Palo Alto City Council
March 16, 2026

used to purchase the alcohol.

Note: U.S. General Services Administration regulations define light refreshments for morning, afternoon or evening breaks to include, but not be limited to, coffee, tea, milk, juice, soft drinks, donuts, bagels, fruit, pretzels, cookies, chips, or muffins. (41 CFR 301-74.7)

FOR STATE CONTINUING ENVIRONMENTAL PROGRAM GRANT RECIPIENTS EXCLUDING STATE UNIVERSITIES:

If the state maintains systems capable of complying with federal grant regulations at 2 CFR 200.432 and 200.438, EPA has waived the prior approval requirements for the use of EPA funds for light refreshments and/or meals served at meetings, conferences, and training, as described above. The state may follow its own procedures without requesting prior approval from EPA. However, notwithstanding state policies, EPA funds may not be used for (1) evening receptions, or (2) other evening events (with the exception of working meetings). Examples of working meetings include those evening events in which small groups discuss technical subjects on the basis of a structured agenda or there are presentations being conducted by experts. EPA funds for meals, light refreshments, and space rental may not be used for any portion of an event (including evening working meetings) where alcohol is served, purchased, or otherwise available as part of the event or meeting, even if EPA funds are not used to purchase the alcohol.

By accepting this award, the state is certifying that it has systems in place (including internal controls) to comply with the requirements described above.

36. Tangible Personal Property

36.1 Reporting Pursuant to 2 CFR 200.312 and 200.314, property reports, if applicable, are required for Federally-owned property in the custody of a non-Federal entity upon completion of the Federal award or when the property is no longer needed. Additionally, upon termination or completion of the project, residual unused supplies with a total aggregate fair market value exceeding $5,000 not needed for any other Federally-sponsored programs or projects must be reported. For Superfund awards under Subpart O, refer to 40 CFR 35.6340 and

35.6660 for property reporting requirements. Recipients should utilize the Tangible Personal Property Report form series (SF-428) to report tangible personal property.

36.2 Disposition

36.2.1 Most Recipients. Consistent with 2 CFR 200.313, unless instructed otherwise on the official award document, this award term, or at closeout, the recipient may keep the equipment and continue to use it on the project originally funded through this assistance agreement or on other federally funded projects whether or not the project or program continues to be supported by Federal funds.

36.2.2 State Agencies. Per 2 CFR 200.313(b), state agencies may manage and dispose of equipment acquired under this assistance agreement in accordance with state laws and procedures.

36.2.3 Superfund Recipients. Equipment purchased under Superfund projects is subject to specific disposal options in accordance with 40 CFR Part 35.6345.

37. Dual Use Research of Concern (DURC)
The recipient agrees to conduct all life science research* in compliance with EPA’s Order on the Policy and Procedures for Managing Dual Use Research of Concern (EPA DURC Order) and United States Government Policy for Institutional Oversight of Life Sciences Dual Use Research of Concern (iDURC Policy). If the recipient is an institution within the United States that receives funding through this agreement, or from any other source, the recipient agrees to comply with the iDURC Policy if they conduct or sponsor research involving any of the agents or toxins identified in Section 6.2.1 of the iDURC Policy. If the institution is outside the United States and receives funding through this agreement to conduct or sponsor research involving any of those same agents or toxins, the recipient agrees to comply with the iDURC Policy. The recipient agrees to provide any additional information that may be requested by EPA regarding DURC and iDURC. The recipient Docusign Envelope ID: A5DDBF3D-508F-4A93-B75C-D3C7442AFC33 Item 10
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agrees to immediately notify the EPA Project Officer should the project use or introduce use of any of the agents or toxins identified in the iDURC Policy. The recipient’s Institution/Organization must also comply with USG iDURC policy and EPA DURC Order and will inform the appropriate government agency if funded by such agency of research with the agents or toxins identified in Section 6.2.1 of the iDURC Policy. If privately funded the recipient agrees to notify the National Institutes of Health at [email protected]. *“Life Sciences Research,” for purposes of the EPA DURC Order, and based on the definition of research in 40 CFR §26.102(d), is a systematic investigation designed to develop or contribute to generalizable knowledge involving living organisms (e.g., microbes, human beings, animals, and plants) and their products. EPA does not consider the following activities to be research: routine product testing, quality control, mapping, collection of general-purpose statistics, routine monitoring and evaluation of an operational program, observational studies, and the training of scientific and technical personnel. [Note: This is consistent with Office of Management and Budget Circular A-11.]

38. Research Misconduct
In accordance with 2 CFR 200.329, the recipient agrees to notify the EPA Project Officer in writing about research misconduct involving research activities that are supported in whole or in part with EPA funds under this project. EPA defines research misconduct as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results [65 FR 76262. I], or ordering, advising or suggesting that subordinates engage in research misconduct. The recipient agrees to:
(1) Immediately notify the EPA Project Officer who will then inform the EPA Office of Inspector General (OIG) if, at any time, an allegation of research misconduct falls into one of the categories listed below:

A. Public health or safety is at risk.

B. Agency resources or interests are threatened.

C. Circumstances where research activities should be suspended.

D. There is a reasonable indication of possible violations of civil or criminal law.

E. Federal action is required to protect the interests of those involved in the investigation.

F. The research entity believes that the inquiry or investigation may be made public prematurely so that appropriate steps can be taken to safeguard evidence and protect the rights of those involved.

G. Circumstances where the research community or public should be informed. [65 FR 76263.III] (2) Report other allegations to the OIG when they have conducted an inquiry and determined that there is sufficient evidence to proceed with an investigation. [65 FR 76263. III]

39. Scientific Integrity Terms and Conditions
The recipient agrees to comply with EPA’s Scientific Integrity Policy when conducting, supervising, and communicating science and when using or applying the results of science. For purposes of this award condition scientific activities include, but are not limited to, computer modelling, economic analysis, field sampling, laboratory experimentation, demonstrating new technology, statistical analysis, and writing a review article on a scientific issue. The recipient agrees to:

39.1 Scientific Products

39.1.1 Produce scientific products of the highest quality, rigor, and objectivity, by adhering to applicable EPA information quality guidelines, quality policy, and peer review policy.

39.1.2 Prohibit all recipient employees, contractors, and program participants, including scientists, managers, and other recipient leadership, from suppressing, altering, or otherwise impeding the timely release of scientific findings or conclusions.

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39.1.3 Adhere to EPA’s Peer Review Handbook, 4th Edition, for the peer review of scientific and technical work products generated through EPA grants or cooperative agreements which, by definition, are not primarily for EPA’s direct use or benefit.

39.2 Scientific Findings

39.2.1 Require that reviews regarding the content of a scientific product that are conducted by the project manager and other recipient managers and the broader management chain be based only on scientific quality considerations, e.g., the methods used are clear and appropriate, the presentation of results and conclusions is impartial.

39.2.2 Ensure scientific findings are generated and disseminated in a timely and transparent manner, including scientific research performed by employees, contractors, and program participants, who assist with developing or applying the results of scientific activities.

39.2.3 Include, when communicating scientific findings, an explication of underlying assumptions, accurate contextualization of uncertainties, and a description of the probabilities associated with both optimistic and pessimistic projections, if applicable.

39.2.4 Document the use of independent validation of scientific methods.

39.2.5 Document any independent review of the recipient’s scientific facilities and testing activities, as occurs with accreditation by a nationally or internationally recognized sanctioning body.

39.2.6 Make scientific information available online in open formats in a timely manner, including access to data and non-proprietary models.

39.3 Scientific Misconduct

39.3.1 Prohibit intimidation or coercion of scientists to alter scientific data, findings, or professional opinions or non-scientific influence of scientific advisory boards. In addition, recipient employees, contractors, and program participants, including scientists, managers, and other leadership, shall not knowingly misrepresent, exaggerate, or downplay areas of scientific uncertainty.

39.3.2 Prohibit retaliation or other punitive actions toward recipient employees who uncover or report allegations of scientific and research misconduct, or who express a differing scientific opinion. Employees who have allegedly engaged in scientific or research misconduct shall be afforded the due process protections provided by law, regulation, and applicable collective bargaining agreements, prior to any action. Recipients shall ensure that all employees and contractors of the recipient shall be familiar with these protections and avoid the appearance of retaliatory actions.

39.3.3 Require all recipient employees, contractors, and program participants to act honestly and refrain from acts of research misconduct, including publication or reporting, as described in EPA’s Policy and Procedures for Addressing Research Misconduct, Section 9.C.

Research misconduct does not include honest error or differences of opinion. While EPA retains the ultimate oversight authority for EPA-supported research, grant recipients conducting research bear primary responsibility for prevention and detection of research misconduct and for the inquiry, investigation, and adjudication of research misconduct alleged to have occurred in association with their own institution.

39.3.4 Take the actions required on the part of the recipient described in EPA’s Policy and Procedures for Addressing Research Misconduct, Sections 6 through 9, when research misconduct is suspected or found.

39.4 Additional Resources
For more information about the Scientific Integrity Policy, an introductory video can be accessed at:
https://youtu.be/FQJCy8BXXq8. A training video is available at: https://youtu.be/Zc0T7fooot8.

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Public Policy Requirements

40. Civil Rights Obligations
This term and condition incorporates by reference the signed assurance provided by the recipient’s authorized representative on: 1) EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting EPA Financial Assistance”; and 2) Certifications and Representations in Sam.gov or Standard Form 424D, as applicable.

These assurances and this term and condition obligate the recipient to comply fully with applicable civil rights statutes and implementing federal and EPA regulations.
a. Statutory Requirements
i. In carrying out this agreement, the recipient must comply with:

1. Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, and national origin, including limited English proficiency (LEP), by entities receiving Federal financial assistance.

2. Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination against persons with disabilities by entities receiving Federal financial assistance; and

3. The Age Discrimination Act of 1975, which prohibits age discrimination by entities receiving Federal financial assistance.
ii. If the recipient is an education program or activity (e.g., school, college or university) or if the recipient is conducting an education program or activity under this agreement, it must also comply with:

1. Title IX of the Education Amendments of 1972, which prohibits discrimination on the basis of sex in education programs and activities operated by entities receiving Federal financial assistance. For further information about your compliance obligations regarding Title IX, see 40 CFR Part 5 and https://www.justice.gov/crt/title-ix iii. If this agreement is funded with financial assistance under the Clean Water Act (CWA), the recipient must also comply with:

1. Section 13 of the Federal Water Pollution Control Act Amendments of 1972, which prohibits discrimination on the basis of sex in CWA-funded programs or activities. b. Regulatory Requirements
i. The recipient agrees to comply with all applicable EPA civil rights regulations, including:

1. For Title IX obligations, 40 C.F.R. Part 5; and

2. For Title VI, Section 504, Age Discrimination Act, and Section 13 obligations, 40 CFR Part7.

3. For statutory and national policy requirements, including those prohibiting discrimination and those described in Executive Order 13798 promoting free speech and religious freedom, 2 CFR 200.300.

4. As noted on the EPA Form 4700-4 signed by the recipient’s authorized representative, these regulations establish specific requirements including maintaining compliance information, establishing grievance procedures, designating a Civil Rights Coordinator and providing notices of non-discrimination.
c. TITLE VI – LEP, Public Participation and Affirmative Compliance Obligation i. As a recipient of EPA financial assistance, you are required by Title VI of the Civil Rights Act to provide meaningful access to LEP individuals. In implementing that requirement, the recipient agrees to use as a guide the Office of Civil Rights (OCR) document entitled "Guidance to Environmental Protection Agency Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons." The guidance can be found at:

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https://www.federalregister.gov/documents/2004/06/25/04-14464/guidance-toenvironmental-protection-agency-financial-assistance-recipients-regarding-title-vi ii. If the recipient is administering permitting programs under this agreement, the recipient agrees to use as a guide OCR’s Title VI Public Involvement Guidance for EPA Assistance Recipients Administering Environmental Permitting Programs. The Guidance can be found at: https://www.govinfo.gov/content/pkg/FR-2006-03-21/pdf/06-2691.pdf iii. In accepting this assistance agreement, the recipient acknowledges it has an affirmative obligation to implement effective Title VI compliance programs and ensure that its actions do not involve discriminatory treatment and do not have discriminatory effects even when facially neutral. The recipient must be prepared to demonstrate to EPA that such compliance programs exist and are being implemented or to otherwise demonstrate how it is meeting its Title VI obligations.

41. Drug-Free Workplace
The recipient organization of this EPA assistance agreement must make an ongoing, good faith effort to maintain a drug-free workplace pursuant to the specific requirements set forth in Title 2 CFR Part 1536 Subpart B. Additionally, in accordance with these regulations, the recipient organization must identify all known workplaces under its federal awards, and keep this information on file during the performance of the award.

Those recipients who are individuals must comply with the drug-free provisions set forth in Title 2 CFR Part 1536 Subpart C.

The consequences for violating this condition are detailed under Title 2 CFR Part 1536 Subpart E. Recipients can access the Code of Federal Regulations (CFR) Title 2 Part 1536 at www.ecfr.gov/.

42. Hotel-Motel Fire Safety
Pursuant to 15 USC 2225a, the recipient agrees to ensure that all space for conferences, meetings, conventions or training seminars funded in whole or in part with federal funds complies with the protection and control guidelines of the Hotel and Motel Fire Safety Act (PL 101-391, as amended). Recipients may search the Hotel-Motel National Master List at https://apps.usfa.fema.gov/hotel/ to see if a property is in compliance, or to find other information about the Act.

43. Lobbying Restrictions
a) This assistance agreement is subject to lobbying restrictions as described below. Applicable to all assistance agreements:
i) The chief executive officer of this recipient agency shall ensure that no grant funds awarded under this assistance agreement are used to engage in lobbying of the Federal Government or in litigation against the U.S. unless authorized under existing law. The recipient shall abide by the Cost Principles available at 2 CFR Part 200 which generally prohibits the use of federal grant funds for litigation against the U.S. or for lobbying or other political activities. ii) The recipient agrees to comply with Title 40 CFR Part 34, New Restrictions on Lobbying. The recipient shall include the language of this provision in award documents for all subawards exceeding $100,000 and require that subrecipients submit certification and disclosure forms accordingly.
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shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such expenditure.
iv) Contracts awarded by a recipient shall contain, when applicable, the anti-lobbying provision as stipulated in the Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
v) By accepting this award, the recipient affirms that it is not a nonprofit organization described in Section 501(c)(4) of the Internal Revenue Code of 1986 as required by Section 18 of the Lobbying Disclosure Act; or that it is a nonprofit organization described in Section 501(c)(4) of the Code but does not and will not engage in lobbying activities as defined in Section 3 of the Lobbying Disclosure Act. Nonprofit organizations exempt from taxation under section 501(c)(4) of the Internal Revenue Code that engage in lobbying activities are ineligible for EPA subawards. b) Applicable to assistance agreements when the amount of the award is over $100,000:
i) By accepting this award, the recipient certifies, to the best of its knowledge and belief, that:
(1) No Federal appropriated funds have been or will be paid, by or on behalf of the recipient, to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant, the making of any Federal loan, the entering into of any cooperative agreement, and the extension, continuation, renewal, amendment, or modification of any Federal contract, grant, loan, or cooperative agreement.
(2) If any funds other than Federal appropriated funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, or any employee of a Member of Congress in connection with this Federal grant or cooperative agreement, the recipient shall complete and submit the linked Standard Form -- LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions. (3) The recipient shall require that the language of this certification be included in the award documents for all subawards exceeding $100,000 at all tiers (including subcontracts, subgrants, and contracts under grants, loans, and cooperative agreements) and that all subrecipients shall certify and disclose accordingly.
ii) This certification is a material representation of fact upon which reliance was placed when this transaction was made or entered into. Submission of this certification is a prerequisite for making or entering into this transaction imposed by Section 1352, Title 31, U.S. Code. Any person who fails to file the required certification shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each failure.

44. Recycled Paper
When directed to provide paper documents, the recipient agrees to use recycled paper and double-sided printing for all reports which are prepared as a part of this agreement and delivered to EPA. This requirement does not apply to reports prepared on forms supplied by EPA.

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45. Resource Conservation and Recovery Act
Consistent with goals of section 6002 of RCRA (42 U.S.C. 6962), State and local institutions of higher education, hospitals and non-profit organization recipients agree to give preference in procurement programs to the purchase of specific products containing recycled materials, as identified in 40 CFR Part 247.

Consistent with section 6002 of RCRA (42 U.S.C. 6962) and 2 CFR 200.323, State agencies or agencies of a political subdivision of a State and its contractors are required to purchase certain items made from recycled materials, as identified in 40 CFR Part 247, when the purchase price exceeds $10,000 during the course of a fiscal year or where the quantity of such items acquired in the course of the preceding fiscal year was $10,000 or more. Pursuant to 40 CFR 247.2 (d), the recipient may decide not to procure such items if they are not reasonably available in a reasonable period of time; fail to meet reasonable performance standards; or are only available at an unreasonable price.

46. Trafficking in Persons
a. Provisions applicable to a recipient that is a private entity. i. The recipient, the recipient’s employees, subrecipients under this award, and subrecipients’ employees may not—

1. Engage in severe forms of trafficking in persons during the period of time that the award is in effect;

2. Procure a commercial sex act during the period of time that the award is in effect; or

3. Use forced labor in the performance of the award or subawards under the award. ii. We as the Federal awarding agency may unilaterally terminate this award, without penalty, if the recipient or a subrecipient that is a private entity—

1. Is determined to have violated a prohibition in paragraph a of this award term; or

2. Has an employee who is determined by the agency official authorized to terminate the award to have violated a prohibition in paragraph a of this award term through conduct that is either—
a. Associated with performance under this award; or
b. Imputed to the recipient or subrecipient using the standards and due process for imputing the conduct of an individual to an organization that are provided in 2 CFR Part 180, ‘‘OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement),’’ as implemented by our Agency at 2 CFR Part 1532.
b. Provision applicable to a recipient other than a private entity. EPA may unilaterally terminate this award, without penalty, if a subrecipient that is a private entity— i. Is determined to have violated an applicable prohibition in paragraph a. of this award term; or
ii. Has an employee who is determined by the agency official authorized to terminate the award to have violated an applicable prohibition in paragraph a of this award term through conduct that is either—

1. Associated with performance under this award; or

2. Imputed to the subrecipient using the standards and due process for imputing the conduct of an individual to an organization that are provided in 2 CFR Part 180, ‘‘OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement),” as implemented by EPA at 2 CFR Part 1532. c. Provisions applicable to any recipient.
i. The recipient must inform the EPA immediately of any information received from any source alleging a violation of a prohibition in paragraph a of this award term. ii. Our right to terminate unilaterally that is described in paragraph a and b:

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1. Implements section 106(g) of the Trafficking Victims Protection Act of 2000 (TVPA), as amended (22 U.S.C. 7104(g)), and

2. Is in addition to all other remedies for noncompliance that are available to us under this award.
iii. The recipient must include the requirements of paragraph a of this award term in any subaward made to a private entity.
d. Definitions. For purposes of this award term:
i. ‘‘Employee’’ means either:

1. An individual employed by you or a subrecipient who is engaged in the performance of the project or program under this award; or

2. Another person engaged in the performance of the project or program under this award and not compensated by you including, but not limited to, a volunteer or individual whose services are contributed by a third party as an in-kind contribution toward cost sharing or matching requirements.
ii. ‘‘Forced labor’’ means labor obtained by any of the following methods: the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
iii. ‘‘Private entity’’:

1. Means any entity other than a State, local government, Indian tribe, or foreign public entity, as those terms are defined in 2 CFR 175.25.

2. Includes:
a. A nonprofit organization, including any nonprofit institution of higher education, hospital, or tribal organization other than one included in the definition of Indian tribe at 2 CFR 175.25(b).
b. A for-profit organization.
iv. ‘‘Severe forms of trafficking in persons,’’ ‘‘commercial sex act,’’ and ‘‘coercion’’ have the meanings given at section 103 of the TVPA, as amended (22 U.S.C. 7102).

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City Council
Staff Report
Report Type: ACTION ITEMS
Lead Department: Human Resources
Meeting Date: March 16, 2026
Report #:2603-6090
TITLE
Approval of an Employment Agreement and Adoption of a Resolution Appointing Christopher Jensen as City Attorney at an Annual Salary of $380,000.

RECOMMENDATION
Approve an employment agreement and adopt a resolution appointing Christopher Jensen to the position of City Attorney at an annual salary of $380,000, with additional compensation and benefits as provided in the employment agreement and applicable City compensation plan.

BACKGROUND
The City Council appoints the City’s four Council-Appointed Officers. The appointment of the City Attorney is brought to Council as an action item consistent with the Ralph M. Brown Act.

The City Attorney’s duties are established by the City Charter and Palo Alto Municipal Code (PAMC) section 2.08.120. Key duties include, but are not limited to, the following:
• Advising the City Council, City Manager, boards, commissions, and City officers and departments on legal matters;
• Drafting ordinances, resolutions, agreements, and contracts to be made or entered into by the City, and approving the form of such instruments; and • Prosecuting violations of City ordinances and representing the City in legal actions.

The prior City Attorney, Molly Stump, retired in January 2026 after 14 years of service. On September 9, 20251, the Council-Appointed Officer (CAO) Committee initiated the recruitment process for the next City Attorney. The CAO Committee reviewed three proposals for executive recruitment services and invited all firms to interview. On September 22, 20252, the CAO Committee interviewed two firms and selected Teri Black & Company to lead the recruitment. 1 Council Appointed Officers Committee, September 9, 2025; Report #2508-5124:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=17948 2 Council Appointed Officers Committee, September 22, 2025, Report # 2509-5201:
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The Council on October 6, 2025, received and approved the Council Appointed Officer committee recommendations.

ANALYSIS
Consistent with the CAO Committee direction and City Council action, Teri Black & Company conducted one-on-one stakeholder meetings with the prior City Attorney, the City Manager, and each Council Member to gather input on recruitment materials, desired qualifications, and the recruitment process.

Teri Black & Company then conducted a national recruitment over approximately five weeks.

The recruitment closed on December 14, 2025. As provided in the scope of work, Teri Black & Company conducted supplemental screening interviews of highly qualified applicants and presented the recommended candidate pool to the City Council in closed session on January 15, 2026.

Finalists were invited to interview with the City Council on January 31 and February 1, 2026.

Following the interview process, the City Council selected Christopher Jensen as the preferred candidate. Mr. Jensen accepted a conditional offer of employment, subject to City Council approval of the employment agreement and adoption of the resolution of appointment in open session.

Mr. Jensen currently serves as Assistant City Attorney for the City of Berkeley and has served a cumulative tenure of three years with the City of Berkeley. Mr. Jensen has 20 years of legal experience, including four years serving as City Attorney for the City of Cupertino, where he led resolution of a long-standing dispute with a local developer that resulted in projected payments of approximately $40 million, and negotiated a settlement with the California Department of Tax and Fee Administration that the City of Cupertino estimated avoided approximately $75 million in liability.

In Berkeley, Mr. Jensen was closely involved in the City’s natural gas restriction ordinance, including leading the City’s legal defense of the ordinance in federal court. In private practice, he focused on land use, environmental, and government law at several Bay Area firms, most recently as a Partner at Hanson Bridgett LLP.

Mr. Jensen earned a Juris Doctor (J.D.) from Stanford Law School, graduating with distinction and as a member of the Order of the Coif. Mr. Jensen also holds a Master of Science (S.M.) in Atmospheric Chemistry from the Massachusetts Institute of Technology and a Bachelor of Arts (B.A.) in Environmental Chemistry from the University of California, San Diego, graduating with highest honors.

Mr. Jensen will start employment with the City of Palo Alto on Monday, March 30, 2026.

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FISCAL/RESOURCE IMPACT
The City Attorney position is budgeted within the City Attorney’s Office and is included in the FY 2026 Adopted Budget. If appointed, Mr. Jensen will be paid an annual salary of $380,000 and will receive additional compensation and benefits as provided in the Management and Professional Employees Compensation Plan, as applicable, and the attached employment agreement including a 401(a)-retirement plan account annual contribution of $20,000.

STAKEHOLDER ENGAGEMENT
The CAO Committee and City Council engaged in a public discussion of this item on various dates on CAO Committee and Council agenda meeting dates between September 9, 2025 to February 1, 2026. The employment agreement will be posted on the City Human Resources Department website after City Council approval.

ATTACHMENTS
Attachment A: City Attorney Agreement – Jensen
Attachment B: Resolution Appointing Christopher Jensen
APPROVED BY:

Sandra Blanch, Human Resources Director
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1 EMPLOYMENT AGREEMENT

BETWEEN CITY OF PALO ALTO
AND
CHRISTOPHER D. JENSEN
THIS AGREEMENT is between the City of Palo Alto (“City”), a municipal corporation and chartered city, and Christopher D. Jensen (“Jensen”). It is effective on the latest date next to the signatures on the last page.

This Agreement is entered into on the basis of the following facts:

A. City, acting by and through its City Council (“Council”), desires to employ Jensen as its City Attorney, effective March 30, 2026 or a date thereafter, mutually agreed upon by the parties, when Jensen reports for and begins work, whichever is sooner. The Council’s employment of Jensen is subject to the terms and conditions set forth in this Agreement, and in the Charter and Municipal Code of the City of Palo Alto.

B. Under the Charter, the City Attorney is appointed by the Council and serves at its pleasure. Notwithstanding any provision of the City of Palo Alto Merit System Rules and Regulations or other City regulation or policy, the City Attorney serves at-will, with no expectation of continued employment, and with no right to pre- or post-separation due process or appeal.

C. Jensen desires to be employed by the City as its City Attorney, subject to the terms and conditions in this Agreement, and in the Charter, Municipal Code and other applicable laws.

D. The City and Jensen wish to establish specific terms and conditions relating to compensation and benefits, performance evaluations, and related matters.

BASED UPON THE FOREGOING, THE CITY AND JENSEN AGREE AS FOLLOWS:

1. Employment Start Date. The Council appoints Jensen as City Attorney for an indefinite term to begin on March 30, 2026 or a date thereafter, mutually agreed-upon by the parties, when Jensen reports for and begins work, whichever is sooner (“Employment Start Date”).

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Attachment A - City
Attorney Agreement -
Jensen
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2 Duties of the City Attorney. Jensen will perform the duties of the City Attorney as established in the Charter, the Palo Alto Municipal Code, and by direction of the Council. Jensen agrees to perform these duties consistent with the California Rules of Professional Responsibility governing licensed attorneys and all other applicable federal, state and local laws, ordinances, rules and regulations.

Full Energy and Skill. Jensen will devote his full energy, skill, ability, and productive time to the performance of his duties under this Agreement.

No Conflict. Jensen will not engage in any employment, activity, consulting service, or other enterprise, with or without compensation, that is actually or potentially in conflict with, or that interferes with, the performance of the City Attorney’s duties. Jensen acknowledges that he is subject to applicable conflict of interest requirements in state law, the California Rules of Professional Responsibility, and local law and policy.

1.1. Uncompensated Professional Activities. Jensen may attend and/or participate in uncompensated appropriate professional activities, provided that these activities do not compromise or impair Jensen’s ability to perform the City Attorney’s duties as set forth in this Agreement. Jensen shall keep the Council informed of professional activities requiring absences of more than one day and activities requiring more than de minimis time and attention. This Section shall not be interpreted to limit the City Attorney’s ability to participate in professional organizations with purposes germane to the practice of municipal law and related fields (e.g., California League of Cities City Attorneys Department).

Compensation and Benefits. Jensen shall receive the following compensation and benefits:

1.1. Initial Compensation. Beginning on and continuing from the Employment Start Date, Jensen will receive a base salary of Three Hundred and Eighty Thousand dollars ($380,000), prorated and paid on the City’s normal paydays. This salary is subject to authorized or required deductions and withholding. Jensen acknowledges that he is an exempt employee under applicable wage and hour law and his base salary is compensation for all hours worked.

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3 1.1. Compensation Adjustments. Commencing with the fiscal year beginning July 1, 2026, and not less than once each subsequent fiscal year, the Council shall meet for the purpose of evaluating the performance of Jensen and determining whether to grant Jensen an increase in annual base salary or other compensation. The Council retains sole discretion to determine whether to grant a compensation increase, and the amount and form thereof, but shall endeavor in good faith to consider performance, labor market conditions, internal equity considerations, and/or other appropriate factors in determining Jensen’s compensation.

1.1. Standard Management Benefits and Allowances. Except as otherwise provided in this Agreement, Jensen's employment with the City shall be governed by the City Council adopted Compensation Plan for Management and Professional Personnel and Council Appointees, as it currently exists and may be modified by the Council from time to time (“Management Compensation Plan”). Jensen will be eligible for, and shall receive, all regular benefits (e.g. health insurance, dental, and vision benefits) and vacation, sick leave, and management leave as are set forth in the Management Compensation Plan. Jensen shall comply with all rules and procedures, and shall make any and all employee contributions (such as employee contributions to the City’s CalPERS employer contribution) set forth in the Management Compensation Plan.

1.1.1. Salary Increases Governed Exclusively by This Agreement. Jensen acknowledges that Subsection 3.2 is the sole method for increasing the City Attorney’s base salary or salary-equivalent compensation, such as 401(a) Defined Benefit Retirement contributions set forth in Subsection 3.4.1. Provisions of the Management Compensation Plan regarding salary increases shall not apply.

1.1. Additional Benefits and Allowances. In addition to the benefits specified in Subsection 3.3, Jensen will receive the following additional benefits and allowances:

1.1.1. 401(a) Defined Contribution Retirement Plan. The City shall contribute $20,000 annually to a 401(a)-retirement plan account established for Jensen, prorated and contributed on the City’s normal paydays ($769.23/pay period).

Jensen will make any additional contribution required under the plan, if any, and may make additional voluntary contributions if eligible under the plan.

1.1.2. Vacation Accrual Rate. In recognition of prior public service, the City Item 11
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4 shall
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4 place Jensen at the highest tier of vacation accrual available within the Management Compensation Plan, which is currently two hundred (200) hours per year, prorated and earned each pay period.

1.1.1. Parking. The City will provide parking at the Civic Center at no cost to Jensen.

1. Professional Fees/Costs. During the term of Jensen’s service and in accordance with applicable City policies and procedures, the City will pay the cost of Jensen’s annual California Bar Association dues, as well as reasonable fees for membership in organizations associated with the office of the City Attorney and costs of appropriate conferences, trainings, and seminars.

1. Fidelity Bonds. The City shall bear the full cost of any fidelity or other bonds that may be required in the performance of Jensen’s services under this Agreement.

Duration of Employment. Jensen understands and agrees that he has no protected property or other interest in continuing employment as City Attorney. Jensen waives any and all rights, if any, under federal, state or local law, the Merit System Rules and Regulations, and the Management Compensation Plan, pertaining to pre- or post-separation due process. Jensen understands and agrees that he works at the will and pleasure of the Council and that he may be terminated or asked to resign at any time, with or without cause, subject to the requirements of Subsection 6.1 of this Agreement.

1.1. Severance Pay. If Jensen is terminated or asked to resign, and upon execution of a release of all claims against the City, the City shall provide Jensen with a cash severance payment or payments (without interest) equivalent to nine months of salary and benefits as set forth in Section 3 of this Agreement. All normal or legally-required withholdings shall be made. After two full years of service as City Attorney, beginning from Jensen’s Employment Start Date, the severance payment in this Subsection will increase to twelve months of salary and benefits.

1.1.1. Severance Not Available Under Certain Conditions. No severance shall be paid if Jensen is separated from employment after conviction of a felony or a conviction for a crime involving an abuse of office or his position, as defined in Government Code § 53243.4, or for conduct that is charged by appropriate Item 11
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5 authorities as a felony and later results in a felony conviction or conviction for a crime involving an abuse of office. If this Subsection is triggered by the filing of charges, the City shall hold the amount of potential severance in a segregated account pending determination of criminal proceedings.

1. Indemnification. The City will defend and pay any costs and judgments assessed against Jensen arising out of an act or omission by Jensen occurring in the course and scope of his performance of his duties under this Agreement in accordance with the provisions of Government Code Sections 825, 995, and 995.2 through 995.8.

1. Miscellaneous.

1.1. Notices. Notices given under this Agreement shall be in writing and shall be either: a) served personally; or b) sent by electronic mail (provided a hard copy is mailed within three (3) business days); or c) delivered by first-class United States mail, certified, with postage prepaid and a return receipt requested; or d) sent by equivalent private mail delivery service. Notices shall be deemed received at the earlier of actual receipt or three (3) days following deposit in the United States mail, postage prepaid. Notices shall be directed to the addresses shown below, provided that a party may change such party's address for notice by giving written notice to the other party in accordance with this Subsection.

CITY: Attn: Human Resources
250 Hamilton Avenue, Palo Alto CA 94301 Phone
(650) 329-2376
JENSEN: Christopher D Jensen
c/o 250 Hamilton Avenue, Palo Alto CA 94301
Phone (650) 329-2171

1.2. Entire Agreement/ Amendment. This Agreement constitutes the entire understanding and agreement between the parties as to those matters contained in it, and supersedes any and all prior or contemporaneous agreements, representations and understandings of the parties. This Agreement may be amended at any time by mutual agreement of the parties, but any such amendment must be in writing, dated, and signed by the parties and attached hereto.

1.3. Applicable Law and Venue. This Agreement shall be governed by and Item 11
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6 interpreted according to the laws of the State of California. Venue of any action regarding this Agreement shall be in the proper court in Santa Clara County.

1.1. Severability. In the event any portion of this Agreement is declared void, such portion shall be severed from this Agreement and the remaining provisions shall remain in effect, unless the result of such severance would be to substantially alter this Agreement or the obligations of the parties, in which case this Agreement shall be immediately terminated.

1.2. Waiver. Any failure of a party to insist upon strict compliance with any term, undertaking, or condition of this Agreement shall not be deemed to be a waiver of such term, undertaking, or condition. To be effective, a waiver must be in writing, signed and dated by the parties.

1.3. Representation by Counsel. Jensen and the City acknowledge that they each did, or had the opportunity to, consult with legal counsel of their respective choosing with respect to the matters that are the subject of this Agreement prior to executing it.

1.4. Section Headings. The headings on each of the sections and subsections of this Agreement are for the convenience of the parties only and do not limit or expand the contents of any such section or subsection.

Christopher D. Jensen
City of Palo Alto
____________________________ ___________________________ Approved as to Form:
________________________________________________________________________ ___ City Attorney’s Office
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NOT YET APPROVED
Resolution No.

A Resolution of the City Council for the City of Palo Alto appointing Christopher Jensen as the Palo Alto City Attorney

R E C I T A L S
A. The Palo Alto City Charter and Municipal Code specify the duties and functions of the City Attorney for the City of Palo Alto;
B. The Palo Alto City Charter and Municipal Code state that the Council shall appoint the City Manager, Clerk, Attorney, and Auditor, who shall serve at its pleasure; C. The Council received notice that City Attorney Molly Stump was retiring effective January 9, 2026;
D. The Council Appointed Officers committee conducted a process in open session on September 9, 2025, and September 22, 2025, to select an executive recruitment firm, outline a process for recruitment, and make a recommendation to the Council on the process for the selection of a new City Attorney;
E. The Council on October 6, 2025, received and approved the Council Appointed Officer committee recommendations;
F. On January 31, 2026, and February 1, 2026, the Council interviewed highly qualified candidates identified through this search and advanced Christopher Jensen to be the next City Attorney of the City of Palo Alto;
G. Council directed the recruitment firm to conduct background and reference checks, which Council reviewed and approved. Concurrently, Council and the recruitment firm negotiated an employment agreement with Christopher Jensen; Now, therefore, the Council of the City of Palo Alto resolves as follows:

Section 1. The Council hereby appoints Christopher Jensen as the City Attorney for the City of Palo Alto;
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Appointing Christopher
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Section 2. Christopher Jensen shall serve as the City Attorney at the will of the Council as provided by the Charter, and shall further serve according to all of the terms and provisions of the Charter, the Municipal Code, and his employment agreement; and Section 3. The Council hereby appoints and employs Christopher Jensen for an indefinite term that begins on March 30, 2026.

Introduced and Passed:

Ayes:

Noes:

Absent:

Abstentions:

Attest:

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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: March 16, 2026
Report #:2512-5734
TITLE
QUASI-JUDICIAL. 2100-2400 Geng Road [24PLN-00356 & 24PLN-00357]: Request for Approval of Applications for Site and Design, a Conditional Use Permit, and a Vesting Tentative Map to Construct 145 For Sale Townhome Units. Thirteen Percent of the Units Would Be Deed Restricted to Low Income Households. The Project is Proposed in Accordance with Builder’s Remedy (California Government Code Section 65589.5(d)(5)). A Senate Bill 330 Pre-Application was Filed on July 8, 2024. The Project Also Includes Adoption of a Parkland Improvement Ordinance to Authorize Tree Removals in the Baylands Athletic Center, Which Would be Impacted by the Project. CEQA Status: Exempt from CEQA in Accordance with CEQA Guidelines Section 15183 (Comprehensive Plan Consistency).

RECOMMENDATION
Staff Recommends that City Council:

1. Consider the project exempt from CEQA in accordance with CEQA Guidelines Section 15183 (Comprehensive Plan Consistency) as documented in Attachment G;

2. Approve the Site and Design, Conditional Use Permit, and Vesting Tentative Map Applications based on findings and subject to conditions of approval in the Draft Record of Land Use Action (RLUA) in Attachment B; and

3. Adopt the Parkland Improvement Ordinance in Attachment C authorizing the proposed work and modifications in the Baylands Athletic Center within the City’s Baylands open space.

EXECUTIVE SUMMARY
The project proposes 145 townhome units for sale with thirteen percent of the units (19 units) deed restricted to serve low-income households. The residential development would be located on two contiguous parcels located at 2100-2400 Geng Road totaling 480,230 square feet (approximately 11-acres). A Vesting Tentative Map is requested to merge these parcels and Item 12
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create 145 for-sale condominium units. The project would replace four existing office buildings which are currently occupied by multiple office tenants.

A Parkland Improvement Ordinance would authorize non-native tree removals along the project site’s shared property line with the Baylands Athletic Center, a City owned public recreation facility within the City’s Baylands Nature Preserve, related to grading and construction impacts.

The applicant filed a compliant pre-application in accordance with Senate Bill (SB) 330 on July 8, 2024 (24PLN-00181). Therefore, the project analysis is based on the applicable standards at the time the pre-application was submitted. In addition, the project is considered a “builder’s remedy project” as defined in the recently adopted Assembly Bill (AB) 1893. Accordingly, the project may not be denied on the basis of inconsistency with the Zoning Ordinance or Comprehensive Plan land use designation. The project is further afforded numerous protections by state law, detailed below.

Consistent with Section 15183 of the CEQA Guidelines, the City prepared an Initial Study checklist and determined that the project is consistent with the Certified Environmental Impact Report for the 2030 Comprehensive Plan (SCH #2014052101).

BACKGROUND
The project has undergone multiple public hearings, and the current project plans incorporate feedback from various boards and commissions, described here.

Planning and Transportation Commission (PTC)
In accordance with the Site and Design Review process, the PTC held a public hearing to provide a recommendation on this project on December 10, 2025.1 The PTC recommended approval of the proposed project to Council (7-0), making the following motion:

Recommend approval of the project to City Council based on the findings with an added condition of approval for compliance with the Dark Skies Ordinance and ask that staff:
• Work with the applicant to increase the percentage of native trees on-site; and • Consider the suggested language changes recommended by Chair Akin and Commissioner Hechtman.2
The landscaping plan has been refined to increase the native plantings. The recommended language changes were incorporated into the RLUA, see Attachment B. 1 December 10, 2025, PTC Staff Report (Agenda Item 2):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84084&dbid=0&repo=PaloAlto&searchid=d35f7bd7 -fd98-43f0-99da-2bb8fe1dab66
2 This related to minor corrections and references in the record of land use action.

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Architectural Review Board
On October 16, 2025, the Architectural Review Board (ARB) held an early hearing to provide feedback on the proposed project design. The project applicant addressed most of the ARB comments and returned to the ARB for a formal recommendation on January 15, 2026. A summary of design refinements to address ARB comments is included in the January 15, 2026, staff report.5 The ARB recommended approval of the proposed project to Council (3-0), with Vice Chair Adcock and Board Member Hirsch absent.

Parks and Recreation Commission (PRC)
On December 16, 2025, the PRC reviewed the Draft Parkland Improvement Ordinance for the project related impacts from grading and construction activity to approximately forty-five (45) non-native Blue Gum Eucalyptus (Eucalyptus globulus) trees located on the project’s shared property line with the Baylands Athletic Center, a City owned public recreation facility within the City’s Baylands Nature Preserve.6 The PRC recommended approval of the Park Improvement Ordinance to Council (6-0), with Commissioner Deng absent, making the following motion:

Recommend City Council adopt the Park Improvement Ordinance at Baylands Athletic Center for the Tree Removals associated with the 2100 Geng Road development project, with an addition that staff will provide another finding that includes a City commitment to canopy (Baylands tree species) in the vicinity of the impact.

Staff incorporated this additional finding to ensure the City commits to using the tree replacement funds to replant native trees within the vicinity of the removals, rather than retaining the funds without providing on-site canopy replacement.

Project Description
The proposed project is a request for approval of a Site and Design application, Conditional Use Permit, and Vesting Tentative Map for development of 59 three-story buildings at a height of 42 feet containing 145 for sale townhome units. Thirteen percent of the units (19 units) would be deed restricted to serve households meeting low income or below. The project would replace the four existing office buildings currently located on the project site totaling approximately 192,000 square feet. The vesting tentative map would merge two existing lots to create a single 480,230-square-foot (approximately 11-acre) parcel and subdivide that lot for condominium purposes. A Conditional Use Permit is required for the residential use within the ROLM(E) Zone District. The project site has frontage on Geng Road and an easement connecting to East Bayshore Road. Driveways are proposed at both locations, each providing ingress and egress and emergency vehicle access to the site. Parking would be above-grade parking, with 333 5 January 15, 2026, ARB Staff Report (Agenda Item 2):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85239&dbid=0&repo=PaloAlto 6 December 16, 2025, PRC Staff Report (Agenda Item 4):
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spaces. Of those spaces, 290 spaces would be provided in the townhome garages (70 tandem spaces) and 43 parking spaces would be provided along the private streets, including 4 accessible spaces. One (1) electrical vehicle parking space would be installed in each garage for the 145 units. Associated site improvements include rooftop amenity spaces, 28,294 sf of common open spaces and 62,108 sf of private open spaces for a total of 90,402 sf of usable open spaces, landscaping, and utility improvements.

The applicant submitted a SB 330 pre-application on July 8, 2024 (24PLN-00181). Therefore, the project analysis is based on the applicable standards at the time the compliant SB 330 preapplication was submitted. The project is also being proposed in accordance with California Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy) and qualifies for additional protections as a “builder’s remedy project,” under AB 1893. The applicant’s project description is provided in Attachment G and includes a list of waivers requested in accordance with State Density Bonus Law. As detailed further in this report, if the project is designed to comply with all relevant objective standards, after application of density bonus incentives, concessions, and waivers, the City cannot impose conditions that would preclude construction of the project as proposed.

Requested Entitlements, Findings, and Purview
The following discretionary applications are being requested and subject to Council purview:
• Site and Design Review: The process for evaluating this type of application is set forth in Palo Alto Municipal Code (PAMC) Chapter 18.30(G). Site and Design applications are reviewed by the PTC and ARB, and recommendations are forwarded to the City Council for final action. Site and Design projects are evaluated against specific findings that include both the ARB findings (ARB purview) and Site and Design findings (PTC purview).

All findings must be made in the affirmative to approve the project. Failure to make any one of the findings requires project redesign or denial. Findings for Council to approve this site and design application are provided in Attachment B. • Conditional Use Permit (CUP): The process for evaluating this type of application is set forth in PAMC Section 18.77.060. CUP applications are reviewed by staff and the Director will prepare a written decision to approve, approve with conditions, or deny the application based on the Findings set in PAMC Section 18.76.010(c).

Notwithstanding, in accordance with PAMC 18.40.170 the Director may forward the decision to Council. Therefore, the findings for approval of a CUP are included in Attachment B.
• Vesting Tentative Map: The process for evaluating this type of application is set forth in Title 21 of the PAMC and California Government Code 66474. The process for approval of a Vesting Tentative Map for a condominium subdivision is outlined in PAMC Sections

21.12.010 and 21.13.020. Vesting Tentative Maps require PTC review. The PTC reviews whether the amended subdivision is consistent with the Subdivision Map Act (in particular, Government Code 66474, Title 21 of the PAMC, the Palo Alto Comprehensive Item 12
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Plan, and other applicable provisions of the PAMC and State law. The PTC’s recommendation is forwarded to the City Council for final approval. Findings for Council to approve the Vesting Tentative Map are provided in Attachment B. • Parkland Improvement Ordinance: The process for evaluating this type of application is set forth in Article VIII of the Charter of the City of Palo Alto and PAMC Section

22.08.005. This process requires a recommendation by the Parks and Recreation Commission, which is forwarded to City Council for final action. Council must approve and adopt a plan covering the proposed improvements before any substantial building, construction, reconstruction or development is approved on dedicated parkland. The draft ordinance is provided in Attachment C.

Purview of the formal application is limited by the following State law in the following ways:
• Housing Accountability Act (Government Code 65589.5): The project constitutes a “housing development project,” as well as “housing for very low, low-, or moderate income households” under the Housing Accountability Act. The Housing Accountability Act Section 65589.5(d) states that a city cannot deny such a project or impose conditions of approval that would render it infeasible unless it makes specified findings.

Among those findings are: (1) that the project would have a specific, adverse impact upon the public health or safety that cannot be mitigated. • Because the project is a “builder’s remedy project,” as defined in AB 1893, the City is further limited to only enforcing those objective standards that exist in a zone district or land use designation that allows the density requested. If there are no such zoning districts or general plan designations in the City, then the applicant may identify any City standards that facilitate the project and only those standards shall apply. If the project meets these identified standards, the City cannot impose conditions of approval that preclude the project from being constructed as proposed by the applicant. • Because the project is a “builder’s remedy project,” as defined in AB 1893, the “base density” for purposes of State Density Bonus Law shall be the maximum density permitted for builder’s remedy projects (e.g. three times the density permitted in the zoning code or general plan). The project applicant is also able to utilize incentives, concessions, and waivers under State Density Bonus Law when demonstrating compliance with the enforceable standards.

ANALYSIS
Staff evaluated the project in accordance with the Comprehensive Plan, Zoning Ordinance, and other applicable goals and policies of the City and found the project consistent, or otherwise deviates in a manner permissible under State law.

Consistency with the Comprehensive Plan, Area Plans, and Guidelines The Comprehensive Plan land use designation for the project site is Research/Office Park, which states: "Office, research and manufacturing establishments whose operations are buffered from adjacent residential uses… in some locations, residential and mixed-use projects may also locate in this category. Maximum allowable FAR ranges from 0.3 to 0.5, depending on site Item 12
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conditions. Consistent with the Comprehensive Plan, multifamily housing may be allowed in specific locations.” Because one of the two parcels on the project site is identified as a Housing Inventory site in accordance with the City’s adopted Housing Element, the proposed land use is consistent with the Comprehensive Plan.9
The proposed Vesting Tentative Map is consistent with the Comprehensive Plan, in that the site allows “Multifamily” land uses and will be developed as a multifamily development. The map facilitates the redevelopment of an existing parcel within the City’s urban service area which is consistent Policy L-1.2 of the Comprehensive Plan as well as the Housing Element, as discussed further below.

The project complies with most of the goals and policies set forth in the adopted elements of the Comprehensive Plan, but it does not conform to the maximum floor area ratios. This is permissible under the Builder’s Remedy provisions established in AB 1893, as further detailed in Attachment B. Comprehensive Plan consistency is not a valid basis for denying this project.

Housing Element Consistency
One of the two parcels on which the proposed project would be located is identified as a housing inventory site. The Housing Element site inventory anticipated the development of 175 units on this proposed site at a moderate-income level. The project is a 145-unit development, of which 126 units will be market rate (above-moderate income) and nineteen units (13%) are designated to be provided at below-market rate (BMR) at a rate affordable to low-income households. Because none of the units are provided at moderate income, as anticipated in the Housing Element, approval of this project would result in a shortfall of capacity for moderate income units in the Housing Element sites inventory and this shortfall will likely exceed the City’s “buffer” for that income level. As a result, if the project is approved, the City will likely need to identify alternative sites for moderate income units within 180 days following the approval. It is not unusual for sites to be developed in a manner different from the projections in the site inventory. Staff have begun work on the identification of alternative sites in anticipation of this shortfall.

The development would add new residential units that contribute to the City’s Regional Housing Need Allocation (RHNA), including 19 affordable housing units, consistent with Goal 2 of the Housing Element, which states, “assist in the provision of safe, attainable, and sustainable housing, especially affordable housing, to meet the needs of all economic segments of the community.”
Baylands Master Plan and Bayland Design Guidelines
The project is located within the boundaries of the Baylands Master Plan on the area identified as Private Lands. The project is subject to Site and Design review, as detailed in this report, consistent with the Baylands Master Plan Policy 1 for Private Lands. The project also includes 9 Housing Inventory Site (APN 008-02-035) projected at 175 units at moderate income level.

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extensive tree planting especially along the perimeter of the property to aid in screening of the new development.

Site Assessment and Design Guidelines
The Site Assessment and Design Guidelines, Palo Alto Baylands Nature Preserve, developed in 2005, are intended to be used when designing or reviewing projects located in any part of the Baylands—including projects on privately-owned land. Conformance with these guidelines ensures compatibility with the special aesthetic qualities and environmental conditions unique to the Baylands. The following design principles are suggested to reflect and preserve the Baylands’ unique landscape character and have been used to review this application:
• Use only muted, natural colors. Choose materials and finishes that will weather without degrading.
• Preserve the horizon line with low and horizontal elements. • Mount fences, enclosures, and identity signs low to the ground. • Reduce the size and mounting heights of regulatory sign.

Following the October 16, 2025, ARB meeting, the applicant revised the material palette to utilize natural, muted colors over the previously proposed high contrast dark and light façade colors as recommended by staff and the ARB. The ARB was supportive of the revised color palette as it better reflects and preserves the Baylands’ unique landscape character. No signs are proposed as part of the project. Any future signage would be evaluated in accordance with these guidelines if and when proposed. Therefore, staff finds the project to be consistent with the Site Assessment and Design Guidelines for the Palo Alto Baylands Nature Preserve.

Palo Alto Comprehensive Airport Land Use Plan (CLUP)
The CLUP is intended to protect the general welfare of residents within the areas surrounding airports. The project site is located within the Traffic Pattern Zone, which is routinely overflown by aircraft. However, the potential for aircraft accidents in this area is relatively low and land use restrictions are minimal. Santa Clara County planning staff confirmed that referral to the Santa Clara County Airport Land Use Commission is not required. The proposed 145-unit townhome development complies with the density limits established in the Comprehensive Plan and zoning, and there are no residential unit caps within the Traffic Pattern Zone. The development would also comply with the maximum height limit of 154 feet.

Palo Alto Airport staff provided recommended conditions of approval that the project secure a Determination of No Hazard from the Federal Aviation Administration and the applicant record of an Avigation Easement and Deed Notice with the Vesting Tentative Map to ensure prospective buyers are made aware of the airport's existence and any potential impact that the airport activity has on surrounding land uses. These conditions are reflected in Attachment B.

Zoning Consistency
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development standards, including the base ROLM (E)(D)(AD) standards. Notably, exclusively residential uses in the ROLM(E) District require compliance with the RM-20 development standards found in PAMC Chapter 18.13. Additionally, the project is required to comply with the objective development standards set forth under PAMC Chapter 18.24. While the project is inconsistent with some zoning development standards as identified in Attachment D, the applicant requests waivers to deviate from these standards in a manner that is consistent with the builder’s remedy provisions set forth under AB 1893 and state density bonus law.

Therefore, these inconsistencies are described for informational purposes, but they do not constitute a basis for denial of a builder’s remedy project. The project complies with the objective standards in PAMC Chapter 18.24 applicable to housing development projects within the ROLM(E) Zone District as detailed in Attachment E.

Multi-Modal Access & Parking
Valley Transit Authority (VTA) bus line 81 and ACE transit AE-F line are the nearest bus lines to the project site. The California Avenue Caltrain Station is located approximately 2.2 miles from the project site and nearby bicycle lanes are located on Embarcadero Road.

The project would include above-grade parking, with 333 spaces, exceeding zoning parking requirements. Of those spaces, 290 spaces would be provided in the townhome garages (including 70 tandem spaces) and 43 parking spaces would be provided along the private streets, including four accessible spaces. One electrical vehicle parking space would be installed in each garage for the 145 units. Access to the site would be provided from Geng Road as well as through an existing ingress/egress easement connecting to East Bayshore Road. Long-term bicycle parking is currently shown within each garage totaling 145 bike spaces. A centrally located bike rack on the project site provides 16 short-term bicycle spaces. The project is consistent with both vehicular parking, and long-term and short-term bike parking requirements of the Municipal Code.

Title 8 Consistency (Trees)
Due to the site’s location in a flood zone, the project must elevate grades to meet floodplain requirements, necessitating tree removals on both the project site and adjacent City property.

The Revised Preliminary Arborist Report prepared by HortScience and Bartlett Consulting in August 2025 (Appendix A2 of the Environmental Document) identifies the removal of 218 onsite trees including 83 protected trees, due to low suitability for preservation during construction. An additional 52 off-site trees are identified for removal, including 46 protected trees located on City property at the Baylands Athletic Center. However, staff notes that recent winter storms damaged three trees along the shared property line, necessitating their removal independent of the proposed development. Therefore, although the plans reflect removal of 52 off-site trees, only 49 total off-site trees would now be removed.

To mitigate the impacts of tree removals, the project proposes 648 new trees on-site, with over 50 percent native species, including a substantial proportion of coast live oaks and valley oaks.

These values were increased in response to the PTC’s recommendation to incorporate more Item 12
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native species. Tree replacement values for the project are detailed in the Tree Disposition Table (L 6.1) of the plan set in Attachment H.

The applicant evaluated an alternative site layout to reduce removals on City property.

However, this required shifting development inward that in turn eliminated dwelling units and reduced open space. Removal of this number of trees on City parkland requires approval of a Parkland Improvement Ordinance (PIO). The Parks and Recreation Commission recommended approval of PIO based on the current proposed plans and removal of the 52 trees currently proposed to be removed. The proposed Parkland Improvement Ordinance is included in Attachment C.

Title 16 Consistency (Affordable Housing Requirements)
The applicant requests a concession from PAMC Section 16.65.075(a)(2), which requires BMR units to be reasonably dispersed within residential projects and comparable in bedroom count and size to the average market-rate units. The applicant proposes to provide BMR units only in the row block townhomes and not in the detached townhomes or duplexes. Under State Density Bonus Law, concessions may allow deviations from development standards if the concession would result in cost reductions for the project. The applicant states that including BMR units in the four-bedroom detached townhomes would increase cost and reduce market returns, as these units are intended to be sold at a premium (Attachment G).

Title 21 Consistency (Subdivision Requirements)
Review and approval of a Vesting Tentative Map are governed by PAMC Title 21 and the State Subdivision Map Act (SMA). Except as otherwise provided in Title 21, all provisions, requirements and procedures set forth in the SMA shall be followed. The SMA provides “reverse” findings for map approval (Section 66474 of the Government Code). On December 10, 2025, the PTC recommended that Council approve the Vesting Tentative map, subject to the Conditions of Approval contained in Attachment B.

Private Street Width
The project includes new private streets that do not meet the 32-foot minimum width required in PAMC Section 21.20.240. The applicant requested a waiver under State Density Bonus Law to allow a 26-foot width. The proposed width would still comply with all safety requirements, including, but not limited to, fire safety and traffic safety.

Parkland Dedication
PAMC Chapter 21.50 provides that as a condition of approval of new condominiums or singlefamily subdivisions in Palo Alto, the City requires that the impact on the Palo Alto parks system be addressed either through dedication of additional parkland, or payment of fees in-lieu of dedication. The required land to be dedicated would be 336 square feet per unit (145) for a total of 48,720 square feet (1.12 acres). The fee is equivalent to the value of the land that the City would otherwise require be dedicated. The square footage required is calculated as specified above. The City uses a default land value of $5.7 million per acre, when calculating Item 12
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fees, but the land value may also be determined by an appraisal of the parcel being developed.

Although the parkland dedication requirement would apply to this site and payment of in-lieu fee as an alternative would typically be subject to Council’s discretion, on-site dedication is not feasible in this case. Providing land would reduce the project’s housing density, which is not permissible under the Builder’s Remedy. Accordingly, the applicant proposes to satisfy this requirement through the payment of in-lieu fees. Parkland Dedication in-lieu fees for the project total approximately $6,372,600.

Application Consistency
As detailed in Attachment B, staff finds that this project meets all required findings for a Site and Design application, Conditional Use Permit, and Vesting Tentative Map and facilitates development of a housing development project that is consistent with the City’s regulations, goals, and policies. Although the project does not comply with all aspects of the Comprehensive Plan and Municipal Code, the project deviates in a manner allowed in accordance with State law.

FISCAL/RESOURCE IMPACT
Processing of this application has limited fiscal impact as applicants are responsible for staff and consultant costs through applicable fees through the deposit-based cost recovery program. The proposed improvements are anticipated to increase the assessed value of the subject property, which will generate additional property tax for the City. Palo Alto receives approximately 9.4% of the additional property tax generated. This project is also subject to Development Impact Fees, currently estimated at $8,306,259.10, which includes the aforementioned Parkland Dedication fees and the Public Art fee.

STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post on March 6, 2026, which is 10 days in advance of the meeting. Postcard mailing occurred on March 4, 2026, which is 12 days in advance of the meeting.

Public Comments
As of the writing of this report, the City has received several comments from interested stakeholders which are included in Attachment F. Overall, most of the comments are inquiries about status updates on the project. One public comment voiced support of the project providing housing for the community.

ENVIRONMENTAL REVIEW
The subject project has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the Item 12
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environmental regulations of the City. An Initial Study (IS) Checklist to determine consistency with the Environmental Impact Report (EIR) (State Clearinghouse [SCH] #2014052101) certified in 2017 (“2017 EIR”) for the City of Palo Alto’s 2030 Comprehensive Plan was prepared for the project. Pursuant to CEQA Guidelines section 15183, the IS Checklist found that the Project is consistent with a Community Plan or Zoning with any project related effects substantially mitigated under uniformly applicable development policies or standards, see Attachment H.

The IS Checklist was published on December 3, 2025.

ATTACHMENTS
Attachment A: Location Map
Attachment B: Draft Record of Land Use Action
Attachment C: Draft Parkland Improvement Ordinance
Attachment D: Zoning Consistency
Attachment E: Objective Standards Consistency Analysis
Attachment F: Public Comments
Attachment G: Applicant’s Project Description
Attachment H: Project Plans and Environmental Review
APPROVED BY:

Jonathan Lait, Planning and Development Services Director Item 12
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City of Palo Alto GIS
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Project Site
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Attachment A
Location Map
2100-2400 Geng Rd CITY OF PALO ALTO

I N C O R P O R A T E D

CAL I FORN I A
P a l o A l t o
T h e C i t y o f A P R I L
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The City of Palo Alto assumes no responsibility for any errors ©1989 to 2016 City of Palo Alto sswitze, 2025-10-08 06:58:18
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1 DRAFT ACTION NO. 2026-__

RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO LAND USE ACTION FOR 2100-2400 GENG RD: SITE AND DESIGN, CONDITIONAL USE PERMIT, AND VESTING TENTATIVE MAP [24PLN-00356 & 24PLN-00357]
On _________, 2026, the City Council of the City of Palo Alto (“City Council”) approved a Site and Design application, Conditional Use Permit, and Vesting Tentative Map for development of 145 for sale townhome units (“the Project”). In approving the application, Council makes the following findings, determinations, and declarations:

SECTION 1. Background.

A. On July 8, 2024, Strada Investment Group filed a compliant pre-application in accordance with Senate Bill (SB) 330 and with California Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy).

B. On December 18, 2024, Strada Investment Group filed a Site and Design and Conditional Use Permit application (24PLN-00356) for 145 for sale townhome units to allow for the proposed multi-family development and use of the site. In addition, Strada Investment Group filed an application for a Vesting Tentative Map (24PLN-00357) to merge two existing lots to create a single resulting 480,230-square-foot parcel (11.02 acres) and to re-subdivide the lot for condominium purposes for 145 townhome units. The project includes the following density bonus waivers and concessions in accordance with State Density Bonus Law, and additional protections as a “builder’s remedy project,” under AB 1893:
• Waiver 1: Floor Area Ratio (0.97:1 where 0.5:1 maximum is allowed) • Waiver 2: Height (42 feet where 30 feet maximum is allowed) • Waiver 3: Front Setback (16.5 feet where 20 feet is required) • Waiver 4: Rooftop Garden Width (Railings intersect a plane measured at a forty-five degree angle from the edge of the building sloping upward and inward toward the center of the unit)
• Waiver 5: Private street width (26 feet where 32 feet is required) • Concession 1: Distribution of below market rate units.

C. The project site is comprised of two existing lots (APN 008-02-035, Approximately 239,800 square feet and APN 008-02-036, Approximately 240,430 square feet).

The site contains four existing office buildings. To the north of the project site is the Baylands Athletic Center that offers softball/baseball lighted fields on a six-acre facility. Adjacent uses to the south, east, and west are office buildings.

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2 D. Following staff review, the Architectural Review Board held a duly noticed public hearing to review the Site and Design application at an initial hearing on October 16, 2025, to provide feedback on the design.

E. Following staff review of the Site and Design application, Conditional Use Permit, and Vesting Tentative Map, the Planning and Transportation Commission held a duly noticed public hearing to review the project and recommended approval on December 10, 2025, subject to conditions of approval.

F. Following the Planning and Transportation Commission’s review of the project, the Architectural Review Board held a duly noticed public hearing to review the Site and Design application and recommended approval on January 15, 2026, subject to conditions of approval.

G. On December 16, 2025 the Parks and Recreation Commission considered the associated Park Improvement Ordinance required for the project and recommended approval, subject to conditions of approval.

H. On ___________, 2026 the City Council held a duly noticed public hearing at which evidence was considered and all persons were afforded an opportunity to be heard in accordance with the City Council’s policies and procedures.

SECTION 2. Environmental Review. The City, acting as the lead agency for the Project, has determined that the project is exempt from the California Environmental Quality Act (CEQA) in accordance with CEQA Guideline section 15183. An Initial Study (IS) Checklist to determine consistency with the Environmental Impact Report (EIR) (State Clearinghouse [SCH] #2014052101) certified in 2017 (“2017 EIR”) for the City of Palo Alto’s 2030 Comprehensive Plan found that the Project is consistent with a Community Plan or Zoning with any project related effects substantially mitigated under uniformly applicable development policies or standards. Documentation to support the exemption is available as part of the public record on file with the Planning and Development Services Division.

SECTION 3. Site and Design Review Objectives. The design and architecture of the proposed improvements, as conditioned, comply with the Site and Design Objectives as required in Chapter 18.30.060(G) of the PAMC.

1. Objective (a): To ensure construction and operation of the use in a manner that will be orderly, harmonious, and compatible with existing or potential uses of adjoining or nearby sites.

The proposed project is located on two contiguous parcels located at 2100-2400 Geng Road. To the north of the project site is the Baylands Athletic Center that offers softball/baseball lighted fields on a six-acre facility. Adjacent uses to the south, east, and west are office buildings. While surrounding uses differ from the proposed residential use, the project site allows residential development with a conditional use permit. The colors and materials of the project are consistent with the Baylands Design Item 12
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3 Guidelines, such as using muted colors. Lighting would be downcast and the proposed landscaping would provide long-term visual screening along the property line abutting the Baylands Athletic Center.

The project would not conflict with the City’s airport operations and is consistent with the adopted Comprehensive Airport Land Use Plan. Therefore, the project is consistent with this objective.

2. Objective (b): To ensure the desirability of investment, or the conduct of business, research, or educational activities, or other authorized occupations in the same or adjacent areas.

The project is located within the boundaries of the Baylands Master Plan on the area identified as Private Lands. The proposed residential project would redevelop two parcels currently occupied with office uses. The proposed use is consistent with the land use designation and, with a Conditional Use Permit, is consistent with the allowed uses set forth in the zoning code. The project would provide 145 townhome units improving the City’s jobs housing imbalance consistent with the Housing Element’s goals and policies. The project would not affect existing or potential future uses within the surrounding area including the adjacent airport, nearby office uses, and/or recreational use of the Baylands and therefore would not affect the desirability of investment, or the conduct of business, research, or educational activities on adjacent sites.

3. Objective (c): To ensure that sound principles of environmental design and ecological balance shall be observed.

The project is consistent with the Baylands Design Guidelines in that it utilizes muted colors and materials that will weather without degrading such as stucco and treated wooden siding. Lighting is designed and conditioned to not shine onto the adjacent properties. The project will implement green building measures as required by the Palo Alto Municipal Code and, in itself, allows for the increased reuse of recycled water within the City of Palo Alto and surrounding communities.

4. Objective (d): To ensure that the use will be in accord with the Palo Alto Comprehensive Plan.

The proposed project complies with all applicable and objective standards in the Comprehensive Plan and the Palo Alto Municipal Code except where waivers or concessions are requested pursuant to state density bonus law or additional protections as a “builder’s remedy project,” under AB 1893. In accordance with The Housing Accountability Act as set forth in California Government Code 65589.5(j)(3), the receipt of a density bonus, incentive, concession, waiver, or reduction of development standards pursuant to Section 65915 shall not constitute a valid basis on which to find a proposed housing development project is inconsistent, not in compliance, or not in conformity, with an applicable plan, program, policy, ordinance, standard, requirement, or other similar provision. Therefore, the project is compliant with the objective standards.

A summary of the project’s consistency with the Comprehensive Plan is provided in this table. The project is required to comply with the Comprehensive Plan to the extent that the requirements are objective.

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4 Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
The Comprehensive Plan land use designation for
the site is Research/Office Park which allows
multifamily housing in specific locations.

One of the two parcels on which the proposed
project would be located is identified as a
housing inventory site. The project adheres to the
Comprehensive Plan by providing housing on this
opportunity site. The proposed multi-family use is
allowed within this land use designation.

Housing Element
Policy 4.3 Implement development standards,
objective design standards, and architectural and
green building standards that encourage new
high-quality rental and ownership housing.

The project complies with the implemented
standards except where requests for waivers or
concessions in accordance with state density
bonus law is provided. The project provides the
necessary upgrades to infrastructure on the site
to provide new high-quality ownership units. The
project complies with all required green building
requirements in accordance with state law and
the city’s local reach code.

Land Use and Community Design Element
Policy L-6.1 Promote high-quality design and site
planning that is compatible with surrounding
development and public spaces.

The project utilizes a muted material palette with
natural colors and materials that will weather
without degrading. The design aligns with The
Site Assessment and Design Guidelines, intended
to ensure compatibility with the special aesthetic
qualities and environmental conditions unique to
the Baylands.

Policy L-9.2 Encourage development that
creatively integrates parking into the project,
including by locating it behind buildings or
underground wherever possible, or by providing
for shared use of parking areas. Encourage other
alternatives to surface parking lots that minimize
the amount of land devoted to parking while still
maintaining safe streets, street trees, a vibrant
local economy and sufficient parking to meet
demand.
290 spaces would be provided in the townhome
garages (70 tandem spaces) and 43 parking
spaces would be provided along the private
streets, including 4 accessible spaces. The
frontage still provides a sidewalk, street trees and
other greenery for an inviting streetscape.

Policy L-9.4 Treat residential streets as both
public ways and neighborhood amenities. Provide
and maintain continuous sidewalks, healthy
street trees, benches and other amenities that
promote walking and “active” transportation.

The project includes private streets lined with
trees as well as new short-term bicycle parking
within the common area and bicycle parking in
garage fronting the streets to promote active
transportation. This improves the current office
park design, which provides surface level parking
along the project frontage.

Policy L-9.9 Involve the Urban Forester, or
appropriate City staff, in development review.

The applicant has worked closely with the City’s
Urban Forestry division to ensure that tree
removals meet the goals of the Urban Forest
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5 Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
Master Plan. The proposed 648 replacement
trees would exceed the required 292 trees.

Further, the applicant has also worked with
Urban Foresty to develop a parkland
improvement ordinance that would address
project related impacts to adjacent City trees on
Parkland.

Policy L-10.2 Regulate land uses in the Airport
Influence Area to ensure consistency with the
Palo Alto Airport Comprehensive Land Use Plan
and the Baylands Master Plan.

The project would not exceed density
requirements as set forth in the adopted
Comprehensive Plan and zoning and there are no
limits on residential units within the Airport
Traffic Pattern Zone. Further, the development
would not exceed the maximum height limit of
154 feet. The project is conditioned to secure a
Determination of No Hazard from the Federal
Aviation Administration and the recording of an
Avigation Easement and Deed Notice with the
Vesting Tentative Map to ensure prospective
buyers are made aware of the airport's existence
and any potential impacts that the airport activity
has on surrounding land uses.

Transportation Element
Policy T-3.7 Encourage pedestrian-friendly design
features such as sidewalks, street trees, on-street
parking, gathering spaces, gardens, outdoor
furniture, art and interesting architectural details.

The project includes direct connections to the
sidewalk that help to activate the frontage along
Geng Road in addition to new street trees and
plantings.

Policy T-3.9 Support citywide sustainability
efforts by preserving and enhancing the tree
canopy where feasible within the public right-ofway, consistent with the Urban Forest Management Plan, as amended.

The project meets the tree canopy replacement
requirements through on site planting. The
project includes removal of 218 trees and
replaces with 648 trees, over which 50 percent
would be California native species, and 57 would
be coast live oaks and valley oaks.

Urban Forest and Understory
Policy N-2.3 Enhance the ecological resilience of
the urban forest by increasing and diversifying
native species in the public right-of-way,
protecting the health of soils and understory
vegetation, encouraging property owners to do
the same and discouraging the planting of
invasive species.

The project will remove the existing 216 trees on
site, and replace them with 648 new trees, an
increase of 432 trees. Of the new trees, a
majority will be native species and high habitat
value species, including coast live oak, valley oak,
and California buckeye. The understory is also
designed to support native habitat. Shrubs &
Grasses are nearly all California native species
with a focus on high habitat value species.

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6 Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
Policy N-2.11 Coordinate City review by the
Urban Forester, Planning, Utilities, and Public
Works Departments, of projects that might
impact the urban forest.

While the project will impact the urban forest,
the replacement tree values will exceed what is
required. The project will also include a parkland
improvement ordinance to address the potential
impacts to City trees on adjacent parkland. This
ordinance includes provisions for a program to
replace the impacted unhealthy non-native public
trees over time.

Flood Hazard and Mitigation
Policy S-2.8 Minimize exposure to flood hazards
by protecting existing development from flood
events and adequately reviewing proposed
development in flood prone areas.

The project site would be graded and raised out
of the flood zone to meet minimum National
Flood Insurance Program standards. The
applicant submitted a Conditional Letter of Map
Revision with FEMA. Following project
construction a Letter of Map Revision from FEMA
will officially revise the current NFIP map to show
changes to floodplains, regulatory floodways, or
flood elevations.

SECTION 4. Conditional Use Permit Findings. Conditional Use Permit approval is based on the findings indicated under PAMC Section 18.76.010:

1. The proposed use, at the proposed location, will not be detrimental or injurious to property or improvements in the vicinity, and will not be detrimental to the public health, safety, general welfare, or convenience.

A Conditional Use Permit is required for a residential use within the ROLM(E) Zone District. In the surrounding vicinity of the project site, there is a Post Office, International School of the Peninsula, two automobile agencies, and office uses. To the north of the project site is the Baylands Athletic Center that offers softball/baseball lighted fields on a six-acre facility.

Adjacent uses to the south, east, and west are office buildings. With the conditions set forth in this record of land use action, which reduce lighting impacts of the proposed project within the Baylands setting, the project would not be detrimental to the public health, safety, general welfare or convenience to other property improvements in the vicinity.

2. The proposed use will be located and conducted in a manner in accord with the Palo Alto Comprehensive Plan and the purposes of the Zoning Ordinance.

The Comprehensive Plan land use designation for the project site is Research/Office Park, which states: "Office, research and manufacturing establishments whose operations are buffered from adjacent residential uses… in some locations, residential and mixed-use projects may also locate in this category. Maximum allowable FAR ranges from 0.3 to 0.5, depending on site Item 12
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7 conditions. Consistent with the Comprehensive Plan, multifamily housing may be allowed in specific locations.” Because a portion of the site is identified as a Housing Inventory site in accordance with the City’s adopted Housing Element, the proposed land use is consistent with the Comprehensive Plan. Though the project exceeds the floor area ratio allowance set forth for this land use designation, the applicant requests a waiver in accordance with state density bonus law for the floor area; therefore, the increase in FAR may not be seen as inconsistent with the zoning ordinance or Comprehensive Plan. Additionally, the proposed application was filed in accordance with the Builder’s Remedy provision in the Housing Accountability Act.

Therefore, inconsistency with the Comprehensive Plan land use designation is not a basis for denial of a project. Because the project is a “builder’s remedy project,” as defined in AB 1893, the City is further limited to only enforcing those objective standards that exist in a zone district or land use designation that allows the density requested. Exclusively residential uses in the ROLM (E) District requires compliance with the development standards prescribed for the RM20 zoning district. The project applicant has identified incentives, concessions, and waivers under State Density Bonus Law to demonstrate compliance with the enforceable standards as detailed in Section 1.

SECTION 5. Architectural Review Findings.

1. The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan, Zoning Code, coordinated area plans (including compatibility requirements), and any relevant design guides.

The project applicant has identified incentives, concessions, and waivers under State Density Bonus Law to demonstrate compliance with the enforceable standards as detailed in Section 1 of this record of land use action. This finding can be made in the affirmative because the project is consistent with applicable Comprehensive Plan goals and policies as summarized above in Section 3, Site and Design Findings, and Section 4, Conditional Use Permit Findings, and the relevant findings can be made in the affirmative. The project is consistent with the Baylands Design Guidelines, as applicable to the proposed project, in that the project uses muted colors and the height is consistent with the requirements for the Palo Alto Comprehensive Airport Land Use Plan and the zoning code as modified in accordance with state law. The proposed 145-unit townhome development would not exceed density requirements as there are no limits on residential units within the Airport Traffic Pattern Zone and the project is consistent with the allowed density set forth in the Zoning and Comprehensive Plan.

2. The project has a unified and coherent design, that:
a. creates an internal sense of order and desirable environment for occupants, visitors, and the general community,
b. preserves, respects and integrates existing natural features that contribute positively to the site and the historic character including historic resources of the area when relevant,
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8 c. is consistent with the context-based design criteria of the applicable zone district, d. provides harmonious transitions in scale, mass and character to adjacent land uses and land use designations,
e. enhances living conditions on the site (if it includes residential uses) and in adjacent residential areas.

There is internal order between the pedestrian entries, car entry, and open spaces on the project site. There are three building typologies provided, detached townhomes, row townhomes, and duplex townhomes, that each have varying defined entrances for residents.

There is no historic character to preserve. The project is designed consistent with the Baylands Design Guidelines with the use of muted colors. While the project mostly complies with the applicable objective standards applied to housing development projects within the ROLM(E) Zone District, the applicant has identified waivers pursuant with State Density Bonus Law and Builder’s Remedy provisions as detailed in Section 1.

3. The design is of high aesthetic quality, using high quality, integrated materials and appropriate construction techniques, and incorporating textures, colors, and other details that are compatible with and enhance the surrounding area.

The project consists of a townhome community designed with a high level of aesthetic quality through the use of durable, high quality materials, including stucco, cementitious panels, treated wood siding, brick, and metal balcony railings. The materials, textures, and construction techniques are cohesively integrated into the building design and reflect a contemporary architectural design comparable to other projects in the surrounding vicinity. The proposed neutral muted color palette is compatible with surrounding development and is consistent with the Baylands Design Guidelines. Overall, the project’s design is compatible with the Baylands’ unique landscape character and the visual quality of the surrounding area.

4. The design is functional, allowing for ease and safety of pedestrian and bicycle traffic and providing for elements that support the building’s necessary operations (e.g. convenient vehicle access to property and utilities, appropriate arrangement and amount of open space and integrated signage, if applicable, etc.).

The project design provides a network of pedestrian and bicycle pathways that access a central green with a stage for community performances, grills, and a games area, pocket parks, and room for additional neighborhood amenities like a community garden. Vehicles would access the site through two entrances: one from Geng Road and the other from East Bayshore road. Bicycle parking is currently shown within each garage totaling 145 bike spaces and a centrally located bike rack on the project site. The proposed centrally located bike parking area holds 16 shortterm bike racks.

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9 5. The landscape design complements and enhances the building design and its surroundings, is appropriate to the site’s functions, and utilizes to the extent practical, regional indigenous drought resistant plant material capable of providing desirable habitat that can be appropriately maintained.

The project will provide a variety of drought-tolerant planting. A majority of the plantings were selected from a California native palette. The selected varieties of trees would provide appropriate habitat for wildlife as a part of a bigger neighborhood and community wide system.

Additional landscaping is provided in the common areas of the project.

6. The project incorporates design principles that achieve sustainability in areas related to energy efficiency, water conservation, building materials, landscaping, and site planning.

In accordance with the City’s Green Building Regulations, the project will satisfy the requirements for CALGreen Mandatory + Tier 2. This is demonstrated on the GB sheets in the plan set. The project also is designed to accommodate future recycled water improvements should they be available in the future, consistent with the municipal code requirements for this area.

SECTION 6. Vesting Tentative Map Findings. A legislative body of a city shall deny approval of a Parcel Map, if it makes any of the following findings (California Government Code Section 66474). The City Council cannot make these findings for the following reasons:

1. That the proposed map is not consistent with applicable general and specific plans as specified in Section 65451:

The site is consistent with the Comprehensive Plan as described below. There is no adopted specific plan for this project site.

2. That the design or improvement of the proposed subdivision is not consistent with applicable general and specific plans:

There is no adopted specific plan for this project site. The proposed vesting tentative map and related improvements is consistent with the Comprehensive Plan in that it facilitates housing development on a site designated for multi-family use within the urban services area, consistent with Goal 2 of the Housing Element and Goal L1.2 of the Land Use Element. The proposed density (13 DU/AC) is consistent with the allowance for multifamily residential in specified locations in the Research/Office Park land use designation of the Land Use Element.

The project replaces four existing office buildings with 145 for sale townhome units with thirteen percent of the units (19 units) deed restricted to serve low-income households.

Nineteen (19) units (13%) are designated to be provided at below-market rate (BMR) at a rate affordable to low-income households (80% of Area Median Income or below). The project improves the city’s jobs housing imbalance consistent with the Housing Element’s goals and Item 12
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10 policies.

3. That the site is not physically suitable for the type of development:

The Project site is suitable for multi-family residential development in that it’s located on a site designated on the City’s Land Use Map that allows for multi-family uses and identified as a housing inventory site in the Housing Element. The proposed resulting parcels meet the minimum code requirements for the ROLM(E) zone district with respect to lot area, width and depth. The proposed number of condominium units for the project site complies with the applicable densities set forth in the land use element.

4. That the site is not physically suitable for the proposed density of development:

The proposed development would create a total of 145 townhome residential units which is 13 dwelling units (DU) per acre (total project site is 11 acres). This density complies with the minimum and maximum allowable residential density as calculated for the total site area under the zoning code (11-20 DU/acre = 121-220 DU). Building, Palo Alto Fire Department, Planning, Transportation, Zero Waste, and Public Works Engineering have reviewed the requested density bonus waiver to permit a minimum 26-foot street width to ensure that all necessary requirements for safety, including but not limited to, fire safety and traffic safety (e.g. curb cut location, turning radius, etc.) have been met as well as to ensure that the street allows for proper function of the site (e.g. trash pickup).

5. That the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat:

The project site is located on the eastern side of Highway 101 adjacent to the Baylands Nature Preserve. The Baylands is an approximately 1,976-acre open space located along the edge of San Francisco Bay (Bay) including multiple habitats and a wide variety of recreational and educational benefits. However, the project site is located in an area of approximately 90 acres of industrial research, office, and commercial uses that are concentrated along Embarcadero Road and East Bayshore frontage road. The project design would incorporate lighting reduction design features to reduce the spillover of lighting or glare/increased luminance perceived by birds and other wildlife, in compliance with recommendations by the International Dark-Sky Association. Though the project proposes the removal of 218 on-site trees, the proposed project would also include the planting of 648 trees, which would gradually replace the existing foraging habitat on the site for native migratory birds as these trees gradually mature. The increase in the number of trees on site would also provide valuable foraging resources for migrating birds. Thus, in the long term, the project will continue to support foraging habitat for migrating birds along the San Francisco Bay. With incorporation of the standard conditions of approval, the project would have less than significant impacts on biological resources, the same Item 12
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11 as those identified in the 2017 EIR. Therefore, the project would not cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat.

6. That the design of the subdivision or type of improvements is likely to cause serious public health problems:

The subdivision of this parcel and associated improvements would not have the potential to result in serious health problems. The proposed multi-family use would not include use or storage of hazardous materials. The site is not located on a hazardous waste site pursuant to government code 65962.5.

7. That the design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements, for access or for use, will be provided, and that these will be substantially equivalent to ones previously acquired by the public. This subsection shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or use of property within the proposed subdivision.

There are no public access easements over the property currently. Therefore, the design of the subdivision will not conflict with any public access easements for access through, or use of, the property. Existing public utility easements would either continue to be used or otherwise vacated and new utility easements created as part of the mapping process to reflect modifications to the location of utility infrastructure.

SECTION 7. Vesting Tentative Map Approval Granted. Vesting Tentative Map Approval is filed and processed in accordance to PAMC Section 21.13.020 and granted by the City Council under PAMC Sections 21.12 and 21.20 and the California Government Code Section 66474, subject to the conditions of approval in Section 9 of this Record of Land Use Action.

SECTION 8. Final Map. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Vesting Tentative Map prepared by CBG Civil Engineers titled “Vesting Tentative Map 2100-2400 Geng Road For Condominium Purposes City of Palo Alto, California”, stamped as received January 30, 2026, except as modified to incorporate the conditions of approval in Section 9. A copy of the Vesting Tentative Map is on file in the Department of Planning and Development Services, Current Planning Division. Prior to the expiration of the Vesting Tentative Map approval, the subdivider shall cause the subdivision or any part thereof to be surveyed, and a Final Map, as specified in Chapter 21.08, to be prepared in conformance with the Vesting Tentative Map as conditionally approved, and in compliance with the provisions of the Subdivision Map Act and PAMC Title 21 and submitted to the City Engineer (PAMC Section 21.16.010[a]).

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12 SECTION 9. Conditions of Approval Site and Design Permit.

PLANNING DIVISION

1. CONFORMANCE WITH PLANS. Construction and development shall conform to the approved plans entitled, "2100-2400 Geng Road, Palo Alto, CA” stamped as received by the City on January 30, 2026, on file with the Planning Department, 250 Hamilton Avenue, Palo Alto, California except as modified by these conditions of approval.

2. BUILDING PERMIT. Apply for a building permit and meet any and all conditions of the Planning, Fire, Public Works, and Building Departments.

3. BUILDING PERMIT PLAN SET. A copy of this cover letter and conditions of approval shall be printed on the second page of the plans submitted for building permit.

4. PROJECT MODIFICATIONS. All modifications to the approved project shall be submitted for review and approval prior to construction. If, during the Building Permit review and construction phase, the project is modified by the applicant, it is the responsibility of the applicant to contact the Planning Division/project planner directly to obtain approval of the project modification. It is the applicant’s responsibility to highlight any proposed changes to the project and to bring it to the project planner’s attention.

5. LANDSCAPE PLAN. Plantings shall be installed in accordance with the approved plan set and shall be permanently maintained and replaced as necessary. Landscaping along the rear lot line between the project and Baylands Athletic Center shall be planted at a minimum height of 8 feet. The landscaping screen along the shared property line shall be maintained in accordance with the code requirements for objective standards.

6. NOISE THRESHOLDS ON RESIDENTIAL PROPERTY. In accordance with PAMC Section

9.10.030, No person shall produce, suffer or allow to be produced by any machine, animal or device, or any combination of same, on residential property, a noise level more than six dB above the local ambient at any point outside of the property plane.

7. OPEN AIR LOUDSPEAKERS (AMPLIFIED MUSIC). In accordance with PAMC Section 9.12, no amplified music shall be used for producing sound in or upon any open area, to which the public has access, between the hours of 11:00pm and one hour after sunrise.

8. PG&E ENCROACHMENT PERMIT. An encroachment permit is required prior to any temporary work or permanent improvements within PG&E easement. The project shall comply with any and all requirements of the encroachment permit.

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13 9. SIGN APPROVAL NEEDED. No signs are approved at this time. All signs, if proposed,shall conform to the requirements of Title 16.20 of the Palo Alto Municipal Code (Sign Code) and shall be subject to approval by the Director of Planning.

10. STANDARD REQUIREMENTS FOR UNANTICIPATED DISCOVERY OF BURIED ARCHEOLOGICAL RESOURCES. No known archeological or paleontological resources are present on or within the immediate vicinity of the site. However, as noted in the project description and per the City’s standard conditions, in the unlikely event that an archeological resource is unearthed during ground disturbing activities, work in the immediate area should be halted and an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for archeology (National Park Service 1983) shall be contacted immediately to evaluate the find. If the find is Native American in origin, then a Native American representative should also be contacted to participate in the evaluation of the find. The qualified archaeologist, and, if applicable, the Native American representative, shall examine the find and make recommendations regarding additional work necessary to evaluate the significance of the find and the appropriate treatment of the resource. Recommendations could include, but are not limited to, invasive or non-invasive testing, sampling, laboratory analysis, preservation in place, or data recovery. A report of findings documenting any data recovered during monitoring shall be prepared by a qualified archaeologist and submitted to the Director of Planning. Prior to commencement of any project-related construction activities, a qualified Archaeologist hired by the applicant shall provide a worker environmental awareness training to all site personnel that addresses cultural and tribal cultural resources. The training shall discuss the appearance of resources that may be encountered during construction as well as the procedures and notification process in the event of discovery.

11. RETENTION OF A QUALIFIED ARCHAEOLOGIST AND ARCHAEOLOGICAL MONITORING. Prior to the start of ground-disturbing activities, the Applicant and/or subsequent responsible parties shall retain an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards (NPS 2020a) (Qualified Archaeologist) to carry out all cultural resources related work associated with the project and to oversee the implementation of all cultural resources mitigation measures. The Qualified Archaeologist shall possess experience and familiarity with historic-period and prehistoric archaeological resources in the region. The Qualified Archaeologist or other designated archaeologist working under the direction of the Qualified Archaeologist shall conduct full-time monitoring within native sediments to the project’s proposed maximum depths of disturbance. In general, archaeological monitoring shall be limited to initial ground disturbance which is defined as construction-related earthmoving of sediments from their native place of deposition and does not include any secondary movement of sediment that might be required for the project. The Qualified Archaeologist may adjust monitoring efforts as needed (increase, decrease, or discontinue monitoring frequency) based on the observed potential for construction activities to encounter archaeological deposits. The archaeological monitor shall maintain daily monitoring logs. Following the completion of construction, the Item 12
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14 Qualified Archaeologist shall prepare an archaeological monitoring report for submittal to the lead agency and the NWIC with the results of the archaeological monitoring program.

12. STANDARD REQUIREMENTS FOR THE PROTECTION OF NESTING BIRDS. As detailed in the project description and per the City’s standard conditions, vegetation or tree removal shall be prohibited during the general avian nesting season (February 1 – August 31), if feasible.

If nesting season avoidance is not feasible, the applicant shall retain a qualified biologist, as approved by the City of Palo Alto, to conduct a preconstruction nesting bird survey to determine the presence/absence, location, and activity status of any active nests on or adjacent to the project site no more than 14 days prior to scheduled vegetation clearance and/or demolition activities. If nesting birds are found to be present, a suitable buffer (typically a minimum buffer of 50 feet for passerines and a minimum buffer of 250 feet for raptors) as determined appropriate by the biologist, shall be established around such active nests and no construction shall be allowed within the buffer areas until a qualified biologist has determined that the nest is no longer active (i.e., the nestlings have fledged and are no longer reliant on the nest). A report documenting any data recovered during monitoring shall be prepared by a qualified biologist and submitted to the Director of Planning prior to final planning inspection.

13. STANDARD REQUIREMENTS FOR PM10 and PM2.5 Emissions. The following conditions shall be implemented during all phases of construction to control dust and exhaust at the project site in compliance with the Comprehensive Plan Policy N-5.5:
• Water all exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) two times per day.
• Cover all haul trucks transporting soil, sand, and other loose material off-site. • Remove all visible mud or dirt track out onto adjacent public roads at least once per day using wet power vacuum street sweepers. The use of dry power sweeping is prohibited.
• Limit all vehicle speeds on unpaved roads to 15 miles per hour. • Pave all new roadways, driveways, and sidewalks as soon as possible. • Lay building pads as soon as possible after grading unless seeding or soil binders are used.
• Suspend all excavation, grading, and/or demolition activities when average wind speeds exceed 20 miles per hour.
• Wash off all trucks and equipment, including their tires, prior to leaving the site. • Post a publicly visible sign with the name and phone number of an on-site construction coordinator to contact regarding dust complaints. The on-site construction coordinator shall respond and take corrective action within 48 Item 12
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15 hours. The sign shall also provide the City’s Code Enforcement Complaints email and number and the Air District’s General Air Pollution Complaints number to ensure compliance with applicable regulations.

14. CONSTRUCTION EQUIPMENT. All construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. EPA Tier 4 Final emission standards for particulate matter (PM10 and PM2.5), if feasible. If Tier 4 Final equipment is not available for a particular piece of equipment, then use equipment that meets U.S. EPA emission standards for Tier 3 engines and include PM emissions control equivalent to CARB Level 3 verifiable diesel emission control devices that altogether achieve an 80 percent reduction in PM exhaust in comparison to uncontrolled equipment.

15. VIBRATION ANALYSIS. Prior to issuance of a demolition permit, a list of all heavy construction equipment to be used for this project known to produce high vibration levels (e.g., tracked vehicles, vibratory compaction, jackhammers, hoe rams, clam shovel drop, and vibratory roller, etc.) shall be submitted to the City by the contractor. This list shall be used to identify equipment and activities that would potentially generate substantial vibration and to define the level of effort for reducing vibration levels below the thresholds. • Smaller equipment (less than 18,000 pounds) shall be used near the property lines adjacent to sensitive buildings to minimize vibration levels to 0.3 in/sec PPV or less. For example, a smaller vibratory roller similar to a Caterpillar model CP433E vibratory compactor could be used when compacting materials within 20 feet of the adjacent conventional building. The smaller equipment intended to implement this requirement shall be individually identified among the list of equipment required under the above condition as the subset of equipment allowed for use at the property lines.
• Select demolition methods that do not involve large impact tools such as hoerams within 20 feet of the adjacent conventional building. Portable jackhammers, saws, or grinders shall be used to minimize impacts to the ground. • Avoid dropping heavy equipment and use alternative methods for breaking up existing pavement, such as a pavement grinder, instead of dropping heavy objects, within 20 feet of the adjacent conventional building. • Designate a Disturbance Coordinator responsible for registering and investigating claims of excessive vibration. The contact information for the responsible party shall be clearly posted on the construction site.

16. SITE MANAGEMENT PLAN. The project applicant shall retain a qualified environmental consultant, California Professional Geologist (PG) or California Professional Engineer (PE), to prepare a Site Management Plan (SMP) prior to construction. The SMP, or equivalent document, will be prepared to address onsite handling and management of impacted soils, soil vapor, groundwater, or other impacted wastes, and reduce hazards to Item 12
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16 construction workers and offsite receptors during construction. The plan shall establish remedial measures and/or soil management practices to ensure construction worker safety, the health of future workers and visitors, and the off-site migration of contaminants from the project site. These measures and practices may include, but are not limited to:
a. Stockpile management, including stormwater pollution prevention and the installation of BMPs
b. Proper disposal procedures of contaminated materials c. Monitoring, reporting, and regulatory oversight notifications d. A health and safety plan for contractors working at the project site that addresses the safety and health hazards of each phase of site construction activities with the requirements and procedures for employee protection e. The health and safety plan will also outline proper soil handling procedures and health and safety requirements to minimize worker and public exposure to hazardous materials during construction.

17. TREE CANOPY REPLACEMENT. Replacement of the tree canopy for the two trees located along the Geng Road frontage of the project proposed to be removed is required in accordance with Chapter 8 of the municipal code and the City’s Tree Technical Manual.

18. REFUSE. All trash areas shall be covered and maintained in an orderly state within private garages to prevent water from entering into the garbage container. No outdoor storage is allowed/permitted except when brought out to the street for pickup as shown in the plan set.

Trash areas shall be maintained in a manner to discourage illegal dumping.

19. BELOW MARKET RATE (BMR) HOUSING. This project is proposed as a Builder’s Remedy project, as defined in AB 1893, and is providing thirteen percent of the proposed units at prices affordable to lower income households. This also represents an alternative means of compliance with the City’s inclusionary housing requirement stated in Palo Alto Municipal Code Chapter 16.65. The applicant shall execute and record a BMR regulatory agreement in a form satisfactory to the City Attorney. The project shall conform to the approved regulatory agreement, which shall be recorded prior to issuance of building permit or final map, whichever occurs first. All BMR units constructed under this condition shall be in conformance with the City’s BMR Program rules and regulations, as modified by the concession granted pursuant to State Density Bonus Law regarding unit distribution.

Failure to comply with the timing of this condition and any adopted BMR Program rules and regulations shall not waive its later enforcement.

20. FEDERAL AVIATION ADMINISTRATION NOTICE OF PROPOSED CONSTRUCTION. The applicant shall notify the Federal Aviation Administration (FAA) as required by FAR Part 77, Subpart B on FAA Form 7460-1, Notice of Proposed Construction or Alteration, for the proposed project including temporary construction equipment, such as cranes. A copy of the submitted form shall be submitted to the City of Palo Alto Planning Division as well as Item 12
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17 a copy of the FAA’s response to this form.

21. ESTIMATED IMPACT FEE. Development Impact Fees, currently estimated in the amount of $8,306,259.10 plus the applicable public art fee, per PAMC 16.61.040, prior to the issuance of the related building permit(s). Impact fees may be paid at occupancy in accordance with the requirements under PAMC 16.64.030.

22. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020 provides that a project applicant who desires to protest the fees, dedications, reservations, or other exactions imposed on a development project must initiate the protest at the time the development project is approved or conditionally approved or within ninety (90) days after the date that fees, dedications, reservations or exactions are imposed on the Project. Additionally, procedural requirements for protesting these development fees, dedications, reservations and exactions are set forth in Government Code Section 66020.

IF YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD OR FOLLOW THE PROTEST PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION 66020, YOU WILL BE BARRED

FROM CHALLENGING THE VALIDITY OR REASONABLENESS OF THE FEES, DEDICATIONS, RESERVATIONS, AND EXACTIONS. If these requirements constitute fees, taxes, assessments, dedications, reservations, or other exactions as specified in Government Code Sections 66020(a) or 66021, this is to provide notification that, as of the date of this notice, the 90-day period has begun in which you may protest these requirements. This matter is subject to the California Code of Civil Procedures (CCP) Section 1094.5; the time by which judicial review must be sought is governed by CCP Section 1094.6

23. ENTITLEMENT EXPIRATION. The project approval shall be valid for a period of two years from the date of issuance of the entitlement. If within such period, the proposed use of the site or the construction of buildings has not commenced, the Planning entitlement shall expire. Application for a one-year extension of this entitlement may be made prior to expiration.

24. FINAL INSPECTION. A Planning Division Final inspection will be required to determine substantial compliance with the approved plans prior to the scheduling of a Building Division final. Any revisions during the building process must be approved by Planning, including but not limited to; materials, landscaping and hard surface locations. Contact your Project Planner, Steven Switzer at [email protected] to schedule this inspection.

25. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City Item 12
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18 may, in its sole discretion, elect to defend any such action with attorneys of its own choice.

PUBLIC ART

26. The applicant has selected to pay the public art in-leiu fee as an alternative to constructing public art on site. Prior to issuance of a building permit, the applicant shall pay the required in-lieu contribution to the Public Art Fund. The Public Art Program team will need to verify the Construction Valuation with an outside consultant. Contact the Public Art Program at the time you apply for Building permit to begin this verification process. All information and application materials may be found at paloalto.gov/public art under the Policies and Documents tab. In-lieu fees may be paid at occupancy in accordance with the requirements under PAMC 16.64.030.

PUBLIC WORKS ENGINEERING

27. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link:
https://www.paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-andPermits

28. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements.

29. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for improvements within the public right-of-way, any existing improvements to be re-used by the project, which are not to current City standards and are not specifically in these project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to current City standards as required by the Director of Public Works and the Director of Utilities.

30. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any changes or modifications to existing utilities, streets, and public infrastructure within or adjacent to the project site. This includes, but is not limited to, the relocation of utility facilities, conduits, or vaults required due to grade changes in the sidewalk area resulting from the development.

31. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for repairing any damage to existing public improvements fronting or adjacent to the project site caused by construction, to the satisfaction of the Public Works Department.

32. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible for researching all existing utility lines to ensure there are no conflicts with the project. Any Item 12
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19 existing utility lines (public or private) or their appurtenances that conflict with the project or do not serve it must be capped, abandoned, removed, relocated, or disposed of to the satisfaction of the City.

33. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines and appurtenances is subject to City review and approval. The Developer’s contractor shall expose the existing storm drain facilities during construction for City inspection or provide video documentation of their condition. Any deficient facilities, as determined by Public Works, must be replaced by the Developer.

34. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain tributary pattern. Any deviations require additional analysis and approval by Public Works during building plan review. The project shall not negatively impact the drainage pattern for adjacent properties.

35. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter

16.28. The permit application and all applicable documents (see Section H of application) shall be submitted to Public Works Engineering. Add the following note: “THIS GRADING

PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE SHOWN FOR

REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.”

36. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall including the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc.

37. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan.

38. SOILS ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide a soil grading report prepared by the soils engineer, including locations and elevation of field density tests, summaries of field and laboratory tests and other substantiating data, and comments on any changes made during grading and their effect on the recommendations made in the soils engineering Item 12
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20 investigation report. The soils engineer shall certify as to the adequacy of the site for the intended use.

39. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace and/or add connections to the City maintained storm drain system, then the applicant may be responsible for improvements to the system. These improvements may include, but not limited to, upsizing the storm drain facility, replacing or adding City standard catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR MANHOLES. The extent of required improvements will be at the public works staff discretion and shall be consistent with Storm Drain Master Plan and Public Works Construction Standards. Any work on the city's storm drain systems requires permits and inspection by Public Works inspectors.

40. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to provide CCTV inspection of the City’s storm drain facilities to verify that any lines were not broken, cracked or damaged during construction. The video shall be high resolution and done by professional who is familiar with the process and meticulous. A CCTV inspection video is required for new storm drain connection (s) to verify proper connections were made into the City’s system and that no construction material was left behind. Videos of storm drain system may also be required where construction occurred less than 5-ft from the city’s storm drain system. Videos shall be provided from structure to structure, such as manhole to manhole. Contractor may want to conduct their own inspection in advance of construction to verify the existing pipe integrity. If existing damages are located, they shall be reported to Public Works inspectors prior to the start of construction. If not reported, the contractor may be responsible to restore the pipe segment as determined by Public Works prior to final.

41. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS

BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”.

42. SWPPP: This proposed development will disturb more than one acre of land. Accordingly, the applicant shall apply for coverage under the State Water Resources Control Board’s (SWRCB) NPDES general permit for storm water discharge associated with construction activity. A Notice of Intent (NOI) shall be filed for this project with the SWRCB in order to obtain coverage under the permit. The General Permit requires the applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP). The applicant is required to submit two copies of the NOI and the draft SWPPP to the Public Works Department for review and approval prior to issuance of the building permit. The SWPPP should include both permanent, post-development project design features and temporary measures employed during construction.

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21 43. FLOOD ZONE: This project is in a FEMA Special Flood Hazard Area and shall comply with the requirements in Palo Alto Municipal Code Chapter 16.52 and the California Residential Code Section 322 (CRC 322).

44. CLOMR: Evidence that this document has been executed shall be provided prior to building permit issuance.

45. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way.

46. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit.

47. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet.

48. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11. Submit the following:
a. Provide a stamped and signed C.3 data form (April 2024 version) from SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/ b. Final stamped and signed letter confirming which documents were reviewed and that the project complies with Provision C.3 and PAMC 16.11.

49. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final.

50. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the building, the third-party reviewer shall submit to the City a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans.

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22 WASTE-GAS-WATER UTILITIES

PRIOR TO ISSUANCE OF DEMOLITION PERMIT

51. The applicant shall submit a request to disconnect utility services and remove meters. The utilities demo is to be processed within 10 working days after receipt of the request. The demolition permit will be issued by the building inspection division after all utility services and/or meters have been disconnected and removed.

52. The applicant shall submit a completed water-gas-wastewater service connection application - load sheet for the City of Palo Alto Utilities. The applicant must provide all the information requested for utility service demands (water in fixture units/g.p.m., gas in b.t.u.h, and sewer in fixture units/g.p.d.). The applicant shall provide the existing (prior) loads, the new loads, and the combined/total loads (the new loads plus any existing loads to remain).

53. The applicant shall submit improvement plans for utility construction. The plans must show the size and location of all underground utilities within the development and the public right of way including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts, sewer lift stations, and any other required utilities. Plans for new wastewater laterals and mains need to include new wastewater pipe profiles showing existing potentially conflicting utilities especially storm drain pipes, electric and communication duct banks. Existing duct banks need to be daylighted by potholing to the bottom of the duct bank to verify cross section prior to plan approval and starting lateral installation. Plans for new storm drain mains and laterals need to include profiles showing existing potential conflicts with sewer, water, and gas.

54. The applicant must show on the site plan the existence of any auxiliary water supply, (i.e. water well, gray water, recycled water, rain catchment, water storage tank, etc).

55. The applicant shall be responsible for installing and upgrading the existing utility mains and/or services, laterals as necessary to handle anticipated peak loads. This responsibility includes all costs associated with the design and construction for the installation/upgrade of the utility mains and/or services/laterals.

56. An approved reduced pressure principle assembly (RPPA backflow preventer device) is required for all existing and new water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPPA shall be installed on the owner's property and directly behind the water meter within 5 feet of the property line. RPPA's for domestic service shall be lead free. Show the location of the RPPA on the plans.

57. An approved reduced pressure detector assembly (RPDA backflow preventer device, STD.

WD-12A or STD. WD-12B) is required for all existing and new fire water connections from Item 12
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23 Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be installed on the owner's property and directly behind the City owned meter, within 5' (feet) of the property line or City Right of Way.

58. All backflow preventer devices shall be approved by the WGW engineering division.

Inspection by the city inspector is required for the supply pipe between the meter and the assembly.

59. The applicant shall pay the capacity fees and connection fees associated with new utility service/s or added demand on existing services. The approved relocation of services, meters, hydrants, or other facilities will be performed at the cost of the person/entity requesting the relocation.

60. If a new water service line installation for fire system usage is required. Show the location of the new water service on the plans. The applicant shall provide to the engineering department a copy of the plans for fire system including all fire department's requirements.

61. Each unit or building shall have its own water meter and gas meter shown on the plans.

Each parcel shall have its own water and gas service and sewer lateral connection shown on the plans.

62. A sewer lateral per lot is required. Show the location of the new sewer lateral on the plans. A profile of the sewer lateral is required showing any possible conflicts with storm, electric/communications ductbanks or other utilities.

63. All existing water, gas, and wastewater services/laterals that will not be reused shall be abandoned at the main per the latest WGW utilities standards.

64. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot be placed over existing water, gas, or wastewater mains/services. Maintain 1' horizontal clear separation from the vault/cabinet/concrete base to existing utilities as found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall be relocated from the plan location as needed to meet field conditions. Trees may not be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water services/or meters. New water or wastewater services/laterals/meters may not be installed within 10' of existing trees unless otherwise approved by water, gas, and wastewater utilities and Urban Forestry. Maintain 10' between new trees and new water and wastewater services/laterals/meters unless otherwise approved by water, gas, and wastewater utilities and Urban Forestry. If 10’ separation is not feasible, project will utilize root barrier protection and maintain 5’ of separation between trees and water and wastewater services/laterals/meters. If any tree shown on the planting plan cannot satisfy the Item 12
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24 required separation distances, and the Water, Gas, and Wastewater utilities and Urban Forestry do not approve a reduced separation standard that would accommodate the proposed planting, the Project shall not be required to plant that tree, provided that the total number of replacement trees otherwise meets the requirements of Palo Alto Municipal Code Chapter 8.10.

The following requirements apply for the offsite improvements of the City of Palo Alto water distribution system (including but not limited to water main, meter, hydrant, services, etc.):

65. Third-Party Beneficiary: the City of Palo Alto shall be a Third-Party Beneficiary of this Project.

66. Before building application approval, developer must prepare a hydraulic model of the planned drinking water utility improvements, and the developer shall complete the water system planning review application and submit to CPAU WGW development services group.

67. Before building application approval, the developer must submit detailed design plans for the new public water main on street B shown on the preliminary utility plan dated September 26, 2025 to the City of Palo Alto Utilities (CPAU) for review and approval.

68. Before building application approval, design plans must adhere to CPAU standards, guidelines, and revision comments set forth by the CPAU WGW Engineering Division.

Incorporate CPAU’s design comments into revised plans and resubmit for final approval.

69. Before building application approval, develop and submit for approval a phasing plan detailing construction of the new public water main, and abandonment of the existing public water main located in the existing easement adjacent to the Baylands Athletic Center. Phasing plan shall include work activities for abandonments, maintaining water service, and protection of public water mains.

70. The existing public water main located in the existing easement adjacent to the Baylands Athletic Center provides critical water flow and fire flow to the nearby City water distribution network. A public water main with the existing capacity shall always be in service during all phases of construction.

71. Permittee/Contractor warranty and “Guarantee to Repair Period a. In addition to the guarantee to repair referenced below and any specific warranty mentioned in the Project specifications, Permittee’s Contractor warrants that all materials and equipment used in or incorporated into the Project will be of good quality, new and free of liens, Claims and security interests of third parties; that all labor, installation, materials and equipment used or incorporated into the Project will be of good quality and free from defects; and that the Project will Item 12
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25 conform with the requirements of the Permit Documents and Applicable Code Requirements. If required, Permittee/Contractor shall furnish satisfactory evidence as to the kind and quality of materials and equipment. Manufactured items installed in the Project and not specifically covered in the Contract Documents are to be installed in strict accordance with manufacturers' current printed instructions.
b. The Guarantee to Repair Period will commence upon the first dates of actual occupancy or use of portions of the Project, as reflected in the City's final notice of acceptance.
c. City of Palo Alto “Guarantee to Repair Period”: Permittee/Contractor shall:
i. Correct defective work that becomes apparent during the progress of the work or during the Guarantee to Repair Period (one year from the City's Final Notice of Acceptance); and
ii. Replace, repair, or restore to City's satisfaction any other parts of the work and any other real or personal property which is damaged or destroyed as a result of defective work or the correction of defective work, without any expense whatsoever to City. City will give notice of observed defective work with reasonable promptness to the Permittee/Contractor, and Permittee/Contractor shall promptly commence such correction, replacement, repair or restoration upon notice from City, but in no case later than seven (7) Days after receipt of such notice. The Permittee/Contractor shall diligently and continuously prosecute such correction to completion. The Permittee/Contractor shall bear all costs of such correction, replacement, repair, or restoration and all losses resulting from such defective work, including additional testing, inspection and compensation for City's services and expenses. The Permittee/Contractor shall perform corrective work at such times that are acceptable to City and in such a manner as to avoid disruption, to the extent practicable. Ordinary wear and tear, unusual abuse, or neglect are excepted from this guarantee.

Permittee/Contractor shall notify City upon completion of repairs. The Insurance requirements from the City's Street Work Permit will apply throughout the Permittee/Contractors Guarantee to Repair period.

PUBLIC WORKS ELECTRIC UTILITIES

72. UTILITY EASEMENT REQUIRED. Prior to energization, a public utility easement is required to provide access to the proposed transformers. This can either be provided through separate instrument and documented on the tentative and final map or dedicated through the tentative and final map process.

73. UTILITIES APPLICATION. Changes to existing electric utilities equipment on site, such as the transformer, will require a utilities application. Submit a utilities application and obtain City Item 12
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26 of Palo Alto Utilities Electrical Engineering approval for the modifications to the electrical system.

74. UTILITY DISCONNECT. The applicant shall submit a request to disconnect all existing utility services proposed for removal, including a signed affidavit of vacancy, on the form provided by the Building Inspection Division. Utilities will be disconnected or removed within 10 working days after receipt of request. The demolition permit will be issued after all utility services and/or meters have been disconnected and, as applicable, removed.

75. UTILITIES SHOWN ON LANDSCAPE PLANS. All utility meters, lines, transformers, backflow preventers, and any other required equipment shall be shown on the landscape and irrigation plans and shall show that no conflict will occur between the utilities and landscape materials.

In addition, all aboveground equipment shall be screened in a manner that is consistent with the building design and setback requirements.

76. PERMIT. Contractors and developers shall obtain permit from the Department of Public Works before digging in the street right-of-way. This includes sidewalks, driveways and planter strips.

77. UNDERGROUND SERVICES ALERT. At least 48 hours prior to starting any excavation, the customer must call Underground Service Alert (USA) at 1-800-227-2600 to have existing underground utilities located and marked. The areas to be checked for underground facility marking shall be delineated with white paint. All USA markings shall be removed by the customer or contractor when construction is complete.

78. CITY STANDARDS. All new underground conduits and substructures shall be installed per City standards and shall be inspected by the Electrical Underground Inspector before backfilling.

PUBLIC WORKS ZERO WASTE

79. REQUIRED DECONSTRUCTION. In conformance with PAMC 5.24, deconstruction and source separation are required for all residential and commercial projects where structures (other than a garage or ADU) are being completely removed, demolition is no longer allowed.

Deconstruction takes longer than traditional demolition, it is important to plan ahead. For more information, visit www.paloalto.gov/deconstruction.

80. SALVAGE SURVEY FOR REUSE. A Salvage Survey is required for deconstruction permit applications. The survey shall be conducted by a City approved reuse vendor. The survey submittal shall include an itemized list of materials that are salvageable for reuse from the project. The applicant shall source separate and deliver materials for reuse. Certification is required indicating that all materials identified in the survey are properly salvaged. Contact The ReUse People to schedule this FREE survey by phone (888) 588-9490 or e-mail Item 12
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27 [email protected]. More information can be found at www.TheReusePeople.org.

Please upload a completed copy to the deconstruction permit.

81. SOURCE SEPARATION FOR RECYCLING. The applicant shall source separate deconstruction materials into specific categories for recycling. Additional staging areas for source separated materials will need to be considered. All materials shall be delivered to one of the City approved materials recovery facilities listed in Green Halo, all records shall be uploaded to www.greenhalosystems.com. For more information, refer to www.paloalto.gov/deconstruction.

PUBLIC WORKS WATER QUALITY
PRIOR TO THE ISSUANCE OF ANY BUILDING PERMIT:

82. Stormwater treatment measures:
a. All Bay Area Municipal Regional Stormwater Permit requirements shall be followed. b. Refer to the Santa Clara Valley Urban Runoff Pollution Prevention Program C.3 Handbook (download here: http://scvurppp-w2k.com/c3_handbook.shtml) for details.

83. Stormwater quality protection:
a. Temporary and permanent waste, compost and recycling containers shall be covered to prohibit fly-away trash and having rainwater enter the containers. b. Drain downspouts to landscaping (outward from building as needed). c. PAMC 16.09.180(b)(5) Condensate from HVAC -Condensate lines shall not be connected or allowed to drain to the storm drain system. Drain HVAC fluids from roofs and other areas to landscaping.
d. Offsite downgrade storm drain inlets shall also be identified on this plan set and protected. If City staff removes protection from an inlet in the ROW during a rain event, the contractor shall replace the inlet protection by the end of the following business day.

PUBLIC WORKS URBAN FORESTRY

84. URBAN FORESTRY STANDARD CONDITIONS: In addition to any project specific Urban Forestry Conditions of Approval listed here, the Urban Forestry Standard Conditions listed on the T-1 Sheet Set included in the plans for this project still apply.

85. MODEL WATER EFFICIENT LANDSCAPE ORDINANCE (MWELO): During the permit phase of the project, applicant must provide all components of an MWELO submission for review.

Please see the document titled “Model Water Efficient Landscape Ordinance (MWELO) Compliance Submittals and Guidelines”
(https://paloalto.gov/civicax/filebank/documents/76159) to determine the specific submission requirements for the project scope. Please follow the instructions in the above Item 12
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28 document when submitting your MWELO package as part of the permit application and plan set.

86. TREE PROTECTION COMPLIANCE: The owner and contractor shall implement all tree protection, tree inspection schedules, design recommendations, construction impact mitigation measures, and construction scheduling as stated in the Preliminary Arborist Report by Hort Science Bartlett Consulting dated August 2025 and any standard measures listed in the T-1 Sheet Set, and is subject to code compliance action pursuant to PAMC

8.10.080. The required protective fencing shall remain in place until final landscaping and inspection of the project.

87. PROJECT ARBORIST REQUIRED: The property owner or contractor shall hire a designated arborist to ensure the project conforms to all Planning and Urban Forestry conditions related to landscaping/trees. The project arborist must be included in a mandatory preconstruction meeting and be present during any rough grading and trenching activities occurring within 10-feet of a Tree Protection Zone, and for any approved activities inside a Tree Protection Zone.

88. PROJECT ARBORIST CERTIFICATION FORM REQUIRED: During the building permit phase, the project arborist must submit an online form
[https://us.openforms.com/Form/2262bf1ac26f-4c04-8daa-15dbd9c8e08e] certifying that they have reviewed the building permit plan set with regards to trees as well as any Urban Forestry Conditions of Approval, and that all requirements have been met. The letter also confirms that any required site monitoring inspections and reporting have been arranged in advance with the contractor or owner. Project Arborist Certification Forms should be included as supporting documents when submitting an application for a building permit that required prior approval through Planning (See Project Arborist Certification Form, TLTM Section 5.03.5).

89. MONTHLY ARBORIST INSPECTIONS REQUIRED: The project arborist shall perform monthly inspections to monitor changing conditions and tree health. The Urban Forester shall be in receipt of an inspection summary during the first week of each calendar month or, immediately if there are any changes to the approved plans or protection measures.

Reports should be submitted via the online form
[https://us.openforms.com/Form/ca5003f1-6836-4789-b534-b4dff1d457b1] (see Tree Monitoring Reports, TLTM Section 5.03.6).

90. ONSITE TREE REMOVAL AUTHORIZATION AND REQUIRED REPLACEMENT. The Project is authorized to remove up to 218 trees. This project approval incorporates a Tree Removal Permit for removal of these trees. The Project shall replace the removed trees by planting approximately 648 trees total. Replacement planting shall be provided in compliance with Palo Alto Municipal Code Chapter 8.10 (Tree and Landscape Preservation and Management). At least 50 percent of the replacement trees shall be California native Item 12
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29 species. The final replacement species mix, tree sizes, and planting locations shall be subject to review and approval by the Planning Division and Urban Forestry prior to issuance of building permits.

91. OFFSITE TREE REMOVAL AUTHORIZATION AND REQUIRED REPLACEMENT. The project is authorized to remove two protected offsite street trees, as shown on the Plans. This project approval incorporates a Tree Removal Permit for removal of these trees.

92. REQUIRED STREET TREES: Based on plans submitted with this application, a minimum of five (5) new street trees will be required. These trees must be a minimum of 24” Box size and be planted per City of Palo Alto Standard Drawings 603 or 604 depending on planting locations.

Irrigation to new street trees is required per City of Palo Alto Standard Drawings 510 or 513 depending on planting locations.

93. CITY TREE REMOVAL REQUIREMENTS. The City adopted Ordinance No. ____ authorizing and approving a process to remove certain City-owned eucalyptus trees at/near the Baylands Athletic Center (“City Trees”) if impacted by Project grading, and requiring the Applicant to comply with certain monitoring and reporting requirements, and pay a tree-replacement contribution to fund replacement plantings, as set forth below. a. UPDATED ARBORIST REPORT PRIOR TO GRADING PERMIT. In connection with submittal of Project grading permit application(s) involving work along the shared boundary with the Baylands Athletic Center, the Applicant shall submit to the City’s Urban Forestry Section (“Urban Forestry”) an updated arborist report prepared by a certified arborist identifying any City Trees located on the Baylands Athletic Center property that must be removed to facilitate grading or site access. Upon application to and review by Urban Forestry, Urban Forestry shall issue a Tree Removal Permit under PAMC section 8.04.040 for those City Trees identified where the Tree Protection Zone is so impacted that the tree will be prone to become unstable or unlikely to survive and otherwise in compliance with the requirements in PAMC Ch. 8.04. The scope of Urban Forestry’s review shall be limited to making this determination. Applicant shall be responsible for removal of the City Tree(s) to be removed. Applicant shall notify Urban Forestry at least 14 calendar days in advance of any scheduled tree removals. b. MONITORING AND REPORTING OF REMAINING TREES. During grading activities, the Applicant shall retain a licensed arborist to be present for any excavation work within the Tree Protection Zones of any City Tree. During active grading work, the arborist shall conduct monthly inspections of the remaining City Trees.

Upon completion of grading, the arborist shall conduct quarterly inspections of the remaining City Trees for the duration of Project construction. The purpose of such inspections shall be to assess City Tree health and identify any City Trees that either (a) pose an imminent hazard to public health or safety, or (b) are Item 12
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30 unlikely to survive as a result of grading impacts. For City Trees that pose an imminent hazard to public health or safety, Applicant shall notify Urban Forestry (including its on-call staff if after hours) and shall remove the tree after receiving a Tree Removal Permit or other City authorization, including over-the-phone approval for emergency issues. For any City Tree that is unlikely to survive as a result of grading impacts, Applicant shall remove any such City Tree following application and issuance of a Tree Removal Permit by Urban Forestry. Applicant shall notify Urban Forestry at least 14 calendar days in advance of any such tree removal.
c. TREE REPLACEMENT CONTRIBUTION. Prior to issuance of a Certificate of Occupancy for the Project, the Applicant shall remit to the City payment for replacement of the City Trees (the “Tree Replacement Contribution”). The Tree Replacement Contribution shall be calculated based on the canopy width of the City Trees that were removed using Table 3-1 of the City of Palo Alto’s Tree Technical Manual. The canopy width of the City Trees shall be based on the canopy width as measured in the Arborist Report described in Recital E. The Tree Replacement Contribution shall be $1,250 per each 24” box tree required. Urban Forestry Section and Parks Golf and Open Space shall use these funds to plant and establish replacement trees on the BAC property.

SECTION 10. Conditions of Approval Conditional Use Permit.

Planning

1. CONFORMANCE WITH PLANS. The use of the site shall include up to 145 residential units in accordance with the approved plans entitled, "2100-2400 Geng Road, Palo Alto, CA” stamped as received by the City on January 30, 2026 , on file with the Planning Department, 250 Hamilton Avenue, Palo Alto, California except as modified by these conditions of approval.

2. NUISANCES AND NOISE. Noise levels shall not exceed the maximum level established in the PAMC Chapter 9.10.

3. LIGHTING. The owner or designee shall ensure that lighting is the minimum necessary and shielded downward to avoid light spillover as shown in the approved plan set.

4. COMMON AREA LIGHTING. Light fixtures shall come on at dusk and off at dawn. Lighting shall have continuous dimming capability to maintain design footcandles when areas are occupied or not.

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31 5. REVOCATION OF APPROVAL. The director may issue a notice of noncompliance for any failure to comply with any condition of this permit approval, or when a use conducted pursuant to a Conditional Use Permit is being conducted in a manner detrimental to the public health, safety, and welfare.

6. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice.

7. FINAL INSPECTION. A Planning Division Final inspection will be required to determine substantial compliance with the approved plans prior to the scheduling of a Building Division final. Any revisions during the building process must be approved by Planning, including but not limited to; materials, landscaping and hard surface locations. Contact your Project Planner, Steven Switzer at [email protected] to schedule this inspection.

SECTION 11. Conditions of Approval Vesting Tentative Map.

Planning

1. PROJECT PLANS. The Vesting Tentative Map submitted for review and approval by the City Council shall be in substantial conformance with the Vesting Tentative Map titled “Vesting Tentative Map 2100-2400 Geng Road For Condominium Purposes City of Palo Alto, California”, prepared by CBG Civil Engineers and submitted January 30, 2026, except as modified to incorporate the conditions of this approval.

2. FINAL MAP COVER PAGE. At such time as the Final Map is filed, the cover page shall include the name and title of the Director of Planning and Development Services.

3. STANDARD CC&R REQUIREMENTS. Section 16.38 of Palo Alto’s Municipal Code provides that all condominium and other “community housing projects” shall submit Covenants, Conditions and Restrictions (CC&R’s) to the City Attorney for approval before issuance of the Final Map. The City Attorney has developed the following standard covenants which shall be included in all CC&R’s.
a. PROPERTY SHALL COMPLY WITH CITY ZONING ORDINANCES. The property, including all common areas within the property, shall at all times comply with Item 12
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32 the City’s Zoning Code and shall not be used for any purpose other than as permitted in the City Zoning Code.
b. MODIFICATIONS TO PROPERTY. Any alterations, modifications, or other improvements to the property shall comply with all applicable City Codes. c. MAINTENANCE AND LANDSCAPING OF COMMON AREAS. The Association is responsible for maintenance and landscaping of all parts of the community housing project which are held in common and such maintenance shall be performed to the standard of maintenance prevalent in the neighborhood. (See PAMC Section 16.38.030(a)).
d. TERMINATION OF MANAGER OR MAINTENANCE CONTRACTS. The association may terminate the contract of any person or organization engaged by the developer to perform management or maintenance duties three months after the association assumes control of the community housing project or any time thereafter. (See PAMC Section 16.38.030(b).) e. PROTECTION OF STORM WATER FACILITIES. Neither the association, its residents, nor their agents, employees, representatives, invitees, licensees, customers, or contractors shall alter or modify any storm water facilities in any way including but not limited to placing, maintaining, constructing, or planting any improvements, landscaping or other items, including without limitation decks, stairs, walls, irrigation systems, trees, or any vegetation on any storm water facilities.
f. TRASH DISPOSAL AND RECYCLING AREAS SHALL COMPLY WITH CITY ORDINANCES. All trash disposal and recycling areas shall be kept in a clean and sanitary condition and shall comply with all applicable City Ordinances. g. PROHIBITION AGAINST AIR AND WATER POLLUTION. Neither the association, its residents, nor their agents, employees, representatives, invitees, licensees, customers, or contractors shall use the property in any way which emits pollution into the atmosphere in excess of environmental standards set forth by City, State, and Federal laws, ordinances, and regulations. Neither the association, its residents, nor their agents, employees, representatives, invitees, licensees, customers, or contractors shall discharge garbage, trash, waste, or any other substance or materials of any kind into any private or public sewer or waterway on the property in violation of any regulations of any private or public body having jurisdiction over such matters. h. AMENDMENTS TO ORGANIZATION DOCUMENTS REQUIRE CITY APPROVAL.

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33 submitted to the city attorney for approval. No amendment or modification to the organizational documents shall be effective without prior written consent of the city attorney.
i. CITY’S RIGHT TO ENFORCE COVENANTS AND RESTRICTIONS. The City is hereby granted the right, but in no event the duty, to enforce the covenants and restrictions set forth in this section of the organizational documents. The association shall recognize that it has the primary responsibility for enforcement of the organizational documents and unequivocally guarantees to institute and expeditiously prosecute any required legal action to obtain compliance with all provisions set forth in the organizational documents. j. NO WAIVER OF CITY’S RIGHTS. No failure of the City to enforce any of the covenants or restrictions contained in the organizational documents will in any event render them ineffective.
k. CITY’S REMEDIES TO CURE A BREACH OR VIOLATION. Remedies available to the City to cure any breach or violation of the organizational documents shall be cumulative to any other provisions of law. The City’s failure to exercise any remedy provided for in the organizational documents shall not, under any circumstances, be construed as a waiver of the remedy. l. SEVERABILITY. Invalidation of any one of the City’s required covenants or restrictions by judgment or court order shall in no way affect any other provisions which shall remain in full force and effect.

4. ADDITIONAL CC&R REQUIREMENT. The CC&Rs shall also include a provision that dictates the responsibilities of residents for the trash pickup for the townhomes as shown in the approved plan set.

5. AVIGATION EASEMENT. Dedication of an avigation easement to the County of Santa Clara shall be required prior to building permit issuance. All such easements shall be similar to that shown as Exhibit 1 in Appendix A of the Palo Alto Airport Comprehensive Land Use Plan (CLUP).
https://plandev.santaclaracounty.gov/hearings-and-committees/airport-land-usecommission

6. AVIGATION DEED NOTICE. Prior to building permit issuance a deed notice shall be required to be recorded with the County Clerk-Recorder disclosing that the property is subject to routine overflights and associated noise and other impacts by aircraft operating at a nearby airport. The deed notice shall be similar to that shown in Exhibit 2 in Appendix A of the Palo Alto Airport Comprehensive Land Use Plan (CLUP).

Item 12
Attachment B - Draft Record
of Land Use Action
Item 12: Staff Report Pg. 45 Packet Pg. 487 of 1140
DRAFT
34 https://plandev.santaclaracounty.gov/hearings-and-committees/airport-land-usecommission

7. DEVELOPMENT IMPACT FEES. The Property Owner or their designee shall pay all applicable development impact fees associated with the proposed development and subdivision, as detailed in the Site and Design Approval Conditions. At the time of the final map. parkland dedication in-lieu fees shall be required to be paid or may be deferred to occupancy in accordance with the requirements under PAMC 16.64.030.

8. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice.

Public Works Engineering

9. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link:
https://www.paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-andPermits

10. SUBDIVISION IMPROVEMENT AGREEMENT: The applicant shall execute a Subdivision Improvement Agreement and provide improvement securities (Bonds) for all proposed public improvements. THE AGREEMENT SHALL BE EXECUTED PRIOR TO MAP

RECORDATION OR ISSUANCE OF ANY PERMITS FOR CONSTRUCTION, ONSITE AND OFFSITE. ADVISORY -- The applicant shall provide a detailed itemized stamped and signed engineer's estimate for all off-site public improvements which will be reviewed to determine the security amount.

11. FINAL MAP: This project is subject to, and contingent upon the approval of a tentative map and recordation of a Final Map. The submittal, approval and recordation of the Map shall be in accordance with the provisions of the California Subdivision Map Act and Palo Alto Municipal Code Title 21 Subdivision requirements. All existing and proposed property lines, easements, dedications shown on the tentative map are subject to City’s technical review and staff approval during the map process prior to issuance of any construction permits.

Item 12
Attachment B - Draft Record
of Land Use Action
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DRAFT
35 12. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements.

13. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for improvements within the public right-of-way, any existing improvements to be re-used by the project, which are not to current City standards and are not specifically in these project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to current City standards as required by the Director of Public Works and the Director of Utilities.

14. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any changes or modifications to existing utilities, streets, and public infrastructure within or adjacent to the project site. This includes, but is not limited to, the relocation of utility facilities, conduits, or vaults required due to grade changes in the sidewalk area resulting from the development.

15. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for repairing any damage to existing public improvements fronting or adjacent to the project site caused by construction, to the satisfaction of the Public Works Department.

16. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible for researching all existing utility lines to ensure there are no conflicts with the project.

Any existing utility lines (public or private) or their appurtenances that conflict with the project or do not serve it must be capped, abandoned, removed, relocated, or disposed of to the satisfaction of the City.

17. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines and appurtenances is subject to City review and approval. The Developer’s contractor shall expose the existing storm drain facilities during construction for City inspection or provide video documentation of their condition. Any deficient facilities, as determined by Public Works, must be replaced by the Developer.

18. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain tributary pattern. Any deviations require additional analysis and approval by Public Works during plan review. The project shall not negatively impact the drainage pattern for adjacent properties.

19. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter

16.28. The permit application and all applicable documents (see Section H of application) shall be submitted to Public Works Engineering. Add the following note:
“THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE Item 12
Attachment B - Draft Record
of Land Use Action
Item 12: Staff Report Pg. 47 Packet Pg. 489 of 1140
DRAFT
36 SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.”

20. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall including the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc.

21. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan.

22. SOILS ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide a soil grading report prepared by the soils engineer, including locations and elevation of field density tests, summaries of field and laboratory tests and other substantiating data, and comments on any changes made during grading and their effect on the recommendations made in the soils engineering investigation report. The soils engineer shall certify as to the adequacy of the site for the intended use.

23. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace and/or add connections to the City maintained storm drain system, then the applicant may be responsible for improvements to the system. These improvements may include, but not limited to, upsizing the storm drain facility, replacing or adding City standard catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR MANHOLES. The extent of required improvements will be at the public works staff discretion and shall be consistent with Storm Drain Master Plan and Public Works Construction Standards. Any work on the city's storm drain systems requires permits and inspection by Public Works inspectors.

24. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to provide CCTV inspection of the City’s storm drain facilities to verify that any lines were not broken, cracked or damaged during construction. The video shall be high resolution and done by professional who is familiar with the process and meticulous. A CCTV inspection video is required for new storm drain connection (s) to verify proper connections were made into the City’s system and that no construction material was left behind. Videos of storm drain system may also be required where construction occurred less than 5-ft from the city’s storm drain system. Videos shall be provided from structure Item 12
Attachment B - Draft Record
of Land Use Action
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DRAFT
37 to structure, such as manhole to manhole. Contractor may want to conduct their own inspection in advance of construction to verify the existing pipe integrity. If existing damages are located, they shall be reported to Public Works inspectors prior to the start of construction. If not reported, the contractor may be responsible to restore the pipe segment as determined by Public Works prior to final.

25. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS

BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”.

26. SWPPP: This proposed development will disturb more than one acre of land.

Accordingly, the applicant shall apply for coverage under the State Water Resources Control Board’s (SWRCB) NPDES general permit for storm water discharge associated with construction activity. A Notice of Intent (NOI) shall be filed for this project with the SWRCB in order to obtain coverage under the permit. The General Permit requires the applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).

The applicant is required to submit two copies of the NOI and the draft SWPPP to the Public Works Department for review and approval prior to issuance of the building permit. The SWPPP should include both permanent, post-development project design features and temporary measures employed during construction.

27. FLOOD ZONE: This project is in a FEMA Special Flood Hazard Area and shall comply with the requirements in Palo Alto Municipal Code Chapter 16.52 and the California Residential Code Section 322 (CRC 322).

28. CLOMR: Evidence that this document has been executed shall be provided prior to building permit issuance.

29. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way.

30. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit.

Item 12
Attachment B - Draft Record
of Land Use Action
Item 12: Staff Report Pg. 49 Packet Pg. 491 of 1140
DRAFT
38 31. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet.

32. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11.

Submit the following:
c. Provide a stamped and signed C.3 data form (April 2024 version) from SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/ d. Final stamped and signed letter confirming which documents were reviewed and that the project complies with Provision C.3 and PAMC 16.11.

33. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final.

34. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the building, the third-party reviewer shall submit to the City a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans.

SECTION 12. Terms of Approval.

1. Site and Design Application. In the event actual construction of the project is not commenced within two years of the date of council approval, the approval shall expire and be of no further force or effect. An extension may be granted in accordance with the allowances set forth in the municipal code and state law.

2. Conditional Use Permit. The project approval shall be valid for a period of two years from the original date of approval. In the event the use does not commence within the time limit specified above, the approval shall expire and be of no further force or effect.

An extension may be granted in accordance with the allowances set forth in the municipal code. Additionally, following commencement, a Use Permit that has not been used for a period of one (1) year or more shall become null and void (PAMC 18.77.100).

3. Vesting Tentative Map. All conditions of approval of the Vesting Tentative Map shall be fulfilled prior to approval of a Final Map (PAMC Section 21.16.010[c]). Unless a Final Map is filed, and all conditions of approval are fulfilled within a two-year period from the date of Vesting Tentative Map approval, the Vesting Tentative Map shall expire and Item 12
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DRAFT
39 all proceedings shall terminate. An extension may be granted in accordance with the allowances set forth in the municipal code and the Subdivision Map Act. //
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INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST: APPROVED:
_________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM:
___________________________ ___________________________ Assistant City Attorney City Manager
Item 12
Attachment B - Draft Record
of Land Use Action
Item 12: Staff Report Pg. 51 Packet Pg. 493 of 1140
DRAFT
40 ____________________________
Director of Planning and
Development Services
PLANS AND DRAWINGS REFERENCED:

Those plans titled “C5_2100-2400 Geng Road” consisting of 101 pages, dated and submitted January 30, 2026.

Those plans titled “C5_2100-2400 Geng Road VTM PLANS ” consisting of 12 pages, dated and submitted January 30, 2026.

A copy of these plans are on file with the Department of Planning and Development Services.

Item 12
Attachment B - Draft Record
of Land Use Action
Item 12: Staff Report Pg. 52 Packet Pg. 494 of 1140

NOT YET APPROVED
1 152_20260302_ts24
Ordinance No. ____
Ordinance of the Council of Authorizing Work in the Baylands Related to the Adjacent Development at 2100-2400 Geng Road (24-PLN-00356) The Council of the City of Palo Alto does ORDAIN as follows:

SECTION 1. Findings and Declarations. The City Council finds and declares as follows:

A. Strada Investment Group, on behalf of San Francisco No. 69 LLC (collectively, the “Applicant”), has proposed a housing development project located at 2100–2400 Geng Road that would redevelop an existing approximately 11-acre site currently improved with office buildings and surface parking lots with approximately 145 multifamily townhome units, including 19 below-market-rate units, and community open spaces, as more detailed in City Planning Permit Application 24-PLN-00356 (the “Project”);
B. CEQA review on the Project (including the plan in this ordinance) has been conducted and is exempt under CEQA regulation 15183;
C. The Project site is located adjacent to the Baylands Athletic Center (“BAC”), a Cityowned public recreation facility within the City’s Baylands open space, which is dedicated parkland under PAMC section 22.08.020 et seq; D. Article VIII of the Charter of the City of Palo Alto and Section 22.08.005 of the Palo Alto Municipal Code (PAMC) require that, before any substantial building, construction, reconstruction or development is commenced or approved, upon or with respect to any land held by the City for park purposes, the Council shall first cause to be prepared and by ordinance approve and adopt a plan therefor; E. To comply with the Federal Emergency Management Agency (FEMA) and the City of Palo Alto’s floodplain management requirements pursuant to Title 16 of the Palo Alto Municipal Code (PAMC), the Project site must be elevated by importing soil ranging from approximately one (1) to six (6) feet in depth across the site; F. An Arborist Report prepared for the Project by HortScience | Bartlett Consulting, dated August 2025 (Attached as Exhibit A) identifies approximately forty-five (45) non-native Blue Gum Eucalyptus (Eucalyptus globulus) trees located on the southern edge of the Baylands Athletic Center adjacent to the Project site (the “City Trees”) that may be impacted by Project-related grading and construction activity; G. According to the Arborist Report, thirty-one (31) of the City Trees are in “poor” condition and fourteen (14) are in “fair” condition;
H. The exact number of City Trees that will be impacted by Project construction cannot be determined until final grading plans are prepared and implemented; I. The City and the Applicant desire to establish a mutually acceptable monitoring and replacement plan to address potential impacts to City Trees during Project construction, consistent with the goals of the City’s Tree Preservation Ordinance (PAMC Chapter 8.10) and the City’s Urban Forestry Guidelines; and J. Unless directed otherwise by the City Council, the City’s Urban Forestry Section and Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 53 Packet Pg. 495 of 1140

NOT YET APPROVED
2 Community Services Department shall use the funds received from the Applicant under this Project to plant and establish replacement trees on City-maintained property east of 101 within a maximum distance of 1 mile from the BAC property.

Replanting efforts will focus on the area around the Baylands Athletic Center first and spread to other Baylands Open Space areas when additional sites are needed.

Tree species selection for replacement trees will include a minimum of two thirds (2/3) climate smart native species compatible with the Baylands habitat zone.

SECTION 2. The City Council hereby approves the following Plan under Article VIII (Parks) of the City Charter and PAMC section 22.08.005 for the removal of certain City Trees in the Baylands under the following provisions:

1. Updated Arborist Report Prior to Grading Permit
In connection with submittal of Project grading permit application(s) involving work along the shared boundary with the Baylands Athletic Center, the Applicant shall submit to the City’s Urban Forestry Section (“Urban Forestry”) an updated arborist report prepared by a certified arborist identifying any City Trees located on the Baylands Athletic Center property that must be removed to facilitate grading or site access. Upon application to and review by Urban Forestry, Urban Forestry shall issue a Tree Removal Permit under PAMC section 8.04.040 for those City Trees identified where the Tree Protection Zone is so impacted that the tree will be prone to become unstable or unlikely to survive and otherwise in compliance with the requirements in PAMC Ch. 8.04. The scope of Urban Forestry’s review shall be limited to making this determination. Applicant shall be responsible for removal of the City Tree(s) to be removed. Applicant shall notify Urban Forestry at least 14 calendar days in advance of any scheduled tree removals.

2. Monitoring and Reporting of Remaining Trees
During grading activities, the Applicant shall retain a licensed arborist to be present for any excavation work within the Tree Protection Zones of any City Tree. During active grading work, the arborist shall conduct monthly inspections of the remaining City Trees. Upon completion of grading, the arborist shall conduct quarterly inspections of the remaining City Trees for the duration of Project construction.

The purpose of such inspections shall be to assess City Tree health and identify any City Trees that either (a) pose an imminent hazard to public health or safety, or (b) are unlikely to survive as a result of grading impacts. For City Trees that pose an imminent hazard to public health or safety, Applicant shall notify Urban Forestry (including its on-call staff if after hours) and shall remove the tree after receiving a Tree Removal Permit or other City authorization, including over-the-phone approval for emergency issues. For any City Tree that is unlikely to survive as a result of grading impacts, Applicant shall remove any such City Tree following application and issuance of a Tree Removal Permit by Urban Forestry. Applicant shall notify Urban Forestry at least 14 calendar days in advance of any such tree removal.

Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 54 Packet Pg. 496 of 1140

NOT YET APPROVED
3 3. Tree Replacement Contribution
Prior to issuance of a Certificate of Occupancy for the Project, the Applicant shall remit to the City payment for replacement of the City Trees (the “Tree Replacement Contribution”). The Tree Replacement Contribution shall be calculated based on the canopy width of the City Trees that were removed using Table 3-1 of the City of Palo Alto’s Tree Technical Manual. The canopy width of the City Trees shall be based on the canopy width as measured in the Arborist Report described in Recital E. The Tree Replacement Contribution shall be $1,250 per each 24” box tree required. Urban Forestry Section and Parks Golf and Open Space shall use these funds to plant and establish replacement trees on the BAC property.

SECTION 3. Other Requirements. This ordinance serves as approval for the Plan described above for the purposes of compliance with Article VIII of the City Charter and PAMC

22.08.005. This ordinance does not fulfill any other requirement as may be required by law, including but not limited to: encroachment permits, grading permits, building permits, and tree removal permits. This ordinance does not waive compliance with such requirements and Applicant remains responsible for compliance.

SECTION 4. CEQA. CEQA review on the Project (including the plan in this ordinance) has been conducted and is exempt under CEQA regulation 15183.

SECTION 5. Severability. If any provision, clause, sentence or paragraph of this ordinance, or the application to any person or circumstances, shall be held invalid, such invalidity shall not affect the other provisions of this Ordinance which can be given effect without the invalid provision or application and, to this end, the provisions of this Ordinance are hereby declared to be severable.
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Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 55 Packet Pg. 497 of 1140

NOT YET APPROVED
4 SECTION 6. Effective Date. This ordinance shall be effective on the 31st day after adoption.

INTRODUCED:

PASSED:

AYES:

NOES:

ABSTENTIONS:

ABSENT:

ATTEST:
____________________________ ____________________________ City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________ Assistant City Attorney City Manager
____________________________
Director, Community Services Department
____________________________
Director, Planning & Development Services
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 56 Packet Pg. 498 of 1140
HortScience│Bartlett Consulting ● Divisions of The F.A. Bartlett Tree Expert Company 2550 Ninth Street Suite 112, Berkeley, CA, 94710, 925.484.0211 ● www.hortscience.com Preliminary Arborist Report
2100 – 2400 Geng Road
Palo Alto, CA
PREPARED FOR:

Carlson, Barbee & Gibson
2633 Camino Ramon, Suite 350
San Ramon, CA 94583
PREPARED BY:

HortScience | Bartlett Consulting
2550 Ninth Street, Suite #112
Berkeley, CA 94710
April 2025
Revised August 2025
Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 57 Packet Pg. 499 of 1140
HortScience│Bartlett Consulting ● Divisions of The F.A. Bartlett Tree Expert Company 2550 Ninth Street Suite 112, Berkeley, CA, 94710, 925.484.0211 ● www.hortscience.com Preliminary Arborist Report
2100 – 2400 Geng Road
Palo Alto, CA
Table of Contents
Page
Introduction and Overview 1
Assessment Methods 1
Description of Trees 2
Palo Alto Tree Protection Requirements 6
Palo Alto Tree Replacement 6
Suitability for Preservation 7
Preliminary Evaluation of Impacts and Recommendations 9 Estimate of Value 10
List of Tables
Table 1. Condition ratings and frequency of occurrence of trees 2 Table 2. Tree suitability for preservation 8
Exhibits
Tree Assessment Form
Tree Assessment Map
Preliminary Tree Disposition and Estimate of Value
Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 58 Packet Pg. 500 of 1140
Preliminary Arborist Report
2100 – 2400 Geng Road
Palo Alto, CA
Introduction and Overview
Carlson, Barbee & Gibson is preparing plans to redevelop property at 2100 – 2400 Geng Road in Palo Alto. HortScience | Bartlett Consulting (Divisions of The F. A. Bartlett Tree Expert Co.) was asked to prepare a Preliminary Arborist Report for the project site for submission to the City of Palo Alto. Plans depict proposed demolition of existing structures and construction of townhomes with associated service roads and parking. In August 2025, plans were altered to eliminate offsite work at the neighboring City Park. The subject report was revised based on the new plans.

This report provides the following information:

1. An assessment of tree health, structure, and suitability for preservation.

2. An estimate of the value of each tree.

3. A preliminary assessment of the impacts of constructing the proposed project and recommendations for action.

Assessment Methods
Trees were assessed on October 22 and 23, 2024. Additional trees were evaluated on November 19, 2024, following discussions with the project team. Trees with a trunk diameter of 4 inches or greater located in or overhanging the project area were included in the assessment.

The assessment procedure consisted of the following steps:

1. Identifying the tree species;

2. Tagging each tree with an identifying number and recording its location on a map;

3. Measuring the trunk diameter at a point 54 inches above grade;

4. Evaluating the health and structural condition using a scale of 1 – 5:
5 - A healthy, vigorous tree, reasonably free of signs and symptoms of disease, with good structure and form typical of the species.
4 - Tree with slight decline in vigor, small amount of twig dieback, minor structural defects that could be corrected.
3 - Tree with moderate vigor, moderate twig, and small branch dieback, thinning of crown, poor leaf color, moderate structural defects that might be mitigated with regular care.
2 - Tree in decline, epicormic growth, extensive dieback of medium to large branches, significant structural defects that cannot be abated. 1 - Tree in severe decline, dieback of scaffold branches and/or trunk; most of foliage from epicormics; extensive structural defects that cannot be abated. 0 - Tree is dead.

5. Rating the suitability for preservation as “high”, “moderate” or “low”. Suitability for preservation considers the health, age and structural condition of the tree, and its potential to remain an asset to the site for years to come.

High: Trees with good health and structural stability that have the potential for longevity at the site.

Moderate: Trees with somewhat declining health and/or structural defects than can be abated with treatment. The tree will require more intense management and monitoring, and may have shorter life span than those in ‘good’ category.

Low: Trees in poor health or with significant structural defects that cannot be mitigated. Tree is expected to continue to decline, regardless of treatment. The species or individual may have characteristics that are undesirable for landscapes, and generally are unsuited for use areas.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 59 Packet Pg. 501 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 2
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Description of Trees
Two hundred and seventy (270) trees were assessed, representing 26 species (Table 1). Blue gum was the most common species with 49 trees, followed by river she-oak with 43, and coast redwood with 33. While species like coast live oak and coast redwood are native to the Palo Alto area, none of the assessed trees appeared to be indigenous to the site. Trees were distributed throughout the entire site, with many lining the property boundaries and others grouped together in landscaped areas next to buildings. Overall, 53 trees were in good condition, 162 were in fair condition, and 55 were in poor condition (Table 1).

Descriptions of each tree are found in the Tree Assessment Form and approximate locations are shown on the Tree Assessment Map (see Exhibits).

Table 1: Condition ratings and frequency of occurrence of trees 2100 – 2400 Geng Road, Palo Alto

Common Name Scientific Name Condition Total
Poor
(1-2)
Fair
(3)
Good
(4-5)

Blackwood acacia Acacia melanoxylon 2 4 6 12
Japanese maple Acer palmatum - 3 1 4
African fern-pine Afrocarpus falcatus - 2 - 2
Black alder Alnus glutinosa - 1 - 1
European white birch Betula pendula - 6 - 6
River she-oak Casuarina cunninghamiana 7 29 7 43
Western redbud Cercis occidentalis - - 1 1
River red gum Eucalyptus camaldulensis 2 6 8 16
Blue gum Eucalyptus globulus 33 15 1 49
Raywood ash Fraxinus angustifolia
'Raywood'
6 7 - 13
Evergreen ash Fraxinus uhdei - 1 - 1
Ginkgo Ginkgo biloba - 1 - 1
Silk oak Grevillea robusta - 5 - 5
Chinese flame tree Koelreuteria bipinnata - - 1 1
Glossy privet Ligustrum lucidum 4 2 - 6
Sweetgum Liquidambar styraciflua 1 20 2 23
Southern magnolia Magnolia grandiflora - - 2 2
Crabapple Malus sylvestris - 8 1 9
Mayten Maytenus boaria - 1 - 1
Canary Island date palm Phoenix canariensis - - 2 2
Cherry Prunus sp. - - 2 2
Coast live oak Quercus agrifolia - 6 3 9
Holly oak Quercus ilex - 2 - 2
Yellow willow Salix lasiandra - 1 - 1
Coast redwood Sequoia sempervirens - 22 11 33
Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 60 Packet Pg. 502 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 3
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company

Common Name Scientific Name Condition Total
Poor
(1-2)
Fair
(3)
Good
(4-5)

Water gum Tristaniopsis laurina - 20 5 25
Total 55 162 53 270
Of the 43 river she-oaks, seven were in good
condition, 29 were in fair condition, and seven
were in poor condition. Condition was largely
related to available growing space and tree
structure. Most trees grew close together in
small groups. She-oaks in good condition had
good structure and vigor. Those in fair condition
had moderately undesireable structural features
such as a low live crown ratio and/or a
phototropic lean. Those in poor condition had
more considerable structural deficiencies like
old topping cuts. Development stage varied
from young to mature, indicated by diameters
measuring between 6 – 25 inches.

Eleven (11) redwoods were in good
condition and 22 were in fair condition.

Development stage was mostly semimature with diameters measuring between 17 – 35 inches. Redwoods in
fair condition often exhibited signs of
drought stress like twig dieback and
browning foliage. Those in good
condition had greener, fuller crowns
(Photo 2).

Photo 1: River she-oaks #200 – 202 (left –
right) competed for space in a small planter.

Each was in good condition.

Photo 2: Coast redwoods #116 – 122
(left – right) were in good condition
with dense, green foliage.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 61 Packet Pg. 503 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 4
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Forty-nine (49) blue gums were assessed. Forty-eight
(48) were off-site and had branches that extended into
the subject property by up to 40 feet. Trunks were
near the property line (Photo 3). Blue gum #24 was
located on the subject property. Of all blue gums, 33
were in poor condition, 15 were in fair condition, and
#23 was in good condition. Trunks were usually not
accessible behind the fence, and diameters were
estimated to be up to 56 inches.

Twenty (20) water gums were in fair conditon and five
were in good condition. Condition was informed by growing space availability, with those in fair condition being heavily suppressed by nearby buildings. Those in good condition had more space to develop good branching structure. Trees were semi-mature to mature in development, indicated by diameters between 7 – 15 inches.

Twenty-three (23) sweetgums were assessed. Most (20 trees) were in fair condition, often suppressed by nearby buildings and having structural deficiencies like codominant trunks.

Sweetgums #63 and 131 were in good condition, while #81 was in poor condition. All were semimature in development with diameters ranging between 10 – 19 inches.

Eight of the 16 river red gums were in good condition, six were fair, and #212 and 213 were poor.

Multiple stems arose from a single point on most trees at a height of between 12 – 20 feet. Trees in good condition were more vigorous than trees in fair condition, and had fewer negative features such as improper heading cuts or sapsucker damage. Poor condition river red gums had very low vigor and/or branch dieback and epicormic sprouting. Diameters ranged from 12 – 43 inches, representing semi-mature to mature development stages.

The 13 Raywood ash trees were
either in fair (7 trees) or poor (6
trees) condition. Multiple upright
stems arose from a single point
on all trees (Photo 4). Condition
varied with overall vigor. Fair
condition trees had denser
foliage than those in poor
condition. Diameters measured
between 11 – 21 inches.

Photo 3: Trunks of off-site blue gums were often
close to the property line fence.

Photo 4: Raywood ash trees
#101 – 105 (left – right,
foreground) had many narrow
branch attachments at a single
point on the trunk.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 62 Packet Pg. 504 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 5
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Twelve (12) blackwood acacias were assessed. Six were in good condition, four were fair, and #160 and 234 were poor. Diameters measured between 9 – 32 inches. Acacia #25 was located on the neighboring property, with branches extending approximately 7 feet into the project area.

Eight crabapples were in fair condition while #13 was in good condition. Fair condition crabapples were often suppressed. All had multiple attachments at a single point on the trunk.

Diameters measured between 5 – 10 inches.

Nine coast live oaks were in fair (6 trees) or good (#219 – 221) condition. Five oaks were (#219 – 221, 227, and 228) located off-site, and had branches extending into the subject property by up to approximately 15 feet. Trunks measured between up to 19 inches.

Six European white birch were in fair condition. Thin foliage was concentrated at the top of each tree. Development stage was young, represented by diameters between 6 – 10 inches.

Six glossy privets were in fair (#232 and 251) or poor (#214, 229, 246, and 247) condition.

Condition varied with differences in overall vigor. Multiple stems arose from the base of most trees, measuring between 4 – 8 inches. Privet #229 was off-site.

The remaining 14 species were represented by 5 trees or fewer:
 Five silk oaks were in fair condition. Four were semi-mature in development with trunks between 7 – 15 inches. Silk oak #223 was mature in development with a 32-inch diameter.
 Japanese maple #34 was in good
condition while #147, 148, and 154 were
fair. Individual stems measured
between 4 – 6 inches. Each was
located at the foot of a nearby building,
resulitng in asymmetric crown profiles
(Photo 5).
 African fern-pines #143 and 144 were in
fair condition. Diameters measured 16
and 13 inches.
 Southern magnolias #217 and 218
measured 19 and 12 inches in diameter,
respectively. Both were in good
condition.
 Canary Island date palms #22 and 252
were in good condition. Palm #22 was
off-site, with fronds extending into the subject property by approximately 13 feet. Eight (8) feet of brown trunk was below the lowest living frond. Palm #252 was taller with approximately 18 feet of brown trunk.
 Cherries #68 and 74 were in good condition. Trunks below 7 and 10 inches, respectively.

Multiple small stems arose from an apparent graft at 4 feet on both trees.

Photo 5: Japanese maple #34
was suppressed and one-sided
due to the nearby building.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 63 Packet Pg. 505 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 6
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company  Holly oaks #42 and 43 were off-site and had branches extending into the subject property by approximately 14 and 9 feet, respectively. Both were in fair conditon and suppressed.

Trunks were estimated at 7 (#42) and 6 (#43) inches in diameter.  Black alder #50 was in fair condition. The 7-inch diameter trunk leaned to the west.  Western redbud #3 was in good condition. Codominant trunks arose from 3 feet to create a rounded crown. The trunk measured 7 inches below the attachment.  Evergreen ash #51 had a very narrowly attached codominant trunks with a seam from the base to 3 feet. Individual diameters measured 11 and 10 inches. Overall condition was fair.
 Ginkgo #222 was in fair condition, having a one-sided crown to the east. The trunk was 15 inches in diameter.
 Chinese flame tree #124 had an 11-inch diameter trunk. Multiple stems arose from wide attachments at approximately 10 feet and the canopy was slightly thin. Overall condition was fair.
 Mayten #95 was in fair condition. It had an 11-inch diameter trunk.  Yellow willow #44 as off-site, and had branches that reached approximately 15 feet into the subject property. Codominant trunks emerged from the base with estimated diameters of 20 and 12 inches.

Palo Alto Tree Protection Requirements
City of Palo Alto Municipal Code, Title 8, Chapter 8.10 (Trees & Landscape Preservation and Management), describes Protected trees as certain native species with a minimum trunk diameter of either 11.5 or 18 inches, and all other species with a minimum diameter of 15 inches. Species with high water use, invasive properties, or undesirable fruit are excluded. Of the trees assessed, species that meet exclusion requirements are black alder, European white birch, blackwood acacia, blue gum, Canary Island date palm, evergreen ash, river red gum, and yellow willow. All street trees and other public trees are also considered Protected, regardless of species.

One hundred and thirty-eight (138) trees meet the criteria for Protected status: eighty-seven (87) are large enough to be considered protected mature trees; 48 blue gums appear to be on City property at Baylands Athletic Center, making them public trees; two trees (#7 and 20) are street trees. Protected trees are regulated by the City of Palo Alto and cannot be removed without a permit. Replacement tree plantings will be required for the removal of any Protected trees.

Protected status of each tree is provided in the Tree Assessment Form (see exhibits).

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 64 Packet Pg. 506 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 7
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Suitability for Preservation
Before evaluating the impacts that will occur during development, it is important to consider the quality of the tree resource itself, and the potential for individual trees to function well over an extended length of time. Trees that are preserved on development sites must be carefully selected to make sure that they may survive development impacts, adapt to a new environment and perform well in the landscape.

Our goal is to identify trees that have the potential for long-term health, structural stability, and longevity. For trees growing in open fields, away from areas where people and property are present, structural defects and/or poor health present a low risk of damage or injury if they fail.

We must be concerned, however, about safety in use areas. Therefore, where development encroaches into existing plantings, we must consider their structural stability as well as their potential to grow and thrive in a new environment. Where development will not occur, the normal life cycles of decline, structural failure, and death should be allowed to continue.

Evaluation of suitability for preservation considers several factors:
 Tree health
Healthy, vigorous trees are better able to tolerate impacts such as root injury, demolition of existing structures, changes in soil grade and moisture, and soil compaction than nonvigorous trees are. For example, many blue gums were in poor condition. These trees would not tolerate construction impacts as well as those in fair condition.  Structural integrity
Trees with significant amounts of wood decay and other structural defects that cannot be corrected are more likely to fail. Such trees should not be preserved in areas where damage to people or property is likely.
 Species response
There is a wide variation in the response of individual species to construction impacts and changes in the environment. For example, coast redwood and river she-oak are tolerant of root severance and general construction impacts. Sweetgum is moderately tolerant. Blue gum is intolerant.
 Tree age and longevity
Old trees, while having significant emotional and aesthetic appeal, have limited physiological capacity to adjust to an altered environment. Young trees are better able to generate new tissue and respond to change. Most trees in this assessment were semimature or mature in development stage.  Invasiveness
Species which spread across a site and displace desired vegetation are not always appropriate for retention. This is particularly true when indigenous species are displaced.

The California Invasive Plant Inventory Database (https://www.cal-ipc.org/paf/) lists species identified as being invasive. Palo Alto is part of the Central West Floristic Province. Blackwood acacia, blue gum, Canary Island date palm, and glossy privet have limited invasive potential. Mayten is on the watch list.

Each tree was rated for suitability for preservation based upon its age, health, structural condition, and ability to safely coexist within a development environment (Table 2, following page).

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 65 Packet Pg. 507 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 8
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Table 2: Tree suitability for preservation.
2100 – 2400 Geng Road, Palo Alto
High Trees in good health and with structural stability that have the potential for longevity at the site. Six trees had high suitability for preservation: Canary Island date palms #22 and 252, coast live oak #219, river red gum #216, and river she-oaks #200 and 201.

Moderate Trees in fair health and/or with structural defects that may be abated with treatment. Trees in this category require more intense management and monitoring, and may have shorter lifespans than those in the “high” category.

One hundred and twenty-three (123) trees had moderate suitability for preservation: black alder #50, nine blackwood acacias, blue gum #23, cherries #68 and 74, Chinese flame tree #124, four coast live oaks, 23 coast redwoods, nine crabapples, evergreen ash #51, ginkgo #222, holly oaks #42 and 43, Japanese maple #34, mayten #95, 11 river red gums, 19 river sheoaks, silk oaks #223 and 230, southern magnolias #217 and 218, eight sweetgums, 24 water gums, and western redbud #3.

Low Trees in poor health or with significant defects in structure that cannot be abated with treatment. These trees can be expected to decline regardless of management. The species or individual tree may possess either characteristics that are undesirable in landscape settings or be unsuited for use areas. One hundred and forty-one (141) trees had low suitability for preservation: African fern-pines #143 and 144, blackwood acacias #19, 160, and 234, 48 blue gums, four coast live oaks, 10 coast redwoods, six European white birch, six glossy privets, Japanese maples #147, 148, and 154, 13 Raywood ash, four river red gums, 22 river she-oaks, silk oaks #231, 233, and 235, 15 sweetgums, water gum #139, and yellow willow #44.

We consider trees with high suitability for preservation to be the best candidates for preservation.

Retention of trees with moderate or low suitability for preservation depends upon the intensity of proposed site changes and the use nature of the site.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 66 Packet Pg. 508 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 9
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Preliminary Evaluations of Impacts and Recommendations
Appropriate tree retention develops a practical match between the location and intensity of construction activities with the quality and health of trees. The Tree Assessment was the reference point for tree condition and quality. Impacts from construction were estimated using a conceptual site plan (Geng Road Site, Dahlin Group and CBG, dated 7/25/25), a Tree Disposition Plan (The Guzzardo Partnership, dated 8/26/2025) and conversations with the project team (to date 8/28/2025). Plans are preliminary in nature. As such, this evaluation of impacts must be considered preliminary.

The site plan depicted locations of new townhomes and associated access roads. All existing structures will be demolished. Improvements would fill the entire site, property line to property line. A storm line is proposed off-site along the edge of the Baylands Athletic Center. No opportunities for tree preservation exist within the property.

Off-site trees adjacent to the project area will be impacted by the proposed construction including root severance and crown pruning. Impacts may be severe. First, demolition of existing infrastructure and landscape may damage trees. Second, grading, excavation, and other construction activities will injure trees, both directly by mechanical injury and indirectly by altering drainage. Most notably, a retaining wall is proposed at the property line on the north side of the site near a row of large, mature blue gums. Finally, existing branches may encroach into the site, requiring significant pruning.

The Project proposes to remove 207 existing trees within the project site and two street trees (209 total tree removals). The grade over the entire site will be raised, and no trees can be preserved within the boundaries. Of these, 83 trees are considered Protected trees by the City of Palo Alto and will require replacement (see Preliminary Tree Disposition and Estimate of Value table in the Exhibits).

Forty-five (45) trees were near the property boundary of Baylands Athletic Center and identified for potential preservation due to the installation of a retaining wall at the property line. All were mature blue gums, and unlikely to respond well to drastic site changes such as the proposed retaining wall and grade change. As a species, blue gums are intolerant of root impacts. The retaining wall is proposed immediately adjacent to the stand of trees at the property line. I expect impacts to be severe, and some trees may sustain impacts that exceed their tolerances. Until excavation begins or an exploratory trench is dug to expose roots, impacts must be considered preliminary. Disposition may change depending on expected impacts if preservation is not expected to be successful. I recommend reevaluating as designs develop.

Palm #22, blue gums #23 and 253, and blackwood acacia #25 were also located off-site at Baylands Athletic Center. Near these trees, no retaining wall will be installed. I expect impacts to be negligible for palm #22 and moderate for trees #23, 25, and 253. These four trees are identified for preservation.

The remaining 12 trees on private property bordering the site are also identified for potential preservation. Impacts may be severe, depending on the required root severance during installation of retaining walls and clearance pruning. Disposition may change depending on expected impacts if preservation is not expected to be successful. I recommend reevaluating as designs develop.

The Project’s tree removal requirements are a result of coastal flooding issues. The Project site’s elevation is currently between 6 and 10 feet above sea level. The site lies in a FEMA flood zone of AE-11, meaning that the site could flood up to 11 feet above sea level in a severe storm or high tide event. To mitigate this, the entire site must be raised to a minimum of 11 feet above sea level by importing 1 – 6 feet of additional soil across the site.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 67 Packet Pg. 509 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 10
The Project site is zoned for multifamily housing, with a portion of the site designated in the City’s 6 th Cycle Housing Element as a housing inventory site. Redevelopment of the project site for these uses is not possible without the entire site grade being raised.

Consistent with Palo Alto Municipal Code Section 8.10.050 (d)(1), there is no feasible way to retain the protected trees without reducing the otherwise-permissible buildable area by more than twenty-five percent. Based on the Project sponsor’s analysis, there is no financially feasible design alternative that would allow for retention of these protected trees in connection with redevelopment of the site for housing.

The Project will fully mitigate the protected tree removals with a robust replacement tree planting plan, prioritizing native species, climate-adaptive drought tolerant species (in alignment with Palo Alto Municipal Code Section 8.10.030 (b)(2), and 8.10.050 (d)(3)(ii)), and species that provide high quality habitat for birds and other wildlife.

Because the plans are preliminary, there may be opportunities to reduce tree impacts. The ability to preserve trees on this site and along the edges of the property depends on 1) selecting trees with moderate or good suitability for preservation and 2) establishing a tree protection zone large enough to sustain tree health and stability. All plans should include surveyed tree trunk locations so that impacts can be accurately assessed, and adequate tree protection measures can be determined. Once a design alternative is selected, impacts to trees should be revisited.

Estimate of Value
To estimate the reproduction cost of each tree, I used the cost approach, reproduction method, trunk formula technique, as described in the Guide for Plant Appraisal, 10th edition (International Society of Arboriculture, Atlanta GA, 2018). In addition, I referred to Species Classification and Group Assignment (2004), a publication of the Western Chapter of the International Society of Arboriculture.

When estimating reproduction cost, the trunk formula technique considers four factors: size, condition, functional limitations, and external limitations. Size is measured as trunk diameter, normally 54 inches above grade. Condition reflects tree health and structural integrity.

Functional limitations reflect constraints to tree development based on the site and species. For example, the off-site blue gums along the north edge of the property were crowded together, and competed for available growing space. Trees in this row were depreciated for the limited growing area and proximity to the property boundary. I did not note any external limitations.

Based on the information gathered, I estimated the reproduction cost for individual trees to range from $250 to $26,950, totaling $943,838 for all trees. The estimated value of trees identified for removal was $791,784 ($411,250 Protected). The estimated value of trees identified for potential preservation was $142,045 ($134,300 Protected). The estimated value of trees identified for preservation was $9,605 (all Protected). Values per tree are depicted in the Preliminary Disposition and Estimate of Value exhibit (see exhibits).

HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 68 Packet Pg. 510 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 11
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Palo Alto Tree Replacement
Tree replacement mitigation is
required for Protected tree removals.

Replacement quantities are based on
the average canopy spread of the
removed tree. Two options are
presented in the Palo Alto Tree
Technical Manual for Replacement
Trees or Alternative Trees (Figure 1).

Individual assignments for
replacement trees are described in the
Preliminary Disposition and
Estimate of Value exhibit (see
exhibits).

The project’s landscape architect will
use these ratios to inform the
replacement planting plan.

Figure 1: Replacement tree matrix. Sourced from Palo
Alto Tree Technical Manual.

Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 69 Packet Pg. 511 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 12
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Preliminary Tree Preservation Guidelines
Trees on adjacent properties may be impacted by construction activities. The key to tree preservation is to minimize adverse impacts near trees to be retained. The following are recommendations for design and construction phases that will assist in successful tree preservation.

1. Reevaluate tree disposition as project plans progress.

2. The Tree Protection Zone shall be the project property line. The project’s security fence will serve as the tree protection fencing.

3. Off-site trees may require pruning to provide vertical clearance for construction. All pruning shall be completed by a Certified Arborist or Tree Worker and adhere to the latest edition of the ANSI Z133 and A300 standards as well as the Best Management Practices -- Tree Pruning published by the International Society of Arboriculture.

4. On-site trees to be removed that have branches extending into the canopy of off-site trees to remain must be removed by a qualified arborist and not by construction contractors. The qualified arborist should remove the tree in a manner that causes no damage to the trees and understory to remain.

5. Any grading, construction, demolition or other work that is expected to encounter tree roots should be monitored by the Consulting Arborist.

6. Enlist the project arborist monitor excavation for the footing of the retaining wall along the north edge of the property. Once roots are exposed, recommendations can be made on management decisions. Overall dispositions may change depending on the size and number of roots encountered.

7. Enlist the project arborist to monitor off-site trees identified for potential preservation on a monthly basis throughout the construction timeline to monitor any changes in condition.

8. If injury should occur to any tree during construction, it should be evaluated as soon as possible by the Consulting Arborist so that appropriate treatments can be applied.

9. Any roots damaged during grading or construction shall be exposed to sound tissue and cut cleanly with a saw.

10. All tree work shall comply with the Migratory Bird Treaty Act as well as California Fish and Wildlife code 3503-3513 to not disturb nesting birds. To the extent feasible tree pruning and removal should be scheduled outside of the breeding season. Breeding bird surveys should be conducted prior to tree work. Qualified biologists should be involved in establishing work buffers for active nests.

If you have any questions about my observations or recommendations, please contact me.

HortScience | Bartlett Consulting
Ryan Suttle, Consulting Arborist & Urban Forester
ISA Board Certified Master Arborist, Utility Specialist No. WE-12647BU ISA Tree Risk Assessment Qualified
ASCA Registered Consulting Arborist #813
ASCA Tree and Plant Appraisal Qualified
Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 70 Packet Pg. 512 of 1140
Preliminary Arborist Report, 2100 – 2400 Geng Road
Revised August 2025 Page 13
HortScience | Bartlett Consulting, Divisions of The F.A. Bartlett Tree Expert Company Exhibits
Tree Assessment Form
Tree Assessment Map
Preliminary Tree Disposition and
Estimate of Value
Exhibit A
Item 12
Attachment C - Draft
Parkland Improvement
Ordinance
Item 12: Staff Report Pg. 71 Packet Pg. 513 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
1 River she-oak 18 Yes 4 Moderate 10,15,12,10 Codominant trunks arise from 10’; high crown; suppressed south.2 River she-oak 19 Yes 4 Moderate 12,8,15,10 Codominant trunks arise from 12&14’; narrow suppressed crown.3 Western redbud 7 No 4 Moderate 6,6,6,6 Codominant trunks arise from 3’; round crown. 4 Crabapple 5 No 3 Moderate 7,2,6,7 Suppressed west; no lower branching; swollen base. 5 Crabapple 8 No 3 Moderate 5,8,7,5 Codominant trunks arise from 4’; high crown; suppressed south.6 Crabapple 8 No 3 Moderate 10,8,5,7 Multiple trunks arise from 5’; high crown; suppressed north.7 River she-oak 24 Yes; Street Tree
4 Moderate 17,17,17,17 Street tree; codominant trunks arise from high in crown; topping cuts throughout crown.
8 Crabapple 7 No 3 Moderate 5,8,7,3 Multiple trunks arise from 5’; no lower branches.9 Crabapple 8 No 3 Moderate 13,7,8,10 Multiple trunks arise from 5’; no lower branches. 10 Crabapple 7 No 3 Moderate 7,4,6,6 Multiple trunks arise from 6’; no lower branches; messy structure.11 Crabapple 7 No 3 Moderate 7,7,7,7 Wide multiple trunks arise from 4’; 8”x2” basal decay cavity.12 Crabapple 7 No 3 Moderate 7,3,5,9 Heavily suppressed north; trunk bends north at 2’.13 Crabapple 10 No 4 Moderate 14,10,10,8 Multiple trunks arise from 5’; no lower branches; swollen base. 14 River she-oak 11 No 3 Moderate 12,10,12,12 Codominant trunks arise from 14’; narrow thin crown. 15 River she-oak 18 Yes 3 Moderate 10,12,14,11 Codominant trunks arise from 14’; narrow thin crown; southern trunk leans south.
16 River she-oak 18 Yes 3 Moderate 7,9,12,12 High narrow crown bows south high in crown; suppressed south.17 River she-oak 19 Yes 4 Moderate 18,15,18,18 Codominant trunks arise from high in crown; topping cuts throughout crown.
18 Blackwood acacia 25 No; invasive,
Cal-IPC
4 Moderate 22,22,22,22 Exposed surface roots; single upright trunk. 19 Blackwood acacia 20 No; invasive,
Cal-IPC
3 Low 10,8,12,12 Codominant trunks arise from 7’; crown weight is southern. 20 River she-oak 18 Yes; Street
Tree
3 Low 16,14,12,15 Street tree; straight upright crown; dead and dying branches throughout crown.

Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
Exhibit
A
Item 12: Staff Report Pg. 72 Packet Pg. 514 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
21 Blackwood acacia 18 No; invasive,
Cal-IPC
4 Moderate 15,15,15,15 Straight upright trunk; some decay on lowest branch (4”); good form.
22 Canary Island date palm 40 Yes; on City
property
4 High 10,10,10,10 Off-site tagged on fence; extends over property by 13’; 8’ wood feet of brown trunk; heavily suppressed under blue gum. 23 Blue gum 42 Yes; on City
property
4 Moderate 30,25,40,20 Off-site tagged on fence; extends over property by 40’; high crown; heading cuts throughout.
24 Blue gum 26 No; invasive,
Cal-IPC
3 Low 20,5,9,24 S-shape in trunk @ 20’; sap sucker evidence on upper crown. 25 Blackwood acacia 12 Yes; on City
property
4 Moderate 8,8,7,8 Off-site tagged on fence; extends over site by 7’; straight upright crown; good form and condition.
26 Water gum 8 No 3 Moderate 8,5,7,8 Pruned for light clearance; good young tree. 27 Water gum 7 No 3 Moderate 8,8,8,8 In median planter; round crown; good form. 28 Water gum 8 No 4 Moderate 8,8,8,8 In median planter; round crown; good form.29 Water gum 9 No 4 Moderate 9,9,9,9 In median planter; round crown; good form.30 Water gum 9 No 4 Moderate 11,11,11,11 In median planter; round crown; good form.31 Water gum 9 No 4 Moderate 10,10,10,10 In median planter; round crown; good form.32 Blackwood acacia 12 No; invasive, Cal-IPC
4 Moderate 5,10,10,10 Narrow codominant trunks arise from 8’; slight lean east. 33 Blackwood acacia 18 No; invasive,
Cal-IPC
3 Moderate 14,14,14,14 Multiple trunks arise from 10’; thin crown. 34 Japanese maple 7,6 Yes 4 Moderate 14,5,5,14 Codominant trunks arise from 1’; heavily suppressed under the building; dead twigs.
35 Coast redwood 18 Yes 3 Low 12,12,12,12 In raised planter; twig dieback; brown leaves. 36 Coast redwood 20 Yes 3 Low 10,10,10,10 In raised planter; twig dieback; brown leaves. 37 Coast redwood 19 Yes 3 Low 10,10,10,10 In raised planter; twig dieback; brown leaves. 38 River red gum 32 No; invasive,
Cal-IPC
3 Moderate 20,16,10,20 Trunk bows north; high crown; good growth. 39 River red gum 31 No; invasive,
Cal-IPC
4 Moderate 21,21,21,25 Trunk bows north; high crown; good growth. 40 River red gum 20 No; invasive,
Cal-IPC
4 Moderate 11,6,11,8 Codominant trunks arise from 12’; leans west.

Exhibit
A
Item 12: Staff Report Pg. 73 Packet Pg. 515 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
41 River red gum 23 No; invasive,
Cal-IPC
4 Moderate 14,14,14,14 Multiple trunks arise from 12’; vase shape crown. 42 Holly oak 7 No 3 Moderate 14,6,2,6 Off-site extends over property by 14’; suppressed. 43 Holly oak 6 No 3 Moderate 9,5,2,5 Off-site extends over property by 9’; suppressed.44 Yellow willow 20,12 No; high water use
3 Low 15,15,10,15 Off-site extends over property by 15’, Codominant trunks lean over property, suppressed.
45 River red gum 35 No; invasive,
Cal-IPC
4 Moderate 23,29,18,20 In parking island; leans over property; high crown; good growth. 46 River red gum 32 No; invasive,
Cal-IPC
4 Moderate 18,18,18,18 In parking island; multiple trunks arise from 10’; high crown; good growth.
47 River red gum 12 No; invasive,
Cal-IPC
4 Moderate 10,10,10,10 Codominant trunks arise from base&12’ wester trunk removed. 48 River she-oak 24 Yes 3 Low 13,13,15,12 Off-site; Codominant trunks; extends over property 13’. 49 Coast live oak 13 Yes 3 Moderate 12,8,8,10 Off-site extends over property by 12’; thin; leans north over property.
50 Black alder 7 No; high
water use
3 Moderate 9,9,9,9 Trunk leans west suppressing trees on west side. 51 Evergreen ash 11,10 No; fruit per
Palo Alto
website
3 Moderate 10,12,15,15 Codominant trunks are fussed from base to 3’; suppressed west. 52 Raywood ash 16 Yes 3 Low 16,16,16,16 In open planter; round crown; multiple trunks arise from 8’; sunscold.53 Raywood ash 11 No 3 Low 12,12,12,12 In open planter; round crown; multiple trunks arise from 8’; sunscold. 54 Raywood ash 13 No 3 Low 11,11,11,11 In open planter; round crown; multiple trunks arise from 8’; sunscold. 55 Raywood ash 18 Yes 2 Low 15,15,15,15 In open planter; round crown; multiple trunks arise from 8’; sunscold.56 Raywood ash 14 No 2 Low 12,11,11,6 In open planter; round crown; multiple trunks arise from 8’; sunscold; history of branch failure; decay.57 Raywood ash 18 Yes 2 Low 16,16,15,13 In open planter; round crown; multiple trunks arise from 8’; sunscold.

Exhibit
A
Item 12: Staff Report Pg. 74 Packet Pg. 516 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
58 Raywood ash 16 Yes 3 Low 15,15,15,15 In open planter; round crown; multiple trunks arise from 8’; sunscold. 59 Raywood ash 16 Yes 3 Low 15,15,15,15 In open planter; round crown; multiple trunks arise from 8’; thin; sun-scold.
60 Raywood ash 14 No 3 Low 16,15,15,15 In open planter; round crown; multiple trunks arise from 8’; thin; sun-scold.
61 Raywood ash 14 No 3 Low 11,12,12,13 In open planter; round crown; multiple trunks arise from 8’; thin; sun-scold.
62 Sweetgum 14 No 3 Low 12,4,12,12 High crown suppressed by building. 63 Sweetgum 16 Yes 4 Moderate 18,15,18,18 Multiple trunks arise from 15’; seams in attachments. 64 Sweetgum 14 No 3 Low 9,5,12,9 High crown suppressed by building. 65 Coast redwood 30 Yes 3 Low 20,20,20,20 Heavily suppressed by building on east; high crown.66 Coast redwood 29 Yes 3 Low 13,13,13,13 Heavily suppressed by building on east; high crown.67 Coast redwood 31 Yes 3 Low 17,17,17,17 Heavily suppressed by building on east; high crown.68 Cherry 7 No 4 Moderate 5,5,5,5 Grafted at 4’; multiple trunks arise from 4’; healthy crown. 69 Sweetgum 12 No 3 Low 20,15,2,15 High crown suppressed by building. 70 Sweetgum 11 No 3 Low 11,10,11,8 Sinuous trunk; suppressed north. 71 Sweetgum 13 No 3 Low 10,12,12,12 Upright trunk; twig dieback.72 Sweetgum 13 No 3 Low 12,12,8,11 Codominant trunks arise from 12’; no lower branches.73 Sweetgum 12 No 3 Low 20,15,2,15 High crown suppressed by building. 74 Cherry 10 No 4 Moderate 5,5,9,9 Grafted at 4’; multiple trunks arise from 4’; healthy crown; growth on west side.
75 Coast redwood 26 Yes 3 Low 14,14,14,14 Typical from; tight cluster of trees; high crown. 76 Coast redwood 19 Yes 3 Low 12,12,12,12 Typical from; tight cluster of trees; high crown. 77 Coast redwood 17 No 3 Low 11,11,11,11 Typical from; tight cluster of trees; high crown. 78 Coast redwood 17 No 3 Low 13,13,13,13 Typical from; tight cluster of trees; high crown. 79 Coast redwood 32 Yes 4 Moderate 15,15,15,15 Typical from; tight cluster of trees; high crown.80 Coast redwood 28 Yes 3 Moderate 13,13,13,13 Typical from; tight cluster of trees; high crown.81 Sweetgum 10 No 2 Low 10,8,8,7 High crown; decay on trunk; poor and condition form.82 Coast redwood 25 Yes 3 Moderate 12,12,12,12 Typical from; tight cluster of trees; high crown; suppressed on southeast.

Exhibit
A
Item 12: Staff Report Pg. 75 Packet Pg. 517 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
83 Coast redwood 21 Yes 3 Moderate 8,8,8,8 Typical from; tight cluster of trees; high crown; suppressed on west.
84 Coast redwood 26 Yes 3 Moderate 13,13,13,13 Typical from; tight cluster of trees; high crown; suppressed on north.
85 Coast redwood 28 Yes 3 Moderate 14,14,14,14 Typical from; suppressed by building. 86 Coast redwood 27 Yes 3 Moderate 13,13,13,13 Typical from; suppressed by building. 87 European white birch 7 No; high
water use
3 Low 6,6,6,6 Upright thin crown; twig dieback in upper crown. 88 Coast redwood 32 Yes 4 Moderate 16,16,16,16 Typical from; good crown and structure; high crown. 89 Coast redwood 25 Yes 3 Moderate 13,13,13,13 Typical from; high crown. 90 Coast redwood 28 Yes 3 Moderate 14,14,14,14 Typical from; high crown.91 Coast redwood 26 Yes 3 Moderate 12,12,12,12 Typical from; high crown; in tight cluster; suppressed by building. 92 Coast redwood 25 Yes 3 Moderate 12,12,12,12 Typical from; high crown; in tight cluster.93 Coast redwood 26 Yes 3 Moderate 15,15,15,15 Typical from; high crown; in tight cluster.94 Coast redwood 31 Yes 3 Moderate 15,15,15,15 Typical from; high crown; in tight cluster.95 Mayten 11 No 3 Moderate 15,16,10,6 Multiple trunks arise from 6’; suppressed east; moderate form.96 Water gum 11 No 3 Moderate 12,13,8,5 Heavily suppressed by building; good health. 97 Water gum 11 No 3 Moderate 9,11,9,0 Heavily suppressed by building; good health.98 Water gum 9 No 3 Moderate 9,10,9,0 Heavily suppressed by building; good health.99 Water gum 10 No 3 Moderate 0,9,9,0 Heavily suppressed by building; good health. 100 Raywood ash 18 Yes 2 Low 10,8,8,8 Multiple trunks arise from but headed back 12’; thin. 101 Water gum 11 No 3 Moderate 0,11,14,14 Heavily suppressed by building; good health.102 Water gum 11 No 3 Moderate 4,12,14,14 Heavily suppressed by building; good health.103 Water gum 11 No 3 Moderate 7,10,13,13 Heavily suppressed by building; good health.104 Water gum 10 No 3 Moderate 7,0,14,11 Heavily suppressed by building; good health.105 Water gum 9 No 3 Moderate 0,13,12,11 Heavily suppressed by building; good health.106 Raywood ash 23 Yes 2 Low 17,17,17,17 Multiple trunks arise from 12’; headed back; thin. 107 Sweetgum 12 No 3 Low 11,12,14,11 High crown suppressed by building. 108 Sweetgum 11 No 3 Low 11,10,10,13 In planter; multiple trunks with cavity at attachment point.109 Sweetgum 13 No 3 Low 12,0,10,14 High crown suppressed by building.

Exhibit
A
Item 12: Staff Report Pg. 76 Packet Pg. 518 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
110 Sweetgum 16 Yes 3 Low 12,12,0,12 High crown suppressed by building; thin. 111 Coast redwood 34 Yes 4 Moderate 17,17,17,17 Typical from; good crown and structure; high crown; suppressed by building.
112 Coast redwood 35 Yes 4 Moderate 18,18,18,18 Typical from; good crown and structure; high crown; suppressed by building; good leaf color.
113 Sweetgum 14 No 3 Low 7,7,7,7 Straight upright trunk; thin.114 Sweetgum 12 No 3 Low 9,8,14,9 Multiple trunks; thin.115 Sweetgum 11 No 3 Low 14,14,0,14 Wide codominant trunks arise from 12’; thin.116 Coast redwood 29 Yes 4 Moderate 15,15,15,15 Typical from; good crown and structure; high crown; suppressed; good leaf color.
117 Coast redwood 26 Yes 4 Moderate 12,12,12,12 Typical from; good crown and structure; high crown; suppressed; good leaf color.
118 Coast redwood 30 Yes 4 Moderate 14,14,14,14 Typical from; good crown and structure; high crown; suppressed; good leaf color.
119 Coast redwood 31 Yes 4 Moderate 14,14,14,14 Typical from; good crown and structure; high crown; suppressed; good leaf color.
120 Coast redwood 25 Yes 4 Moderate 15,15,15,15 Typical from; good crown and structure; high crown; suppressed; good leaf color.
121 Coast redwood 27 Yes 4 Moderate 16,16,16,16 Typical from; good crown and structure; high crown; suppressed; good leaf color.
122 Coast redwood 35 Yes 4 Moderate 18,18,18,18 Typical from; good crown and structure; high crown; suppressed; good leaf color.
123 Raywood ash 21 Yes 2 Low 9,12,15,15 Multiple trunks headed back; thin; wide attachments. 124 Chinese flame tree 11 No 4 Moderate 14,14,17,17 Multiple trunks arise from 10’; wide attachments; somewhat thin.125 River she-oak 18 Yes 3 Moderate 10,12,12,10 High narrow crown; history of branch failure.126 Blackwood acacia 15 No; invasive, Cal-IPC
4 Moderate 15,15,15,15 Good upright form; base is flat on both the west and east sides. 127 River she-oak 19 Yes 3 Moderate 7,7,12,10 Codominant trunks arise from 12’&14’; thin; suppressed west. 128 River she-oak 14 No 3 Moderate 9,14,9,9 High narrow crown; codominant trunks high in crown. 129 River she-oak 16 Yes 3 Moderate 9,9,9,9 High narrow crown; bleeding at base.

Exhibit
A
Item 12: Staff Report Pg. 77 Packet Pg. 519 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
130 Blackwood acacia 26 No; invasive,
Cal-IPC
4 Moderate 17,17,17,17 Codominant trunks arise from 17’; high crown. 131 Sweetgum 19 Yes 4 Moderate 16,16,16,16 High crown suppressed by building.132 Sweetgum 19 Yes 3 Moderate 15,15,15,15 Codominant trunks; thin; no lower foliage; Sa sucker evidence. 133 Sweetgum 12 No 3 Moderate 11,12,8,6 Codominant trunks; messy crown.134 Sweetgum 15 Yes 3 Moderate 19,15,0,15 Codominant trunks; messy crown.135 Sweetgum 17 Yes 3 Moderate 9,11,11,11 Corrected bow on trunk; high crown; thin. 136 Sweetgum 10 No 3 Moderate 13,12,8,12 Upright trunk thin crown.137 Sweetgum 12 No 3 Moderate 16,12,12,12 Crooked trunk; thin; one-sided east.138 Water gum 12 No 3 Moderate 14,9,8,11 Heavily suppressed by building; good health. 139 Water gum 12 No 3 Low 18,5,5,11 Heavily suppressed by building; thin. 140 Water gum 12 No 3 Moderate 10,8,0,10 Heavily suppressed by building; good health.141 Water gum 13 No 3 Moderate 9,9,5,12 Heavily suppressed by building; good health. 142 Water gum 12 No 3 Moderate 17,3,0,12 Heavily suppressed by building; good health; codominant trunk; gurdling root.
143 African fern-pine 16 Yes 3 Low 15,16,16,0 Leans east away from building; thin; gurdling root; healthy leaves.144 African fern-pine 13 No 3 Low 10,10,10,10 In planter; wide attachment; good growth. 145 European white birch 8 No; high
water use
3 Low 5,5,5,5 High narrow crown; thin.
146 European white birch 10 No; high
water use
3 Low 8,8,8,8 Crook at 2’; high narrow crown; thin.
147 Japanese maple 6 No 3 Low 8,0,11,12 Suppressed under building; bows away from structure.148 Japanese maple 7 No 3 Low 0,0,10,10 Suppressed under building on two sides; bows away from structure.
149 Blackwood acacia 29 No; invasive,
Cal-IPC
3 Moderate 9,19,28,15 Leans and bows west away from other trees; multiple trunks arise from 13’; somewhat thin.
150 River she-oak 22 Yes 3 Moderate 9,9,12,6 Multiple trunks arise from 11’; thin; high narrow crown. 151 River she-oak 25 Yes 3 Moderate 11,6,12,12 Multiple trunks arise from 10’; thin; high narrow crown. 152 River she-oak 20 Yes 3 Moderate 8,8,10,8 Codominant trunks arise from 8’; thin; high narrow crown.

Exhibit
A
Item 12: Staff Report Pg. 78 Packet Pg. 520 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
153 European white birch 7 No; high
water use
3 Low 5,5,5,5 High narrow crown; thin.
154 Japanese maple 6,4 Yes 3 Low 0,0,10,12 Suppressed under building on two sides; bows away from structure.
155 European white birch 6 No; high
water use
3 Low 2,2,6,5 High narrow crown; heavily suppressed; thin. 156 European white birch 10 No; high
water use
3 Low 4,4,8,5 High narrow crown; heavily suppressed; thin. 157 River she-oak 19 Yes 3 Moderate 6,6,10,10 Multiple trunks arise from high in crown; bleeding on trunk at 2’; thin; high narrow crown.
158 River she-oak 16 Yes 3 Moderate 6,6,10,10 Single upright trunk; high narrow crown.159 River she-oak 15 Yes 3 Moderate 9,9,12,7 Codominant trunks arise from 10’; thin; high narrow crown.160 Blackwood acacia 9 No; invasive, Cal-IPC
2 Low 5,7,7,6 Bows south; dead top; thin.
161 Blue gum 25 Yes; on City
property
2 Low 40,10,10,20 Off-site tagged on fence; can’t see trunk; extends over property by 7’; messy form.
162 Blue gum 38 Yes; on City
property
2 Low 30,15,15,30 Off-site tagged on fence; can not see trunk; extends over property by 16’; messy form; pruned away from property. 163 Blue gum 36 Yes; on City
property
2 Low 25,20,10,20 Off-site tagged on fence; can’t see trunk; extends over property by 7’; messy form; pruned away from property.
164 Blue gum 38 Yes; on City
property
2 Low 10,6,5,15 Off-site tagged on fence; can’t see trunk; extends over property by 8’; messy form; pruned away from property.
165 Blue gum 36 Yes; on City
property
3 Low 35,30,20,25 Off-site tagged on fence; can’t see trunk; extends over property by 10’; messy form; pruned away from property.
166 Blue gum 40 Yes; on City
property
3 Low 40,50,25,35 Off-site tagged on fence; can’t see trunk; extends over property by 16’; messy form; pruned away from property.
167 Blue gum 56 Yes; on City
property
3 Low 40,35,10,5 Off-site tagged on fence; extends over property by 10’; messy form; pruned away from property; leans heavily away from property. 168 Blue gum 40 Yes; on City
property
3 Low 40,25,15,5 Off-site tagged on fence; can’t see trunk; extends over property by 10’; messy form; pruned away from property.
169 Blue gum 28,26 Yes; on City
property
3 Low 40,10,15,10 Off-site tagged on fence; can’t see trunk; extends over property by 9’; messy form; pruned away from property.

Exhibit
A
Item 12: Staff Report Pg. 79 Packet Pg. 521 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
170 Blue gum 38 Yes; on City
property
3 Low 30,35,15,20 Off-site tagged on fence; can’t see trunk; extends over property by 7’; messy form; pruned away from property.
171 Blue gum 21 Yes; on City
property
2 Low 15,10,5,1 Off-site tagged on fence; can’t see trunk; extends over property by 2’; messy form; pruned away from property.
172 Blue gum 19 Yes; on City
property
2 Low 15,10,10,10 Off-site tagged on fence; can’t see trunk; extends over property by 8’; messy form; pruned away from property.
173 Blue gum 19 Yes; on City
property
2 Low 35,20,10,5 Off-site tagged on fence; can’t see trunk; extends over property by 7’; messy form; pruned away from property.
174 Blue gum 42 Yes; on City
property
2 Low 40,55,10,10 Off-site tagged on fence; can’t see trunk; extends over property by 7’; messy form; pruned away from property.
175 Blue gum 53 Yes; on City
property
2 Low 40,40,10,15 Off-site tagged on fence; can’t see trunk; doesn’t extend over property, roots are lifting parking lot pavement; pruned and leans away from property. 176 Blue gum 48 Yes; on City
property
2 Low 25,20,25,30 Off-site tagged on fence; can’t see trunk; extends over property by 10’; messy form; pruned away from property.
177 Blue gum 42 Yes; on City
property
2 Low 35,15,15,30 Off-site tagged on fence; can’t see trunk; extends over property by 4’; messy form; pruned away from property.
178 Blue gum 25 Yes; on City
property
2 Low 20,15,10,5 Off-site tagged on fence; can’t see trunk; extends over property by 10’; messy form; pruned away from property; base at fence line. 179 Blue gum 36 Yes; on City
property
2 Low 30,10,15,15 Off-site tagged on fence; can’t see trunk; extends over property by 9’; messy form; pruned away from property.
180 Blue gum 17 Yes; on City
property
2 Low 5,5,8,4 Off-site tagged on fence; can’t see trunk; extends over property by 4’; messy form; pruned away from property.
181 Blue gum 46 Yes; on City
property
3 Low 35,45,15,20 Off-site tagged on fence; can’t see trunk; extends over property by 8’; messy form; pruned away from property.
182 Blue gum 42 Yes; on City
property
3 Low 30,15,10,25 Off-site tagged on fence; can’t see trunk; extends over property by 4’; messy form; pruned away from property.
183 Blue gum 16,10,5 Yes; on City
property
2 Low 30,10,10,5 Off-site tagged on fence; can’t see trunk; extends over property by 6’; messy form; pruned away from property.
184 Blue gum 25 Yes; on City
property
2 Low 25,10,10,20 Off-site tagged on fence; can’t see trunk; extends over property by 6’; messy form; pruned away from property.

Exhibit
A
Item 12: Staff Report Pg. 80 Packet Pg. 522 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
185 Blue gum 26 Yes; on City
property
2 Low 35,25,10,5 Off-site tagged on fence; can’t see trunk; extends over property by 8’; messy form; pruned away from property.
186 Blue gum 28 Yes; on City
property
2 Low 15,20,10,5 Off-site tagged on fence; can’t see trunk; extends over property by 9’; messy form; pruned away from property.
187 Blue gum 52 Yes; on City
property
3 Low 40,35,20,45 Off-site tagged on fence; can’t see trunk; extends over property by 8’; messy form; pruned away from property.
188 Blue gum 26 Yes; on City
property
2 Low 5,10,5,5 Off-site tagged on fence; can’t see trunk; extends over property by 5’; messy form; pruned away from property.
189 River she-oak 10 No 3 Low 6,6,6,6 Codominant trunks arise from 8’; high narrow crown. 190 River she-oak 6 No 2 Low 0,6,8,5 Codominant trunks arise from 8’; branch is horizontal turning at 6”; high narrow crown.
191 River she-oak 10 No 2 Low 5,5,9,6 Single upright trunk; high narrow crown. 192 River she-oak 12 No 3 Low 0,8,12,7 Single upright trunk; high narrow crown. 193 River she-oak 7 No 2 Low 5,5,5,5 No tag; single upright trunk; topped; yellow jacket nest at base; high narrow crown.
194 River she-oak 8 No 2 Low 0,6,8,3 Single upright trunk; high narrow crown. 195 River she-oak 7 No 2 Low 0,7,7,0 Single upright trunk; topped; yellow jacket nest at base; high narrow crown.
196 Blue gum 30 No; invasive,
Cal-IPC
2 Low 20,20,30,20 Off-site tagged on fence; can’t see trunk; extends over property by 9’; dieback; pruned away from property.
197 River red gum 26 No; invasive,
Cal-IPC
3 Moderate 12,15,20,20 Wide codominant attachment @ 12’;some included bark; good growth.
198 River red gum 39 No; invasive,
Cal-IPC
3 Low 16,10,20,20 Wide multiple trunks arise from 20’; branches over property topped.
199 River red gum 30 No; invasive,
Cal-IPC
3 Moderate 16,18,20,16 Wide multiple trunks arise from 15&17’; sap sucker evidence; branches over property topped.
200 River she-oak 15 Yes 4 High 10,10,10,10 Single upright trunk; good form; good growth.201 River she-oak 23 Yes 4 High 17,17,17,17 Codominant upright trunks; good form; good growth.202 River she-oak 12 No 4 Moderate 6,6,8,8 Codominant upright trunks arise from 12&14’; branches topped; good growth.
203 Water gum 15 Yes 4 Moderate 8,5,12,19 Heavily suppressed by building; good health; codominant trunks.

Exhibit
A
Item 12: Staff Report Pg. 81 Packet Pg. 523 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
204 Water gum 15 Yes 3 Moderate 14,0,15,16 Heavily suppressed by building; good health; thin. 205 Water gum 10 No 3 Moderate 10,0,10,8 Heavily suppressed by building; good health; thin; multiple trunks arise from 8’.
206 Water gum 10 No 3 Moderate 14,0,12,10 Heavily suppressed by building; good health; thin; codominant and multiple trunks.
207 Water gum 9 No 3 Moderate 12,0,10,8 Heavily suppressed by building; good health; thin; codominant trunks.
208 River red gum 40 No; invasive,
Cal-IPC
4 Moderate 24,24,26,24 Wide multiple trunks arise from 12&15’; good growth and condition.
209 Blackwood acacia 32 No; invasive,
Cal-IPC
3 Moderate 20,22,18,20 Wide multiple trunks arise from 8’; thin; in small planter. 210 River red gum 22 No; invasive,
Cal-IPC
3 Moderate 13,14,15,18 Narrow codominant trunks arise from 10’; sap sucker evidence in upper crown decay on southern branch.
211 River red gum 38 No; invasive,
Cal-IPC
3 Low 12,15,20,15 Trunk bow over neighbor property; topped in places; thin. 212 River red gum 32 No; invasive,
Cal-IPC
2 Low 26,26,26,26 Narrow codominant trunks arise from 20’; thin; a lot of dead and dying branches.
213 River red gum 26 No; invasive,
Cal-IPC
2 Low 26,24,26,28 Wide multiple trunks arise from 12’; thin; only growth is epicormic. 214 Glossy privet 8,6,4 No; invasive,
Cal-IPC
1 Low 8,4,5,6 Growing in fence; multiple trunks arise from base; thin; ivy. 215 Coast live oak 18 Yes 3 Low 23,22,20,22 Growing at property fence line; suppressed; high crown. 216 River red gum 43 No; invasive,
Cal-IPC
4 High 40,35,35,35 Codominant trunks arise from high in crown; good form and growth; oak under crown.
217 Southern magnolia 19 Yes 4 Moderate 24,22,24,24 Multiple trunks arise from 4’; good form and growth; round crown.218 Southern magnolia 12 No 4 Moderate 17,17,16,18 Multiple trunks arise from 4’; good form and growth; round crown. 219 Coast live oak 16 Yes 5 High 10,21,8,10 Off-site tagged on fence; extends over the property by 15’. 220 Coast live oak 11 Yes 4 Moderate 8,17,15,10 Off-site tagged on fence; extends over the property by 8’. 221 Coast live oak 15 Yes 4 Moderate 6,11,15,15 Off-site tagged on fence; extends over the property by 4’.222 Ginkgo 15 Yes 3 Moderate 18,12,18,18 Straight upright crown; one-sided east.

Exhibit
A
Item 12: Staff Report Pg. 82 Packet Pg. 524 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
223 Silk oak 32 Yes 3 Moderate 18,18,20,18 Multiple trunks arise from 5’; high crown. 224 River she-oak 15 Yes 3 Moderate 15,15,15,15 Straight upright trunk; leans slightly east; minimal lateral branching.
225 River she-oak 6 No 3 Low 12,12,5,12 Codominant trunks arise from 14’; leans slightly east; minimal lateral branching.
226 River she-oak 12 No 2 Low 4,4,4,4 Single topped trunk; no branches. 227 Coast live oak 7 No 3 Low 6,0,4,5 Off-site tagged on fence; trunk embedded in property line fence; doesn’t extend over property.
228 Coast live oak 15 Yes 3 Low 4,4,15,7 Off-site tagged on fence; bows south; doesn’t extend over property.
229 Glossy privet 7,6,5,4,4,
4,4
No; invasive,
Cal-IPC
1 Low 8,8,8,8 Off-site; growing in fence; multiple trunks arise from base; thin; ivy.
230 Silk oak 15 Yes 3 Moderate 8,8,8,8 Single upright trunk; narrow high crown.231 Silk oak 12 No 3 Low 6,6,6,6 Crook in single upright trunk at 2’; narrow high crown. 232 Glossy privet 6 No; invasive,
Cal-IPC
3 Low 10,10,0,0 Sucker growth throughout crown; suppressed. 233 Silk oak 7 No 3 Low 6,6,6,6 High narrow crown.234 Blackwood acacia 17 No; invasive, Cal-IPC
2 Low 17,13,0,0 Leans heavily north; growth only at top. 235 Silk oak 13 No 3 Low 10,10,10,10 High narrow crown; suppressed. 236 River she-oak 21 Yes 3 Low 18,22,25,20 Codominant trunks arise from high in crown; leans slightly south; suppressing other trees.
237 River she-oak 17 Yes 3 Low 5,5,12,10 Codominant trunks arise from high in crown; trunk engulfed in ivy; somewhat suppressed.
238 River she-oak 14 No 3 Low 5,5,10,8 Codominant trunks arise from high in crown; in row of other trees; somewhat suppressed.
239 River she-oak 13 No 3 Low 6,4,8,5 Straight upright trunk; in row of other trees; somewhat suppressed.
240 River she-oak 10 No 3 Low 6,5,8,8 Straight upright trunk; in row of other trees; topped; somewhat suppressed.
241 River she-oak 19 Yes 3 Low 10,8,15,10 Straight upright trunk; in row of other trees; somewhat suppressed.

Exhibit
A
Item 12: Staff Report Pg. 83 Packet Pg. 525 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
242 Coast live oak 7 No 3 Low 12,7,12,8 Codominant trunks arise from base; suppressed north. 243 Coast live oak 19 Yes 3 Moderate 15,10,18,15 Upright trunk; healthy but suppressed.244 River she-oak 19 Yes 3 Low 0,0,18,0 Leaning heavily west; animal borrowing at base; heavily one sided south.
245 River she-oak 24 Yes 3 Low 18,18,18,18 Straight upright trunk; in row of other trees; somewhat suppressed.
246 Glossy privet 9,8,7 No; invasive,
Cal-IPC
2 Low 11,11,11,11 Multiple trunks; twig and branch dieback. 247 Glossy privet 6,5,4 No; invasive,
Cal-IPC
2 Low 8,8,8,8 Multiple trunks; twig and branch dieback; suppressed. 248 River she-oak 25 Yes 3 Low 15,0,10,15 Straight upright trunk; suppressed north.249 River she-oak 22 Yes 3 Low 14,14,16,14 Straight upright trunk; high narrow crown.250 River she-oak 18 Yes 2 Low 0,15,15,10 Straight upright trunk; high narrow crown; upper crown complete enfolded in other trees.
251 Glossy privet 8,8 No; invasive,
Cal-IPC
3 Low 19,19,0,10 Codominant trunks; heavily suppressed north. 252 Canary Island date palm 34 No; invasive,
Cal-IPC
4 High 14,14,14,14 18’ wood feet typical form.
253 Blue gum 13 Yes; on City
property
2 Low 5,8,5,4 Off-site; tag on fence; branches S 5’ over fence; very narrow codominant at 5’; narrow crown; poor structure.
254 Blue gum 18 Yes; on City
property
2 Low 15,10,4,10 Off-site; heading cuts at property fence; repeatedly topped. 255 Blue gum 25 Yes; on City
property
3 Low 30,35,10,10 Off-site; tag on fence; multiple attachments at 15 feet; one-sided N; branch tips over fence by 5’ to S.
256 Blue gum 20 Yes; on City
property
3 Low 15,15,4,6 Off-side; tag on fence; one-sided N; narrow intermediate tree. 257 Blue gum 14 Yes; on City
property
3 Low 15,10,3,5 Off-side; tag on fence; one-sided N; narrow suppressed tree. 258 Blue gum 8,6,6,6,5,
5 Yes; on City
property
2 Low 6,5,6,7 Off-side; tag on fence; small stems from narrow attachment at base.
259 Blue gum 10 Yes; on City
property
2 Low 6,3,3,3 Off-side; tag on fence; suppressed and leans E.

Exhibit
A
Item 12: Staff Report Pg. 84 Packet Pg. 526 of 1140
Tree No. Species Trunk
Diameter
(in.)
Protected
Tree?
Condition
1=poor
5=excellent
Suitability for
Preservation
Canopy
Spread
(N,E,S,W) (ft.)
Comments
Tree Assessment
2100 - 2400 Geng RoadPalo Alto, CANovember 2024
260 Blue gum 12 Yes; on City
property
2 Low 6,3,3,3 Off-side; tag on fence; suppressed and leans N away from fence. 261 Blue gum 22 Yes; on City
property
2 Low 20,20,5,5 Off-side; tag on fence; suppressed and leans N away from fence to baseball field; N most in group.
262 Blue gum 16 Yes; on City
property
2 Low 6,30,5,0 Off-side; tag on fence; suppressed and heavy Bow E away from fence to baseball field; middle of group.
263 Blue gum 12 Yes; on City
property
2 Low 15,5,5,0 Off-side; tag on fence; suppressed and heavy Bow N away from fence to baseball field.
264 Blue gum 12 Yes; on City
property
2 Low 10,5,3,5 Off-side; tag on fence; suppressed and heavy Bow N away from fence to baseball field; mechanical damage at base S.
265 Blue gum 26,10 Yes; on City
property
2 Low 35,15,10,10 Off-side; tag on fence; narrow intermediate tree. 266 Blue gum 10,8,6,6,5 Yes; on City
property
2 Low 10,10,6,10 Off-side; tag on fence; stump resprout; suppressed. 267 Blue gum 35,4,4,4 Yes; on City
property
2 Low 30,30,10,15 Off-side; tag on fence; set back from fence; branch tips reach fence to S.
268 Blue gum 20 Yes; on City
property
2 Low 10,10,10,8 Off-side; tag on fence; set back from fence; ivy engulfed; suppressed.
269 Blue gum 30 Yes; on City
property
3 Low 30,30,10,5 Off-side; tag on fence; set back from fence; ivy engulfed; sweep E.
270 Blue gum 25 Yes; on City
property
3 Low 25,5,5,10 Off-side; tag on fence; set back from fence; ivy engulfed; suppressed.

Exhibit
A
Item 12: Staff Report Pg. 85 Packet Pg. 527 of 1140
Tree Assessment Map
2100 –2400 Geng Road Palo Alto, CA Prepared for: Carlson, Barbee & Gibson San Ramon, CA Revised November 2024 No Scale Notes: Base map provided by: Dahlin Numbered tree locations are approximate. 2550 Ninth Street, Suite 112 Berkeley, CA 94710 Phone 925.484.0211 Fax 925.484.0596 1 2 3
7 4
5 6
8 9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 27 26
28 29
30 31
32 33
34 35 36
37 38
39 40
41 42
43 44 45
46 47
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51 52
53 54
55 61
60 59
58 57
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63 64
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80 79
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111
112
113
114
115
116
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123
124
125
127 126
128
129
130
131 132
133
134
135
136
137
138
139
140
141
142
143
144
145
146 147
148
149
150
151
152
153
154
155
156
157
158 159
160 161
162
163 164
165
166
175 174 173 172 171 170
168 167 169 200
201 202
189 187
176
178 177 179
186 185
181 180 182 184 183
190 188
191 192
193
194
195
196
197
198
199
203
204
205
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209
210
211
212
213
214
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230
231
232 233
235 234
236
237
244
245
238
239
246
247 248
249
250 251
252
253
254
255
256
257 260 261
265
264
263
264 266
267 270 269 268
262
259 258
Exhibit
A
Item 12: Staff Report Pg. 86 Packet Pg. 528 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) 1 River she-oak 18 Yes Remove Within development footprint 6,750.00 $ 24 Three 24-inch box Two 36-inch box 2 River she-oak 19 Yes Remove Within development footprint 7,500.00 $ 23 Three 24-inch box Two 36-inch box 3 Western redbud 7 No Remove Within development footprint 2,000.00 $ 12 Three 24-inch box Two 36-inch box 4 Crabapple 5 No Remove Within development footprint $ 750.00 11 Three 24-inch box Two 36-inch box 5 Crabapple 8 No Remove Within development footprint 1,650.00 $ 13 Three 24-inch box Two 36-inch box 6 Crabapple 8 No Remove Within development footprint 1,650.00 $ 15 Three 24-inch box Two 36-inch box 7 River she-oak 24 Yes; street
tree
Remove Frontage being demolished and 6,850.00 $ 34 Four 24-inch box Two 48-inch box 8 Crabapple 7 No Remove Within development footprint 1,300.00 $ 12 Three 24-inch box Two 36-inch box 9 Crabapple 8 No Remove Within development footprint 1,650.00 $ 19 Three 24-inch box Two 36-inch box 10 Crabapple 7 No Remove Within development footprint 1,300.00 $ 12 Three 24-inch box Two 36-inch box11 Crabapple 7 No Remove Within development footprint 1,300.00 $ 14 Three 24-inch box Two 36-inch box12 Crabapple 7 No Remove Within development footprint 1,300.00 $ 12 Three 24-inch box Two 36-inch box13 Crabapple 10 No Remove Within development footprint 3,350.00 $ 21 Three 24-inch box Two 36-inch box14 River she-oak 11 No Remove Within development footprint 1,950.00 $ 23 Three 24-inch box Two 36-inch box15 River she-oak 18 Yes Remove Within development footprint 4,900.00 $ 24 Three 24-inch box Two 36-inch box 16 River she-oak 18 Yes Remove Within development footprint 4,900.00 $ 20 Three 24-inch box Two 36-inch box 17 River she-oak 19 Yes Remove Within development footprint 7,500.00 $ 35 Four 24-inch box Two 48-inch box18 Blackwood acacia
25 No; invasive Remove Within development footprint 12,850.00 $ 44 Six 24-inch box Two 48-inch box & two 36-inch box
Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
Exhibit
A
Item 12: Staff Report Pg. 87 Packet Pg. 529 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
19 Blackwood
acacia
20 No; invasive Remove Within development footprint 5,150.00 $ 21 Three 24-inch box Two 36-inch box 20 River she-oak 18 Yes; street
tree
Remove Frontage being demolished and 2,900.00 $ 29 Four 24-inch box Two 48-inch box 21 Blackwood
acacia
18 No; invasive Remove Within development footprint 6,750.00 $ 30 Four 24-inch box Two 48-inch box 22 Canary Island
date palm
40 Yes; City
property
Remove Off-site; edge of development, st $ 20 Three 24-inch box Two 36-inch box 3,704.00 23 Blue gum 42 Yes; City
property
Remove Off-site; edge of development, st $ 58 Two 24-inch box 4,300.00 & two 36-inch box + two 48-inch box
Replace the tree with a combination of both tree canopy and tree value standards 24 Blue gum 26 No; invasive Remove Within development footprint 4,650.00 $ 29 Four 24-inch box Two 48-inch box 25 Blackwood
acacia
12 Yes; City
property
Remove Off-site; edge of development, st $ 16 Three 24-inch box Two 36-inch box 1,050.00 26 Water gum 8 No Remove Within development footprint 1,400.00 $ 14 Three 24-inch box Two 36-inch box 27 Water gum 7 No Remove Within development footprint 1,300.00 $ 16 Three 24-inch box Two 36-inch box 28 Water gum 8 No Remove Within development footprint 2,200.00 $ 16 Three 24-inch box Two 36-inch box 29 Water gum 9 No Remove Within development footprint 2,750.00 $ 18 Three 24-inch box Two 36-inch box 30 Water gum 9 No Remove Within development footprint 2,750.00 $ 22 Three 24-inch box Two 36-inch box 31 Water gum 9 No Remove Within development footprint 2,750.00 $ 20 Three 24-inch box Two 36-inch box 32 Blackwood
acacia
12 No; invasive Remove Within development footprint 1,850.00 $ 18 Three 24-inch box Two 36-inch box 33 Blackwood
acacia
18 No; invasive Remove Within development footprint 3,550.00 $ 28 Four 24-inch box Two 48-inch box 34 Japanese maple 7,6 Yes Remove Within development footprint 1,450.00 $ 19 Three 24-inch box Two 36-inch box 35 Coast redwood 18 Yes Remove Within development footprint 1,800.00 $ 24 Three 24-inch box Two 36-inch box 36 Coast redwood 20 Yes Remove Within development footprint 2,200.00 $ 20 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 88 Packet Pg. 530 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
37 Coast redwood 19 Yes Remove Within development footprint 2,000.00 $ 20 Three 24-inch box Two 36-inch box 38 River red gum 32 No; invasive Remove Within development footprint 6,550.00 $ 33 Four 24-inch box Two 48-inch box39 River red gum 31 No; invasive Remove Within development footprint 8,550.00 $ 44 Six 24-inch box Two 48-inch box & two 36-inch box
40 River red gum 20 No; invasive Remove Within development footprint 3,650.00 $ 18 Three 24-inch box Two 36-inch box 41 River red gum 23 No; invasive Remove Within development footprint 4,800.00 $ 28 Four 24-inch box Two 48-inch box42 Holly oak 7 No Preserve Off-site; severe impacts $ 900.00 14 Three 24-inch box Two 36-inch box 43 Holly oak 6 No Preserve Off-site; severe impacts $ 700.00 11 Three 24-inch box Two 36-inch box44 Yellow willow 20,12 No; high water use
Preserve Off-site; severe impacts $ 3,800.00 28 Four 24-inch box Two 48-inch box 45 River red gum 35 No; invasive Remove Within development footprint 10,850.00 $ 45 Six 24-inch box Two 48-inch box & two 36-inch box
46 River red gum 32 No; invasive Remove Within development footprint 9,100.00 $ 36 Four 24-inch box Two 48-inch box47 River red gum 12 No; invasive Remove Within development footprint 1,450.00 $ 20 Three 24-inch box Two 36-inch box 48 River she-oak 24 Yes Preserve Off-site; severe impacts $ 2,600.00 27 Three 24-inch box Two 36-inch box 49 Coast live oak 13 Yes Preserve Off-site; severe impacts $ 900.00 19 Three 24-inch box Two 36-inch box 50 Black alder 7 No; high
water use
Remove Within development footprint $ 700.00 18 Three 24-inch box Two 36-inch box 51 Evergreen ash 11,10 No; messy
fruit
Remove Within development footprint 2,050.00 $ 26 Three 24-inch box Two 36-inch box 52 Raywood ash 16 Yes Remove Within development footprint 3,800.00 $ 32 Four 24-inch box Two 48-inch box 53 Raywood ash 11 No Remove Within development footprint 1,900.00 $ 24 Three 24-inch box Two 36-inch box 54 Raywood ash 13 No Remove Within development footprint 2,550.00 $ 22 Three 24-inch box Two 36-inch box55 Raywood ash 18 Yes Remove Within development footprint 2,900.00 $ 30 Four 24-inch box Two 48-inch box 56 Raywood ash 14 No Remove Within development footprint 1,850.00 $ 20 Three 24-inch box Two 36-inch box57 Raywood ash 18 Yes Remove Within development footprint 2,900.00 $ 30 Four 24-inch box Two 48-inch box 58 Raywood ash 16 Yes Remove Within development footprint 2,900.00 $ 30 Four 24-inch box Two 48-inch box Exhibit
A
Item 12: Staff Report Pg. 89 Packet Pg. 531 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
59 Raywood ash 16 Yes Remove Within development footprint 2,900.00 $ 30 Four 24-inch box Two 48-inch box 60 Raywood ash 14 No Remove Within development footprint 2,250.00 $ 31 Four 24-inch box Two 48-inch box 61 Raywood ash 14 No Remove Within development footprint 2,250.00 $ 24 Three 24-inch box Two 36-inch box 62 Sweetgum 14 No Remove Within development footprint 2,250.00 $ 20 Three 24-inch box Two 36-inch box 63 Sweetgum 16 Yes Remove Within development footprint 6,500.00 $ 35 Four 24-inch box Two 48-inch box 64 Sweetgum 14 No Remove Within development footprint 2,250.00 $ 18 Three 24-inch box Two 36-inch box 65 Coast redwood 30 Yes Remove Within development footprint 4,650.00 $ 40 Four 24-inch box Two 48-inch box66 Coast redwood 29 Yes Remove Within development footprint 4,350.00 $ 26 Three 24-inch box Two 36-inch box 67 Coast redwood 31 Yes Remove Within development footprint 4,950.00 $ 34 Four 24-inch box Two 48-inch box68 Cherry 7 No Remove Within development footprint 1,250.00 $ 10 Three 24-inch box Two 36-inch box69 Sweetgum 12 No Remove Within development footprint 1,700.00 $ 26 Three 24-inch box Two 36-inch box 70 Sweetgum 11 No Remove Within development footprint 1,900.00 $ 20 Three 24-inch box Two 36-inch box 71 Sweetgum 13 No Remove Within development footprint 3,750.00 $ 23 Three 24-inch box Two 36-inch box 72 Sweetgum 13 No Remove Within development footprint 3,750.00 $ 22 Three 24-inch box Two 36-inch box 73 Sweetgum 12 No Remove Within development footprint 1,700.00 $ 26 Three 24-inch box Two 36-inch box 74 Cherry 10 No Remove Within development footprint 2,300.00 $ 14 Three 24-inch box Two 36-inch box 75 Coast redwood 26 Yes Remove Within development footprint 5,800.00 $ 28 Four 24-inch box Two 48-inch box76 Coast redwood 19 Yes Remove Within development footprint 3,200.00 $ 24 Three 24-inch box Two 36-inch box 77 Coast redwood 17 No Remove Within development footprint 2,600.00 $ 22 Three 24-inch box Two 36-inch box78 Coast redwood 17 No Remove Within development footprint 2,600.00 $ 26 Three 24-inch box Two 36-inch box79 Coast redwood 32 Yes Remove Within development footprint 12,050.00 $ 30 Four 24-inch box Two 48-inch box80 Coast redwood 28 Yes Remove Within development footprint 6,700.00 $ 26 Three 24-inch box Two 36-inch box 81 Sweetgum 10 No Remove Within development footprint $ 850.00 17 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 90 Packet Pg. 532 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
82 Coast redwood 25 Yes Remove Within development footprint 5,350.00 $ 24 Three 24-inch box Two 36-inch box 83 Coast redwood 21 Yes Remove Within development footprint 3,850.00 $ 16 Three 24-inch box Two 36-inch box 84 Coast redwood 26 Yes Remove Within development footprint 5,800.00 $ 26 Three 24-inch box Two 36-inch box 85 Coast redwood 28 Yes Remove Within development footprint 4,100.00 $ 28 Four 24-inch box Two 48-inch box86 Coast redwood 27 Yes Remove Within development footprint 3,800.00 $ 26 Three 24-inch box Two 36-inch box 87 European white
birch
7 No; high
water use
Remove Within development footprint $ 500.00 12 Three 24-inch box Two 36-inch box 88 Coast redwood 32 Yes Remove Within development footprint 12,050.00 $ 32 Four 24-inch box Two 48-inch box89 Coast redwood 25 Yes Remove Within development footprint 3,300.00 $ 26 Three 24-inch box Two 36-inch box 90 Coast redwood 28 Yes Remove Within development footprint 4,100.00 $ 28 Four 24-inch box Two 48-inch box91 Coast redwood 26 Yes Remove Within development footprint 3,550.00 $ 24 Three 24-inch box Two 36-inch box 92 Coast redwood 25 Yes Remove Within development footprint 3,300.00 $ 24 Three 24-inch box Two 36-inch box 93 Coast redwood 26 Yes Remove Within development footprint 3,550.00 $ 30 Four 24-inch box Two 48-inch box94 Coast redwood 31 Yes Remove Within development footprint 4,950.00 $ 30 Four 24-inch box Two 48-inch box95 Mayten 11 No Remove Within development footprint 2,450.00 $ 24 Three 24-inch box Two 36-inch box 96 Water gum 11 No Remove Within development footprint 1,100.00 $ 19 Three 24-inch box Two 36-inch box 97 Water gum 11 No Remove Within development footprint 1,100.00 $ 15 Three 24-inch box Two 36-inch box 98 Water gum 9 No Remove Within development footprint $ 800.00 14 Three 24-inch box Two 36-inch box 99 Water gum 10 No Remove Within development footprint $ 950.00 9 Two 24-inch box One 36-inch box 100 Raywood ash 18 Yes Remove Within development footprint 2,900.00 $ 17 Three 24-inch box Two 36-inch box 101 Water gum 11 No Remove Within development footprint 1,100.00 $ 20 Three 24-inch box Two 36-inch box 102 Water gum 11 No Remove Within development footprint 1,100.00 $ 22 Three 24-inch box Two 36-inch box 103 Water gum 11 No Remove Within development footprint 1,100.00 $ 22 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 91 Packet Pg. 533 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
104 Water gum 10 No Remove Within development footprint $ 950.00 16 Three 24-inch box Two 36-inch box 105 Water gum 9 No Remove Within development footprint $ 800.00 18 Three 24-inch box Two 36-inch box 106 Raywood ash 23 Yes Remove Within development footprint 4,650.00 $ 34 Four 24-inch box Two 48-inch box107 Sweetgum 12 No Remove Within development footprint 1,700.00 $ 24 Three 24-inch box Two 36-inch box108 Sweetgum 11 No Remove Within development footprint 1,900.00 $ 22 Three 24-inch box Two 36-inch box109 Sweetgum 13 No Remove Within development footprint 2,000.00 $ 18 Three 24-inch box Two 36-inch box110 Sweetgum 16 Yes Remove Within development footprint 2,900.00 $ 18 Three 24-inch box Two 36-inch box111 Coast redwood 34 Yes Remove Within development footprint 8,250.00 $ 34 Four 24-inch box Two 48-inch box 112 Coast redwood 35 Yes Remove Within development footprint 8,700.00 $ 36 Four 24-inch box Two 48-inch box 113 Sweetgum 14 No Remove Within development footprint 2,950.00 $ 14 Three 24-inch box Two 36-inch box114 Sweetgum 12 No Remove Within development footprint 2,200.00 $ 20 Three 24-inch box Two 36-inch box115 Sweetgum 11 No Remove Within development footprint 1,900.00 $ 21 Three 24-inch box Two 36-inch box116 Coast redwood 29 Yes Remove Within development footprint 6,050.00 $ 30 Four 24-inch box Two 48-inch box 117 Coast redwood 26 Yes Remove Within development footprint 4,900.00 $ 24 Three 24-inch box Two 36-inch box 118 Coast redwood 30 Yes Remove Within development footprint 6,450.00 $ 28 Four 24-inch box Two 48-inch box 119 Coast redwood 31 Yes Remove Within development footprint 6,850.00 $ 28 Four 24-inch box Two 48-inch box 120 Coast redwood 25 Yes Remove Within development footprint 7,450.00 $ 30 Four 24-inch box Two 48-inch box 121 Coast redwood 27 Yes Remove Within development footprint 8,650.00 $ 32 Four 24-inch box Two 48-inch box 122 Coast redwood 35 Yes Remove Within development footprint 14,400.00 $ 36 Four 24-inch box Two 48-inch box123 Raywood ash 21 Yes Remove Within development footprint 3,900.00 $ 26 Three 24-inch box Two 36-inch box124 Chinese flame tree
11 No Remove Within development footprint 2,650.00 $ 31 Four 24-inch box Two 48-inch box 125 River she-oak 18 Yes Remove Within development footprint 3,550.00 $ 22 Three 24-inch box Two 36-inch box126 Blackwood acacia
15 No; invasive Remove Within development footprint 3,450.00 $ 30 Four 24-inch box Two 48-inch box 127 River she-oak 19 Yes Remove Within development footprint 3,950.00 $ 18 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 92 Packet Pg. 534 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
128 River she-oak 14 No Remove Within development footprint 2,250.00 $ 21 Three 24-inch box Two 36-inch box129 River she-oak 16 Yes Remove Within development footprint 2,850.00 $ 18 Three 24-inch box Two 36-inch box130 Blackwood acacia
26 No; invasive Remove Within development footprint 6,050.00 $ 34 Four 24-inch box Two 48-inch box 131 Sweetgum 19 Yes Remove Within development footprint 5,500.00 $ 32 Four 24-inch box Two 48-inch box132 Sweetgum 19 Yes Remove Within development footprint 4,000.00 $ 30 Four 24-inch box Two 48-inch box133 Sweetgum 12 No Remove Within development footprint 1,700.00 $ 19 Three 24-inch box Two 36-inch box134 Sweetgum 15 Yes Remove Within development footprint 2,550.00 $ 25 Three 24-inch box Two 36-inch box135 Sweetgum 17 Yes Remove Within development footprint 3,250.00 $ 21 Three 24-inch box Two 36-inch box136 Sweetgum 10 No Remove Within development footprint 1,250.00 $ 23 Three 24-inch box Two 36-inch box137 Sweetgum 12 No Remove Within development footprint 1,700.00 $ 26 Three 24-inch box Two 36-inch box138 Water gum 12 No Remove Within development footprint 1,300.00 $ 21 Three 24-inch box Two 36-inch box 139 Water gum 12 No Remove Within development footprint 1,300.00 $ 20 Three 24-inch box Two 36-inch box 140 Water gum 12 No Remove Within development footprint 1,300.00 $ 14 Three 24-inch box Two 36-inch box 141 Water gum 13 No Remove Within development footprint 1,450.00 $ 18 Three 24-inch box Two 36-inch box 142 Water gum 12 No Remove Within development footprint 1,300.00 $ 16 Three 24-inch box Two 36-inch box 143 African fern-pine 16 Yes Remove Within development footprint 2,900.00 $ 24 Three 24-inch box Two 36-inch box 144 African fern-pine 13 No Remove Within development footprint 3,150.00 $ 20 Three 24-inch box Two 36-inch box 145 European white
birch
8 No; high
water use
Remove Within development footprint $ 600.00 10 Three 24-inch box Two 36-inch box 146 European white
birch
10 No; high
water use
Remove Within development footprint $ 800.00 16 Three 24-inch box Two 36-inch box 147 Japanese maple 6 No Remove Within development footprint $ 350.00 16 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 93 Packet Pg. 535 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
148 Japanese maple 7 No Remove Within development footprint $ 350.00 10 Three 24-inch box Two 36-inch box149 Blackwood acacia
29 No; invasive Remove Within development footprint 10,650.00 $ 36 Four 24-inch box Two 48-inch box 150 River she-oak 22 Yes Remove Within development footprint 6,200.00 $ 18 Three 24-inch box Two 36-inch box151 River she-oak 25 Yes Remove Within development footprint 7,950.00 $ 21 Three 24-inch box Two 36-inch box152 River she-oak 20 Yes Remove Within development footprint 5,150.00 $ 17 Three 24-inch box Two 36-inch box153 European white birch
7 No; high
water use
Remove Within development footprint $ 500.00 10 Three 24-inch box Two 36-inch box 154 Japanese maple 6,4 Yes Remove Within development footprint $ 400.00 11 Three 24-inch box Two 36-inch box 155 European white
birch
6 No; high
water use
Remove Within development footprint $ 400.00 8 Two 24-inch box One 36-inch box 156 European white
birch
10 No; high
water use
Remove Within development footprint $ 800.00 11 Three 24-inch box Two 36-inch box 157 River she-oak 19 Yes Remove Within development footprint 4,700.00 $ 16 Three 24-inch box Two 36-inch box158 River she-oak 16 Yes Remove Within development footprint 3,350.00 $ 16 Three 24-inch box Two 36-inch box159 River she-oak 15 Yes Remove Within development footprint 3,000.00 $ 19 Three 24-inch box Two 36-inch box160 Blackwood acacia
9 No; invasive Remove Within development footprint $ 500.00 13 Three 24-inch box Two 36-inch box 161 Blue gum 25 Yes; City
property
Remove
Off-site; edge of development, st
$ 40 Four 24-inch box Two 48-inch box 1,450.00
162 Blue gum 38 Yes; City
property
Remove
Off-site; edge of development, st
$ 45 Six 24-inch box Two 48-inch box 3,050.00
& two 36-inch box
163 Blue gum 36 Yes; City
property
Remove
Off-site; edge of development, st
$ 38 Four 24-inch box Two 48-inch box 2,750.00
164 Blue gum 38 Yes; City
property
Remove
Off-site; edge of development, st
$ 18 Three 24-inch box Two 36-inch box 3,050.00
165 Blue gum 36 Yes; City
property
Remove
Off-site; edge of development, st
$ 55 Six 24-inch box Two 48-inch box 4,500.00
& two 36-inch box
Exhibit
A
Item 12: Staff Report Pg. 94 Packet Pg. 536 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
166 Blue gum 40 Yes; City
property
Remove
Off-site; edge of development, st
$ 75 Replace the tree 5,500.00
with a combination of both tree canopy and tree value standards Replace the tree with a combination of both tree canopy and tree value standards 167 Blue gum 56 Yes; City
property
Remove
Off-site; edge of development, st
$ 45 Six 24-inch box Two 48-inch box 10,550.00
& two 36-inch box
168 Blue gum 40 Yes; City
property
Remove
Off-site; edge of development, st
$ 43 Six 24-inch box Two 48-inch box 5,500.00
& two 36-inch box
169 Blue gum 28,26 Yes; City
property
Remove
Off-site; edge of development, st
$ 38 Four 24-inch box Two 48-inch box 5,050.00
170 Blue gum 38 Yes; City
property
Remove
Off-site; edge of development, st
$ 50 Six 24-inch box Two 48-inch box 5,000.00
& two 36-inch box
171 Blue gum 21 Yes; City
property
Remove
Off-site; edge of development, st
$ 16 Three 24-inch box Two 36-inch box 1,100.00
172 Blue gum 19 Yes; City
property
Remove
Off-site; edge of development, st
$ 23 Three 24-inch box Two 36-inch box 900.00
173 Blue gum 19 Yes; City
property
Remove
Off-site; edge of development, st
$ 35 Four 24-inch box Two 48-inch box 900.00
174 Blue gum 42 Yes; City
property
Remove
Off-site; edge of development, st
$ 58 Two 24-inch box 3,700.00
& two 36-inch box
+ two 48-inch box
Replace the tree with a combination of both tree canopy and tree value standards 175 Blue gum 53 Yes; City
property
Remove
Off-site; edge of development, st
$ 53 Six 24-inch box Two 48-inch box 5,750.00
& two 36-inch box
176 Blue gum 48 Yes; City
property
Remove
Off-site; edge of development, st
$ 50 Six 24-inch box Two 48-inch box 4,750.00
& two 36-inch box
177 Blue gum 42 Yes; City
property
Remove
Off-site; edge of development, st
$ 48 Six 24-inch box Two 48-inch box 3,700.00
& two 36-inch box
Exhibit A
Item 12: Staff Report Pg. 95 Packet Pg. 537 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
178 Blue gum 25 Yes; City
property
Remove
Off-site; edge of development, st
$ 25 Three 24-inch box Two 36-inch box 1,450.00
179 Blue gum 36 Yes; City
property
Remove
Off-site; edge of development, st
$ 35 Four 24-inch box Two 48-inch box 2,750.00
180 Blue gum 17 Yes; City
property
Remove
Off-site; edge of development, st
$ 11 Three 24-inch box Two 36-inch box 750.00
181 Blue gum 46 Yes; City
property
Remove
Off-site; edge of development, st
$ 58 Two 24-inch box 7,200.00
& two 36-inch box + two 48-inch box
Replace the tree with a combination of both tree canopy and tree value standards 182 Blue gum 42 Yes; City
property
Remove
Off-site; edge of development, st
$ 40 Four 24-inch box Two 48-inch box 6,050.00
183 Blue gum 16,10,5 Yes; City
property
Remove
Off-site; edge of development, st
$ 28 Four 24-inch box Two 48-inch box 900.00
184 Blue gum 25 Yes; City
property
Remove
Off-site; edge of development, st
$ 33 Four 24-inch box Two 48-inch box 1,450.00
185 Blue gum 26 Yes; City
property
Remove
Off-site; edge of development, st
$ 38 Four 24-inch box Two 48-inch box 1,550.00
186 Blue gum 28 Yes; City
property
Remove
Off-site; edge of development, st
$ 25 Three 24-inch box Two 36-inch box 1,750.00
187 Blue gum 52 Yes; City
property
Remove
Off-site; edge of development, st
$ 70 Replace the tree 9,150.00
with a combination of both tree canopy and tree value standards Replace the tree with a combination of both tree canopy and tree value standards 188 Blue gum 26 Yes; City
property
Remove
Off-site; edge of development, st
$ 13 Three 24-inch box Two 36-inch box 1,550.00
189 River she-oak 10 No Remove Within development footprint 1,450.00 $ 12 Three 24-inch box Two 36-inch box190 River she-oak 6 No Remove Within development footprint $ 450.00 10 Three 24-inch box Two 36-inch box 191 River she-oak 10 No Remove Within development footprint $ 950.00 13 Three 24-inch box Two 36-inch box192 River she-oak 12 No Remove Within development footprint 2,000.00 $ 14 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 96 Packet Pg. 538 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
193 River she-oak 7 No Remove Within development footprint $ 550.00 10 Three 24-inch box Two 36-inch box 194 River she-oak 8 No Remove Within development footprint $ 700.00 9 Two 24-inch box One 36-inch box 195 River she-oak 7 No Remove Within development footprint $ 550.00 7 Two 24-inch box One 36-inch box 196 Blue gum 30 No; invasive Preserve Off-site; severe impacts $ 2,000.00 45 Six 24-inch box Two 48-inch box & two 36-inch box
197 River red gum 26 No; invasive Remove Within development footprint 7,200.00 $ 34 Four 24-inch box Two 48-inch box198 River red gum 39 No; invasive Remove Within development footprint 15,900.00 $ 33 Four 24-inch box Two 48-inch box 199 River red gum 30 No; invasive Remove Within development footprint 9,500.00 $ 35 Four 24-inch box Two 48-inch box200 River she-oak 15 Yes Remove Within development footprint 4,100.00 $ 20 Three 24-inch box Two 36-inch box201 River she-oak 23 Yes Remove Within development footprint 9,400.00 $ 34 Four 24-inch box Two 48-inch box202 River she-oak 12 No Remove Within development footprint 2,700.00 $ 14 Three 24-inch box Two 36-inch box203 Water gum 15 Yes Remove Within development footprint 2,550.00 $ 22 Three 24-inch box Two 36-inch box204 Water gum 15 Yes Remove Within development footprint 1,900.00 $ 23 Three 24-inch box Two 36-inch box205 Water gum 10 No Remove Within development footprint $ 950.00 14 Three 24-inch box Two 36-inch box 206 Water gum 10 No Remove Within development footprint $ 950.00 18 Three 24-inch box Two 36-inch box 207 Water gum 9 No Remove Within development footprint $ 800.00 15 Three 24-inch box Two 36-inch box 208 River red gum 40 No; invasive Remove Within development footprint 23,350.00 $ 49 Six 24-inch box Two 48-inch box & two 36-inch box
209 Blackwood
acacia
32 No; invasive Remove Within development footprint 6,550.00 $ 40 Four 24-inch box Two 48-inch box 210 River red gum 22 No; invasive Remove Within development footprint 5,200.00 $ 30 Four 24-inch box Two 48-inch box211 River red gum 38 No; invasive Remove Within development footprint 15,100.00 $ 31 Four 24-inch box Two 48-inch box 212 River red gum 32 No; invasive Remove Within development footprint 6,550.00 $ 52 Six 24-inch box Two 48-inch box & two 36-inch box
213 River red gum 26 No; invasive Remove Within development footprint 4,400.00 $ 52 Six 24-inch box Two 48-inch box & two 36-inch box
Exhibit
A
Item 12: Staff Report Pg. 97 Packet Pg. 539 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
214 Glossy privet 8,6,4 No; invasive Remove Within development footprint $ 300.00 12 Three 24-inch box Two 36-inch box215 Coast live oak 18 Yes Remove Within development footprint 1,550.00 $ 44 Six 24-inch box Two 48-inch box & two 36-inch box
216 River red gum 43 No; invasive Remove Within development footprint 26,950.00 $ 73 Replace the tree with a combination of both tree canopy and tree value standards Replace the tree with a combination of both tree canopy and tree value standards 217 Southern
magnolia
19 Yes Remove Within development footprint 6,450.00 $ 47 Six 24-inch box Two 48-inch box & two 36-inch box
218 Southern
magnolia
12 No Remove Within development footprint 1,850.00 $ 34 Four 24-inch box Two 48-inch box 219 Coast live oak 16 Yes Preserve Off-site; severe impacts $ 3,050.00 25 Three 24-inch box Two 36-inch box 220 Coast live oak 11 Yes Preserve Off-site; severe impacts $ 1,250.00 25 Three 24-inch box Two 36-inch box221 Coast live oak 15 Yes Preserve Off-site; severe impacts $ 2,150.00 24 Three 24-inch box Two 36-inch box222 Ginkgo 15 Yes Remove Within development footprint 3,350.00 $ 33 Four 24-inch box Two 48-inch box223 Silk oak 32 Yes Remove Within development footprint 21,750.00 $ 37 Four 24-inch box Two 48-inch box224 River she-oak 15 Yes Remove Within development footprint 3,000.00 $ 30 Four 24-inch box Two 48-inch box225 River she-oak 6 No Remove Within development footprint $ 650.00 21 Three 24-inch box Two 36-inch box 226 River she-oak 12 No Remove Within development footprint 1,250.00 $ 8 Two 24-inch box One 36-inch box227 Coast live oak 7 No Preserve Off-site; severe impacts $ 500.00 8 Two 24-inch box One 36-inch box 228 Coast live oak 15 Yes Preserve Off-site; severe impacts $ 1,600.00 15 Three 24-inch box Two 36-inch box 229 Glossy privet 7,6,5,4,4,4,4 No; invasive Preserve Off-site; severe impacts $ 250.00 16 Three 24-inch box Two 36-inch box 230 Silk oak 15 Yes Remove Within development footprint 4,150.00 $ 16 Three 24-inch box Two 36-inch box 231 Silk oak 12 No Remove Within development footprint 2,700.00 $ 12 Three 24-inch box Two 36-inch box232 Glossy privet 6 No; invasive Remove Within development footprint $ 400.00 10 Three 24-inch box Two 36-inch box Exhibit
A
Item 12: Staff Report Pg. 98 Packet Pg. 540 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
233 Silk oak 7 No Remove Within development footprint $ 700.00 12 Three 24-inch box Two 36-inch box 234 Blackwood
acacia
17 No; invasive Remove Within development footprint 1,300.00 $ 15 Three 24-inch box Two 36-inch box 235 Silk oak 13 No Remove Within development footprint 2,000.00 $ 20 Three 24-inch box Two 36-inch box 236 River she-oak 21 Yes Remove Within development footprint 4,750.00 $ 43 Six 24-inch box Two 48-inch box & two 36-inch box
237 River she-oak 17 Yes Remove Within development footprint 3,200.00 $ 16 Three 24-inch box Two 36-inch box238 River she-oak 14 No Remove Within development footprint 2,250.00 $ 14 Three 24-inch box Two 36-inch box239 River she-oak 13 No Remove Within development footprint 1,950.00 $ 12 Three 24-inch box Two 36-inch box240 River she-oak 10 No Remove Within development footprint 1,250.00 $ 14 Three 24-inch box Two 36-inch box241 River she-oak 19 Yes Remove Within development footprint 3,950.00 $ 22 Three 24-inch box Two 36-inch box242 Coast live oak 7 No Remove Within development footprint $ 700.00 20 Three 24-inch box Two 36-inch box243 Coast live oak 19 Yes Remove Within development footprint 3,200.00 $ 29 Four 24-inch box Two 48-inch box244 River she-oak 19 Yes Remove Within development footprint 3,950.00 $ 9 Two 24-inch box One 36-inch box245 River she-oak 24 Yes Remove Within development footprint 6,150.00 $ 36 Four 24-inch box Two 48-inch box246 Glossy privet 9,8,7 No; invasive Remove Within development footprint $ 750.00 22 Three 24-inch box Two 36-inch box247 Glossy privet 6,5,4 No; invasive Remove Within development footprint $ 450.00 16 Three 24-inch box Two 36-inch box248 River she-oak 25 Yes Remove Within development footprint 6,650.00 $ 20 Three 24-inch box Two 36-inch box249 River she-oak 22 Yes Remove Within development footprint 5,200.00 $ 29 Four 24-inch box Two 48-inch box250 River she-oak 18 Yes Remove Within development footprint $ 600.00 20 Three 24-inch box Two 36-inch box 251 Glossy privet 8,8 No; invasive Remove Within development footprint 1,000.00 $ 24 Three 24-inch box Two 36-inch box 252 Canary Island
date palm
34 No; invasive Remove Within development footprint 8,334.00 $ 28 Four 24-inch box Two 48-inch box 253 Blue gum 13 Yes; on City
property
Remove
Off-site; edge of development, st
$ 11 Three 24-inch box Two 36-inch box 550.00
Exhibit
A
Item 12: Staff Report Pg. 99 Packet Pg. 541 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
254 Blue gum 18 Yes; on City
property
Remove
Off-site; edge of development, st
$ 20 Three 24-inch box Two 36-inch box 850.00
255 Blue gum 25 Yes; on City
property
Remove
Off-site; edge of development, st
$ 43 Six 24-inch box Two 48-inch box 2,250.00
& two 36-inch box
256 Blue gum 20 Yes; on City
property
Remove
Off-site; edge of development, st
$ 20 Three 24-inch box Two 36-inch box 1,500.00
257 Blue gum 14 Yes; on City
property
Remove
Off-site; edge of development, st
$ 17 Three 24-inch box Two 36-inch box 850.00
258 Blue gum 8,6,6,6,5,5 Yes; on City
property
Remove
Off-site; edge of development, st
$ 12 Three 24-inch box Two 36-inch box 400.00
259 Blue gum 10 Yes; on City
property
Remove
Off-site; edge of development, st
$ 8 Two 24-inch box One 36-inch box 400.00
260 Blue gum 12 Yes; on City
property
Remove
Off-site; edge of development, st
$ 8 Two 24-inch box One 36-inch box 500.00
261 Blue gum 22 Yes; on City
property
Remove
Off-site; edge of development, st
$ 25 Three 24-inch box Two 36-inch box 1,150.00
262 Blue gum 16 Yes; on City
property
Remove
Off-site; edge of development, st
$ 21 Three 24-inch box Two 36-inch box 700.00
263 Blue gum 12 Yes; on City
property
Remove
Off-site; edge of development, st
$ 13 Three 24-inch box Two 36-inch box 500.00
264 Blue gum 12 Yes; on City
property
Remove
Off-site; edge of development, st
$ 12 Three 24-inch box Two 36-inch box 500.00
265 Blue gum 26,10 Yes; on City
property
Remove
Off-site; edge of development, st
$ 35 Four 24-inch box Two 48-inch box 1,750.00
266 Blue gum 10,8,6,6,5 Yes; on City
property
Remove
Off-site; edge of development, st
$ 18 Three 24-inch box Two 36-inch box 550.00
267 Blue gum 35,4,4,4 Yes; on City
property
Remove
Off-site; edge of development, st
$ 43 Six 24-inch box Two 48-inch box 2,650.00
& two 36-inch box
268 Blue gum 20 Yes; on City
property
Remove
Off-site; edge of development, st
$ 19 Three 24-inch box Two 36-inch box 1,000.00
269 Blue gum 30 Yes; on City
property
Remove
Off-site; edge of development, st
$ 38 Four 24-inch box Two 48-inch box 3,200.00
Exhibit
A
Item 12: Staff Report Pg. 100 Packet Pg. 542 of 1140
Tree
No. Species
Trunk
Diameter
(in.)
Protected
Tree Disposition Notes Estimated Value Canopy (Avg. Diameter, ft.) Replacement Trees (24-inch box) Alternative Trees (36-inch box) Preliminary Disposition and Estimate of Value
2100 - 2400 Geng RoadPalo Alto, CAApril 2025
270 Blue gum 25 Yes; on City
property
Remove
Off-site; edge of development, st
$ 23 Three 24-inch box Two 36-inch box 2,250.00
Total $ 943,838
Exhibit
A
Item 12: Staff Report Pg. 101 Packet Pg. 543 of 1140
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS

GAS GAS GAS GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS
GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW OHW GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS GAS W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H GREEN TRASH RECYCLEW/H GREENTRASH RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLEW/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLEW/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLEW/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE W/H TRASH GREEN RECYCLE UP W/H UP W/H UP W/H UP W/H UP W/H UP W/H UP W/H UP W/H UP W/H UP W/H UP W/H 67 LYO FLO 24" BOX 5 CER FLO 24" BOX 5 ARB UNE 24" BOX 5 CAS CUN 24" BOX 6 HET ARB 24" BOX 35 GEI PAR 24" BOX 4 QUE LOB 24" BOX 3 PRU ILI 24" BOX 3 PRU ILI 24" BOX 4 ARB MEN 24" BOX 8 GIN BIL 24" BOX 5 GAR ELL 24" BOX 6 GAR ELL 24" BOX 9 ERI JAP 24" BOX 3 ARB MEN 24" BOX 4 GIN BIL 24" BOX 13 GIN BIL 24" BOX 22 ARB UNE 24" BOX 3 ARB UNE 24" BOX 11 TRI LAU 24" BOX12 CER OCC 24" BOX 48 POD GRA 24" BOX 5 CER OCC 24" BOX11 POD GRA 24" BOX 3 LAG NAT 24" BOX 27 CER OCC 24" BOX 11 LAG NAT 24" BOX 4 CER OCC 24" BOX 6 ACE CIR 24" BOX 6 ACE CIR 24" BOX 6 ARB UNE 24" BOX 15 CER OCC 24" BOX 1 QUE AGR 24" BOX 4 CER OCC 24" BOX 4 ERI JAP 24" BOX 36 POD GRA 24" BOX 14 ERI JAP 24" BOX 3 CIT MEY 24" BOX 11 CER OCC 24" BOX 4 CER OCC 24" BOX 3 CER OCC 24" BOX Treatment Type: Silva Cell. Treatment Area Name: UTS-1. See Civil Drawings. 6 ARB MEN 24" BOX 3 QUE AGR 24" BOX 2 QUE LOB 24" BOX 3 CER OCC 24" BOX 1 PRU ILI 24" BOX 15 GAR ELL 24" BOX 9 GAR ELL 24 " BOX 6 QUE AGR 24" BOX 10 GIN BIL 24" BOX 8 GAR ELL 24" BOX 6 CER OCC 24" BOX 4 GAR ELL 24" BOX 1 QUE AGR 24" BOX 3 PRU ILI 24" BOX 1 QUE AGR 24" BOX 3 QUE LOB 24" BOX 18 PLA RAC 24" BOX 20 LOP CON 24" BOX 7 GAR ELL 24" BOX 5 ARB UNE 24" BOX 10 GIN BIL 24" BOX 3 ERI JAP 24" BOX 1 QUE LOB 24" BOX 8 PRU ILI 24" BOX 4 PRU ILI 24" BOX 6 ARB UNE 24" BOX 5 PRU ILI 24" BOX 3 TRI LAU 24" BOX Treatment Type: Bioretention. Treatment Area Name: BR 3. See Civil Drawings. Treatment Type: Bioretention. Treatment Area Name: BR 2. See Civil Drawings. Treatment Type: Bioretention. Treatment Area Name: BR 4. See Civil Drawings. Existing Trees to Remain, Typ. Existing Trees to Remain, Typ. Existing Trees to Remain, Typ. Existing Trees to Remain, Typ 3 AES CAL 24 " BOX 2 GAR ELL 24" BOX 3 CER OCC 24" BOX 8 QUE AGR 24" BOX 3 PRU ILI 24" BOX 1 QUE AGR 24" BOX 0'SCALE: 1" = 50'-0" 25' 50' 100' THE INC. Guzzardo Partnership, Landscape Architects Land Planners Pier 9, The Embarcadero, Suite 115 San Francisco, CA 94111 www.tgp-inc.com 11-24-2025 PLANTING PLAN L 2.1 Exhibit
A
Item 12: Staff Report Pg. 102 Packet Pg. 544 of 1140
GAS
GAS
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OHW
OHW
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OHW

OHW GAS
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W/H
TRASH

GREEN RECYCLE

W/H TRASH
GREEN

RECYCLE W/H

TRASH GREEN

RECYCLE
W/H

TRASH GREEN

RECYCLE

W/H TRASH
GREEN

RECYCLE
W/H
TRASH

GREEN RECYCLE
W/H
TRASH

GREEN RECYCLE

W/H TRASH
GREEN

RECYCLE W/H

TRASH GREEN

RECYCLE
W/H

TRASH GREEN

RECYCLE

W/H TRASH
GREEN

RECYCLE
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TRASH

GREEN RECYCLE
W/H

TRASH GREEN

RECYCLE
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GREEN

RECYCLE
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RECYCLE

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UP
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UP
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UP
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Tree Protection
Fence, Per Arborist
Tree Protection
Fence, Per Arborist
Tree Protection
Fence, Per Arborist
Tree Protection
Fence, Per Arborist
Tree Protection
Fence, Per
Arborist
1 2
3 5
4 6
7 9 8
10 13 11
12 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
29 30
31 32
33 34
35 36
37 38
39 40 41
42 43
44 45
46 47
48 49
50 51
52 53
54 55
56 57
58 59
60 61
62 63
64 65
67 68
66 71 69
70 81
73 75 72
74 76
77 80
78 79
82 83
84 85
86 88 87
89 90
95 94
93 91 92
96 97
98 100 99
102
101
103
104
105
106 107
109 110
108
111
112
116
118
117
120
119
121
122
123
124
115
114
113
131
132
133
125
126
127
128
129 130
144
134
136
135
137 138
139
140
141
142
143
151
150 152
149
157
158
159
153
154
155
156
145
146
147
148
161
165
164 163
162
166
188
187
186 185 184 183 182 181 180 179 178 177 176 175
174
173 172 171
170 169 168 167
207
203
206
205
204
200
201
202
209
210
211
212
213
214
215
216
218
217
248
247
246
252
251
250
249
245
232
233
234
235
236
237
238
239
240
241
243
242
244
231
230
229
227
223
226
225 224
219 222
220
221
160
253
254
255
257 256
260
264
265 263
266
267 269 270 268
262
261
258
259
228
208
199
198
197
195
193
189
190 191
192
196
194
0'
SCALE: 1" = 50'-0"
25' 50' 100'
THE
INC.

GuzzardoPartnership,
Landscape Architects Land Planners
Pier 9, The Embarcadero, Suite 115
San Francisco, CA 94111 www.tgp-inc.com
11-24-2025
TREE DISPOSITION PLAN L 6.1

TREE DISPOSITION TABLE AND LEGEND
KEY
REMAIN
0 NON-PROTECTED TREE 0PROTECTED TREE
REMOVE
81 135
ON-SITE TREES QTY. KEY QTY.

KEY
46 NON-PROTECTED TREE 6PROTECTED TREE 2
0 OFF-SITE TREES QTY. KEY QTY.

KEY
46 NON-PROTECTED TREE 6PROTECTED TREE 83
135
TOTALS QTY. KEY QTY.

TREE REPLACEMENT ANALYSIS

TOTAL PROPOSED
24" BOX TREE
648

CANOPY SPREAD

SIZE OF EXISTING

TREE TO BE

REMOVED
4'-9'
10'-27'
28'-39'
REPLACEMENT
TREES
(2) 24" BOX(3) 24" BOX(4) 24" BOX
ALTERNATIVE
TREES
(1) 36" BOX
(2) 36" BOX(2) 48" BOX
44 35
# OF EXISTING

PROTECTED

TREES BEING

REMOVED
TOTAL

REPLACEMENT

REQUIREMENT
AT 24" BOX
2 132140
TOTAL

REPLACEMENT

REQUIREMENT
AT 36" BOX
---

PROPOSED TREES ANALYSIS
* Approximate ratio of new trees to trees removed - 3:1 40'-55' (6) 24" BOX (2) 36" BOX 3 18 -
56'-60' (2) 24" BOX + 0 0 0
60'+ (15) 24" BOX + 0 0 -
(2) 48" BOX
+ Replace the tree with a combination of both Tree Canopy and Tree Value Standards (2) 36" BOX(2) 48" BOX
TOTALS 648 TOTAL PROPOSED TREES
TOTAL

REPLACEMENT

REQUIREMENT
AT 48" BOX
----
0 -
TOTAL 83 292 0 0
1 CANOPY SPREAD

SIZE OF EXISTING

TREE TO BE

REMOVED
4'-9'
10'-27'
REPLACEMENT
TREES
(2) 24" BOX(3) 24" BOX(4) 24" BOX
ALTERNATIVE
TREES
(1) 36" BOX
(2) 36" BOX(2) 48" BOX
(6) 24" BOX (2) 36" BOX(2) 24" BOX +
60'+ (15) 24" BOX +
(2) 48" BOX
(2) 36" BOX(2) 48" BOX
TOTAL
TOTAL

PROPOSED

REPLACEMENT
AT 24" BOX
2 132140
---
648
18 -
-
- -
TOTAL

PROPOSED

REPLACEMENT
AT 36" BOX
TOTAL

PROPOSED

REPLACEMENT
AT 48" BOX
-----
- -
TOTAL
PROPOSED 24"

BOX IN-LIEU
-------
-
-
*Note: The ratio of 24" box trees per each 60' plus canopy is not from the CPA Tree Technical Manual.**Note: The required 48" box replacements have been added to the 36" total using a 1:1.5 ratio + Note: The proposed 36" box trees have been assigned to each canopy class using the associated ratio.

NOTE:

All existing tree information is referenced from the Arborist Report dated August 2025, prepared by
HORT Science Bartlett Consulting, (925) 484-0211.NOTE:Existing trees to remain may be impacted during construction.

See Arborist Report for more information.

PROPOSED TREES
EXTRA 356 - - -
44 35
# OF EXISTING

PROTECTED

TREES BEING

REMOVED
300
1 83
28'-39'
40'-55'
56'-60'
Exhibit
A
Item 12: Staff Report Pg. 103 Packet Pg. 545 of 1140

ATTACHMENT D

ZONING COMPARISON TABLE
2100-2400 Geng Road, 24PLN-00356
Table 1: COMPARISON WITH CHAPTER 18.20 (ROLM (E) DISTRICT) Note: Exclusively Residential Use is subject to RM-20 District Standards.

Regulation Required Proposed
Minimum/Maximum Site
Area, Width and Depth
8,500 sf area, 70 foot width, 100
foot depth
APN 008-02-035: Approximately 748 feet
wide, 300 feet deep, 239,800 square feet
APN 08-02-036: Approximately 1178 feet
wide, 500 feet deep, 240,430 square feet
Total: 480,230 square feet (~11 acres)
Minimum Front Yard 20 feet 16.5 feet
Rear Yard 10 feet 10 feet
Street Side Yard 16 feet N/A
Interior Side Yard (for
lots greater than 70 feet
in width)
10 feet 10 feet
Max. Building Height 30 feet 42 feet
Max. Site Coverage 35% (plus an additional 5% for
covered patios or overhangs) 29%
Max. Total Floor Area
Ratio
RM-20: 0.5:1
*ROLM HIS site: 1.5:1 0.98:1
Residential Density 11 to 20 units per acre 145 total units on 11 acres = 13.18 units per acre
Minimum Site Open
Space 35% 43.8%
Minimum Usable Open
Space 150 sf per unit (21,750 sf) 90,402 sf
Minimum Common Open
Space 75 sf per unit (10,875 sf) 28,294 sf
Minimum Private Open
Space 50 sf per unit (7,250 sf) 62,108 sf
Item 12
Attachment D - Zoning
Consistency
Item 12: Staff Report Pg. 104 Packet Pg. 546 of 1140
Table 2: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking) for Multiple-Family Residential
Type Required Proposed
Housing
2 per 2-bedroom or larger unit; 290
spaces
Tandem parking allowed for any unit
requiring two spaces (one tandem space
per unit, associated directly with another
parking space for the same unit, up to a
maximum of 25% of total required spaces
for any project with more than four (4)
units)
290 spaces
Includes:
70 Tandem spaces (24%) in
garages
43 additional on-street spaces
including 4 Accessible stalls
provided
Vehicle Parking
Total 290 Residential 333 Residential
Bicycle Parking One (1) per unit; 145 Long-term
One (1) per 10 units; 14.5 Short-term
145 Long-term
16 Short-term
Item 12
Attachment D - Zoning
Consistency
Item 12: Staff Report Pg. 105 Packet Pg. 547 of 1140
City of Palo Alto - Objective Design Standards Checklist