Operations. The City has
contracted with a fair
housing services
organization to support the
public awareness of related
programs and opportunities
through multilingual
announcements.

6.6E Partner with non-profit service providers to conduct random compliance testing of rental properties in
South Ventura at least twice per year during the
planning period. Refer individuals to State Fair
Employment and Housing, HUD Fair Housing and Equal
Opportunity division, and other legal services as
appropriate
Ongoing; maintain contract
with non-profit service
providers.

Aim to reduce fair housing complaints by
approximately 10 percent annually in the
years following implementation of this
program.

Ongoing Ongoing/Standard
Operations. The City has
contracted with a non-profit
service provider to conduct
compliance testing.

6.6F Allocate annual funding for fair housing services
through the Action Plan process for the use of CDBG
funds.

Annually as part of the CBDG
update.

Ongoing Ongoing/Standard
Operations. The City
continues to allocate CDBG
funding to fair housing-
related service providers.

6.6G Continue to require mixed-income developments
accessible to lower income residents citywide,
especially in high opportunity and resource-rich areas
through use of the City’s Below Market Rate (BMR)
requirements. Continue to give priority for use of
Housing Trust Funds, development of city-owned
properties, and use of grant funding for housing to
projects located in high opportunity and resource-rich
areas. Pursue additional funding sources, such as State grants.

Ongoing as housing projects
are proposed and City
prepares notices of grant
funding.

Support the development of 1,556 units
for very-low income, and 896 units for
low-income households in high
opportunity and resource-rich during the
planning period.

Ongoing Ongoing/Standard
Operations. The City
continues to enact its Below
Market Rate Housing
requirements city-wide. In
2025, the City committed
funding for a new
construction affordable
development in a High
Resource area and advanced
affordable housing
development opportunities
on a city-owned High
Resource-designated site.

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6.6H In addition to existing funding, develop or identify a source for the City to provide expanded funding to non- profit service providers. Ongoing and expanded funding
will support efforts to address housing discrimination in the City, to conduct site tests, and to educate the
general public on fair housing issues.

Identify and, if applicable,
prepare an application for
new funding by Fall 2024.

Goal for expanded funding to reach an
additional 20 residents annually.

Ongoing Ongoing/Standard
Operations. The City
continues to monitor
available funds and apply as
applicable, such as for the
HCD Encampment
Resolution Funding.

6.6I Adopt tenant protections to prevent anti-displacement including the following: eviction reduction; rental
registry program; security deposit limit; right to
counsel. Specific proposals include: Fair Chance
Ordinance for persons with criminal records, self-
funded rental registry and survey program; expanding
AB 1482 protections to apply to new construction and
limiting security deposits 1.5x of monthly rent for
unfurnished units. Local relocation assistance
requirements were significantly expanded in 2022.

Begin implementation in
December 1, 2023 with
implementation completed
by the following dates: June
2024 (Fair Chance Ordinance,
rental registry program,
eviction reduction and
security deposit limit
legislation) and December
2027 (right to counsel)
Develop a database for tracking tenant
displacement and evictions to establish
baseline, trends, and develop policies that
would reduce unjust evictions.

In Progress In Progress. A security
deposit limit of 1.5x of
monthly rent was adopted
by the City Council in 2023.

Just cause eviction
protections were enacted by
the City Council in 2023. The
City's Rental Registry
Program implementation
began in 2024; Program Year
1 (FY 2024-2025) completed
and launch of Program Year
2 (FY 2025-2026)
commenced; the Rental
Registry Program now
operates on an ongoing
basis and can now be used
for tracking tenant
displacement and evictions
to establish a baseline,
trends, and to develop
policies that would reduce
unjust evictions. Staff
received direction on a draft
Fair Chance in Housing
Ordinance in April 2025.

Staff is tracking regional
work on right to counsel-
related topics on an ongoing
basis.

6.6J As state law permits, require a 90-day notice for a rent increase of 6% instead of the State’s 10% threshold for noticing. Provide educational materials to landlords and tenants as part of Programs 6.6 A, B, D, and L.

Begin implementation in
December 1, 2023, with
legislation adopted by June
2024.

Pending On Hold. Currently, State
law does not permit the City
to change its noticing
requirements.

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6.6K Promote Housing Choice Vouchers to support housing mobility by educating landlords about income
discrimination (i.e., Cannot post “NO Section 8” on
applications), with a goal to increase acceptance of
Housing Choice Vouchers in high opportunity and high
resource areas. Include educational materials as part of Programs 6.6 A, B, D, and L.

Ongoing Assist 200 households annually or the
number of vouchers allocated under the
housing choice voucher program,
including project-based vouchers
Ongoing Ongoing/Standard
Operations. The City has
completed mailings and
provided workshops to
further educate landlords
about income
discrimination.

6.6L Work with non-profit service providers and renter
organizations to conduct an annual workshop in the
South Ventura and Downtown North neighborhoods to
educate tenants and landlords about fair housing
requirements.

Ongoing, annually. Aim to reduce fair housing complaints by educating at least 20 tenants and
landlords annually
Ongoing Ongoing/Standard
Operations. The City has
contracted with a fair
housing services
organization to educate
tenants and landlords
throughout the year. This
includes multiple workshops
for tenants and landlords
regarding fair housing
requirements.

6.6M Work with non-profit service providers to respond to complaints of discrimination (i.e. intaking, investigation of complaints, and resolution) within 3 days and follow up with information on the resources and services
available through fair housing services.

Ongoing. Aim to reduce fair housing complaints by
ensuring timely attention to complaints.

Ongoing Ongoing/Standard
Operations. The City has
contracted with a fair
housing services
organization to respond to
discrimination complaints
and provide mediation
services.

6.6N Educate tenants and landlords about their rights and responsibilities related to relocation assistance required by the City or state law in the event of an owner move- in, Ellis Act eviction, or property redevelopment.

Conduct one workshop for tenants and one workshop
for landlords annually, in multiple languages
Annually. Aim to educate at least 20 tenants and
landlords annually.

Ongoing Ongoing/Standard
Operations. The City
continues to contract with a
fair housing services
organization that educates
tenants and landlords
throughout the year. This
includes multiple workshops
for tenants and landlords.

6.6O Enforce relocation payment required through
imposition of liens in cases where landlords fail to pay required assistance.

Ongoing Establish a complaint tracking system by
June 2024 through Code Enforcement
with a goal of minimizing complaints
through outreach and education and of
ensuring that all tenants receive required
relocation payments
Ongoing Ongoing/Standard
Operations. A complaint
tracking system through
Code Enforcement is in
place.

Program 6.7: Community Outreach Program

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6.7A Partner with Human Services for community outreach with a focus on additional engagement to traditionally
underrepresented groups. Meet with Human Services
representatives bi-annually to formulate strategies
aimed at engaging the City’s most vulnerable
populations located in areas with lower income
households, particularly along Alma Street and
Embarcadero Road northeast of Highway 101.

Bi-annually; initiate first
meeting by January 2024.

Reach at least 20 households annually
through work with Human Services.

Ongoing Ongoing/Standard
Operations. The Planning
and Development Services
Department regularly
communicates with the
Human Services team.

Collaborative events are
held to engage the City's
most vulnerable
populations. A Resource Fair
for low income and
unhoused individuals was
held in June 2025.

6.7B The City shall continue to facilitate opportunities for all residents and stakeholders to provide meaningful and
effective input on proposed planning activities early on and continuously throughout plan development and
the public review process. Outreach efforts to
disadvantaged communities, , particularly areas with
higher poverty rates (University Avenue and Downtown
North, and South Ventura neighborhood) and areas
designated as moderate resource (along Embarcadero
Road northeast of Highway 101) will be a priority.

Engagement materials will be made available in
multiple languages and the City will ensure that all
public meetings are in locations accessible to all
persons.

Ongoing. Increase public participation rates
amongst City’s underrepresented groups
by at least 20% by the end of the planning
period.

Ongoing Ongoing/Standard
Operations. The City widely
distributes materials for
outreach efforts in multiple
languages.

6.7C Create a website that provides relevant housing
application and processing information to the home
building community.

Complete by June 30, 2024
and update annually.

Support the development of 1,556 units
for very-low income, 896 units for low
income, 1,013 units for moderate income,
and 2,621 above-moderate households
during the planning period.

Ongoing Ongoing/Standard
Operations. Housing
application and processing
information is posted on the
City's website and is
updated regularly.

6.7D Promote general awareness of lower-income housing
availability by providing the location, type, and contact information of housing developments in the City on the
website.

Complete by January 15, 2024
and update annually
Promote availability of lower-income
housing opportunities to lower-income
residents concentrated along Alma Street
and Embarcadero Road northeast of
Highway 101.

Ongoing Ongoing/Standard
Operations. Information
about lower-income housing
developments is posted on
the City's website and
updated regularly.

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6.7E Develop language accessibility improvements to ensure residents with limited English proficiency have access to housing information.

Complete policy by January
15, 2025 and full
implementation by December
31, 2025.

Promote housing opportunities to limited
English proficiency residents.

In Progress In Progress. Policies have
been developed to expand
language accessibility
improvements for housing
information.

Implementation of these
improvements will continue
in 2026.

Palo Alto City CouncilMarch 2, 2026

Palo Alto City Council
March 2, 2026