Palo Alto City Council
March 16, 2026

Objective Design Standards Checklist
The Objective Design Standards Checklist is a tool to evaluate a project’s compliance with the Zoning Ordinance (Chapter 18.24). The Checklist is not the Zoning Ordinance. Applicants shall be responsible for meeting the standards in the Zoning Ordinance. To simplify evaluation of the Zoning Ordinance, language in the Checklist may vary from the Zoning Ordinance. (Note: sf = square feet) If a standard is not applicable to applicant’s project, please write N/A in Applicant’s Justification column.

18.24.020 Public Realm/Sidewalk Character
Check Standard Sheet # Applicant’s Justification
(b)(1) Sidewalk Widths
☐
(A) In the following districts, public sidewalk width (curb to back of walk) is at least:
• Commercial Mixed-Use District: CN, CS, CC, CC(2), CD-C, CD-S, CD-N, PTOD: 10 ft • El Camino Real: 12 ft
• San Antonio Road, from Middlefield Road to East Charleston Road: 12 ft And consists of:

Pedestrian clear path width of 8 foot minimum: feet
Landscape or furniture area width of 2 foot minimum: feet ☐
If the existing public sidewalk does not meet the minimum standard, a publicly accessible extension of the sidewalk, with corresponding public access easement, shall be provided.
☐
(B) Public sidewalks or walkways connecting through a development parcel (e.g. on a through lot with a public access easement, leading to a commercial entry) must be at least 6 feet wide.
☐
(C) The width of walkways designed to provide bicycle access (e.g. pathway to bike racks/lockers) must be at least 12 feet wide, consisting of:

Pedestrian clear path width (8 feet min.): ft
Clear space/buffer – (2 feet min. on each side of path, ground cover is allowed): ft & ft
N/A as property is within the
ROLM zone, not within a
Commercial Mixed-Use District,
not along El Camino Real, and
not along San Antonio Road
N/A as no public sidewalks or
walkways will connect through
the property; private walkways
will be provided.

N/A see above
N/A see above
N/A see above
Two of the bike racks are located
immediately adjacent to the main
circulation drive so 12' pedestrian
access is not required. The 4 bike
racks on the central green is
connected by a 8' wide walkway
with min 2' buffers on either side.

L1
8 2 2
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 106 Packet Pg. 548 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check Standard Sheet # Applicant’s Justification
(B)(2) Street Trees
☐

1. One street tree provided for every 30 linear feet of public sidewalk length and located within six feet of the sidewalk.
a. Length of parcel frontage/public sidewalk length: ft b. Street Trees required (i.e. frontage/30 feet): ft
c. Street Trees provided: ft
(B)(3) Accent Paving
☐
Parcels abutting University Avenue between Alma Street and Webster include accent paving along the project frontages, as indicated below:
• Brick paving at corners
• Brick trim mid-block
☐ Parcel abutting California Avenue between El Camino Real and Park Blvd include decorative glass accent paving along project frontages
(B)(4) Mobility Infrastructure Pick One
☐
(A) On-site micromobility infrastructure (e.g. bike racks/lockers) is located within 30 feet of the primary building entry and/or on a path leading to the primary building entry; OR
☐ Existing micromobility infrastructure (e.g. bike racks/lockers) is already located within 50 feet of project site and located in a public right-of-way.

Pick One
☐
(B) Primary building entries shall provide at least one seating area or bench within 30 feet of building entry and/or path leading to building entry. On arterials (see Map T-5), except Downtown, seating areas or benches shall not be located between the sidewalk and the curb; OR
☐ Existing seating areas or benches that are already located in the public right-of-way within 50 feet of the building entry.

N/A as the project does not abut
University Avenue
Each unit has a private garage and long term
bike parking is provided in the garages. Bike
racks are centrally located so that they are
conveniently accessible to all.

Eating/benches are centrally located and
along paths to building entries so that they are
conveniently accessible to all.
154
5 5 ( two existing + 3 new )
Applicable frontage length 154'
(north of the project entry).

L1
L1.0
L1.1
L1.0
L1.1
N/A - see above
N/A - see above
N/A as the project does not abut
University Avenue
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 107 Packet Pg. 549 of 1140
City of Palo Alto - Objective Design Standards Checklist

18.24.030 Site Access
Check Standard Sheet # Applicant’s Justification
(b)(1) Through Lot Connections
☐
Through lots located more than 300 feet from an intersecting street or pedestrian walkway shall provide a publicly accessible sidewalk or pedestrian walkway (with public access easements) connecting the two streets.
(b)(2) Building Entries
☐
Primary Building Entries shall be located from a public right-of-way. If there is no public right-of-way adjacent to the building, entries shall be located from a private street or Pedestrian Walkway.
(b)(3) Vehicle Access
☐ (A) Vehicle access shall be located on alleys or side streets when they abut the property.
☐
(B) Except for driveway access and short-term loading spaces (e.g. taxi), off-street parking, off-street vehicle loading (delivery trucks), and vehicular circulation areas are prohibited between the building and primary building frontage. (b)(4) Loading Docks and Service Areas
Loading and service areas shall be integrated into building and landscape design and located to minimize impact on the pedestrian experience as follows:
☐ (A) Loading docks and service areas shall be located on façades that do not face a primary building frontage
☐
(B) Loading docks and service areas located within setback areas shall be screened by a solid fence, or wall, or dense landscaping and separated from pedestrian access to the primary building entry to avoid impeding pedestrian movement/safety.

N/A as the site is not a through lot located
more than 300 feet from an intersecting
street or pedestrian walkway
N/A as no loading docks or
service areas required or provided
N/A - see above
A.5.2
All homes are connected from a
private street or a pedestrian
walkway
A.5.1, A.5.2
A.5.1, A.5.2
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 108 Packet Pg. 550 of 1140
City of Palo Alto - Objective Design Standards Checklist

18.24.040 Building Orientation and Setbacks
Check Standard Sheet # Applicant’s Justification
(b)(1) Building Corner Elements (less than 40 feet in height) Corner buildings less than 40 feet in height and end units of townhouses or other attached housing products that face the street shall include all of the following features on their secondary building frontage: Check All ☐
(A) height and width of corner element shall have a ratio greater than 1.2:1. For townhomes, the width would be equal to the smallerside of one unit? a. Secondary building frontage height: feet
b. Secondary building frontage length: feet
c. Secondary building frontage height to width ratio:
☐
(B) minimum of 15% fenestration area.
a. Total secondary building frontage façade area: sf
b. Secondary building frontage façade fenestration area: sf c. Percent of fenestration area %
☐ (C) At least one facade modulation with a minimum depth of 18 inches and a minimum width of two feet.
(b)(2)(A) & (B) Treatment of Buildings Corners on Corner Lots (40+ feet in height) Corner Buildings 40 feet or taller in height shall include at least one of the following special features: Check One or More within A or B A. Street wall is located at the minimum front yard setback or build-to line for a minimum aggregated length of 40 feet on both facades meeting at the corner and includes one or more of the following building features:
☐ i. An entry to ground floor retail or primary building entrance located within 25 feet of the corner of the building.
☐ ii. A different material application and/or fenestration pattern from the rest of the façade.
☐ iii. A change in height of at least 4 feet greater or less than the height of the adjacent/abutting primary façade.

N/A as project heights exceed
40 feet.

A.10&A.22
N/A as project heights exceed
40 feet.

N/A as project heights exceed
40 feet.

Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 109 Packet Pg. 551 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check One or
More within A or B
B. An open space with a minimum dimension of 20 feet and minimum area of 450 sf. The open space shall be at least one of the following
☐ i. A publicly accessible open space/plaza.
☐ ii. A space used for outdoor seating for public dining. ☐
iii. A residential Common Open Space adjacent to a common interior space (i.e. lobby, retail, etc.) and less than two feet above adjacent sidewalk grade.

Fences and railing shall be a minimum 50% open/transparent. (b)(3) Primary Building Entry
The primary building entry meets at least one of the following standards: Check One or More ☐ A. Faces a public right-of-way.
☐ B. Faces a publicly accessible pedestrian walkway.
☐
C. Is visible from a public right-of-way through a forecourt or front porch that meets the following standards:
i. For residential buildings with fewer than seven units, building entry forecourts or front porch minimum dimensions of (min. 36 sf and min. dimension of 6 feet required): sf and ft. min. dimension ii. For commercial buildings or residential buildings with seven or more units, building entry forecourts or front porch minimum dimensions of (min. 100 sf and a min. width of 8 feet required): sf and ft. min. width
(b)(4) Ground Floor Residential Units
A. Finished Floor Height for Ground Floor Units
☐
The finished floor of ground floor residential units, when adjacent to a public right-ofway, must be within the minimum and maximum heights according to setback distance from back of walk identified in Figure 2a and 2b of the Zoning Ordinance. Calculate minimum ground floor finished floor height:

A.6
A.5.2
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 110 Packet Pg. 552 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check All that Apply
☐ Setback adjacent to public right of way: feet
☐
Minimum ground floor finished floor height: feet
𝟒𝟒𝟒𝟒 𝟏𝟏𝟏𝟏𝟏𝟏𝟏𝟏
𝒚𝒚𝒚𝒚 = �− �(𝒙𝒙𝒙𝒙) +
𝟏𝟏𝟏𝟏𝟏𝟏𝟏𝟏 𝟑𝟑𝟑𝟑
where 𝑥𝑥𝑥𝑥 = setback length from back of walk, in feet
and 𝑦𝑦𝑦𝑦 = ground floor finished floor height, in feet
☐ Sites with slopes greater than 2% along building façade – Average height of finished floor: feet
☐ Sites located in flood zones – the minimum ground floor finished floor height shall be defined by FEMA, less flood zone elevation: feet B. Setback Trees
☐
Ground floor units with a setback greater than 15 feet must have at minimum an average of one tree per 40 linear feet of facade length, within the setback area.

Facade length: feet
Trees required: tree(s) (i.e. façade length / 40)
Trees provided: tree(s)
C and D. Front Setback Pick One
☐ C. Ground floor residential entries are setback a minimum of 10 feet from the back of public sidewalk; OR
☐
D. Where no minimum building setback is required, all ground floor residential units must be set back a minimum 5 feet from back of public sidewalk. 20 0
A5.1 and C2.0
The site is in a flood zone and
there the finished floor height is
determined by FEMA.
the proposed finished floor height
and not by the elevation of Geng
Road ( public road) since the road
is within the floodplain.
11 Ground floor units are setback
greater than 15' only along Geng
avenue 47'8"
2 8
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 111 Packet Pg. 553 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check Standard Sheet # Applicant’s Justification
E. Unit Entry
☐
A minimum 80% of ground floor residential units that face a public right-of-way or publicly accessible path, or open space shall have a unit entry with direct access to the sidewalk, path, or open space for minimum.
a. Total number of ground floor residential units facing a public right-of-way, publicly accessible path, or open space: units
b. 80% of total units in (a): units
c. Subset of number of units in (a) that have a unit entry with direct access to the sidewalk, path, or open space: entries
(b)(5) Front Yard Setback Character
Required setbacks provide a hardscape and/or landscaped area to create a transition between public and private space. The following standards apply, based on intended use and exclusive of areas devoted to outdoor seating, front porches, door swing of building entries, and publicly accessible open space and meet the following: Check All that Apply ☐
(A). Ground-floor retail or retail like uses have a minimum of 10% of the required setback as landscape or planters.
i. Minimum setback area (setback x frontage x 10%): sf
ii. Landscape or planter area in required setback: sf
☐
(B). Ground-floor residential uses have a minimum of 60% landscaped area in the required setback area.
i. Minimum setback area (setback x frontage x 60%): sf
ii. Landscape area in required setback: sf
(b)(6) Side Yard Setback Character
☐
(A) Each detached dwelling unit shall have at least one usable side yard, at least six feet wide, between the house and fence or other structure, to provide outdoor passage between the front and rear yards.
145
116
145
3,121 SF
4,518 sf
L1
15' or greater setback
only occurs on the
front along Geng
Road.

A5.1
setbacks measured by parcel for
condos. complies
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 112 Packet Pg. 554 of 1140
City of Palo Alto - Objective Design Standards Checklist

18.24.050 Building Massing
Check Standard Sheet # Applicant’s Justification
(b)(1) Upper Floor Step Backs and Daylight Planes
☐
(A) When the height of the subject building is more than 20 feet above the average height (i.e. average of low and high roof elevations) of an adjacent building(s), an upper floor step back shall start within two vertical feet of the average height of the adjacent building. The step back shall be a minimum depth of six feet along both the façade on the primary building frontage and the façade facing the adjacent building, and the step shall occur for a minimum of 70% of each façade length.
i. Proposed building height: feet
ii. Average building height of the adjacent building(s): feet iii. Building height where upper floor step back begins: feet ☐ (B) Notwithstanding, subsection (A), when adjacent to a single-story building, the upper floor step back shall occur between 33 and 37 feet in height. ☐
(C) If a project meets the following criteria, a daylight plane with an initial height of 25 feet above grade at the property line and a 45-degree angle shall be required. This daylight plane is required if all of these criteria are met:
i. The project is not subject to a daylight plane requirement, pursuant to district regulations in Title 18; and
ii. The project proposes a building which is more than 20 feet above the average height (i.e., average of low and high roof elevations) of an adjacent building(s); and
iii. The project abuts residential units in the side or rear yard. (b)(2) Privacy and Transitions to Residential Uses
When a building abuts a residential use on an interiorside and/or rear property line, the building shall break down the abutting façade and maintain privacy by meeting all of the following:

N/A since there are no
adjacent residential units
N/A Proposed buildings
are no more than 20 feet
above the average height
of adjacent commerical
buildings
N/A Proposed buildings are not
adjacent to residential structures
N/A since there are no
adjacent residential units
42'2"
27 Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 113 Packet Pg. 555 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check All
☐
(A) Landscape Screening. A landscape screen that includes a row of trees with a minimum one tree per 25 linear feet and continuous shrubbery planting. This screening plant material shall be a minimum 72 inches (6 feet) in height when planted. Required trees shall be minimum 24” box size.
☐ (B) Façade Breaks. A minimum façade break of 4 feet in width, 2 feet in depth, and 32 sf of area (i.e. 8 ft tall minimum) for every 36 to 40 feet of façade length ☐
(C) Maximum Amount of Transparent Windows. Within 40 feet of an abutting structure, no more than 15% of the facing façade area shall be windows or other glazing. Additional windows are allowed in order to maintain light, if fixed and fully obscured
(D) Windows. Within 30 feet of facing residential windows (except garage or common space windows) or private open space on an adjacent residential building, facing windows on the subject site shall meet the following:
(i) Window sills at and above the 2nd floor shall be at least five feet above finished floor; or
(ii)Windows shall have opaque or translucent glazing at or below five feet above finished floor; or
(iii)Windows shall be angled up to 30 degrees (parallel to window) to face away from the adjacent privacy impacts; and
(iv) Landscape screening shall be 24-inch box size or larger and eight+ feet height at planting; 50% evergreens; and located to align with proposed second floor windows at maturity.
(E). Balconies: Within 30 feet of residential windows (except garage or common space windows) or private open space on an adjacent residential building, balconies and decks on the subject site shall be designed to prevent views:
(i) No sight lines to the adjacent property window or open space are permitted within five feet above the balcony or deck flooring and a 45- degree angle downward from balcony railing.
(ii) Submit section view of proposed balcony/deck and abutting residential windows and/or private open space.
(iii) Provide balcony/deck design measure which may include:
a. Minimum 85% solid railing
b. Obscure glass railing
c. Barrier with min. 18" horizontal depth from railing (e.g. planter) Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 114 Packet Pg. 556 of 1140
City of Palo Alto - Objective Design Standards Checklist

(b)(3)(A) & (B) Maximum Façade Length - facing a street or public path Pick One Category
Buildings 70 feet in length or greater and greater than 25 feet in height ☐
For building facades 70 feet in length or greater and facing a public street, rightof-way, or publicly accessible path shall not have a continuous façade plane greater than 70% of the façade length without an upper floor modulation, of at least 2 feet in depth
Largest façade length featuring continuous plane: feet
Total Façade length: feet
Percent of façade length without upper floor modulation (a/b) (maximum 70%): %
Buildings 250 feet in length or greater
☐
(A) Buildings 250 feet in length or greater, which face a public street, right-ofway, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 400 sf and a width greater than or equal to two times the depth
Total Building length: feet
Number of vertical façade breaks: area
Width: feet, Depth: feet, Area: sf
Buildings between 150 feet and 250 feet in length
☐
(B) Buildings 150 to 250 feet in length, which face a public street, right-of-way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 64 sf and a minimum width of 8 feet and minimum depth of 4 feet.

Total Building length: feet
Number of vertical façade breaks: area
Width: feet, Depth: feet, Area: sf
N/A see above
N/A see above
N/A as buildings along
Geng Road are not longer
than 70'
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 115 Packet Pg. 557 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check Standard Sheet # Applicant’s Justification
(b)(4) Special Conditions: Railroad Frontages
All parcels with lot lines abutting railroad rights-of-way shall meet the following standards on the railroad-abutting façade(s): Check All
☐ (A) A minimum facade break of at least 10 feet in width and six feet in depth for every 60 feet of façade length.
☐ (B) For portions of a building 20 feet or greater in height shall not have a continuous façade length that exceeds 60 feet.
(b)(5) Diversity of Housing Types
☐
A diversity of housing types (e.g. detached units, attached rowhouses/townhouses, condominiums or apartments, mixed use) are required for projects on large lots:
• Less than one acre lots: minimum 1 housing types
• 1 to 2-acre lots: minimum 2 housing types; or
• More than 2-acre lots: minimum 3 housing types

18.24.060 Façade Design
Check
Two or
More
Standard Sheet # Applicant’s Justification
(c)(1) Base-Middle-Top
☐
Buildings three stories or taller and on lots wider than 50 feet shall be designed to differentiate a defined base or ground floor, a middle or body, and a top, cornice, or parapet cap. Each of these elements shall be distinguished from one another for a minimum of 80% of the façade length through use of three or more of the following four techniques:
☐
i. Variation in Building Modulation: Building modulation shall extend for a minimum 80% of the façade length feet, and shall include one or more of the following building features.

A.6
3 housing types provided:- Front
Loaded Pullapart townhomes - Alley
loaded Duplex Townhomes- Alley
loaded Row Townhomes
N/A see above
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 116 Packet Pg. 558 of 1140
City of Palo Alto - Objective Design Standards Checklist

Check one or more if
selected
☐ a. Horizontal shifts. Changes in floor plates that protrude and/or recess with a minimum dimension of 2 feet from the primary facade.
☐
b. Upper floor step backs. A horizontalstep back of upper-floor façades with a minimum 5 foot stepback from the primary façade for a minimum of 80% of the length of the façade
☐
c. Ground floorstep back. A horizontalshift of the ground floor facade with a minimum depth of 2 feet for a minimum 80% of the length of the façade.

Ground floor step backs shall not exceed the maximum setback, where stated ☐ ii. Variation in Façade Articulation: Façade articulation modulation shall include one or more of the following building features.

Check one or more if
selected
☐
a. Horizontal and/or Vertical Recesses or Projections. Recesses or projections such as a pattern of recessed grouping of windows, recessed panels, bay windows or similar strategies. The recess or projection shall be a minimum 4 inches in depth.
☐
b. Horizontal and/or Vertical Projections. Projectionssuch as shading, weather protection devices, decorative architectural details, orsimilar strategies.
☐
c. Datum Lines. Datum lines that continue the length of the building, such as parapets or cornices, with a minimum 4 inches in height or a minimum 2 inches in depth and include a change in material
☐ iii. Variation in two of the following: Check two if selected ☐ a. Fenestration Size
☐ b. Fenestration Proportion
☐ c. Fenestration Pattern
☐ d. Fenestration Depth or Projection
☐ iv. Variation in two of the following: Check two if selected ☐ a. Façade Material
☐ b. Facade Material Size
☐ c. Façade Texture and Pattern
☐ d. Façade Color
A.9- A.26
A.9- A.26
A.9- A.26
A.9- A.26
A.9- A.26
A.9- A.26
A.9- A.26
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 117 Packet Pg. 559 of 1140
City of Palo Alto - Objective Design Standards Checklist

(c)(2) Façade Composition
Building facades shall use a variety of strategies including building modulation, fenestration, and façade articulation to create visual interest and express a variety of scales through a variety of strategies. All facades shall include a minimum of three of the following façade articulation strategies to create visual interest: Check Three or More ☐ A. Vertical and horizontal recesses such as a pattern of recessed grouping of windows or recessed panels. The recess shall be a minimum 4 inches in depth. ☐ B. Vertical and horizontal projections such as shading and weather protection devices or decorative architectural details. Projections shall be a minimum 4 inches in depth. ☐
C. Datum lines that continue the length of the building, such as cornices, with a minimum 4 inches in depth, or a minimum 2 inches in depth and include a change in material.
☐ D. Balconies, habitable projections, or Juliet balconies(every 20 to 40 feet) with a minimum 4 inches in depth.
☐ E. Screening devices such as lattices, louvers, shading devices, or perforated metal screens.
☐ F. Use of fine-grained building materials, such as brick or wood shingles, not to exceed 8 inches in either height or width.
☐ G. Incorporate a minimum of three colors, materials, and/or textures across the whole building.
(c)(3) Compatible Rhythm and Pattern
(A) Buildings shall express a vertical rhythm and pattern that reflects the size and scale of a housing unit and/or individual rooms and spaces.

This may be achieved with building modulation to create vertically oriented façades (height greater than the width of the façade), façade articulation and fenestration repetitive vertically oriented patterns. Depending on the length of the façade, the following standards apply:
☐
i. For continuous façades less than 100 feet in length, the façade shall have vertically oriented patterns of vertical recesses or projections, façade articulation, and/or fenestration.
ii. For continuous façades 100 feet or greater in length, the façade shall include either:

Check
One
☐
a. A vertical recess or change in façade plane with a minimum 2 feet deep vertical shift modulation for a minimum 4 feet in width to establish a vertical rhythm between 20 to 50 feet in width; OR
A.9- A.26
A.9- A.26
A.9- A.26
A.9- A.26
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 118 Packet Pg. 560 of 1140
City of Palo Alto - Objective Design Standards Checklist

☐ b. A vertical recess or projection with a minimum depth of 2 feet that establishes the vertical rhythm between 10 to 16 feet in width
(B) Residential mixed-use buildings Check One or More
☐ i. Vertical Patterns and Modulation: Façades shall use vertical patterns of building modulation, façade articulation, and fenestration.
☐
ii. Horizontal Patterns and Modulation: Façades that use horizontal articulation and fenestration patterns shall use a vertical massing strategy with a minimum 4 feet wide and 2 feet deep vertical shift in modulation at least once every 50 feet of façade length.
(C) Storefronts
☐ Storefront uses must express a vertical rhythm not to exceed 30 to 50 feet in width. (c)(4) Emphasize Building Elements & Massing
(A)(i) Building Entries within Façade Design. Primary building entries shall be scaled proportionally to the number of people served (amount of floor-area or number of units accessed). Building entries shall meet the following minimum dimensions: Check All
☐ a. Individual residential entries: 5 feet in width
☐ b. Shared residential entry,such as mixed-use buildings: 8 feet in width ☐ c. Commercial building entry: 20 feet in width
☐ d. Storefront entry: 6 feet in width
(ii) Primary building entries (not inclusive of individual residential entries) shall include a façade modulation that includes at least one of the following: Check One or More ☐ a. Recess or projection from the primary façade plane (minimum 2 feet). ☐ b. Weather protection that is a minimum 4 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods (c)(5) Storefront/Retail Ground Floors
☐
A. Ground floor height shall be a minimum 14 feet floor-to-floor OR shall maintain a 2nd floor datum line of an abutting building.
a. Ground floor height (minimum 14 feet): feet; OR
b. Height of 2nd floor datum line of abutting building: feet N/A as all entries
are private entries
N/A as the project is not a mixed use
N/A as the project is not a mixed use
A.31- A.39
N/A as the project is not a mixed use
Item 12
Attachment E - Objective Standards
Consistency Analysis
Item 12: Staff Report Pg. 119 Packet Pg. 561 of 1140
City of Palo Alto - Objective Design Standards Checklist

☐
B. Transparency shall include a minimum 60% transparent glazing between 2 and 10 feet in height from sidewalk, providing unobstructed views into the commercialspace. a. Façade area between 2 feet and 10 feet: sf
b. Transparent glazing area between 2 feet and 10 feet: sf c. Percentage of transparent glazing (minimum 60%): %
☐ C. If provided, bulkheads and solid base walls measure between 12 and 30 inches from finished grade
☐
D. Primary entries shall include weather protection by recessing the entry, providing an awning or using a combination of these methods.
a. Weather protection width (minimum 6 feet): feet
b. Weather protection depth (minimum 4 feet): feet
☐
E. Awnings, canopies and weather protection: (i) When transom windows are above display windows, awnings, canopies and similar, weather protection elements shall be installed between transom and display windows. These elements should allow for light to enter the storefront through the transom windows and allow the weather protection feature to shade the display window. (ii) Awnings may be fixed or retractable (c)(6) Other Non-Residential Ground Floors
☐ (A) Ground floor height must be a minimum 14 feet floor-to-floor OR match the 2nd floor datum line of an abutting building
Pick One
☐ Ground floor height (minimum 14 feet): feet; OR
☐ Height of 2nd floor datum line of abutting building: feet ☐
(B) Minimum of 50% transparent glazing between 4 and 10 feet in height from sidewalk or terrace grade, providing unobstructed views into the commercial space Façade area between 4 feet and 10 feet: sf
Transparent glazing area: sf
Percentage of transparent glazing (minimum 50%): %
☐
(C) Primary entries include weather protection that is a minimum 6 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods.

Weather protection width (minimum 6 feet): feet
Weather protection depth (minimum 4 feet): feet
N/A as the project is not a mixed use
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City of Palo Alto - Objective Design Standards Checklist

(c)(7) Parking/Loading/Utilities
(A) Entry Size
☐
No more than 25% of the site frontage facing a street shall be devoted to garage openings, carports, surface parking, loading entries, or utilities access. On sites with less than 100 feet of frontage, no more than 25 feet.

Site frontage: feet
Frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access: feet
Percent of frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access %
(B) Above Ground Structured Parking
☐
Above grade structured parking levels facing a public right-of-way or publicly accessible open space/path, with the exception of vehicular alleys, must be lined with commercial or habitable uses with a minimum depth of 20 feet
(C)&(D) Partially Sub-Grade Structured Parking
☐ Partially sub-grade parking must not have an exposed façade that exceeds 5 feet in height above abutting grade at back of sidewalk.
☐ Partially sub-grade parking must be screened with continuous landscaping and shrubbery with minimum height of 3 feet and be located within 10 feet of the sub-grade parking.

18.24.070 Residential Entries
Pick One
or More
(A – E)
Standard Sheet # Applicant’s Justification
(b)(1) Ground Floor Unit Entries
Where ground floor residential unit entries are required, one or more of the following entry types shall be provided:
☐ (A) Stoop
N/A as no structured parking provided
A.5.1, C2
204

12.3 N/A as no structured parking provided
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City of Palo Alto - Objective Design Standards Checklist

Check All if
Selected
☐ (i) Stoops provide entry access for a maximum of two ground floor units. ☐ (ii) Stoop heights are within one step of finished floor height of adjacent unit. ☐ (iii) Stoop entry landings are a minimum 5 feet in depth ☐ (iv) The maximum stoop height from the back of sidewalk grade is 5 feet. ☐ (B) Porch Check All if Selected
☐ (i) Porches provide entry access for a maximum of one ground floor unit. ☐ (ii) Porch heights are within one step of finished floor height of adjacent unit. ☐ (iii) Porches are large enough so a 6-foot by 6-foot square can fit inside ☐ (iv) The maximum porch height from the back of sidewalk grade is 5 feet. ☐ (C) Patio Entry Check All if Selected
☐ (i) Patio entries provide access for a maximum of two ground floor units. ☐ (ii) Patio entries are large enough so a 5-foot by 5-foot square can fit inside of the patio for each unit
☐ (iii) The patio shall include at least one of the following features to define the transition between public and private space:

Pick One or More
☐ a. Row of shrubs: not exceeding 42 inches in height located between the sidewalk and the patio. One gallon size and max 3 feet on center ☐ b. Fence: not to exceed 36 inches in height located between the sidewalk and the patio with a gate or fence opening to provide access ☐
c. Metal, Wood, or Stone Wall: not to exceed 36 inches in height located between the sidewalk and the patio with gate or opening, AND a minimum 18-inch landscape strip is located between the wall and the abutting pedestrian way and entirely landscaped
☐ (D) Terrace Check All if Selected
☐ (i) Terraces provide entry access for multiple ground floor units. ☐ (ii) Terraces are a maximum height of 30 inches above the grade of the back of the adjacent sidewalk or accessway.
☐ (iii) Walls, fences and hedges on Terraces are a maximum of 42 inches tall and have a minimum transparency of 40%.

A.31- A.39
A.31- A.39
A.31- A.39
A.31- A.39
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Consistency Analysis
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City of Palo Alto - Objective Design Standards Checklist

☐ (E) Frontage Court Check All if Selected
☐ (i) Frontage courts provide entry access for multiple ground floor units. ☐ (ii) The minimum frontage court width along a primary frontage is 25 feet. ☐ (iii) The maximum frontage court width along a primary frontage is 50% of the facade length or 80 feet, whichever is less.
☐ (iv) The minimum Frontage Court depth is 25 feet.
☐ (v) The maximum Frontage Court depth is 50 feet or a ratio not to exceed 2:1 depth to width.

18.24.080 Open Space
Check Standard Sheet # Applicant’s Justification
(b)(1) Private Open Space
☐ (A) Floor area includes clear space with a minimum dimension of a circle with a sixfoot diameter. ☐ (B) Minimum clear height dimension of 8’-6” feet.
☐ (C) Directly accessible from a residential unit.
☐ (C) Balconies are not located within the daylight plane. (b)(1)(E) Private Open Space - Ground Floor Patios
☐
(i) RM-20 and RM-30 districts: Minimum 100 sf of area, the least dimension of which is 8 feet for at least 75% of the area.
☐
(ii) RM-40 districts: Minimum 80 sf of area, the least dimension of which is 6 feet for at least 75% of the area
☐
(iii) Street facing private open space on the ground floor shall meet the finished floor height for ground floor residential standards in section 18.24.040(b)(4) N/A as property is not within the
RM-40 district
N/A as project doesn't provide
ground floor private open space
N/A as project doesn't provide ground
floor private open space. Private open
space provided on roofs. A.35-A.43
A.31- A.39
A.31- A.39
A.31- A.39
A.31- A.39
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Consistency Analysis
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City of Palo Alto - Objective Design Standards Checklist

(b)(2) Common Open Space
☐ (A)&(B) Minimum 200 sf of area. Area shall include a space with a minimum dimension of a circle with a 10-foot diameter.
☐ (C) A minimum of 60% of the area shall be open to the sky and free of permanent weather protection or encroachments. Trellises and similar open-air features allowed ☐
(D) Notwithstanding subsection (1), courtyards enclosed on four sides shall have a minimum dimension of 40 feet and have a minimum courtyard width to building height ratio of 1:1.25
☐ (E) Common open space provides seating.
☐ (F) Common open space has a minimum 20% of landscaping. ☐ (G) Planting in above grade courtyards has minimum soil depth of 12 inches for ground cover, 20 inches forshrubs, and 36 inches for trees.

18.24.090 Materials
Check Standard Sheet # Applicant’s Justification
☐
(b)(1) Primary, secondary, and accent materials are allowed or prohibited as in the Residential and Residential Mixed-use Material List, which may be updated from time to time by the Director of Planning with a recommendation by the ARB. See webpage for list - https://www.cityofpaloalto.org/News-Articles/Planning-and-DevelopmentServices/Multifamily-Mixed-Use-Objective-Standards

18.24.100 Sustainability and Green Building Code
Check Standard Sheet # Applicant’s Justification
☐
(b) See Chapter 16.14: California Green Building Standards additional requirements for green building and sustainable design. Notwithstanding Section 18.24.010(c), these regulations may not be modified through alternative compliance.

N/A as courtyard is not above grade
N/A as courtyard not enclosed
A.6
A.6
A.26 -A.30
A.57
L1
L1
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Consistency Analysis
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Dec 10, 2025
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Proposed Housing Development Project at 2100-2400 Geng Road By email: [email protected]
Cc: [email protected]; [email protected]; [email protected]; [email protected]; Dear Palo Alto Planning Commission,
The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation to abide by the Housing Accountability Act (“HAA”), the Density Bonus Law (“DBL”), AB 130, California Environmental Quality Act (“CEQA”) Guidelines when evaluating the proposed 145-unit housing development project at 2100-2400 Geng Road, which includes 19 units affordable to low-income households.

Under the HAA,
1 a city may not disapprove a qualifying affordable housing project (i.e., a housing development project that provides a certain percent of the total units to lower-income households, as defined by Health and Safety Code Section 50079.5) on the grounds it does not comply with the city’s zoning and general plan if the developer submitted either a statutorily defined "preliminary application" or a "complete development application" while the city's housing element was not in substantial compliance with state law. (See Gov. Code, § 65589.5, subds. (d)(5), (h)(5), (o)(1). 2 ) This statutory provision temporarily
suspends the power of non-compliant municipalities to enforce their zoning rules against qualifying affordable housing projects. (See, e.g., California Housing Defense Fund v. City of La Cañada Flintridge, Case Number: 23STCP02614 (attached), for a recent court decision affirming the plain language of the statute in this regard.) The City’s Housing Element was 2 These code section numbers correspond to the HAA as it existed when the preliminary application for the project at issue was submitted (i.e. before AB 1893 went into effect). 1 AB 1893, effective January 1, 2025, has amended the “Builder’s Remedy” provisions of the HAA.

However, the AB 1893 allows for vested Builder’s Remedy applications to proceed under the previous version of the law.
2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
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not in substantial compliance with state law when the preliminary application under SB 330 was submitted. The City must therefore allow the project to be developed as proposed.

CalHDF also writes to emphasize that the DBL offers the proposed development certain protections. The City must respect these protections. In addition to granting the increase in residential units allowed by the DBL, the City must not deny the project the proposed waivers and concessions with respect to floor area ratio; height; front setback; rooftop garden width; private street width; and distribution of below market rate units. If the City wishes to deny requested waivers, Government Code section 65915, subdivision (e)(1) requires findings that the waivers would have a specific, adverse impact upon health or safety, and for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact. If the City wishes to deny requested concessions, Government Code section 65915, subdivision (d)(1) requires findings that the concessions would not result in identifiable and actual cost reductions, that the concessions would have a specific, adverse impact on public health or safety, or that the concessions are contrary to state or federal law. The City, if it makes any such findings, bears the burden of proof. (Gov. Code, § 65915, subd. (d)(4).) Of note, the DBL specifically allows for a reduction in required accessory parking in addition to the allowable waivers and concessions. (Id. at subd. (p).) Additionally, the California Court of Appeal has ruled that when an applicant has requested one or more waivers and/or concessions pursuant to the DBL, the City “may not apply any development standard that would physically preclude construction of that project as designed, even if the building includes ‘amenities’ beyond the bare minimum of building components.” (Bankers Hill150 v. City of San Diego (2022) 74 Cal.App.5th 755, 775.)
Furthermore, the project is eligible for a statutory exemption from CEQA review pursuant to section 15183 of the CEQA guidelines and it may also be eligible for the newly enacted CEQA exemption under AB 130 (Pub. Res. Code, § 21080.66), which was signed into law on June 30, 2025 and was effective immediately (Assembly Bill No. 130, 2025-2026 Regular Session, Sec. 74, available here). Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 911.)
As you are well aware, California remains in the throes of a statewide crisis-level housing shortage. New housing such as this is a public benefit: it will provide badly-needed affordable housing; it will bring new customers to local businesses; it will increase the city’s tax revenue; and it will reduce displacement of existing residents by reducing competition for existing housing. It will also help cut down on transportation-related greenhouse gas emissions by providing housing in denser, more urban areas, as opposed to farther-flung regions in the state (and out of state). While no one project will solve the statewide housing crisis, the proposed development is a step in the right direction. CalHDF urges the City to approve it, consistent with its obligations under state law. 2 of 3
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CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org.

Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
3 of 3
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-----Original Message-----
From: ann rothblatt <[email protected]>
Sent: Tuesday, November 25, 2025 12:14 PM
To: Planning Commission <[email protected]> Cc: Council, City <[email protected]>; Architectural Review Board <[email protected]>; ParkRec Commission <[email protected]>
Subject: [INSERT SUBJECT HERE]
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hello Palo Alto PTC, my name is Ann Rothblatt and I live in south Palo Alto.

Please support the homes proposed for 2100 Geng Road. I want to create more ownership options in our community, including affordable homeownership. We are still enjoying the home we purchased in 1977 for $103,000,
and wish other deserving people could have the same opportunity. I hope the PTC will vote to move this project forward as quickly as possible.

Thank you for supporting more homes in our community,
Ann and Don Rothblatt
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From: Adam Schwartz
To: Planning Commission
Cc: Council, City; Architectural Review Board; ParkRec Commission; Planning Commission Subject: Please support new homes at 2100 Geng Road
Date: Sunday, November 30, 2025 1:35:26 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Greetings to the Palo Alto Planning and Transportation Committee:

I'm Adam Schwartz and I live in Palo Alto in University South. I write to urge you to please support the new homes proposed for 2100 Geng Road.

Our wonderful community's biggest problem is the shortage of new homes for all kinds of people at all price points. The solution must include building new homes. I'd like to see 145 new townhomes (including 19 affordable) at 2100 Geng Road.

I hope the PTC will vote to move this project forward as quickly as possible. Thank you for supporting more homes in our community.

Sincerely,
Adam Schwartz
523 Channing Ave.

This message needs your attention
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&nbsp;
From: Switzer, Steven
To: "Steve Saffold"
Subject: RE: 2100 Geng Road
Date: Thursday, November 13, 2025 3:13:00 PM
Attachments: image001.png
image002.png
Hi Steve,
You are correct. We are still evaluating the project. The webpage will be updated once we have some further movement on that environmental analysis.

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]
www.PaloAlto.gov
From: Steve Saffold <[email protected]>
Sent: Wednesday, November 12, 2025 1:02 PM
To: Switzer, Steven <[email protected]>
Subject: 2100 Geng Road
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi Steven, I'm just reaching out to inquire about this project. The planning website says the city is preparing an initialCEQA checklist, just wanted to see if that is current, or what the status is. Thank you in advance for any help you can offer. Steve THEAGENCYRedefining r ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ i
This message needs your attention
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CGBANNERINDICATOR
Hi Steven,
I'm just reaching out to inquire about this project. The planning website says the city is preparing an initial CEQA checklist, just wanted to see if that is current, or what the status is.

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Item 12: Staff Report Pg. 130 Packet Pg. 572 of 1140
Thank you in advance for any help you can offer.

Steve

THEAGENCY
Redefining real estate

STEVE SAFFOLD
Managing Director New Development - Bay Area
510-282-9169
TheAgencyRE.com
Steve Saffold
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From: Chris Douvos
To: Switzer, Steven
Subject: Re: 2100 Geng
Date: Monday, October 27, 2025 10:24:41 AM
Attachments: image001.png
image002.png
image003.png
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Thanks!
CD
From: Switzer, Steven <[email protected]>
Sent: Monday, October 27, 2025 9:54 AM
To: Chris Douvos <[email protected]>
Subject: RE: 2100 Geng
Hi Chris,
The project located at 2100-2400 Geng Rd is still under review.

We are anticipating taking the project to the Planning Commission in December 2025 and then on to the Architectural Review Board and City Council in early/spring 2026.

Hopefully that helps.

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]
www.PaloAlto.gov
From: Chris Douvos <[email protected]>
Sent: Thursday, October 23, 2025 3:27 PM
To: Switzer, Steven <[email protected]>
Subject: 2100 Geng
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

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Hi!
I apologize for bothering you, but I'm a PA resident who has an office at 2100 Geng Road and I was looking up the status of the project planned for this location and your name was listed as the city contact. I was wondering if you might be able to share the status of the project? My office lease expires at some point soon and I'm wondering if I should start looking for new space (the Regus from whom we sublease is pretty tight lipped on the topic, although one of their people told me a year ago that they expected us to get kicked out sometime in 2026.) Thanks for any insight you can share,
Chris
___________
Chris Douvos
Founder
2100 Geng Road, Suite 210
Palo Alto, CA 94301
[email protected]
(650) 384 9434
www.ahoycap.com
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From: Janet L. Billups
To: Switzer, Steven
Cc: Barbara Greiner; Mathieu Farrugia; Mindie S. Romanowsky Subject: 2100 Geng Road. 24PLN-00356 project
Date: Monday, September 22, 2025 4:16:38 PM
Attachments: image001.png
Importance: High
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Hi Steven,
I hope this email finds you well. I’m writing to request that the persons named below be added to the mailing list and/or notification system related to the project at 2100 Geng Road, 24PLN00356. We would appreciate receiving meeting notices, updates, or any relevant documentation as it becomes available.

Please let me know if there is a form or procedure to complete to be included.

Thank you in advance for your time and consideration.

Notices to:

Barbara Greiner, Head of School
Silicon Valley International School
151 Laura Ln, Palo Alto, CA 94303
[email protected]
Mathieu Farrugia
[email protected]
Mindie Romanowsky, Esq.
[email protected]
Kind regards,
Janet Billups
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Item 12: Staff Report Pg. 134 Packet Pg. 576 of 1140
Janet L. Billups, Legal Assistant to Mindie S. Romanowsky, Esq.

Jorgenson, Siegel, McClure & Flegel, LLP
1100 Alma Street, Suite 210 | Menlo Park, CA 94025
Office: (650) 324-9300 x1230
Email: [email protected] | Website: www.jsmf.com
CONFIDENTIALITY NOTICE: This e-mail and any attachments are for the sole use of the intended recipients and contain information that may be confidential or legally privileged. If you have received this e-mail in error, please notify the sender by reply e-mail and delete the message. Any disclosure, copying, distribution, or use of this communication by someone other than the intended recipient is prohibited.

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From: Mark Millet
To: Switzer, Steven
Subject: Re: questions about conditional use permit for 2100 Geng Road project Date: Monday, March 31, 2025 5:49:21 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Confirmed 10 am, please call my cell
Mark Millet
(650) 303 2394
> On Mar 31, 2025, at 5:40 PM, Switzer, Steven <[email protected]> wrote:
>
> Hi Mark-
>
> Would 10:00 AM work?
>
>
> Steven Switzer
> Historic Preservation Planner
> Planning and Development Services Department
> 650-329-2321 | [email protected]
> www.cityofpaloalto.org
>
>
>
>
> -----Original Message-----
> From: Mark Millet <[email protected]>
> Sent: Monday, March 31, 2025 5:39 PM
> To: Switzer, Steven <[email protected]> > Subject: Re: questions about conditional use permit for 2100 Geng Road project >
> CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
>
> I am available before noon Tuesday, when is good for you? >
> Thank you for the quick response,
>
> Mark
>
> Mark Millet
> (650) 303 2394
>
>> On Mar 31, 2025, at 5:33 PM, Switzer, Steven <[email protected]> wrote:
>>
>> Hi Mark-
>>
>> Feel free to give me a call or send your questions to me via email for a written response. >>
>> For the time being, follow the link to view more about the Conditional >> Use Permit Process:

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>> https://www.cityofpaloalto.org/files/assets/public/v/2/planning-amp-de >> velopment-services/file-migration/current-planning/forms-and-guideline >> s/cup-process-09-26-24.pdf
>>
>> I should have some availability tomorrow morning and later this week. >>
>> Looking forward to connecting with you on this.
>>
>>
>> Steven Switzer
>> Historic Preservation Planner
>> Planning and Development Services Department
>> 650-329-2321 | [email protected]
>> www.cityofpaloalto.org
>>
>>
>>
>>
>> -----Original Message-----
>> From: Mark Millet <[email protected]>
>> Sent: Monday, March 31, 2025 4:34 PM
>> To: Switzer, Steven <[email protected]> >> Subject: questions about conditional use permit for 2100 Geng Road >> project
>>
>> CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
>>
>> Steven,
>>
>> I had a couple of questions about the process for conditional use permit and residential conversion. >>
>> Thank you,
>>
>> Mark.
>>
>> Mark Millet
>> 650 303 2394 (c)
>> [email protected]
>
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1 2100-2400 Geng Road
Project Description
Updated: 11/24/2025
The proposed project would transform an existing underutilized business park located at 2100- 2400 Geng Road into a new residential neighborhood with 145 multifamily townhome units and community open spaces. All units will be offered for-sale with either three-bedroom or fourbedroom configurations, providing both much-needed housing and new homeownership opportunities in the city and region. Section I of this project description provides an overview of the project site and existing conditions; Section II describes the project land use program and site plan features; Section III describes the project’s affordability and State Density Bonus Law strategy, including information regarding the project site’s Housing Element site inventory status.

I. Project Site Overview
The project site totals approximately 11-acres and is comprised of two parcels: APN 008-02-035 (addressed as 2100-2200 Geng Road, totaling approximately 5 acres) and APN 008-02-036 (addressed as 2300-2400 Geng Road, totaling approximately 6 acres).

The property is zoned ROLM (E)(D)(AD), in which multifamily development is permitted subject to the RM-20 district development standards. A portion of the project site is also identified in the City’s 6th Cycle Housing Element as a housing opportunity site, as further described in Section III below.

The project site is currently improved with four, two-story office buildings and surface parking. In connection with development of the proposed project, the existing buildings will be demolished, and necessary site improvements will be undertaken to redevelop the property. The project site is bounded by Geng Road to the east, the Baylands Athletic Center to the north, and office buildings to the west and south. Primary access to the property is from Geng Road, with secondary access (via an adjacent property) from East Bayshore Road.

II. Proposed Project & Land Use Program Overview
The proposed project includes 145 multifamily residential units comprised of seven different townhome unit types. Along the northern boundary, adjacent to the Baylands Athletic Center, are 22 front-loaded pull-apart (detached) townhomes, in two different unit plans. These homes feature backyards that transition to the parkland, creating a buffer between the development and the park.

Across the street from these units are 14 alley-loaded pull-apart (detached) townhomes, in two different unit plans and across Alley C from these units are 6 duplex buildings with a total of 12 units. The remaining units consist of traditional attached townhomes arranged in clustered buildings of five, six, and eight units, comprised of three different unit plans. The site plan layout is designed to minimize visibility of alleys from public viewpoints. The variety of housing types is cohesively arranged around shared green spaces and connected by pedestrian paseos. The project design features contemporary architectural design that blends well with the surrounding context while setting a precedent for the transformation of predominantly office-oriented uses in the East of 101 area into residential neighborhoods.

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2 Site Circulation
Primary access to the project will be from Geng Road, with a clearly defined major circulation loop providing access to all areas of the site. Secondary access (via an adjacent property) is provided from East Bayshore Road. Offsite parking is provided within each unit. On-street parking is strategically placed along this loop to provide convenient access for visitors. Building entries and porches are oriented towards this loop road to create a pedestrian-friendly streetscape.

Project Open Space & Pedestrian Circulation
At the center of the site is a large communal central open space surrounded by residential units.

This central open space will serve as the community's focal point and is within easy walking distance for all residents. Guest parking is located along the edges of the green space to provide convenient access for visitors. A fully landscaped pedestrian network will connect the housing to the central open space and provide a natural and green environment throughout the project site.

The central open space will provide passive and programmed uses for the residents including quiet seating areas and outdoor cooking and dining areas. The programmed areas will be distributed around a large central lawn area that can be used by residents for a variety of purposes, including outdoor games and picnics. The planting character throughout the site will consist of drought tolerant, native, and adapted species of a variety of shape, sizes, and colors.

All buildings are three stories tall (approximately +/- 42’-2” in height), with living areas complemented by balconies and roof decks. The combination of individual balconies, roof decks and backyards ensure ample private outdoor space, while the central green space offers a communal gathering area for all residents.

Utilities & Services
The project will have electricity service from City of Palo Alto, and the proposed project site plan allows ample space for meter and utility connections. The project will be “electric only,” and will not have gas service. The project will have water, wastewater, and sanitary sewer service from the City of Palo Alto. The project will utilize solid waste service from GreenWaste of Palo Alto.

The HOA will contract with a service to collect trash, recycling and compost from each unit and bring it to a central enclosure where it will be stored until picked up by GreenWaste.

Sustainability
A key project objective is to provide modern, energy-efficient and sustainable housing units that limit new emissions and natural resource usage. To that end, the project incorporates a range of sustainability features, including solar photovoltaic panels on building roofs, cool roofs, electric vehicle charger ready garages, energy efficient fixtures and appliances, low-water use fixtures, construction waste reduction, low VOC materials, and both private and shared bicycle parking on site.

The project landscaping and tree placement planting plan focuses on incorporation of native and drought tolerant species, with an anticipated tree planting plan that yields over 50% California native species. The project would result in a net increase in landscaped areas and pervious surface at buildout, reducing the heat island effect of the site which is currently improved with significant surface parking. Tree and plant species have additionally been selected to help create a high-quality habitat that will support biodiversity and bird populations.

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3 In recognition of the project site’s proximity to the San Francisquito Creek and Baylands Nature Preserve and Shoreline Park, the project design also incorporates lighting reduction design features to reduce the spillover of lighting or glare/increased luminance perceived by birds and other wildlife, all of which follow recommendations by the International Dark-Sky Association.

Project Affordability & Density Bonus Law Relief
The project includes 19 affordable for-sale units on-site (13% of the total units) that will be restricted to low-income households. This onsite affordability percentage meets the requirements of the Housing Accountability Act as amended by AB 1893 that went into effect as of January 1, 2025 (see Gov. Code Section 65589.5(h)(3)(C)(i)(II)). Under the Housing Accountability Act, as amended, the project is entitled to utilize this reduced affordability percentage, along with the other associated amendments to the Housing Accountability Act, because it meets the definition of a builder’s remedy project (see Gov. Code Section 65589.5(f)(7)(A)).

The State Density Bonus Law applies to the Project because it is a housing development project that proposes to include a qualifying percentage of units onsite as affordable to low-income households. The project’s density of 145 units (approximately 13 dwelling units per acre) is within the 11 du/a minimum density and 20 du/a maximum density allowed under the applicable RM-20 zoning requirements, no bonus residential density is required. However, the project will utilize waivers or reductions of development standards and is also entitled to three incentives/concessions. One incentive/concession is provided under the State Density Bonus Law for projects proposing at least ten percent of total units for low-income households (see Gov.

Code Section 65915(d)(2)), and two additional incentives/concessions are provided pursuant to the Housing Accountability Act as amended by AB 1893 (see Gov. Code Section 65589.5(f)(6)(C)).

Density Bonus Waivers/Reductions
Under the State Density Bonus law, the project is entitled to a waiver of all development standards that would physically preclude the development at the density permitted and with the concession(s) granted. The project is requesting the following waivers/reductions of development standards. The project reserves the right to identify additional waivers as the project advances through the entitlement process.

Chapter 18.13 – RM-20 Development Standards

1. Maximum FAR (0.5:1)
Waiver requested to exceed the maximum FAR allowance to achieve the proposed residential density, which is consistent with the applicable residential zoning density controls. Maintaining a 0.5 FAR would physically preclude the density of the project as proposed. Proposed project FAR is 1.0:1.

2. Height (30’ max.)
Waiver requested to exceed the height allowance. The proposed height of each residential building is approximately +/- 42’ -2”. The proposed project uses compact footprints to achieve the proposed density, which requires additional height to accommodate the proposed project unit types and bedroom counts. Maintaining the 30’ height limit would physically preclude the density of the project as proposed.

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4 Chapter 18.24 – Contextual Design Criteria and Objective Design Standards

3. Mobility Infrastructure – Proximity to Primary Building Entry Under PAMC 18.24.020(b)(4)(A), micromobility infrastructure, such as locations to lock bicycles and scooters, shall be located within 30 feet of the primary building entry and/or a path leading to the primary building entry. This standard may be satisfied by existing infrastructure already located within 50 feet of the project site and located in the public right-of-way.

Based on the project’s townhome unit type configurations, the project has one primary entry per unit, and providing bike racks within 30 feet of all entries would physically preclude the project as proposed.

However, the project would provide bike racks in the community open space area, which is centrally located and accessible from all units. By providing the bike racks in a central location, the project meets the intent of the standard to provide bike racks in a convenient location that is easily accessible by all users and visitors.

4. Detached Unit Side Yards
Under PAMC 18.24.040(b)(6)(A), each detached dwelling unit shall have at least one usable side yard, at least six feet wide, between the house and fence or other structure, to provide outdoor passage between the front and rear yards. Some of the project’s pullapart townhomes have side yards of four feet. The project is requesting a waiver from this development regulation as increasing the side yard to six feet would physically preclude the project as proposed.

Chapter 18.40 – General Standards and Exceptions

5. Height Limits on Rooftop Garden Fixtures
Under PAMC 18.40.230, certain permanent fixtures on the rooftop may exceed applicable height limits, however, the Code provides that such fixtures “shall not intersect a plane measured at a forty-five-degree angle from the edge of the building starting at the rooftop garden surface sloping upward and inward toward the center of the property.” The project is requesting a waiver from the requirement as this would require the units to be much wider than currently planned and therefore would physically preclude the project as proposed.

Chapter 21.20 – Subdivision Design

6. Private Street Width Requirement
Under PAMC 21.20.240, private streets serving five or more lots are required to maintain a street width of thirty-two feet, whereas private streets serving four or less lots are required to maintain a street width of twenty-two feet. The project proposes a private street loop that will range in width from 26’ wide in certain areas to 35’ wide in other areas. The project is requesting a waiver from this PAMC 21.20.240 development regulation as increasing the streets and alleys to 32’ would reduce the allowable buildable area and thus Item 12
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5 physically preclude the project as proposed. The proposed onsite private street allows day to day traffic, service, and emergency vehicles.

Incentives/Concessions
The project is entitled to three concessions pursuant to State Density Bonus Law and AB 1893.

Under the State Density Bonus law, the City can only deny a concession if it finds that it would not result in identifiable and actual cost reductions; would have an unmitigable/unavoidable specific, adverse impact on public health and safety or any real property listed on the California Register of Historical Resources; or would violate state or federal law. With respect to identifiable and actual cost reductions, applicants do not bear the burden to prove that incentives would result in actual cost reductions; rather, requested incentives are presumed to result in cost reductions, and local governments must either accept this presumption or make written findings based on substantial evidence to the contrary. At this time the project is requesting the following concession:

Chapter 16.65.075 – Distribution of Affordable Units
Under PAMC 16.65.075(a)(2), affordable units “shall be reasonably dispersed” within the residential project, with unit locations “comparable” to those of the market-rate units. Further, affordable units must have a comparable number of bedrooms to the market rate units. PAMC

16.65.075(a)(2) also allows for the Planning Director to approve clustering of BMR units within the residential project “when this furthers affordable housing opportunities.” The proposed site plan proposes larger, four-bedroom pull-apart townhouse and duplex units in the northern section of the site and smaller, three- and four-bedroom attached townhouse units in the balance of the site. The project’s 19 BMR units have been well distributed throughout the attached townhouse buildings and the BMR units have the same proportion of three and four bedroom units as the project as a whole. The project’s proposed BMR distribution plan is provided on Sheet A.7 of the plan sets and is intended to meet the City’s distribution standard.

However, we understand that Planning staff have indicated that the BMR distribution as proposed may not meet its PAMC 16.65.075(a)(2) requirement. As a result, if staff ultimately determines that the proposed BMR distribution plan does not meet its PAMC 16.65.075(a)(2) standard, the project seeks a concession for this requirement. This request meets the State Density Bonus Law requirements for issuance of a concession, as further detailed below.

The project development costs are significantly reduced by providing the required BMR units in the attached townhouse units, as opposed to the detached, pull-apart townhouse units. While the proposed BMR units in attached townhouses will have a proportional number of bedrooms as the market rate units, it would cost considerably more to build these BMR units as pull-apart, detached townhouses. Construction costs for the larger detached units are higher than for the attached units because the detached units require construction of more square feet of floor area and significantly more building envelope because they are fully detached.

Additionally, the project relies on reasonable market returns in order to be financially feasible to construct. Because the pull-apart units will sell at a premium to the attached townhouse units, selling pull-apart units at BMR prices would significantly reduce the sales revenue relative to the proposed plan of selling attached townhouse units at BMR prices. This reduced sales revenue will directly reduce the financial viability of the project, resulting in a delayed financing process, Item 12
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6 additional construction cost escalation, and increased costs to deliver the on-site affordable housing.

The project reserves the right to identify and utilize the available two additional incentives/concessions as the project advances through the entitlement process.

Housing Inventory Site Status
As described above, the project is comprised of two parcels. One of the parcels, APN 008-02-035 (~5 acres) is listed in the City’s 6th Cycle Housing Element as a Housing Inventory Site with a target yield of 175 units. The other parcel, APN 008-02-036 (~6 acres), is not listed as a Housing Inventory Site.

The project is proposing to provide 145 units, which is below the target yield of 175 units for APN 008-02-035. Based on the information provided in the Housing Element, it is not clear how a determination of 175-unit yield for APN 008-02-035 was made; however, there are several reasons why the project is unable to meet the target unit yield and why the proposed 145 units is the appropriate density for the project site:
• The project seeks to be consistent with the existing zoning density of 11 du/a – 20 du.

Height, setback, lot coverage, and FAR maximums in the ROLM(E) district, pursuant to the RM-20 district standards that apply to residential development in the ROLM(E) district, limit density and development potential and thus limit the feasibility of achieving the target unit yield. While the project utilizes Density Bonus Law waivers to achieve relief from some of these standards, the project seeks to minimize deviations from these standards wherever possible.
• An important design consideration for the project is to be sensitive to the context of the site and surrounding uses. The project is adjacent to low office buildings, the Baylands Athletic Center, and more generally is in the vicinity of San Francisquito Creek and the Baylands. Keeping the buildings to three stories in height ensures that the project maintains a context-sensitive design and minimizes visual impacts of the project. • A key goal of the project is to provide family sized units, including on-site BMR family sized units, to help meet the needs of the residents of Palo Alto. One consequence of providing larger units is that the project ends up providing fewer units in the same amount of development area.
• Achieving a unit yield of 175 units on just a five-acre portion of the site would require utilization of a construction typology that is far more expensive to build on a per square foot basis as compared to townhome construction costs. Because of this, a denser project that meets the Housing Element target unit yield would reduce the project’s financially feasibility, and thus be less likely to be financed and built than the proposed, lower density townhome project.

By including on-site affordable units and offering a range of housing types, the project’s mixedincome units provide the "missing middle" housing needed by the Palo Alto community, offering new opportunities for home ownership, which will be a valuable addition to the housing fabric of Palo Alto.

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If you need assistance reviewing the above documents, please contact the Project Planner or call the Planner-on-Duty at 650-617-3117 or email [email protected]
Project Plans
In order to reduce paper consumption, a limited number of hard copy project plans are provided to Council members for their review. The same plans are available to the public, at all hours of the day, via the following online resources.

Environmental Document
An Initial Study (IS) Checklist (CEQA Guidelines Section 15183 Exemption) 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. The environmental document is available at: https://www.paloalto.gov/Departments/PlanningDevelopment-Services/Current-Planning/Projects/2100-Geng-Road Directions to review project plans and environmental documents online:

1. Go to: bit.ly/PApendingprojects

2. Scroll down to find “2100 Geng Rd” and click the address link

3. On this project-specific webpage you will find a link to the project plans and other important information
Direct Link to Project Webpage:
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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 #:2510-5277
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 4075 El Camino Way [23PLN-00202]: Adoption of an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities).

RECOMMENDATION
Staff recommend the City Council take the following actions:

1. Find the project exempt from CEQA in accordance with CEQA Guidelines Section 15301;

2. Adopt the ordinance in Attachment B, amending Planned Community Ordinance 5116; and

3. Approve the Record of Land Use Action in Attachment C based on findings and subject to conditions of approval.

EXECUTIVE SUMMARY
The applicant requests approval of an amendment to Planned Community Ordinance 5116 to allow for the addition of 11 assisted living units at the existing Palo Alto Commons Assisted Living Facility located at 4075 El Camino Way.

Council previously reviewed a 16-unit proposal on May 5, 2025, and remanded the project to the Planning and Transportation Commission (PTC) for further consideration, recommending specific changes including a reduction in the number of units to between 11 and 13 units. The PTC reviewed a revised project that included 13 units, and recommended approval, with the recommendation that the project be reduced to add only seven units to the existing facility.

In response to the PTC review, the applicant has revised the project to propose an 11-unit addition. Additional items requested by Council and the PTC have also been addressed or otherwise included in the conditions of approval, as appropriate. These modifications help to Item 13
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address some of the adjacent neighborhood residents’ expressed concerns related to privacy and operations. Therefore, staff recommend approval of the revised project, as currently proposed, and consistent with Council’s motion to explore an 11- to 13-unit project.

Adjacent residents have commented extensively on the proposed project throughout the process, as summarized below.

BACKGROUND
Palo Alto Commons, a 121-unit Assisted Living facility, was originally approved in 1987 as a Planned Community (PC) project under Ordinance 3775. In 2011, the Avant Independent Senior Living building was added through Ordinance 5116, which incorporated Ordinance 3775 by reference.1
Previous Council Review
On May 5, 2025,2 Council considered a proposed PC Amendment for a 16-unit addition with 172 square feet of additional support space. At the public hearing, 35 members of the public provided comments. Council continued the hearing for further deliberation to May 27, 2025. At this meeting, Council discussed prioritizing enforcement of the TDM plan (Attachment G), repairing the relationship between Palo Alto Commons and the neighborhood, and considering the PTC recommendation. Council made the following motion:

Refer this project back to the Planning and Transportation Commission for a review of a project between 11 to 13 units that would eliminate the 3rd floor units adjacent to Wilkie Way backyards.

The motion passed 4-3 (Councilmembers Reckdahl, Lauing, and Stone dissenting).

Councilmembers Reckdahl and Lauing spoke to their dissent, indicating that they believe even the motion’s proposed reduction would not sufficiently address neighbor concerns. Mayor Stone spoke to his dissent, indicating that he did not want to lengthen the review process and supported a previous motion that did not pass, which would have approved a project consistent with the PTC’s initial recommendation of seven additional units.

PTC Review
Following the Council hearing, the applicant revised the project to include the addition of 13 units instead of the previously proposed 16 units. PTC held a public hearing to consider the 1 Ordinance 3775: https://portal.laserfiche.com/Portal/DocView.aspx?id=104198&repo=r-704298fc; Ordinance 5116: https://portal.laserfiche.com/Portal/DocView.aspx?id=2179&repo=r-704298fc 2 May 5, 2025 Council report:
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revised design on September 24, 2025.5
At the hearing, several commissioners continued to
express concerns, consistent with their prior motion, that the revised design did not sufficiently address impacts to neighboring residents. The PTC recommended approval of the project, with the proposed conditions, and with the following modifications:
• Allow the addition of only seven units (units labeled 1-4 and 9-11), consistent with their December 2024 recommendation.
• To not allow the proposed 172 square feet of ground floor office spaces. • Require annual monitoring of conditions and public benefits, specifically including Section 3D of the original PC Ordinance 3775 (including an annual report of occupancy, vacancy status, number and age of occupants, number of employees, residents and employees who would use parking spaces and a copy of a renewal license for residential care facility).
• Strike the language in Section 3, Finding 2, that referred to the old benefits from the original PC (specifically regarding bus improvements and prior payment benefits). • Add a condition of approval that staff must park on-site, or off-site in private/paid parking and arrive by shuttle if spaces are not available (during construction and after as necessary to prevent spillover parking in the neighborhood). • Include an appendix to the TDM plan that incorporates the proposed Parking Plan which may include specific requirements such as a valet with operating hours, and a plan to provide 986 parking spaces at all times, on-site or off-site with consequences for noncompliance.

This motion passed 5-1-1 (Hechtman dissenting, Ji recused). Hechtman spoke to his dissent, stating that he would prefer to see 11 units be approved, rather than only seven. However, he agreed with the other Commissioners that a two-story addition is better for the neighborhood context, and agreed that monitoring and regulating parking, construction logistics, and the TDM plan are a priority for this project.

ANALYSIS
Staff has reviewed the modified design and finds it generally consistent with relevant adopted plans, policies, and goals for the City. Staff also finds that the proposed project has been modified to balance expressed neighborhood concerns, as described below, while also adding senior assisted living units, consistent with several goals and policies set forth in the Comprehensive Plan, as described further in Attachment B. Staff’s recommendation differs 5 September 24, 2025 PTC report:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=7677&dbid=0&repo=PaloAlto 6 The reference to 98 spaces appears to have been an error as the intent was to require all of the parking spaces on site to remain and be available at all times. There are 97 existing spaces on site, 96 of which were required under the existing planned community zone district. The proposed ordinance reflects a requirement to maintain all 97 parking spaces.

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from the PTC’s recommendation based on Council’s express direction to return with an 11 to 13 unit project. However, Council in its discretion may choose to support a reduced project, consistent with the PTC’s motion, or move forward with additional modifications, or denial based on specific findings.

Response to Prior Feedback
In response to feedback from the Council and PTC, the applicant revised the plans and project materials to:
• Reduce the number of proposed units to 11, consisting of one new third-floor unit facing internally toward the Avant (and not Wilkie Way), seven new second-floor units, and three new first-floor units;
• Eliminate the previously proposed 172 square feet of office space; • Respond to neighbor’s expressed concerns regarding parking on residential streets by identifying a designated location for van parking when the facility’s van is not in use and by clearing three additional spaces on site to provide a total of 97 on-site parking spaces, one more than the 96 required in accordance with the existing PC; • Include the required annual report in accordance with existing PC requirements (Attachment D) and implement commuter benefits as part of a Transportation Demand Management (TDM) plan; and
• Respond to neighbor comments regarding the color scheme by revising the façade facing neighboring properties to green, while maintaining the ARB-recommended blue, cream, and gray color scheme on the remaining building elevations.

Although the project provides 11 units instead of the seven units that the PTC recommended, staff believes that the applicant has revised their plans to address most of the PTC’s recommendations and in alignment with the Council’s motion to explore an 11 to 13 unit project that minimizes impacts to the neighbors. Updates have also been made to the draft PC Ordinance (Attachment B) and Record of Land Use Action (RLUA) (Attachment C) to respond to PTC recommendations. Specifically, RLUA Section 3, Finding 2 removes reference to the old benefits from the original PC and a condition of approval has been added to address the recommended modifications to the TDM plan. The ordinance was also updated to reflect the most recent plans, which excludes the support space, and to incorporate modifications to the TDM plan.

The current plans utilize both the ARB-recommended color scheme, and a modified version of the existing color scheme. Neighbors, as well as some Council and PTC members, mentioned preferring the existing building’s green color. In response, the main portions of the façade facing Wilkie Way are now green, but the green was not incorporated on any other sides of the building. While this change to one façade of the building on the plans is intended to be responsive to adjacent residents, staff notes it differs from the rest of the building, which was recently painted in a blue, grey, and cream color scheme.

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Parking and Transportation Demand Management Plan
On a recent site inspection, staff observed 94 usable spaces, and three spaces that were blocked off as storage areas and were therefore unusable. Although three parking spaces in the garage were unavailable, the number of available spaces was only two fewer than the 96 required spaces per the existing PC (41 spaces for The Avant and 55 spaces for Palo Alto Commons). Materials being stored in the three additional parking spaces have since been moved to accommodate a total of 97 on-site parking spaces. The proposed ordinance has been updated to require the applicant to maintain these 97 parking spaces on site.

Table 1: Palo Alto Commons and The Avant Parking
Required by PAMC

18.52 Required by PC 3775
and PC 5116
Observed Useable
Spaces
Palo Alto Commons 54 spaces 55 spaces 54 spaces
The Avant 33 spaces 41 spaces 40 spaces
Note: ADA spaces were not counted twice for the purpose of this table.

Staff also observed that the valet service was operational, consistent with the proposed parking plan, and parking spaces were available in both garages, including on both sides of the Palo Alto Commons gate. The applicant states the valet is available between 8:30 a.m. and 4:30 p.m.

Monday through Friday. The applicant has noted that these hours were intentionally designated to support peak activity periods, when residents, family members, healthcare providers, and guests are most frequently arriving and departing.

Shuttle Van Parking
Palo Alto Commons owns a shuttle van used to provide rides to its residents. The van did not have a designated location to park on site. Palo Alto Commons has now arranged to park the van at the Congregation Etz Chayim at 4161 Alma, approximately one mile from the site. While this is less desirable than an on-site location, the van does not fit into a standard parking space and there was not a feasible option on site to park the van without reducing parking or removing a tree. The van was observed at this off-site location as a part of the inspection and fit into the parking space on that site. As of 2023, Congregation Etz Chayim has 130 parking spaces, 120 of which are required under the PAMC, therefore, allowing the use of one space for this van would be allowed. Condition of approval #14 has been added to require recordation of a shared parking agreement to ensure that this off-site space remains available for the van.

When the van is on-site it is in active use and would load allow passengers to load in the designated non-red-curbed area near the site entrance.

Construction Logistics Plan
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plan for construction-related equipment and vehicles in addition to other standard requirements such as deliveries, materials storage, and other items that may impact surrounding neighbors, including dust and noise mitigation. The Public Works Engineering standard condition of approval is included in the Record of Land Use Action and has been modified to Council and PTC’s additional concerns regarding employee parking during construction. While the applicant has not yet provided the construction logistics plan, they have indicated that they have already started discussions with their general contractor to identify a nearby off-site location for construction staging to ensure that on-site parking remains available for the ongoing operational use of the site, such as employee parking.

FISCAL/RESOURCE IMPACT
The processing of this application has no fiscal impact, as applicants are responsible for staff and consultant costs through applicable fees through the deposit-based cost recovery program.

The proposed addition requires payment of development impact fees, which are currently estimated at $221,554.18.

STAKEHOLDER ENGAGEMENT
All previously submitted written comments on this project are included in Attachment E. In general, the key concerns raised include:
• Loss of privacy
• Reduced access to natural sunlight
• Insufficient parking
• Opposition to any zoning code exceptions for the proposed addition • Concern that WellQuest, as a for-profit entity, does not prioritize the interests of neighboring residents
• Potential negative impacts on property values and overall quality of life • Questions about compliance with conditions of approval included in PC-3775 The City has encouraged the applicant to maintain open communication with the neighbors and requested that the applicant provide an update on the most recent plan modifications in advance of this Council hearing. Staff is not aware of any additional communication that has occurred between the applicant and adjacent neighbors except that the applicant provided the City with a flier related to commuter benefits and off-site parking improvements they have started implementing and stated an intent to send to neighboring residents. At the time of publication of this report, the applicant had not confirmed that this flier had been sent.

However, the applicant has made modifications to their plans in response to neighbor comments, such as eliminating third floor units facing neighbors, in addition to modifying their operations to address some of the expressed concerns raised by residents regarding ongoing operations, particularly those related to parking and compliance with existing conditions.

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ENVIRONMENTAL REVIEW
The subject project has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. The City, acting as the lead agency, has determined that the project is exempt from CEQA in accordance with CEQA Guidelines Section 15301 (existing facilities). Attachment F summarizes the project’s eligibility for a Class 1 exemption and why none of the exceptions to the exemptions apply to this project.

ATTACHMENTS
Attachment A: Location Map
Attachment B: 4075 El Camino Ordinance
Attachment C: Draft Record of Land Use Action
Attachment D: Applicant Project Description Letter and Annual Report Attachment E: Zoning Comparison
Attachment F: Public Comments
Attachment G: Project Plans, TDM Plan, and Environmental Documents APPROVED BY:

Jonathan Lait, Planning and Development Services Director Item 13
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Palo Alto
4075 El Camino Way
PC-5116
Attachment A
4075 El Camino Way
Location Zoning Map

0.17 ()

0.35 0.7
Miles
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1 Ordinance No. ____
Ordinance of the Council of the City of Palo Alto Amending Section

18.08.040 of the Palo Alto Municipal Code (The Zoning Map) to Amend PC Planned Community Zone (PC-5116) to Allow an Addition to an Existing Senior Assisted Living Facility
The Council of the City of Palo Alto ORDAINS as follows:

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

A. On March 21, 2011, the City Council adopted Ordinance No. 5116, creating PC Planned Community 5116.

B. On August 9, 2023, Irwin Partner Architects on Behalf of Wellquest Living submitted an application for an Ordinance Amending Planned Community Zone District 5116 (PC-5116) to allow a 16-Unit addition and 172 square feet of support space to an existing 121-unit Assisted Living and Memory Care Facility (the “Project”) at 4041 and 4075 El Camino Way (the “Subject Property”).

C. Following Staff Review, the Planning and Transportation Commission (“PTC”) reviewed the project on February 28, 2024 and June 12, 2024 and recommended the project to the Architectural Review Board.

D. The Architectural Review Board reviewed the project on July 18, 2024 and October 17, 2024; and recommended approval of the project to the City Council.

E. The PTC reviewed the project on December 11, 2024 and moved to advance the project to Council, recommending approval of only the seven units which do not face Wilkie Way and denial of the nine units and ground floor office space which faces towards the neighborhood. The motion also recommended returning the Transportation Demand Management plan to the PTC for approval, revising the Findings to reflect the PTC’s recommendation, and removing consideration of past public benefits from the PC Ordinance.

F. The City Council reviewed the project on May 5, 2025 and May 27, 2025 and moved to refer the project back to the PTC with direction that the project be reduced to 11 to 13 units, eliminating third floor units facing Wilkie Way.

G. The PTC reviewed the project again on September 24, 2025 and recommended approval of the project with additional revisions.

H. Approval of the Planned Community Project would constitute a project under the provisions of the California Environmental Quality Act of 1970, together with related state and local implementation guidelines promulgated thereunder (“CEQA”).

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2 I. The City is the Lead Agency pursuant to Public Resources Code section 21067 as it has the principal responsibility to approve and regulate the Planned Community Project.

J. The City, in compliance with CEQA, determined the project to be Categorically Exempt from CEQA per Section 15301 of the CEQA Guidelines (Existing Facilities).

K. The Council is the decision-making body for approval of the Planned Community Project.

L. The site is so situated, and the use or uses proposed for the site are of such characteristics that the application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development. Specifically, the project modifies an existing Planned Community Project (PC 5116) and includes 11 additional units, beyond the 121 units approved in ordinance 5116, and associated modifications to the development plan in accordance with this change.

M. Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts, as set forth in Section 6 of this ordinance.

N. The use or uses permitted, and the site development regulations applicable within the district are consistent with the Palo Alto Comprehensive plan, and compatible with existing and potential uses on adjoining sites or within the general vicinity.

SECTION 2. Amendment of Zoning Map.

Section 18.08.040 of the Palo Alto Municipal Code, the “Zoning Map,” is hereby amended by changing the zoning of the property formerly zoned as PC Planned Community Zone 5116 from PC Planned Community Zone 5116 to “PC Planned Community Zone _____”.

SECTION 3. Project Description.

The Project as a whole is described in the Development Plan titled “PALO ALTO COMMONS Wellquest Living” and uploaded to the Palo Alto Online Permitting Services Citizen Portal on October 16, 2025. The Development Plan and approved supplemental materials and conditions included as part of Ordinance 5116 and Ordinance 3775 are incorporated into this ordinance by reference. With respect to the Subject Property, the Project comprises the uses included in this Ordinance, depicted on the Development Plans, incorporated by reference, including the following components:
(a) Modifications to an existing 121-unit assisted living and memory care facility, approved as part of PC Planned Community 5116. The additions would include construction of 11 additional assisted living units (approximately 3,958 square feet).

SECTION 4. Land Uses.
(a) The following land uses shall be permitted:

1. Senior Housing;

2. Eating and Drinking Services for use by residents, employees, and their guests; Item 13
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3 3. Personal Services for use by residents, employees, and their guests;

4. Retail Services for use by residents, employees, and their guests;

5. Recreational Facilities for use by residents, employees, and their guests;

6. Administrative Offices for administration of Palo Alto Commons;

7. Medical care for residents as is customarily associated with senior assisted living facilities; and

8. Accessory Uses.

SECTION 5. Site Development Regulations and Development Schedule. (a) Development Standards:

Development standards for the Subject Property shall be those conforming to the Development Plan.
(b) Parking and Loading Requirements:

The Owner shall provide parking and loading as set forth in the Development Plan and Parking Management Plan, entitled “Parking Study & Parking Management Plan for Palo Alto Commons at 4075 El Camino Way in Palo Alto, California,” uploaded to Accela on April 9, 2025. The existing 97 spaces on the property shall be maintained and the Owner shall implement all modifications to the Parking Management Plan required by the Record of Land Use Action for the Project (RLUA No. 2025-XX). (c) Modifications to the Development Plan, Land Uses and Site Development Regulations:

Once the Project has been constructed consistent with the approved Development Plan, any modifications to the exterior design of the Development Plan or any new construction not specifically permitted by the Development Plan or the site development regulations contained in Section 5 (a) – (b) above shall require an amendment to this Planned Community zone. Any use not specifically permitted by this ordinance shall require an amendment to the PC ordinance. (d) Development Schedule:

The Project is required to include a Development Schedule pursuant to PAMC §18.38.100.

The approved Development Schedule is set forth in the Applicant Project Description Letter, and anticipates commencing in April 2025 and concluding in October 2026.

Construction of the project shall commence within two years of the effective date of this ordinance. Prior to expiration of this timeline, the Owner may seek a one year extension from the Director of Planning and Development Services.

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4 SECTION 6. Public Benefits.
(a) Public Benefits:

Development of the Project Site under the provisions of the PC Planned Community District will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts.

The public benefit provided by the Project is providing a safe place for Palo Alto residents and other seniors to age and making improvements to the existing facility to expand and improve these services.
(b) Monitoring of Conditions and Public Benefits:

The Applicant shall be responsible for reimbursing the City for all costs incurred in connection with annual compliance inspections and any code enforcement–related activities associated with this approval that occur outside of the annual review process.

Such reimbursement shall be provided either through the placement of a deposit or by payment on a time-and-materials basis, as determined by the Director of Planning and Development Services, in accordance with the Palo Alto Municipal Fee Schedule in effect at the time the costs are incurred.

If conditions or benefits are found deficient by staff, the applicant shall correct such conditions in not more than 90 days from notice by the City. If correction is not made within the prescribed timeframe, the Director of Planning and Development Services will schedule review of the project before the Planning and Transportation Commission and Council to determine appropriate remedies, fines or other actions.

SECTION 7. Environmental Review.

The project would not result in a substantial expansion of the current use and is therefore eligible for a categorical exemption from CEQA under Section 15301 of the CEQA Guidelines (Existing Facilities). //
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5 SECTION 8. Effective Date.

This ordinance shall be effective on the thirty-first day after the date of its adoption (second reading).

INTRODUCED:

PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST:

____________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED:

____________________________ ____________________________ Assistant City Attorney City Manager

____________________________
Director of Planning and
Development Services
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APPROVAL NO. 2026-____
RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO LAND USE ACTION FOR 4075 El Camino Way ADOPTION OF AN ORDINANCE TO AMEND PLANNED COMMUNITY 5116 to PLANNED COMMUNITY (PC) _______ (FILE NO. 23PLN-00202)
On March 16, 2026, the City Council of the City of Palo Alto (“City Council”) adopted Ordinance ____ approving an amendment to Planned Community (PC) 5116 to allow a 11-Unit addition to an existing 121 unit Assisted Living and Memory Care Facility (Palo Alto Commons). In approving the application, the Council makes the following findings, determination and declarations:

SECTION 1. Background.

A. Irwin Partner Architects on Behalf of Wellquest Living Requests Approval of an Ordinance Amending Planned Community Zone District 5116 (PC-5116) to allow an 11-Unit addition to an existing 121-unit Assisted Living and Memory Care Facility. (“The Project”).

B. The Project site is located on a 110,642 sf (2.54-acre) site on APN 132-43-177 located at 4075 El Camino Way. The Site is designated on the Comprehensive Plan Land Use Map with a split landuse designation of Multi-family and Community Neighborhood and is Zoned Planned Community 5116.

C. On August 7, 2023 City Council conducted a prescreening review of the proposed legislative actions in accordance with PAMC 18.79.

D. On February 28, 2024 Planning and Transportation Commission (PTC) reviewed the project held a duly noticed public hearing and recommended the project return to the PTC. On June 12, 2024 the PTC held a duly noticed public hearing and recommended that the applicant submit the proposed plans to the Architectural Review Board based on the conceptual design and proposed project in accordance with the Planned Community Rezoning process set forth in 18.38.

E. Following PTC and staff review, on July 18, 2024 the ARB held a public hearing to review the project design and recommend modifications in accordance with the ARB findings for approval.

On October 17, 2024 ARB held a duly noticed public hearing and recommended approval.

F. On December 11, 2024 PTC held a duly noticed public hearing and recommended approval of only the seven units which do not face Wilkie Way, and to recommend denial of the other nine units and ground floor office space which faces towards the neighborhood.

G. On May 5, 2025, City Council held a duly noticed public hearing, at which evidence was presented and all persons were afforded an opportunity to be heard in accordance with the Palo Alto Municipal Code and the Council’s Policies and Procedures. After hearing public testimony, the Council continued the meeting to a date uncertain. On May 27, 2025, the Council voted to refer this project back to the Planning and Transportation Commission for a review of a project between 11 to 13 units that would eliminate the 3rd floor units adjacent to Wilkie Way backyards.

H. On September 24, 2025 PTC held a duly noticed public hearing and recommended approval of only the seven units, which do not face Wilkie Way, and recommended additional conditions of approval.

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I. On March 16, 2026, City Council held a duly noticed public hearing, at which evidence was presented and all persons were afforded an opportunity to be heard in accordance with the Palo Alto Municipal Code and the Council’s Policies and Procedures. After hearing public testimony, the Council voted to _________the project subject to the conditions set forth in Section 6 of this Record of Land Use Action.

SECTION 2. Environmental Review. On March 1, 2026, the City, as the lead agency for the Project, determined that the project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) in accordance with CEQA Guidelines Section 15301 because it includes minor modifications to an existing building that involves negligible expansion of use. A document analyzing the project’s eligibility for a categorical exemption was prepared. The document is available on file with the Planning and Development Services department and on the project webpage, as an attachment to the November 11, 2025 Staff Report.

SECTION 3. Planned Community Findings
Finding #1: The site is so situated, and the use or uses proposed for the site are of such characteristics that the application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development.

The project is consistent with Finding #1 because:

The proposed project amends the existing Planned Community zoning in order to accommodate 11 additional Assisted Living units. Because the existing PC 5116 specifies the exact number of units to be constructed on the site (121), modification of the zoning ordinance is necessary to reflect the proposed unit count.

Finding #2: Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. In making the findings required by this section, the planning commission and city council, as appropriate, shall specifically cite the public benefits expected to result from use of the planned community district.

The project is consistent with Finding #2 because:

In keeping with the existing development, the public benefit for the proposed amendment is the addition of these 11 rental assisted living units, which will provide services to more seniors who need a high level of care. Although these units are not considered as dwelling units towards the Regional Housing Needs Allocation (RHNA), they provide a safe place to live for seniors.

Finding #3: The use or uses permitted, and the site development regulations applicable within the district shall be consistent with the Palo Alto Comprehensive Plan, and shall be compatible with existing and potential uses on adjoining sites or within the general vicinity.

The project is consistent with Finding #3 because:

This project is consistent with the Palo Alto Comprehensive Plan, as described further in Architectural Review Finding #1 below. The proposed project is a negligible expansion of the existing use, which is compatible with the neighborhood. The site is shared with an independent senior living apartment Item 13
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building, and other surrounding uses are currently mostly one- to two-story single-family houses, as well as condominiums and the Goodwill store. The character of the neighborhood will remain the same, and improvements are being made to privacy landscaping bordering the single-family neighborhood.

SECTION 4. Architectural Review Findings
Finding #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 is consistent with Finding #1 because:

In conformance with the following Comp Plan Goals and Policies, the project will include high quality design compatible with surrounding development.

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 a split land use that includes both
Multiple Family Residential and Neighborhood
Commercial.

The project maintains the existing use of Assisted
Living.

Land Use Element
Policy L-1.3 Infill development in the urban
service area should be compatible with its
surroundings and the overall scale and character
of the city to ensure a compact, efficient
development pattern.

This project proposes to expand an existing
facility, in a manner that is compatible with the
neighborhood and will improve the services
provided.

Policy L-2.11 Encourage new development and
redevelopment to incorporate greenery and
natural features such as green
rooftops, pocket parks, plazas and rain gardens.

As a part of the project, landscaping is being
improved to provide better privacy and more
greenery.

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

The proposed building additions will meet the
high-quality standards of the Architectural Review
Board.

Policy L-6.7 Where possible, avoid abrupt
changes in scale and density between residential
and non-residential areas and between
residential areas of different densities. To
promote compatibility and gradual transitions
between land uses, place zoning district
boundaries at mid-block locations rather than
along streets wherever possible.

The proposed addition does not add additional
height to the building, which borders a singlefamily residential neighborhood. The new windows are proposed with privacy measures and
privacy landscaping is being added to and/or
maintained.

Policy L-6.8 Support existing regulations that
preserve exposure to natural light for single
family residences.

The proposed addition complies with the R-1 side
yard daylight plane that was initially applied to
the existing building and adopted in PC Ordinance
3775. A shadow study was prepared that showed
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the increases in shadows as a result of the
addition would be minimal.

Transportation Element
Policy T-1.2 Collaborate with Palo Alto employers
and business owners to develop, implement and
expand comprehensive programs like the TMA to
reduce single-occupant vehicle commute trips,
including through incentives.

In keeping with this policy and the related policy
programs, a TDM plan will reduce the number of
single-occupant vehicle employee trips.

Policy T-5.11 Work to protect residential areas
from parking impacts of nearby businesses and
uses, recognizing that fully addressing some
existing intrusions may take time.

The proposed TDM plan and parking plan are
expected to minimize parking impacts of Palo Alto
Commons on the nearby neighborhood.

As an amendment to a Planned Community, adoption of the zoning ordinance to allow for the proposed modifications to the development, and specifically the total number of units would ensure that the project is in compliance with the zoning ordinance in accordance with the provisions set forth in the municipal code. No other design guidelines or documents apply to this location.

Finding #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, 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.

The project is consistent with Finding #2 because:

This project balances adding new units to the existing building, while making improvements to the existing operations. The new TDM plan will improve parking and vehicle circulation for occupants, visitors, and staff. The proposed addition is consistent with the existing height and existing PC daylight plane, which combined with new landscaping and privacy measures for new windows, will maintain an appropriate mass and character adjacent to the residential neighborhood. The new assisted living and memory care units will provide an important service to seniors in the community.

Finding #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 is consistent with Finding #3 because:

The project proposes horizontal siding in a variety of colors, including gray, blue, and khaki, with brown awnings, and white railings. This palette is appropriate for a residential building, and the variety of colors helps break up the massing. The change from white trim to brown trim helps to visually minimize the height, while white emphasizes it. Existing balcony railings will remain, and balcony awnings will be Item 13
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replaced in the new color scheme. New sloped roof area will also add visual interest and enhance the residential feel. The corners will be finished in a manner that meets the requirements of the Architectural Review Board.

Finding #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 is consistent with Finding #4 because:

Functional operations of this building are important because the building has multiple shifts of approximately 50 employees. The TDM plan will help manage parking on site and encourage staff and visitors to take alternative modes of transportation through provisions such as the addition of bicycle parking. Residents are not expected to drive vehicles. The existing number of parking spaces is sufficient for the proposed number of assisted living beds, consistent with the zoning code requirements.

Finding #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 is consistent with Finding #5 because:

The project primarily maintains existing landscaping. No trees are proposed for removal. An additional 8 trees, four Tupelo and four Forest Pansy Redbud are proposed to fill gaps in the existing screening. While normally evergreen trees are preferred for privacy, deciduous trees are proposed at the request of neighbors who would like to minimize additional shade in their backyards. Proposed trees are low to medium water use. Windows on the new addition were also designed in a manner that respects privacy of adjacent neighbors including higher sill heights and angling of windows to reduce views into neighboring yards.

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

The project is consistent with Finding #6 because:

In accordance with the City’s Green Building Regulations, the building will satisfy the requirements for CALGreen Mandatory + Tier 2.

SECTION 5. Development Plan Approval. The plans submitted for Building Permit shall be in substantial conformance with those plans prepared by the applicant titled Palo Alto Commons, Wellquest Living, 4075 El Camino Way, Palo Alto, CA 94306, consisting of 76 pages, uploaded to the Palo Alto Online Permitting Services Citizen Portal on October 16, 2025, except as modified to incorporate the conditions of approval in Section 6. A copy of these plans is on file in the Department of Planning and Community Development. The conditions of approval in Section 6 shall be printed on the cover sheet of the plan set submitted with the Building Permit application.

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SECTION 6. Conditions of Approval.

PLANNING DIVISION

1. CONFORMANCE WITH PLANS: Construction and development shall conform to the approved plans entitled, " Palo Alto Commons, Wellquest Living, 4075 El Camino Way, Palo Alto, CA 94306” uploaded to the Palo Alto Online Permitting Services Citizen Portal on October 16, 2025, as modified by these conditions of approval.

2. CONFORMANCE WITH PLANNED COMMUNITY ORDINANCE. Operation of the project shall comply with the approved plans described in Condition 1, the PC Ordinance adopted as a part of the rezoning approval, and the conditions of approval herein. a. Prior to the issuance of a building permit, the Applicant shall place a deposit with the City in an amount determined by the Director of Planning and Development Services to cover anticipated costs of annual compliance inspections and any code enforcementrelated activities associated with this approval (not to exceed $3,000.00). The Applicant shall reimburse the City for all actual costs incurred on a time-and-materials basis in accordance with the Palo Alto Municipal Fee Schedule in effect at the time the costs are incurred.

3. BUILDING PERMIT: Apply for a building permit and meet any and all conditions as contained in this document. Project plans submitted for Building permits shall incorporate the following changes:
a. Prior to building permit issuance, plans shall be revised to demonstrate a minimum of 97 unobstructed on-site parking spaces, consistent with the PC Ordinance requirement.

4. BUILDING PERMIT PLAN SET: A copy of this record of land use action shall be printed on the second page of the plans submitted for building permit.

5. PROJECT MODIFICATIONS: All modifications to the approved project shall be submitted in writing to the Director of Planning and Development Services for review and approval prior to implementation. It is the Applicant's responsibility to clearly identify and describe all proposed changes. No work reflecting a modification shall commence until written approval is received.

6. LANDSCAPE PLAN. Plantings shall be installed in accordance with the approved plan set and shall be permanently maintained and replaced as necessary. a. The screening landscaping is developed in concert with neighbor preferences and Architectural Review findings. No screening landscaping shall be altered without approval from the Director of Planning and Development Services.

7. 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 commercial property, a noise level more than eight dB above the local ambient at any point outside of the property plane. All noise producing equipment shall be located outside of required setbacks.

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8. 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.

9. SIGN APPROVAL NEEDED. No signs are approved at this time. All signs 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. TRASH ROOM. The trash room shall be used solely for the temporary storage of refuse and recycling that is disposed on a regular basis and shall be closed and locked during non-business hours.

11. REFUSE. All trash areas shall be effectively screened from view and covered and maintained in an orderly state to prevent water from entering into the garbage container. No outdoor storage is allowed/permitted unless designated on the approved plan set. Trash areas shall be maintained in a manner to discourage illegal dumping.

12. UTILITY LOCATIONS. In no case shall utilities be placed in a location that requires equipment and/or bollards to encroach into a required parking space. In no case shall a pipeline be placed within 10 feet of a proposed tree and/or tree designated to remain.

13. SHARED PARKING AGREEMENT. Prior to building permit issuance, the Applicant shall submit evidence of a recorded shared parking agreement between WellQuest Living, Congregation Etz Chayim (4161 Alma Street), St. Andrew's Methodist Church (4111 Alma Street), and the City of Palo Alto. The agreement shall, at minimum, specify: (a) the hours and days during which the Palo Alto Commons van may park on Congregation Etz Chayim property; (b) any conditions or limitations on use; and (c) a process for amendment or termination. If the Applicant is unable to execute such an agreement with the third-party property owners, the Applicant shall notify the Director of Planning and Development Services and propose an alternative parking arrangement for the van subject to Director approval.

14. ESTIMATED IMPACT FEE: Development Impact Fees, currently estimated in the amount of $221,554.18 shall be paid prior to the issuance of the related building permit. Fees are subject to change per annual Municipal Fee Schedule.

15. 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 Item 13
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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.

16. 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.

17. 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, Emily Kallas at [email protected] to schedule this inspection.

BUILDING

18. A building permit is required for the scope of work shown.

19. At building permit submit the following:
a. Structural calculations
b. Green building compliance
c. T24 Energy calculations
d. Complete MEP plans
e. Accessible building elements (i.e, elevator, bathrooms, etc.) and onsite (i.e., accessible route from public sidewalk, bus stop, entrances, etc.)

20. Refer to this link for additional submittal requirements:
https://www.cityofpaloalto.org/files/assets/public/v/3/development-services/buildingdivision/checklists/simplified/c1-new-comm-shell-checklist-07062023.pdf

PUBLIC WORKS ZERO WASTE

21. WellQuest will need to have the bins pulled out to within 25' of the gate. Otherwise GreenWaste of Palo Alto pull out charges will apply. Please add a note to the plans to specify how the bins will be pulled to the pick up area.

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22. Ensure the refuse staging area can house three - 4 cubic yard bins plus three - 96 gallon carts.

Please show bins and carts to scale in the staging area.

23. Refuse truck pull-out spot shall contain signage notifying tenants and other users that parking is not allowed during trash pickup days.

24. The following comments below are part of the Palo Alto Municipality Code. If your scope of work includes internal and external bins then cut-sheets for the color-coded internal and external containers, related color-coded millwork, and its colored signage must be included in the building plans prior to receiving approval from Zero Waste. Please see below for more details.

As per Palo Alto Municipal Code 5.20.108 the site is required to have color-coded refuse containers, related color-coded millwork, and colored signage. The three refuse containers shall include recycle (blue container), compost (green container), and garbage (black container).

Applicant shall present on the plan the locations and quantity of both (any) internal and external refuse containers, its millwork, along with the signage. This requirement applies to any external or internal refuse containers located in common areas such as entrances, conference rooms, open space, lobby, garage, mail room, gym, and etc. except for restrooms, copy area, and mother’s room. Millwork to store the color-coded refuse containers must have a minimum of four inches in height worth of color-coding, wrapping around the full width of the millwork. Signage must be color coded with photos or illustrations of commonly discarded items. Restrooms must have a green compost container for paper towels and an optional black landfill container if applicable.

Copy area must have either a recycle bin only or all three refuse receptacles (green compost, blue recycle, and black landfill container). Mother’s room must minimally have a green compost container and black landfill container. Please refer to PAMC 5.20.108 and the Internal Container Guide. Examples of appropriate signage can be found in the Managing Zero Waste at Your Business Guide. Electronic copies of these signage can be found on the Zero Waste Palo Alto’s website, https://www.cityofpaloalto.org/Departments/Public-Works/Zero-Waste/What-GoesWhere/Toolkit#section-2 and hard copies can be requested from the waste hauler, Greenwaste of Palo Alto, (650) 493-4894.

PUBLIC WORKS ENGINEERING

25. LOGISTICS PLAN: Prior to the issuance of a building permit, the Applicant shall submit a construction logistics plan to the satisfaction of the Director of Planning and Development Services and the Director of Public Works. The plan shall address all impacts to the public and include, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, stormwater pollution prevention, job trailer location, contractors' parking, truck routes, staging areas, 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 applicable route map.

Some elements of the construction logistics plan may require a separate encroachment permit, which shall be obtained prior to commencement of the applicable work. The plan shall also include:
a. A staging plan identifying whether any existing parking areas will be impacted by the staging of materials, vehicles, or equipment.

Item 13
Attachment C - Draft Record
of Land Use Action
Item 13: Staff Report Pg. 23 Packet Pg. 609 of 1140

0160184_20260226_ay16
b. An alternative parking plan identifying off-site parking spaces available to employees during construction, along with any proposed shuttle or transportation arrangements to prevent parking spillover into the adjacent residential neighborhood.

TRANSPORTATION

26. TDM PROGRAM AND ANNUAL REPORTING REQUIREMENT: The applicant shall abide by the Transportation Demand Management (TDM) plan, entitled “Palo Alto Commons 4075 El Camino Way Transportation Demand Management Plan” uploaded to Accela on April 9, 2025, or as modified, to the satisfaction of the Chief Transportation Official. The TDM plan includes measures and programs to achieve a reduction in single-occupancy vehicle trips to the site by a minimum of 20%, in conformance with the City’s Comprehensive Plan. The TDM plan includes an annual monitoring plan to document mode split and trips to the project site. The TDM annual report shall be submitted to the Chief Transportation Official, beginning one year from the date of Ordinance approval. Monitoring and reporting requirements may be revised in the future if the minimum reduction is not achieved through the measures and programs initially implemented. Projects that do not achieve the required reduction may be subject to daily penalties as set forth in the City’s fee schedule. The parking plan, as modified by condition of approval 27, shall be included as an appendix to the Final TDM plan and resubmitted to the City prior to the approval of the building permit.

27. PARKING PLAN: The applicant shall abide by the Parking plan, entitled “Parking Study & Parking Management Plan for Palo Alto Commons at 4075 El Camino Way in Palo Alto, California” uploaded to Accela on April 9, 2025, or as modified, to the satisfaction of the Chief Transportation Official. This document shall also be included as an appendix to the TDM plan.

Prior to Building Permit issuance, the parking plan shall be revised to include the following:
a. Update the description of the on-site valet parking to include hours of operation. b. Include a statement that employees are asked not to park in the adjacent neighborhood, and a reference to the commuter benefits provided per the TDM plan. c. Consistently refer to the total number of parking spaces as 97. d. Ensure the parking spaces are available at all times, including during construction.

Consider providing temporary off-site parking and shuttle service.

URBAN FORESTRY
The following conditions and/or standard Municipal Code requirements are provided for supplemental guidance, recommendation and/or best practices. Any applicable items shall be addressed prior to any future related permit application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance, Street Work Permit, Encroachment Permit, etc.

28.Show outline of tree protection fencing in a boxed off dashed line for tree to be protected as specified in the consulting Arborist report.

Item 13
Attachment C - Draft Record
of Land Use Action
Item 13: Staff Report Pg. 24 Packet Pg. 610 of 1140

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29.The owner and contractor shall implement all protection and inspection schedule measures, design recommendations and construction scheduling as stated in the TPR and/or Sheet T-1, 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. If called for, project arborist approval must be obtained and documented in the monthly activity report sent to the City. When required, the Contractor and Arborist Monthly Tree Activity Report shall be sent monthly to the City ([email protected]) beginning with the initial verification approval, using the template in the Tree Technical Manual, Addendum 11.

30. Revisions and/or changes to plans before or during construction shall be reviewed and responded to by the (a) project site arborist, or (b) landscape architect with written letter of acceptance before submitting the revision to the Building Department for review by Planning, PW or Urban Forestry.

31. Tree Damage, Injury Mitigation and Inspections apply to Contractor. Reporting, injury mitigation measures and arborist inspection schedule (1-5) apply pursuant to TTM, Section 2.20-2.30.

Contractor shall be responsible for the repair or replacement of any publicly owned or protected trees that are damaged during the course of construction, pursuant to Title 8 of the Palo Alto Municipal Code, and city Tree Technical Manual, Section 2.25.

32.The following general tree preservation measures apply to all trees to be retained: No storage of material, topsoil, vehicles or equipment shall be permitted within the tree enclosure area. The ground under and around the tree canopy area shall not be altered. Trees to be retained shall be irrigated, aerated and maintained as necessary to ensure survival.

33. Prior to any site work, contractor must call Derek Sproat at 650-496-6985 to schedule an inspection of any required protective fencing. The fencing shall contain required warning sign and remain in place until final inspection of the project.

34. Any approved grading, digging or trenching beneath a tree canopy shall be performed using ‘airspade’ method as a preference, with manual hand shovel as a backup. For utility trenching, including sewer line, roots exposed with diameter of 1.5 inches and greater shall remain intact and not be damaged. If directional boring method is used to tunnel beneath roots, then Table 2-1, Trenching and Tunneling Distance, shall be printed on the final plans to be implemented by Contractor.
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Item 13
Attachment C - Draft Record
of Land Use Action
Item 13: Staff Report Pg. 25 Packet Pg. 611 of 1140

0160184_20260226_ay16
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SECTION 7. Term of Approval.

The approval shall be valid for a term consistent with the Development Schedule provided in PC Ordinance No. _____.

INTRODUCED AND PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST: APPROVED:
_________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED AS TO CONTENT:
___________________________ ___________________________ Assistant City Attorney City Manager
___________________________
Director of Planning and
Development Services
PLANS AND DRAWINGS REFERENCED:

1. Those plans prepared by the applicant titled Palo Alto Commons, Wellquest Living, 4075 El Camino Way, Palo Alto, CA 94306, consisting of 76 pages, uploaded to Accela Citizen Access on October 16, 2025, except as modified to incorporate the conditions of approval in Section 6.

Item 13
Attachment C - Draft Record
of Land Use Action
Item 13: Staff Report Pg. 26 Packet Pg. 612 of 1140
245 Fischer Ave., Suite B2, Costa Mesa, California 92626 W: ipaoc.com CA: 714-557-2448 TX: 713-805-9097 Palo Alto Commons, 4075 El Camino Way, Palo Alto CA 94306 Project Description
Scope of Work:

New additions to an existing assisted living and memory care facility that had consisted of 121 units.

The addition would include 11 additional units. (7 studios and 4 1-bed rooms). 5 units will be assisted living units, and 6 units will be memory care units. Assisted living consists of residential care for the elderly that needs day to day assistance. Memory care consists of residential care for the elderly with memory disorders. The proposed total of units would be 132 units for the Palo Alto Commons and 176 including the Avant building. The Avant building is an independent senior living facility located on the same property.

Existing and Proposed Uses:

Existing use to remain. Facility will remain an assisted living and memory care facility.

Purpose of Proposed Changes:

To allow an increase in the unit count. Existing has 121 Units. Proposed will have 132 Units.

Design Intent:

Existing design to remain. Additions will reflect the existing design. Existing height and daylighting plane are being maintained. The building is being designed to minimize privacy impacts. A new color scheme is being proposed to refreshen the appearance of the building.

Materials, colors, and construction methods:

Existing materials (wood siding) to remain. Colors are proposed to be updated.

Front and sides:

Siding colors – Silver Springs, Heather, and Frozen Lake Railing Color – Precious Pearls
Trim Color – Renwick Brown
Rear
Siding colors – Gardening
Railing Color – Precious Pearls
Trim Color – Renwick Brown
Item 13
Attachment D - Applicant
Project Description Letter
and Annual Report
Item 13: Staff Report Pg. 27 Packet Pg. 613 of 1140
245 Fischer Ave., Suite B2, Costa Mesa, California 92626 W: ipaoc.com CA: 714-557-2448 TX: 713-805-9097 Landscaping:

Existing landscape to remain. No trees are expected to be removed. In addition, 8 trees will be added to help block the views of the additions from the neighboring residents. 6 of those trees will be evergreens and 2 will be deciduous.

Lighting:

Existing lighting to remain, except for the lighting that will need to be replaced to make room for the enlarged trash enclosure. A new light will be attached to the new trash enclosure.

Transportation:

A TDM is being implemented to improve circulation and parking conditions.

Construction Schedule:

Estimated construction commencement: 6/1/20256
Demolition: 6/1/2026 - 11/1/2026
Site Preparation: 10/1/2026 – 11/31/2026
Grading/Excavation: 11/31/2026 – 3/1/2027
Trenching/Foundation: 11/31/2026 – 3/1/2027
Building – Exterior: 11/1/2026 - 11/1/2027
Building – Interior/Architectural Coating: 5/1/2027 - 12/31/2027 Paving: 11/1/2027 - 12/1/2027
Estimated completion: 12/31/2027
Item 13
Attachment D - Applicant
Project Description Letter
and Annual Report
Item 13: Staff Report Pg. 28 Packet Pg. 614 of 1140
185 South State Street
Suite 1300
Salt Lake City, UT 84111
City of Palo Alto October 14, 2025
Attention: Director of Planning Updated Dec. 9, 2025
& Development Services
250 Hamilton Ave
Palo Alto, CA 94301
RE: Palo Alto Commons 4075 El Camino Real, Palo Alto, Ca 94306 Annual Reporting Requirement per Ord. 3775
To Whom it May Concern:

Please see the following information, as required by PC Ordinance 3775, dated 10.26.87, Section D. Annual Report:

1. Current occupancy: 94 Assisted Living, 41 Memory Care. Total 135 residents.

Per Emily Kallas Request: Update as follows:

As of December, The Avant has 50 residents occupancy with a total of 45 apartments (only two apartments vacancy).

Palo Alto Commons has a 132 residents occupancy with a total of 136 apartments (with 7 apartment vacancy).

2. Total number of employees: 176 Employees (161 full time, 16 part time)

3. Number of staff who use onsite parking spaces:
• Total 96 Parking spaces onsite
 53 spaces within Palo Alto Commons
 43 spaces within the Avant
 21 ungated spaces available from Commons and Avant
 13 Residents currently using parking
• Employees are able to use onsite parking for each shift:
approximately 69 employees at busiest AM shift.

4. Staff who use public transportation, carpool:
• 10 Carpool drivers
• 12 carpool passengers, dropped off
• 12 public transportation
• 1 bike

5. Copy of our license is attached.

Copy of PC ordinance 3775 below. This satisfies the annual reporting requirement for 2025. Please advise of anything additional is required.

Item 13
Attachment D - Applicant
Project Description Letter
and Annual Report
Item 13: Staff Report Pg. 29 Packet Pg. 615 of 1140
Wellquest Living, LLC
Sincerely,
Charlene Kussner
Representative of Management Company, WellQuest Living.

Item 13
Attachment D - Applicant
Project Description Letter
and Annual Report
Item 13: Staff Report Pg. 30 Packet Pg. 616 of 1140

ATTACHMENT E

ZONING COMPARISON TABLE
4075 El Camino Way, 23PLN-00202
Table 1: COMPARISON WITH EXISTING PCs (5116 AND 3775)(1) Exclusively Non-residential Development Standards
Regulation Existing (PC 5116 and PC 3775) Proposed
Site Area, width and depth 110,642 sf
Irregularly shaped
110,642 sf
Irregularly shaped
Minimum Front Yard
(El Camino Way)

14.5 ft 14.5 ft
Rear Yard
(Closest to Wilkie Way)
10 ft 10 ft
Interior Side Yards N/A left
8 ft other sides
N/A left
8 ft other sides
6 ft at proposed addition
Street Side Yard
(W. Meadow Drive)
20 ft 20 ft
Build-to-lines Approximately 7.5 ft (2.3%)
built to front setback
Approx. 7.5 ft plus 2 corners
(8.2%) built to street side
setback
No change, complies
Max. Site Coverage 47.4% (52,470 sf) 48.4% (53,496 sf)
Max. Building Height 32 ft 5 in 32 ft 5 in
New addition max height
21 ft 6 in for second floor,
28 ft for third floor
Max. Floor Area Ratio (FAR) 0.43:1 (47,500 sf) Independent Senior Living (The Avant)

0.76:1 (83,511 sf) Assisted Living
(Palo Alto Commons)

1.18:1 (131,011 sf) total

0.43:1 (47,500 sf) Independent
Senior Living (The Avant)

0.82:1 (87,473 sf) Assisted
Living (Palo Alto Commons)

1.22:1 (134,973 sf) total
Daylight Plane for lot lines abutting one
or more residential zone districts other
than an RM-40 or PC Zone (2)
Complies Complies
(1) PC 3775 is for Palo Alto Commons, PC 5116 is for The Avant. (2) The initial height and slope shall be identical to those of the most restrictive residential zone abutting the site line in question.

Item 13
Attachment E - Zoning
Comparison
Item 13: Staff Report Pg. 31 Packet Pg. 617 of 1140
Table 2: CONFORMANCE WITH CHAPTER 18.38.150

SPECIAL REQUIREMENTS FOR PC
Requirement when Adjacent to RE, R-1, R-2, RM or
applicable PC district
Proposed
(b) The maximum height within 150 feet of any RE, R-1, R2, RMD, RM, or applicable PC district shall be 35 feetComplies, 32’6” height existing and to be maintained.
(c) A minimum interior yard of 10 feet shall be required, and a solid wall or fence between 5 and 8 feet in height shall be constructed and maintained along the common
site line.

Complies, 10 foot setback for the
building, 7 ft fence on property line.
(d) A minimum street-side or front yard of 10 feet shall be required. For housing projects, the minimum yard
requirement shall be at least as restrictive as the yard requirements of the most restrictive residential district opposite such site line. The minimum yard shall be
planted and maintained as a landscaped screen, excluding areas required for access to the site.

Complies, change to front or streetside
setbacks are proposed.
(e) A maximum height established by a daylight plane
beginning at a height of ten feet at the applicable side or rear site lines and increasing at a slope of three feet for each six feet of distance from the side or rear site lines until intersecting the height limit otherwise established for the PC district; for housing projects, the daylight planes may be identical to the daylight plane
requirements of the most restrictive residential district abutting each such side or rear site line until intersecting the height limit otherwise established for the PC district. If the residential daylight plane, as allowed in this section, is selected, the setback regulations of the same adjoining residential district shall be imposed.

Complies. The addition fits within the R-1
side daylight plane that was established
for the existing PC.

Table 3: PARKING CONFORMANCE WITH ZONING CODE
Type Chapter 18.52
(For Reference Only)
Existing PC Proposed
Vehicle Parking 0.75 per Senior
Housing Unit (33
spaces)
1 per 2.5 beds Assisted
Living (57 spaces)
41 spaces
Independent Senior
Living (The Avant)
57 spaces
Assisted Living (Palo Alto
Commons)
41 spaces
Independent Senior
Living (The Avant)
57 spaces
Assisted Living (Palo
Alto Commons)
Item 13
Attachment E - Zoning
Comparison
Item 13: Staff Report Pg. 32 Packet Pg. 618 of 1140
Complies
Bicycle Parking None per Senior
Housing Unit
1 per 25 beds
Assisted Living (2 LT)
None 4 short term
2 long term
Loading Space 1 loading space for
10,000-99,999 sf.
2 required for 100,000-
199,999 sf.

None No change
Item 13
Attachment E - Zoning
Comparison
Item 13: Staff Report Pg. 33 Packet Pg. 619 of 1140
From: Ellen Hartog
To: Council, City
Subject: The Commons
Date: Monday, December 22, 2025 9:19:38 AM
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i
From: Ellen Hartog <[email protected]>
Date: December 22, 2025 at 8:55:39 AM PST
To: [email protected]
Subject: The Commons
Dear honorable council
members,
I ask City Council to Approve only the 7 internal units as recommended by the Planning & Transportation Commission (PTC).

As a long time resident I was here during the approval of the original construction and conditions of approval after huge negotiations with the neighborhood. We compromised on height and density at that time and finally agreed on the present configuration with conditions of approval this is the extent of the massing. Today they are requesting to undermine the neighborhood agreement. The existing situation has robbed light and air and this design further erodes fundamental rights of property owner’s light and air. This property is not a builders remedy and doesn’t contribute to the housing element. They simply want to destroy the quality of life for neighbors so to reap more money. They are an out of state franchise and have no game in being a part of the neighborhood. The seniors they are building units for have no idea how they impact us. They look into yards and light at night floods into the yards. The Commons has proved they are terrible neighbors parking on streets and under utilizing their own parking - they haven’t provided any of the data required by the conditions of approval.

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Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 34 Packet Pg. 620 of 1140
I have a formal complaint with code enforcement and have yet to see any corrections since and continues to be very difficult to park with el Camino parking removed. Please Enforce the conditions of approval, including Transportation Demand Management (TDM), with real consequences.

Upon City Council's request, PTC carefully reviewed the project and strengthened its recommendation (from 3-2 vote to 5-1) for only 7 units with additional conditions.

Historical agreement (1986) promised no development on the Wilkie Way side; neighbors already compromised by allowing 7
Developer violating existing PC Ordinance and using parking spaces for construction equipment, parking in fire lanes, and causing overflow into nearby streets such as Wilkie
The Commons are in non-compliance. Why do we expect them to be in compliance with their proposed expansion?
Developer ignored Council’s direction to remove all third-floor units when the project was sent back to PTC.

Parking and safety problems are serious and will worsen, with the recent loss of parking on El Camino and planned removal on El Camino Way Rooms cost $15K per month, and the owner, FJ Management, is a large national corporation that can afford to build only 7 units or expand on the El Camino Way side instead.

Bottom line:
7 internal units is the maximum reasonable compromise.

Anything more increases safety risks, parking problems, and breaks past agreements.

Please do not approve the Commons further destroying the neighborhood for a few more units Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 35 Packet Pg. 621 of 1140
that ought to be built where there is space in front yard. This solution further destroys property values for the entire street, people’s lives and quality they already compromised so much. The units are not affordable and should have an environmental impact report done because we can not trust them. For instance parking is not enough and the shadow study show shadows stop on property lines, it’s not accurately portraying the reality. A proper environmental report should be necessary.

Thank you for your time and consideration.

Ellen Hartog
Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 36 Packet Pg. 622 of 1140
From: Natacha Telusca
To: Council, City
Subject: Palo Alto Commons
Date: Monday, December 22, 2025 3:47:12 PM
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Dear Council Members
We respectfully ask City Council to:

Uphold the Planning & Transportation Commission’s recommendation Only Approve the 7 internal units
Please reject all external units and office space adjacent to the R-1 neighborhood
Please Adopt and enforce the PTC’s recommended conditions of approval, including TDM requirements with consequences for noncompliance Thank your for your consideration
Natacha Telusca
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Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 37 Packet Pg. 623 of 1140
From: Penny Brennan
To: Council, City
Cc: Kallas, Emily
Subject: Palo Alto Commons: 7 internal units max + enforceable contingencies Date: Monday, December 22, 2025 10:26:36 PM
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Dear City Council,
The Palo Alto Commons has historically broken its 1986 promises to its Wilkie Way neighbors and by breaking them has significantly diminished the quality of life of Wilkie Way residents, especially with regard to the invasiveness of the Palo Alto Commons into the backyards and interiors of Wilkie Way residents' homes, and the burden of excess traffic and over-parking of Wilkie Way by Palo Alto Commons employees, suppliers, and residents' visitors and service providers.

Palo Alto Commons should be permitted a maximum of an additional 7 internal units to its complex and then only with enforceable contingencies that require Palo Alto Commons to live up to its current promises to minimize the negative impacts of 7 new iinternal units on its Wilkie Way neighbors, especially with respect to the traffic and parking problems it has created on Wilkie Way.

At every meeting regarding the Palo Alto Commons proposal much is made of the need for more senior housing in Palo Alto. I note again that, although this need is quite real, Palo Alto Commons has always been and will continue to be housing for wealthy seniors. Over the years Palo Alto Commons has made no effort to provide affordable housing to Palo Alto elders who have modest-to-low incomes in the same way that, for example, Lytton Gardens has. Palo Alto Commons is generating huge profits that are flowing out of Palo Alto to benefit out-of-state, for-profit corporations. In my opinion, Palo Alto Commons provides no appreciable benefit to its local neighborhood and negligible benefit to the broader City of Palo Alto.

Sincerely,
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Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 38 Packet Pg. 624 of 1140
Penny Brennan, PhD
Ventura Neighborhood
Palo Alto
Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 39 Packet Pg. 625 of 1140
From: Kai Porter
To: Council, City
Cc: Kallas, Emily
Subject: 4075 El Camino Way - comments for 1/12/2026 City Council Mtg Date: Monday, December 22, 2025 8:00:14 PM
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Dear Members of the City Council,
I agree with the PTC vote for 7 internal residential units and opposition to any external units that face neighbors. I urge you to vote for the same.

I have lived since 2005 at 4080 Wilkie Way. I do care about seniors and would like to see FJ Management, owner of Wellquest Living, to take care of seniors while following requirements for safety, traffic, and parking. I have given detailed comments about the failure to address parking and congestion meaningfully in its TDM plan update. I had urged the City to enforce existing requirements. Then after hearing concerns, FJ Management’s own buses and vans keep blocking fire access and handicapped spaces, it stores construction materials and equipment in spaces that are supposed to be for visitors, etc. So even if the plans on paper improved, actual compliance with plans is not happening now every day. I again urge you to work with the City’s code enforcement department and any others responsible for holding this company accountable for following basic requirements that protect the safety of its residents from fire hazards, allow parking for visitors, especially those with disabilities, and that can reduce impacts on the neighbors. Any new TDM should build in even more enforcement measures.

How can any of us trust this company? If it earns $15,000 per month per unit, then surely it can afford to find solutions to these continuing problems. Only after FJ Management demonstrates compliance with even basic, simple legal requirements should you consider any expansion proposals. And if you do, then expansion should be limited to 7 interior units. Thank you for considering these comments.

Sincerely,
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Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 40 Packet Pg. 626 of 1140
Kai Porter
Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 41 Packet Pg. 627 of 1140
Dear Members of the City Council
I am writing to express my strong opposition to the proposed expansion of the Palo Alto Commons in its current form and respectfully request that City Council approve only the 7 internal units, with no external units or office space adjacent to the R-1 neighborhood, consistent with the Planning & Transportation Commission’s (PTC) recommendation.

When this project last came before City Council, you directed the applicant to work with neighbors toward a compromise. After further review, the PTC returned with a strengthened recommendation, approved by a 5–1 vote, to approve the 7 internal units only, along with additional conditions of approval. I strongly support that recommendation and urge Council to uphold it.

When this project first came before Council, the neighborhood overwhelmingly opposed any additional units, based on a clear and documented compromise made on the public record in 1986 that expressly agreed to no further development on the Wilkie Way side of the property.

Despite this, neighbors repeatedly negotiated in good faith and ultimately accepted 7 internal units as a compromise.

A neighborhood petition signed by over 100 individuals, including residents of The Avant and other WellQuest-managed properties, demonstrates broad, sustained opposition to any external expansion of the Commons.

Since this project was first proposed, parking has already been removed from El Camino, an area the applicant previously stated should accommodate staff and visitor parking.

Additionally, the City’s 2025 Bike and Pedestrian Transportation Plan proposes removing all parking on El Camino Way. Approving further expansion under these conditions will create a significant parking and safety crisis for the surrounding neighborhood.

These concerns led the PTC to appropriately recommend Transportation Demand Management (TDM) measures with enforcement mechanisms for noncompliance, which I strongly support.

Throughout this process, the applicant has demonstrated a pattern of inconsistent and bad-faith negotiation:
● An initial claim of reducing units from 18 to 16 was accomplished only by converting rooms into offices, without reducing building mass.
● At the May 27 City Council meeting, the applicant stated that any proposal with fewer than 16 units was financially infeasible.
● Subsequently, the applicant stated willingness to build 13 units, then 11 units, while continuing to assert that 7 units “do not pencil out.”
I respectfully ask City Council to:
● Uphold the Planning & Transportation Commission’s recommendation ● Approve only the 7 internal units
● Reject all external units and office space adjacent to the R-1 neighborhood Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 42 Packet Pg. 628 of 1140
● Adopt and enforce the PTC’s recommended conditions of approval, including TDM requirements with consequences for noncompliance
This approach reflects the maximum compromise offered by the neighborhood, aligns with the PTC’s careful review, and avoids setting a dangerous precedent by relying on outdated municipal code provisions from the time of the original construction.

Thank you for your time, consideration, and commitment to neighborhood safety, trust, and sound planning.

Sincerely,
Anne Mason
Item 13
Attachment F - Public
Comments
Item 13: Staff Report Pg. 43 Packet Pg. 629 of 1140
From: James Porter
To: Council, City; Kallas, Emily
Subject: Comment for 1/12/26 City Council Agenda Topic: Palo Alto Commons Date: Monday, December 22, 2025 5:25:26 PM
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Dear City Council Members,
I'm James Porter, 30 year resident of Palo Alto and 22 year resident of Wilkie Way. I'm writing to express my staunch opposition to the current expansion proposal for the Palo Alto Commons. As Palo Alto needs additional senior housing, I fully support the 7 unit expansion (with no 1st floor or exterior additions) that was approved twice (with increasing margins) by the Planning and Transportation Commission. 7 units allows for more senior care without crowding out the neighbors on Wilkie Way. When the Commons was approved in 1986, the developers had promised not to expand backwards and fill in the step back design which allows some natural light in the backyards. I appreciated the removal of the 3rd floor units but the new second floor units also fill in needed areas that could allow views of the sky and natural sunlight. Despite this broken promise, neighbors repeatedly negotiated in good faith and ultimately accepted 7 internal units as a compromise. The applicant, by contrast, refused to meaningfully engage or reduce the project until the final stages of review, despite repeated requests from both neighbors and the PTC. The earlier compromise of 13 units was actually made in the council meeting after community residents were told that the project wouldn't "pencil out" with less than 16 units. There is likely a good financial case for the 7 interior unit option.

I also feel 7 is a great compromise given the parking and congestion impacts. Parking violations at the Commons are ongoing, welldocumented, and acknowledged even in the applicant’s own consultant parking study. Please also note other arguments in the community petition that is part of the January meeting packet.

I realize the Avant is a separate project but it is immediately adjacent to the Commons and serves seniors. Our neighbors and my family welcomed this expansion as it had adequate parking and did not go back on the promises made in 1986. Wilkie Way has done its part to host senior housing and care facilities.

I respectfully ask City Council to:

Uphold the Planning & Transportation Commission’s recommendation Approve only the 7 internal units
Reject all external units and office space adjacent to the R-1 neighborhood Adopt and enforce the PTC’s recommended conditions of approval, including TDM requirements with consequences for noncompliance
This approach reflects the maximum compromise offered by the neighborhood and aligns with the PTC’s careful review,
Thank you for your consideration,
James Porter
4080 Wilkie Way
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Comments
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From: Jagdish Pamnani
To: Council, City
Cc: Kallas, Emily
Subject: Palo Alto Commons Application Comment
Date: Monday, December 22, 2025 4:28:29 PM
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i
Dear Members of the City Council
I am writing to express our strong opposition to the proposed expansion of the Palo Alto Commons in its current form and to respectfully request that City Council approve only the 7 internal units, with no external units or office space adjacent to the R-1 neighborhood, consistent with the Planning & Transportation Commission’s (PTC) recommendation.

When this project last came before City Council, you directed the applicant to work with neighbors toward a compromise. After further review, the PTC returned with a strengthened recommendation, approved by a 5–1 vote, to approve the 7 internal units only, along with additional conditions of approval. We strongly support that recommendation and urge Council to uphold it.

Neighborhood History and Good-Faith Compromise
When this project first came before Council, the neighborhood overwhelmingly opposed any additional units, based on a clear and documented compromise made on the public record in 1986 that expressly agreed to no further development on the Wilkie Way side of the property. Despite this, neighbors repeatedly negotiated in good faith and ultimately accepted 7 internal units as a compromise. The applicant, by contrast, refused to meaningfully engage or reduce the project until the final stages of review, despite repeated requests from both neighbors and the PTC.

A neighborhood petition signed by over 100 individuals (Attachment Q), including residents of The Avant and other WellQuest-managed properties, demonstrates broad, sustained opposition to any external expansion of the Commons.

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Failure to Follow Council Direction
Council sent the project back to the PTC with direction to remove third-floor units. However, the proposal that returned to the PTC did not fully remove those units. In addition, during this period, they started illegally parking their bus to block fire lanes. 38+ Years of Noncompliance with Planned Community Ordinance Since approval of its original Planned Community ordinance in 1987 (PC3775, Attachment A), the Commons has failed to comply with multiple conditions of approval. These violations have been raised repeatedly, including before City Council. While the Commons has acknowledged noncompliance, required data and corrective actions have still not been adequately submitted.

Multiple code enforcement requests remain unresolved.

Persistent Parking Violations and Safety Concerns
Parking violations at the Commons are ongoing, well-documented, and acknowledged even in the applicant’s own consultant parking study. Recent and continuing issues include:

Employees taking parking on South Wilkie Way so neighbours have to park 2 blocks down the street
Blocking of fire access lanes with buses and vans (Attachment M, N) Misuse of handicap parking spaces (Attachment C)
Equipment stored in visitor parking spaces (Attachment B, O) Parking in no-parking zones (Attachment D)
Overflow parking onto public streets (Attachment E)
Palo Alto Commons bus parked on Wilkie Way (Attachment G) Commons vehicles occupying visitor spaces (Attachment H) Staff parking in the surrounding neighborhood (Attachment I) Item 13
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Therapists and visitors directed by staff to park on Wilkie Way Inconsistent or absent valet service (Attachment J)
These violations have continued even after being explicitly raised before both City Council and the PTC. As recently as December 2025, there are still violations (Attachment M, N, O).

Reduced Parking and Future Impacts
Since this project was first proposed, parking has already been removed from El Camino, an area the applicant previously stated should accommodate staff and visitor parking.

Additionally, the City’s 2025 Bike and Pedestrian Transportation Plan proposes removing all parking on El Camino Way. Approving further expansion under these conditions will create a significant parking and safety crisis for the surrounding neighborhood. Attachment P shows how fully parked El Camino Way already is.

These concerns led the PTC to appropriately recommend Transportation Demand Management (TDM) measures with enforcement mechanisms for noncompliance, which we strongly support.

Pattern of Bad-Faith Negotiation
Throughout this process, the applicant has demonstrated a pattern of inconsistent and badfaith negotiation:

An initial claim of reducing units from 18 to 16 was accomplished only by converting rooms into offices, without reducing building mass.

At the May 27 City Council meeting, the applicant stated that any proposal with fewer than 16 units was financially infeasible.

Subsequently, the applicant stated willingness to build 13 units, then 11 units, while continuing to assert that 7 units “do not pencil out.”
These shifting positions undermine confidence in the applicant’s claims.

Daylight Plane Violations
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As previously discussed, the proposed design continues to violate the daylight plane requirements under PAMC 18.38.150. The code specifies a 3/6 angle with a 10-foot setback for commercial developments. This project qualifies as commercial since it does not meet RHNA housing requirements. Even if it were considered housing, which we dispute, it would require a 20-foot setback at a 45º angle. The current design fails to comply with either standard.

Our Request
We respectfully ask City Council to:

Uphold the Planning & Transportation Commission’s recommendation Approve only the 7 internal units
Reject all external units and office space adjacent to the R-1 neighborhood Adopt and enforce the PTC’s recommended conditions of approval, including TDM requirements with consequences for noncompliance
This approach reflects the maximum compromise offered by the neighborhood, aligns with the PTC’s careful review, and avoids setting a dangerous precedent by relying on outdated municipal code provisions from the time of the original construction.

Thank you for your time, consideration, and commitment to neighborhood safety, trust, and sound planning.

Sincerely,
Jagdish Pamnani
4100 Wilkie Way
Palo Alto, CA
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From: Lily Lee
To: Council, City
Cc: Kallas, Emily
Subject: 4075 El Camino Way - comments for 1/12/2026 City Council Mtg Date: Monday, December 22, 2025 4:22:07 PM
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Dear Members of the City Council,
I have lived behind 4075 El Camino Way since 2003. We felt the 1987 PC created valuable senior services while creating a transition to residential zoning. Then in 2014, the Avant added 44 new units, which further impacted traffic, visual massing, and shadows for Wilkie Way neighbors. But we did not oppose that because it helps seniors.

Today, however, in spite of original commitments, FJ Management, a $7 billion corporation, which owns Wellquest Living, has continued to pursue yet another expansion that betrays their original promise to the neighbors for stepdown constructions with smooth transition from residential to commercial and minimizing massing and density, as required by PAMC 18.16.090(b)(4) and 18.13.060(b)(2)(B).

This City designated this project commercial, but it violates the commercial requirements for a 3/6 angle with 10-foot setback requirements (PAMC 18.38.150).

Even if it could be considered residential, it does not meet the 20 ft set back and 45 degree angle requirements for that.

FJ Management has also violated other requirements. It parks vehicles in fire lanes, stores supplies in visitor parking spaces, thus putting more pressure on neighborhood parking. The removal of parking spaces on El Camino Real to accommodate bike lines further exacerbates this problem. And it failed to submit decades of required annual reports to the city about residential preference.

The City created requirements for the good of the community as a whole. If anyone can get exceptions any time they want, then businesses get preferential treatment, and developers no longer have a consistent level playing field, and the community changes in ways that can harm residents. FJ Management should comply with existing requirements, and the City should step up enforcement.

Even after this neighborhood absorbed the 44 units at the Avant’s, I still support senior services, so I encourage you to vote to add 7 interior residential units.

However, for the reasons above, please oppose 4 external units that face Wilkie Way Item 13
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backyards.

Thank you,
Lily Lee
4080 Wilkie Way
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From: James Cham
To: Council, City
Cc: Kallas, Emily
Subject: Comments on Palo Alto Commons Proposal
Date: Monday, December 22, 2025 3:51:08 PM
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i
Dear Mayor and City Council Members,
As a local resident, I am writing to ask the City Council to reject the developer’s 11-unit proposal for the Palo Alto Commons and instead approve only the seven internal units recommended by the Planning & Transportation Commission (PTC).

My opposition is based on:
- Ordinance Violations: The developer currently violates the existing PC Ordinance by using required parking for equipment and allowing parking in fire lanes, impacting the community around Wilkie Way.
- Community Safety: With the loss of parking on El Camino Real and El Camino Way, our streets are at a breaking point. Further density threatens the safety of students who bike through this neighborhood to attend school.
- Broken Agreements: There was a 1986 agreement that promised no development on the Wilkie Way side of this property. We have already compromised significantly by agreeing to 7 units. I have been surprised that the developers ignored the Council’s previous direction to remove third-floor units.

The 7-unit plan is the maximum reasonable compromise. Anything more breaks past agreements and creates untenable safety risks for our community.

The Palo Alto Commons has had a history of ignoring past agreements so I also request that the Council enforce strong conditions of approval, specifically a robust Transportation Demand Management (TDM) program with clear, enforceable consequences for noncompliance.

Thank you for your time and for considering the safety and stability of our neighborhood.

Sincerely,
James Cham
Wilkie Way, Palo Alto Resident
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From: Nia Porter
To: Council, City; Kallas, Emily
Subject: 4075 El Camino Way 1/12 City Council Item Comments Date: Monday, December 22, 2025 3:45:22 PM
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Dear Members of the City Council,
I have lived at 4080 Wilkie Way, behind 4075 El Camino Way, since 2007. I learned about the 1987 compromise. Because I support senior services, I therefore support the previous PTC vote to add 7 internal units. However, I do not support adding the 6 external units and 2 offices facing the backyards of me and my neighbors. These additions would increase traffic/parking, visual massing, shadows and other neighborhood problems.

My family and I have met with FJ Management, owner of Wellquest Living, multiple times to express our concerns. They kept saying that they could not afford to reduce the residential units below 16. But they charge $15,000 per unit per month for “luxury” units. Only when faced at the City Council meeting in May 2025 with a vote to agree with the PTC did they suddenly talk about going from 16 to 13 backyard-facing residential units. Then they disregarded Council direction to remove 3rd floor units.

Now they say they can do 11. These changes in position shows they were not completely honest before.

Additionally, FJM is a $7 billion, for-profit company. The owner’s daughter, who runs the company, even said “do what’s best for the business, not what’s best for the family”.

In these and other ways, this corporation has repeatedly shown that although they claim to listen, but they make minimal effort to respond meaningfully. I urge the City Council to affirm the PTC position to only approve 7 interior units.

Sincerely,
Nia Porter
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From: jennie chan
To: Council, City
Cc: Kallas, Emily
Subject: Palo Alto Commons Comment, 1/12 City Council Meeting Date: Monday, December 22, 2025 3:32:14 PM
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Dear Council members,
Please do not allow any unit to be built against the Wilkie home's backyards. The most important reason for my appeal is because that was what was promised to the Wilkie residents years ago. Wilkie residents have already made sacrifice when they made the initial compromise and in return the Common's agreed to the current building configuration. It would be very disappointing and unethical if the Common's were allowed to renege on their commitment. Another reason is parking issue caused by the Common's visitors and caretakers. Even though on paper the Commons appear to have enough parking space, in reality some of their parking spaces were either hard to reach or blocked, thus actual available parking space is a lot less, thus causing spill over to the Wilkie block, sometimes even as far as Maclane Street after the Common's told people not to park on Wilkie while the discussion is still on going. They need to be held accountable for providing sufficient real/usable parking spaces. In addition, the Common's have been out of compliance for the past many years on other issus, ignoring their legal obligations after they first built their building. They can not be trusted.

The Commons have already profited when the Wilkie residences made the initial compromise , while the Wilkie residents suffered less sunlight in their backyard, less privacy and home value depreciation. It is not right to ask the Wilkie residences to extend their loss of sunlight, privacy and home value even further, while the Common's gain even more profit, breaking their initial commitment to the Wilkie residents.

Sincerely,
Jennie Chan
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From: jenny chen
To: Council, City
Cc: Burt, Patrick; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Stone, Greer; Veenker, Vicki; Kallas, Emily; Lu, George; Lauing, Ed
Subject: The Palo Alto Commons project
Date: Sunday, December 21, 2025 7:48:05 PM
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Dear Mayor and City Council Members,
I am writing on behalf of Wilkie Way residents to respectfully but urgently ask the City Council to approve only the 7 internal units for The Commons project, as recommended by the Planning & Transportation Commission (PTC).

Wilkie Way residents have acted in good faith, with empathy and compromise, even though the historical agreements are clear that no expansion toward the neighborhood should occur at all. In recognition of the need for senior housing and senior-serving facilities, neighbors agreed—reluctantly—to allow 7 internal units as a reasonable compromise. That compromise should be respected and treated as the absolute maximum.

The current proposal relies on outdated 1987 daylight plane rules rather than today’s code.

Allowing this would not only harm our neighborhood, but also set a dangerous precedent for future development citywide. The Commons promised decades ago that it would not expand toward Wilkie Way. Breaking that promise now erodes trust—not just with our neighborhood, but with the community as a whole.

The developer’s shifting claims—from 16 units, to 13, to now asserting that 7 units are “infeasible”—further undermine confidence. This is especially concerning given that rooms reportedly rent for $15,000 per month, and the owner, FJ Management, is a large national corporation. They clearly have the financial capacity to limit expansion to 7 units or build on the El Camino Way side instead of further impacting Wilkie Way.

Residents are already dealing with serious parking and safety issues, including blocked fire lanes, parking spillover onto Wilkie Way, and the loss of parking along El Camino. These impacts will only worsen if more units are added. The Commons is currently out of compliance, which raises serious concerns about whether any future conditions would actually be honored.

Seven internal units are not a starting point—they are the end point.

They represent the maximum compromise neighbors are willing to make, even though no additional units should be allowed under past agreements.

Please hold the developer to today’s code, enforce strong conditions of approval (including meaningful TDM requirements), and honor the commitments made to this neighborhood.

Thank you for standing up for community trust, public safety, and fair governance.

Sincerely,
Jenny Chen
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Wilkie Way Resident
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Dear Members of the City Council
We are writing to express our strong opposition to the proposed expansion of the Palo Alto Commons in its current form and to respectfully request that City Council approve only the 7 internal units, with no external units or office space adjacent to the R-1 neighborhood, consistent with the Planning & Transportation Commission’s (PTC) recommendation.

When this project last came before City Council, you directed the applicant to work with neighbors toward a compromise. After further review, the PTC returned with a strengthened recommendation, approved by a 5–1 vote, to approve the 7 internal units only, along with additional conditions of approval. We strongly support that recommendation and urge Council to uphold it.

Neighborhood History and Good-Faith Compromise
When this project first came before Council, the neighborhood overwhelmingly opposed any additional units, based on a clear and documented compromise made on the public record in 1986 that expressly agreed to no further development on the Wilkie Way side of the property.

Despite this, neighbors repeatedly negotiated in good faith and ultimately accepted 7 internal units as a compromise. The applicant, by contrast, refused to meaningfully engage or reduce the project until the final stages of review, despite repeated requests from both neighbors and the PTC.

A neighborhood petition signed by over 100 individuals (Attachment Q), including residents of The Avant and other WellQuest-managed properties, demonstrates broad, sustained opposition to any external expansion of the Commons.

Failure to Follow Council Direction
Council sent the project back to the PTC with direction to remove third-floor units. However, the proposal that returned to the PTC did not fully remove those units. In addition, during this period, they started illegally parking their bus to block fire lanes. 38+ Years of Noncompliance with Planned Community Ordinance Since approval of its original Planned Community ordinance in 1987 (PC3775, Attachment A), the Commons has failed to comply with multiple conditions of approval. These violations have been raised repeatedly, including before City Council. While the Commons has acknowledged noncompliance, required data and corrective actions have still not been adequately submitted.

Multiple code enforcement requests remain unresolved.

Persistent Parking Violations and Safety Concerns
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Parking violations at the Commons are ongoing, well-documented, and acknowledged even in the applicant’s own consultant parking study. Recent and continuing issues include:
● Blocking of fire access lanes with buses and vans (Attachment M, N) ● Misuse of handicap parking spaces (Attachment C)
● Equipment stored in visitor parking spaces (Attachment B, O) ● Parking in no-parking zones (Attachment D)
● Overflow parking onto public streets (Attachment E)
● Palo Alto Commons bus parked on Wilkie Way (Attachment G) ● Commons vehicles occupying visitor spaces (Attachment H) ● Staff parking in the surrounding neighborhood (Attachment I) ● Therapists and visitors directed by staff to park on Wilkie Way ● Inconsistent or absent valet service (Attachment J)
These violations have continued even after being explicitly raised before both City Council and the PTC. As recently as December 2025, there are still violations (Attachment M, N, O).

Reduced Parking and Future Impacts
Since this project was first proposed, parking has already been removed from El Camino, an area the applicant previously stated should accommodate staff and visitor parking.

Additionally, the City’s 2025 Bike and Pedestrian Transportation Plan proposes removing all parking on El Camino Way. Approving further expansion under these conditions will create a significant parking and safety crisis for the surrounding neighborhood. Attachment P shows how fully parked El Camino Way already is.

These concerns led the PTC to appropriately recommend Transportation Demand Management (TDM) measures with enforcement mechanisms for noncompliance, which we strongly support.

Pattern of Bad-Faith Negotiation
Throughout this process, the applicant has demonstrated a pattern of inconsistent and bad-faith negotiation:
● An initial claim of reducing units from 18 to 16 was accomplished only by converting rooms into offices, without reducing building mass.
● At the May 27 City Council meeting, the applicant stated that any proposal with fewer than 16 units was financially infeasible.
● Subsequently, the applicant stated willingness to build 13 units, then 11 units, while continuing to assert that 7 units “do not pencil out.”
These shifting positions undermine confidence in the applicant’s claims.

Daylight Plane Violations
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As previously discussed, the proposed design continues to violate the daylight plane requirements under PAMC 18.38.150. The code specifies a 3/6 angle with a 10-foot setback for commercial developments. This project qualifies as commercial since it does not meet RHNA housing requirements. Even if it were considered housing, which we dispute, it would require a 20-foot setback at a 45º angle. The current design fails to comply with either standard.

Our Request
We respectfully ask City Council to:
● Uphold the Planning & Transportation Commission’s recommendation ● Approve only the 7 internal units
● Reject all external units and office space adjacent to the R-1 neighborhood ● Adopt and enforce the PTC’s recommended conditions of approval, including TDM requirements with consequences for noncompliance
This approach reflects the maximum compromise offered by the neighborhood, aligns with the PTC’s careful review, and avoids setting a dangerous precedent by relying on outdated municipal code provisions from the time of the original construction.

Thank you for your time, consideration, and commitment to neighborhood safety, trust, and sound planning.

Sincerely,
Jenny Chen
4072 Wilkie Way
Palo Alto, CA
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ATTACHMENT A
PC3775 (Original 1987 PC)
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ATTACHMENT B
Construction Equipment in Parking
Spaces over Several Months
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ATTACHMENT C
Cone Reserving Handicap Spot for Palo
Alto Commons Bus
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ATTACHMENT D
Palo Alto Commons Vehicles Illegally
Parking
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ATTACHMENT E
Illegal Street Parking from Overflow
Visitor Parking
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Parking on El Camino Way on the right side is illegal and only occurs in front of the Palo Alto Commons.

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ATTACHMENT F
1986/1987 Public Meeting Notes
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ATTACHMENT G
Palo Alto Commons Bus on Wilkie
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Attachment H
Palo Alto Commons Vehicles in
Visitor Parking
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ATTACHMENT I
Palo Alto Commons Staff in
Neighborhood
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ATTACHMENT J
Inconsistent Valet
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There is often no one at the valet stand.

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There is often no valet at all.

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ATTACHMENT K
Avant Public Benefit (PC5116)
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ATTACHMENT L
Current Public Benefit
(6/12/24 PTC Packet Page 182)
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ATTACHMENT M
Continued Illegal Bus Parking
(September 2025)
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Van in Fire Lane (August 2025)
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Bus Blocking Fire Access Road (September 2025)
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Bus in ADA Spot with Cones (September 2025)
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ATTACHMENT N
Continued Illegal Fire Lane Parking
(December 2025)
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Bus in Fire Access Road (September, October 2025)
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Vehicles in Fire Access (October 2025)
Palo Alto Commons construction vehicle sin fire lane
Palo Alto Commons Bus in fire lane. It says “Do not block fire gate!” Item 13
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ATTACHMENT O
Continued Illegal Parking Blocked by
Items
(December 2025)
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Items Blocking Parking in Underground Garage (October,
December 2025)
October Photos
December Photo
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ATTACHMENT P
El Camino Way Full of Vehicles
(December 2025)
Only full of vehicles outside of Palo Alto Commons
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ATTACHMENT Q
Signed Neighborhood Petition
(Includes Avant Residents, 100+
residents)
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Dear Chair Akin, Vice Chair Chang, and Members of the Planning Commission, We are writing to express our strong opposition to the proposed expansion of the Palo Alto Commons (the Commons) in its current form. This is now the fourth time the project has come before the Planning & Transportation Commission with only minimal changes, none of which address the fundamental issues that remain. The City Council directed the PTC to work with neighbors toward a compromise, and we continue to believe that the appropriate compromise is to allow the 7 internal units without the 9 external units and 2 offices.

We are providing specific comments on this latest iteration, along with a previously submitted letter to the City Council (attached) that details our concerns more fully.

Daylight Plane Violations
The proposed design continues to violate the daylight plane requirements under PAMC

18.38.150. The code specifies a 3/6 angle with a 10-foot setback for commercial developments. This project qualifies as commercial since it does not meet RHNA housing requirements. Even if it were considered housing—which we dispute—it would require a 20-foot setback at a 45º angle. The current design fails to comply with either standard.

In addition, allowing this project to rely on the outdated 1987 version of the Municipal Code rather than the current code sets a dangerous precedent. Such an interpretation could invite hundreds of projects citywide to claim the right to bypass present-day laws and Council policy. Staff has not fully presented Council with the significant legal consequences of this approach.

Staff has suggested that a 10-foot setback with a 45º daylight plane angle would make the project “consistent,” but this interpretation is inconsistent with the plain reading of PAMC 18.38.150, which falls under “special requirements.” A project cannot be deemed consistent with municipal code while violating its special requirements.

Additionally, the proposed massing conflicts with design standards regarding visual bulk and neighborhood character, violating PAMC 18.16.090(b)(4) and 18.13.060(b)(2)(B), which govern appropriate density transitions and context-sensitive design. There is still space on the front of the building facing El Camino Way to expand without having impacts on the neighbors that the Commons refuses to consider.

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38+ Years of Noncompliance with PC Ordinance
Since approval of its original PC ordinance in 1987 (PC3775), the Commons has failed to comply with its conditions. Even when these violations were raised before the City Council, the Commons acknowledged noncompliance but has still submitted the required data.

Parking Violations and Safety Issues
Parking violations have been persistent and well-documented, including in the consultant’s parking study. Recent issues include blocking fire access with buses and vans (Attachment M), misuse of handicap spaces, equipment stored in visitor spaces, and overflow parking onto public streets. Additional examples include:
● Visitor parking blocked with equipment (Attachment B) ● Misuse of handicap spaces (Attachment C)
● Parking in no-parking zones (Attachment D)
● Overflow onto public streets (Attachment E)
● Palo Alto Commons bus parked on Wilkie (Attachment G) ● Commons vehicles in visitor spaces (Attachment H)
● Commons staff parking in the neighborhood (Attachment I) ● Therapists and visitors directed to park on Wilkie by Commons staff ● Inconsistent valet services (Attachment J)
Violation of Original Agreements with Neighbors
In 1987, the Commons agreed—explicitly, as part of the PC process—to limit density and respect the surrounding R-1 neighborhood. The project was “downzoned to protect the neighbors from over-intrusion” and promised “comparable density and mass” with a “1-2-3 step-up closest to the property line.” The current proposal violates that promise.

Further, while the developers initially claimed they could only build 16 units or none at all due to financial infeasibility, they later admitted 13 units were possible. With unit costs reportedly up to $15,000 per month, it is difficult to believe this project is not financially viable. The Commons is part of FJ Management, a for-profit corporation based in Utah that operates the largest truck stop chain in America. Their shifting claims reflect a continued pattern of misrepresentation and profit-driven motives.

Bad Faith Negotiation Undermining Neighborhood Trust
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Throughout this process, the Commons has demonstrated a pattern of bad-faith negotiation. Initially, they stated they would reduce the number of units from 18 to 16 as a compromise. Instead of modifying the building’s massing, they simply converted two rooms into offices while maintaining the same overall structure.

At the City Council meeting on May 27, the developers claimed that any proposal with fewer than 16 units “did not pencil out.” Yet, in an apparent effort to build more than 7 units, they later stated they would be willing to build 13 units. They maintain that 7 units are financially unfeasible. Given their inconsistent statements, it is difficult to take their claims at face value.

Our Request
We respectfully ask the Planning & Transportation Commission to recommend approval of only the 7 internal units, with no external units or office space adjacent to the R-1 neighborhood. This approach reflects both neighbor feedback and the PTC’s prior recommendation to Council, while avoiding the dangerous precedent of relying on outdated municipal code provisions from the time of the original construction.

Sincerely,
Janis Iourovitski Adrian Lee James Cham Jenny Chen Natalie Choo Lily Lee James Porter Kai Porter Nia Porter Jeffrey Shore Aaron Schultz Michael Ji Minami
Sakakibara
Tirumala
Ranganath
JP Napaa
Jinmei Tian Yanfeng Wang Mingzhuo Pei Barry Katz Cathy
Berwaldt
Maegan Chew Mona He Bill Moss Andie Reed Magdalena
Cabrera
Mircha Panduru Zhengjun Pei Ellen Hartog Susan Kemp Simon Weng Mark Greenbaum Penny Brennan Bert Davies Heather Davies Bella Davies Shashank Divekar Brian Xu Rob Cassin Suchana Costa Natacha Yanling Wang Kaiwen Xu Daniel Pei Xuhao Xie Jennie Chan Pengyi Ji Guizhi You Zhiying Chen Yaofang Zhao Lucy Wu
Devan Singh Batu
Buyukbezci
Edwin Ong Rebecca Sanders Mason
Rodriguez
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Rand
Jayashree Divekar Joanne So Maofeng Lan Esther Lan Hei Chu Lau Carol Gilbert Daniel Hansen DeAnna
Hansen
Julie Baskind Pearl Y
Jagdish Pamnani Iravati Pamnani Eva Dobrov Carol Bly Anne Mason Andy Dobrov Jim Bly Garrett Chan Marty Douglas Zeb
Burke-Conte
Tim Pense Rowan Pense Gordon Pense Adalaide Pense Nikki Pense Tim Zhang Greyson Assa Nick Massie Jen Owens Alex Fu
Freda Huang Eliot Jones Alex Cauthen Carly Davenport Nishanth Salinamakki
Manas Khadka Austin Tang Jetta Chu Gabe Uribe Trent Edwards Peter Chatain Jonathan
Victorino
Kareem
Hage-ali
Paul de Supinski Amantina
Rossi
Syler Peralta-Ramos Celine Wang Yichen Zhou Devan Shanker Akanksha Sharan
Catherine Zhang Eric Tang Tom Tang Ellen Huang
Dear Mayor Lauing and Members of the City Council,
I am writing to express my strong opposition to the proposed expansion of the Palo Alto Commons. This letter outlines serious concerns regarding ongoing code violations and patterns of irresponsible behavior that should be fully considered before any further action is taken. The issues outlined here speak not only to noncompliance with existing agreements, but also to a troubling disregard for neighborhood integrity and public trust.

Illegal Behavior
The Palo Alto Commons has a long history of failing to comply with city regulations and the terms of its original Planned Community (PC) ordinance approved in 1987 (PC-3775). These are not minor oversights—they are foundational requirements meant to safeguard the quality of life for nearby residents and ensure a fair, transparent relationship between developers and the City. Specific violations include:

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● 38+ Years of PC Ordinance Violation: Since its original PC ordinance approved in 1987, the Palo Alto Commons has failed to comply with the requirements set out in the original PC (PC3775, Attachment A) in two fundamental ways. ○ Failure to Prioritize Palo Alto Residents: Section 3(a)(9) of the ordinance clearly states that preference must be given to residents of Palo Alto and their families. This measure was meant to ensure that our community benefits from the services and housing offered. Yet, there is no evidence that the Commons has made any pro-active effort to honor this stipulation in practice.
○ Lack of Required Annual Reporting: Section 3(d) mandates that the operator submit annual reports detailing occupancy levels, staffing patterns, and parking usage. This data is essential for monitoring compliance and assessing community impacts. These reports have not been submitted.
○ Insufficient Parking: Section 3(b)(2) requires a minimum of 55 on-site parking spaces. However, the most recent parking study indicates not all spaces are currently available. This ongoing shortfall directly affects neighborhood congestion and quality of life.
○ No enforcement: Even more troubling is that these violations have been documented in the staff report and in a filed complaint (#16747006), yet no enforcement action has been taken. This lack of accountability erodes public confidence in the City’s oversight mechanisms.
● Parking Violations: The Palo Alto Commons have committed numerous parking related violations:
○ Blocking Visitor Parking with Equipment (Attachment B): Construction and maintenance equipment often blocks designated visitor spaces, including those in the underground garage, further reducing accessibility.

This occurred for several months.
○ Misuse of Handicap Spaces (Attachment C): The Commons’ shuttle routinely occupies handicap spots and reserves them with cones when not in use—an inappropriate and potentially unlawful practice. This has occurred for several months and continues to occur.
○ Parking in No Parking Zones (Attachment D): The shuttle van is frequently seen parked in zones marked for no parking. This behavior, noted even in the parking study, indicates a disregard for basic parking laws.
○ Overflow onto Public Streets (Attachment E): The facility’s lack of adequate parking has forced employees and visitors to park illegally across the street on El Camino Way. Only the Palo Alto Commons has Item 13
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illegal parking in front of it. This is also incredibly dangerous for bikers, as parked cars illegally block the bike lane.
● Municipal Code Violations: The proposed Palo Alto Commons expansion violates the Municipal Code in several ways:
○ Daylight Plane Encroachment: The proposed expansion violates Palo Alto Municipal Code (PAMC) Section 18.38.150, which requires buildings adjacent to R-1 zones to follow a daylight plane to preserve neighbor access to light and air. Ignoring this regulation directly harms adjacent homeowners.
○ Design Incompatibility: The proposal eliminates prior architectural step-backs, which were designed to reduce visual bulk and preserve neighborhood character. This conflicts with PAMC Sections

18.16.090(b)(4) and 18.13.060(b)(2)(B), which govern appropriate density transitions and context-sensitive design.

Bad Neighbor Behavior
Beyond legal violations, the Commons has consistently demonstrated disregard for its residential neighbors and the spirit of community-based planning. Rather than being a cooperative presence, it has become a source of tension due to the following behaviors:
● Abandonment of Original Agreements (Attachment F): The original PC approval was contingent on a lower density design with a step-back architectural transition to respect the surrounding R-1 neighborhood. The proposed expansion disregards these commitments and would impose a larger, more intrusive building on the community. As early as 1978, the El Camino Way area was actually “downzoned to protect the neighbors from over intrusion.” The original developer in 1986 promised that the building would have “comparable density and mass” and proposed a “1-2-3 step-up closest to the property line” as a compromise.
● Persistent Parking Burdens: Since 1986, neighbors have expressed concern over parking shortages caused by the Commons. These issues remain unresolved nearly four decades later:
○ Palo Alto Commons Bus on Wilkie (Attachment G): While the Palo Alto Commons claims to have enough parking on site, their bus will often park on Wilkie.
○ Palo Alto Commons Vehicles in Visitor Parking (Attachment H): When not on Wilkie, the Palo Alto Commons Bus and Van will take up visitor parking, causing visitors to park on nearby streets.
○ Commons Staff Parking in Neighborhood (Attachment I): Numerous residents have observed staff members from the Palo Alto Commons Item 13
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parking along Wilkie Way and adjacent residential streets. Staff are easily identifiable by their uniforms—scrubs and badges bearing the facility’s logo. When approached, some staff have candidly shared that they were instructed by management to park in the neighborhood due to the lack of available spaces on-site. While neighbors are sympathetic to the staff, who are clearly left without sufficient alternatives, the resulting strain on street parking has led to significant disruption and frustration. Residents have also been informed that a dedicated off-site staff parking lot was previously available but has since been eliminated by the operator, further exacerbating the issue.
○ Additional Therapists Parking: Per the Palo Alto Commons’ own parking policy, these people are asked to park on the neighborhood streets. This directly contradicts assurances that parking is sufficient on-site.
○ Visitors Parking: Numerous people we know have told us that they park in our neighborhood to visit the Palo Alto Commons. In fact, when the facility’s own parking contact phone number was dialed, Commons staff used to recommend visitors park on Wilkie. Vice Chair Chang of the PTC had this experience, as described in the 6/12/24 PTC meeting. ○ Misleading Information on Parking: Past presentations to the PTC and ARB claimed underutilization of parking. However, the current parking study reveals that all spaces are already in use. No additional parking is proposed for the new development, compounding the problem. ○ Inconsistent Valet (Attachment J): In the new parking study attached in the staff report, the Palo Alto Commons stated that they have a valet helping reduce parking issues. While valet parking is purportedly offered, in practice the stand is frequently unstaffed. There is also no one depicted on page 4 of the parking study. In addition, most of the time, there is no valet. For example, when Mayor Lauing came to visit, there was no valet. ● Misleading Landscape Information: The ARB asked the Palo Alto Commons to work with the neighbors on the landscaping. Most of the neighbors wanted evergreen trees (one specifically requested Italian cyprus) and have stated this on the record. However, the Palo Alto Commons continues to plan on planting deciduous trees. In addition, their landscape architect told us that Italian cyprus do not grow in this region, even though one neighbor has them in her backyard. ● Diminished Public Benefit: When the project was originally built, the developers made an “in-lieu contribution of $205,200” (Attachment A) in 1987 dollars ($588,688 in 2024 dollars). When building the Avant, the Commons made a $100,000 contribution to Avenidas (Attachment K, PC5116). Yet the public benefit this time is “2 small trees,” “space for both recycling and compost bins,” Item 13
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and “bike parking” (Attachment L). They claim that the primary public benefit is more housing, but this project does not qualify for RHNA housing.

Conclusion
The Palo Alto Commons has repeatedly violated the terms of its original development agreement, ignored City ordinances, and shown disregard for the neighborhood that surrounds it. To approve an expansion under these circumstances would not only reward noncompliance, but it would also set a dangerous precedent for future developments throughout the city.

Our community depends on the integrity of its planning process. If a project fails to honor prior commitments, meet regulatory standards, or respect its neighbors, it should not be allowed to grow further at our expense.

I respectfully urge the City Council to deny the proposed expansion until all existing violations are rectified and meaningful accountability is established.

Sincerely,
Kevin Ji
4072 Wilkie Way
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Dear Chair Akin, Vice Chair Chang, and Members of the Planning Commission, I speak today as a neighbor deeply concerned about the Palo Alto Commons’ ongoing disregard for its residential surroundings. Over nearly four decades, this project has consistently demonstrated a pattern of bad-faith negotiation and behavior that undermines neighborhood trust.

When the original Planned Community (PC) was approved in 1987, the Commons agreed to limit density, respect the surrounding R-1 neighborhood, and provide a step-back design to reduce visual impact. Today, the Commons continues to violate these original commitments, ignoring the conditions that were meant to protect neighbors.

The Commons has repeatedly argued that anything below 16 units financially infeasible, claiming that such a reduction would not “pencil out.” Yet now, they propose 13 units, a clear shift in rationale that raises serious questions about the credibility of their claims. If were misleading about how 13 units are actually feasible, it is unclear why 7 units could not also be built responsibly without violating financial constraints.

Beyond financial claims, they have consistently failed to comply with past agreements and city requirements. Parking continues to spill into neighborhood streets, fire access has been blocked by vehicles, and massing and landscaping decisions ignore prior commitments. Even when violations are documented, enforcement has been limited, and the Commons shows little willingness to address these ongoing issues.

This pattern—claiming constraints to push for more units, violating original PC commitments, and disregarding neighborhood concerns—demonstrates that the Commons is not acting as a responsible neighbor. We ask the Planning Commission to recommend approval of only the 7 internal units, with no additional external units or office space, consistent with prior Commission recommendations and community feedback.

Approving more under these circumstances would reward bad behavior and set a dangerous precedent. Our neighborhood deserves a development that respects both the rules and the people who live here.

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From: michael ji
To: Council, City
Cc: Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki Subject: Request to Enforce Current Code and Limit The Commons Project to 7 Internal Units Date: Sunday, December 21, 2025 7:33:46 PM
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i
Dear Mayor and City Council Members,
I respectfully request that the City Council approve only the 7 internal units for The Commons project, consistent with the Planning & Transportation Commission’s 5–1 recommendation, and enforce strong, measurable conditions of approval.

The current proposal relies on obsolete 1987 daylight plane standards, despite being a new project that should be evaluated under today’s municipal code. Allowing an exception in this case would establish a precedent that undermines the City’s regulatory framework.

Historical agreements from 1986–1987 explicitly committed that The Commons would not expand toward the Wilkie Way neighborhood. From a planning and land-use perspective, this commitment remains relevant. While neighbors could reasonably oppose any additional units, Wilkie Way residents demonstrated good-faith compromise by supporting up to 7 internal units due to the project’s senior-serving use. That compromise should be recognized as the maximum allowable development, not a baseline for further expansion.

The developer’s inconsistent project descriptions—first 16 units, then 13, and now claiming 7 units are infeasible—raise concerns regarding project feasibility claims and credibility. This is particularly notable given the project’s financial context: reported rents of $15,000 per month and ownership by FJ Management, a national corporation with sufficient resources to redesign the project or shift development to the El Camino Way frontage.

The project also presents ongoing compliance and enforcement concerns, including:

Violations of existing Planning Commission ordinances
Use of required parking spaces for construction equipment Parking in fire lanes and overflow parking on Wilkie Way Failure to comply with Council direction to remove all third-floor units when the project was remanded to the PTC
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Given the documented non-compliance, it is reasonable to question whether additional conditions would be followed without strong enforcement mechanisms.

Parking and safety impacts are already significant and will be exacerbated by:

Recent loss of parking along El Camino
Planned removal of parking on El Camino Way
Conclusion:

Approval of only 7 internal units is the most defensible outcome from a policy, legal, and planning standpoint. Any additional units would increase safety risks, worsen parking impacts, violate historical commitments, and weaken the City’s ability to enforce its own code.

I urge the City Council to adopt the PTC’s recommendation, enforce robust TDM requirements with clear consequences, and hold the applicant to both current regulations and past agreements.

Thank you for your consideration.

Sincerely,
Micheal Ji
4072 Wilkie Way
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From: Shashank Divekar
To: Council, City
Cc: Kallas, Emily; Jayashree Divekar
Subject: Palo Alto Commons Expansion - Public Comment
Date: Sunday, December 21, 2025 3:02:22 PM
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i
Dear Members of the City Council,
We (Jayashree and I - residents at 4054 Wilkie Way, Palo Alto, directly behind Palo Alto Commons) are writing to express our strong opposition to the proposed expansion of the Palo Alto Commons in its current form and to respectfully request that City Council approve only the 7 internal units, with no external units or office space adjacent to the R-1 neighborhood, consistent with the Planning & Transportation Commission’s (PTC) recommendation.

When this project last came before City Council, you directed the applicant to work with neighbors toward a compromise. After further review, the PTC returned with a strengthened recommendation, approved by a 5–1 vote, to approve the 7 internal units only, along with additional conditions of approval. We strongly support that recommendation and urge Council to uphold it.

A neighborhood petition signed by over 100 individuals, including residents of The Avant and other WellQuest-managed properties, demonstrates broad, sustained opposition to any external expansion of the Commons.

Our (Neighbors) ask to City Council:

Approve only the 7 internal units recommended by the Planning & Transportation Commission (PTC).

Enforce strong conditions of approval, including Transportation Demand Management (TDM), with real consequences.

Why
Upon City Council's request, PTC carefully reviewed the project and strengthened its recommendation (from 3-2 vote to 5-1) for only 7 units with additional conditions.

Historical agreement (1986) promised no development on the Wilkie Way side; neighbors already compromised by allowing 7
Developer violating existing PC Ordinance and using parking spaces for construction equipment, parking in fire lanes, and causing overflow into nearby streets such as Wilkie This message needs your attention
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The Commons are in non-compliance. Why do we expect them to be in compliance with their proposed expansion?
Developer ignored Council’s direction to remove all third-floor units when the project was sent back to PTC.

Parking and safety problems are serious and will worsen, with the recent loss of parking on El Camino and planned removal on El Camino Way
Rooms cost $15K per month, and the owner, FJ Management, is a large national corporation that can afford to build only 7 units or expand on the El Camino Way side instead.

Daylight Plane Violations
As previously discussed, the proposed design continues to violate the daylight plane requirements under PAMC 18.38.150.

Loss of Property Value : As residents of Palo Alto, a City that prides itself on its robust real estate and premier School District, we are very concerned of the adverse impact on single family home values with the construction of new units at Palo Alto Commons right across from us on the other side of our backyard fence. Our next-door neighbors have sold their house and left.

Bottom line:
7 internal units is the maximum reasonable compromise.

Anything more increases safety risks, parking problems, and breaks past agreements.

Thank you for your time and support.

Sincerely,
Shashank & Jayashree Divekar
(4054 Wilkie Way, Palo Alto, CA 94306
(650)681-7494
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From: Julie Baskind
To: Council, City
Cc: Kallas, Emily
Subject: Palo Alto Commons Project- 1/12/2026
Date: Sunday, December 21, 2025 11:41:02 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Dear CIty Council members:

As a long time resident and neighbor of the Palo Alto Commons, I urge you to:

Approve only the 7 internal units recommended by the Planning & Transportation Commission (PTC).

Enforce strong conditions of approval, including Transportation Demand Management (TDM), with real consequences.

Why
Upon City Council's request, PTC carefully reviewed the project and strengthened its recommendation (from 3-2 vote to 5-1) for only 7 units with additional conditions.

Historical agreement (1986) promised no development on the Wilkie Way side; neighbors already compromised by allowing 7
Developer violating existing PC Ordinance and using parking spaces for construction equipment, parking in fire lanes, and causing overflow into nearby streets such as Wilkie
The Commons are in non-compliance. Why do we expect them to be in compliance with their proposed expansion?
Developer ignored Council’s direction to remove all third-floor units when the project was sent back to PTC.

Parking and safety problems are serious and will worsen, with the recent loss of parking on El Camino and planned removal on El Camino Way Rooms cost $15K per month, and the owner, FJ Management, is a large national corporation that can afford to build only 7 units or expand on the El Camino Way side instead.

Bottom line:
7 internal units is the maximum reasonable compromise.

Anything more increases safety risks, parking problems, and breaks past agreements.

This message needs your attention
Some Recipients have never replied to this person.

This is a personal email address.

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Thank you very much for your consideration.

Julie Baskind
4250 El Camino Real
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From: Planning Commission
To: Lily Lee; Kallas, Emily; Armer, Jennifer; Tavera, Samuel Cc: [email protected]; Planning Commission
Subject: RE: Presentation slides for Lily Lee and Janis Iourovitski PTC Mtg 9/24 public comment Date: Wednesday, September 24, 2025 2:57:53 PM
These presentations have been received. Please note that individually you will have up to 3 minutes to speak (this is subject to change at the discretion of the chair) depending on the number of speakers.

If you each are spokespersons and are representing a group of 5 or more (not including yourself) those individuals must be identified as present at the meeting at the time of the presentation (via zoom or in person). These individuals must agree not to speak individually as they are being represented. And if they are being represented in one group, they cannot be represented in another group. Group speakers may be allowed up to 10 minutes (this is subject to change at the discretion of the chair) depending on the number of speakers.

Please check in with the clerk at the beginning of the meeting or before the item. Thank you! From: Lily Lee <[email protected]>
Sent: Tuesday, September 23, 2025 12:05 AM
To: Kallas, Emily <[email protected]>; Armer, Jennifer <[email protected]>; Tavera, Samuel <[email protected]>
Cc: [email protected]; Planning Commission <[email protected]> Subject: Presentation slides for Lily Lee and Janis Iourovitski PTC Mtg 9/24 public comment CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hello Emily, Jennifer, and Samuel, I and Janis Iourovitski will sign up to present at the 9/24/25 PTC meeting about the 475 El Camino Way project. Here is my presentation: https://docs.google.com/presentation/d/1KAirHTtl1QhG7c18XCwuiZQAMC5R6Yq3Nw_LG3kZYyU/edit?usp=sharing Here ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ i
This message needs your attention
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CGBANNERINDICATOR
Hello Emily, Jennifer, and Samuel,
I and Janis Iourovitski will sign up to present at the 9/24/25 PTC meeting about the 475 El Camino Way project.

Here is my
presentation: https://docs.google.com/presentation/d/1KAirHTtl1QhG7c18XCwuiZQAMC5R6Yq3Nw_LG3kZYy U/edit?usp=sharing
Here is the presentation for
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Janis: https://docs.google.com/presentation/d/1EPW32o0wfXWp6krcVaikhSKDmK9pvA3FNB_W2_s8dc/edit?slide=id.g382113c1b4d_0_0#slide=id.g382113c1b4d_0_0 Please let me know if you have any trouble accessing these slides.

Sincerely,
Lily
650-815-9749
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Comments
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4075 El Camino Way
Palo Alto PTC 9/24/2025
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Historical Context
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Originally Zoned to Protect Neighbors (Council 9/21/87) Item 13
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Developer Respects Neighbors Wishes (Meeting 6/23/86)
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Agreement on Step Back from the Architect (ARB, 7/2/87) Item 13
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Agreement on Step Back from the Architect (ARB, 7/2/87) Item 13
Attachment F - Public Comments
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Daylight Plane
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Palo Alto Municipal Code 18.38.150
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Palo Alto Municipal Code 18.38.150
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Daylight Plane Impacts Diagrams
Commercial:
- 10 ft setback
- 3/6 daylight plane
Residential
- 20 ft setback
- 45 degree daylight plane
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Daylight Plane Impacts in Real Life
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Daylight Plane Impacts in Real Life
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Daylight Plane Impacts in Real Life
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Daylight Plane Impacts in Real Life
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Why is the Existing PC Daylight Plane 10ft 45°
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Grandfathering in 10ft 45°?
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Recommendation
We recommend that the applicant only build the 7 internal units to be in compliance with the current Municipal Code
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Thank You
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4075 El Camino Way
Palo Alto PTC 9/24/25
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Parking
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Parking was Always a Concern (1987)
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Original PC Required Parking to be Reported (1987)
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38+ Years of Non Compliance
● In the 38 years of the original PC, the Commons have never reported the required information
● At City Council, the Commons admitted they never have submitted the information
● Yet, per staff, since that City Council meeting 5 months ago, they have still not submitted the required information
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Current Conditions
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Current Parking Conditions
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Current Parking Conditions
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Bus On Wilkie
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Palo Alto Commons Bus on Wilkie? (Packet Pg 83)
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Palo Alto Commons Bus on Wilkie? (Packet Pg 83)
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Palo Alto Commons Bus on Wilkie? (Packet Pg 83)
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Parking Violations
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Construction Equipment in Parking (Packet Pg 70)
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Construction Equipment in Parking (Packet Pg 70)
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Construction Equipment Underground
● Even the parking study shows that 3 of underground spots are illegally filled with equipment and unusable
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Cone Blocking Spots
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Cones Blocking Parking (Packet Pg 72)
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Cones Blocking Parking (Sep. 2025, Packet Pg 99)
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Inconsistent Valet
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Valet, no Person (Packet Pg 90)
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No Valet (Packet Pg 91)
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Fire Lane Blockage
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Vehicles in Fire Lane (April 2025)
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Vehicles in Fire Lane (June 2025)
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Vehicles in Fire Lane (August 2025, Packet 97)
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Bus in Fire Access Road (Sep. 2025, Packet 97)
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Bus in Fire Access Road (Sep. 2025, Packet 97)
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Firetruck Blocked
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Recommendation: Trust But Verify
We recommend existing parking issues be resolved before the project continues in the process
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Recommendations: Trust But Verify, TDM
We would like to see stronger assessment monitoring and enforcement in the TDM, including:
● 3rd party anonymous surveys of workers and visitors
● 3rd party monthly TDM compliance assessments
● Escalating schedule of penalties for noncompliance
● Assess parking of visitors/staff in the residential neighborhood Item 13
Attachment F - Public Comments
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Thank You
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From: Daniel Hansen
To: Planning Commission; Kallas, Emily
Cc: [email protected]
Subject: Proposed Expansion of Palo Alto Commons at 4075 El Camino Way Date: Wednesday, September 17, 2025 10:15:31 AM
Attachments: Palo Alto Commons Objection Letter.pdf
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i
Dear Members of the Planning and Transportation Commission and Ms. Kallas, Please see the attached letter regarding the proposed expansion of Palo Alto Commons at 4075 El Camino Way.

Best regards,
Daniel Hansen
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Attachment F - Public
Comments
Item 13: Staff Report Pg. 173 Packet Pg. 759 of 1140
VIA E-MAIL ([email protected]; [email protected]) September 17, 2025
Honorable Allen Akin, Chair
and Members of the Planning & Transportation Commission City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Emily Kallas
Senior Planner
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Proposed Expansion of Palo Alto Commons at 4075 El Camino Way Dear Members of the Planning & Transportation Commission and Ms. Kallas:

We are writing in opposition to the expansion of Palo Alto Commons. Although, we do not live on Wilkie Way – we live on Edgewood Drive – we know the feeling of proposed land use changes that could reduce value and enjoyment of our property.

In addition to the arguments of our Wilkie Way neighbors, which we support, we offer these observations:
• Wellquest Living, which operates Palo Alto Commons, is owned by FJ Management, Inc. (FJM). FJM is a huge company based in Utah with billions of dollars in investments, real estate and assets under management, built mainly on petroleum. It can afford to build senior housing in locations other than Palo Alto Commons without adversely impacting residents.
• Wellquest and FJM can also afford to provide direct substantial monetary contributions to the community, like the property owner did in 1987 when Commons was built and in its 2011 expansion.
• Wellquest has provided no financial information supporting its position that less than X units is not feasible (X keeps moving). Palo Alto Commons is described on its website as “Luxury Senior Living” and these units rent from an astonishing $7,000 to $15,000 per month. How can even one additional unit not be profitable? Wellquest should provide full transparency on their financial models and projections, as well as its and FJM’s balance sheets, so feasibility claims can be tested.
• Wellquest, like similar private equity businesses, is driven by profit. We’ve experienced how private equity acquisitions of veterinary and health care clinics have resulted in reduced care and higher costs in our community. The same thing is happening in senior Docusign Envelope ID: 0E532C4C-1EA2-49E1-AD20-11668C588C5E Item 13
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Comments
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Planning & Transportation Commission
September 17, 2025

living care. If this expansion proceeds, in addition to addressing the Wilkie neighbor’s concerns, the City should put in place regulations to ensure high levels of care, such as specified nurse to tenant ratios, and preference for Palo Alto residents.

FJ Management, Inc.

FJM owns Wellquest Living. The “FJ” in FJ Management stands for “Flying J,” the gas stations started in the 1960s by Jay Call. Over time, FJ Management has expanded further into petroleum refining, transportation, solar, hotel management and gas and convenience stations, including the acquisitions of Maveriks and Kum & Go gas and convenience stores, which together have over 800 locations. https://fjmgt.com/about/. FJM is owned by the Maggelet family and run by Crystal Maggelet, Jay Call’s daughter.

Crystal’s advice is: “Do what is best for the business, not what is best for the family.” https://familybusinessmagazine.com/family-offices/family-office-management/helm-crystalmaggelet/ In 2024, FJM’s annual revenue was $7 billion and it ranked #89 on the list of the largest US private companies, according to Forbes. https://www.forbes.com/companies/fj-management/ Wellquest shares the same headquarters address as FJM in Salt Lake City, Utah, with Wellquest located one suite below.

Clearly, Wellquest and FJM can afford to select a different location for their senior living expansion in Palo Alto, one that will not adversely impact neighboring residents.

Wellquest Living, LLC
Wellquest’s CEO, Steve Sandholtz, also serves as managing partner with FJ Capital, LLC, a real estate private equity and development firm, according to his linked in profile. https://www.linkedin.com/in/steve-sandholtz-1828574. Presumably, FJM also owns FJ Capital.

With Palo Alto Commons, Wellquest is the operator and William Reller is the property owner. The arrangement between Wellquest and Mr. Reller is not disclosed. These operating agreements generally come in two flavors: (1) the operator manages the business and takes a percentage of revenue and the owner pays the costs, or (2) the operator manages the business and keeps the profit and pays the owner a lease-type fee. Either way, these agreements are crafted to drive a single goal: increase revenue and profit. Wellquest should disclose its management contract with Reller so the underlying incentives can be understood by the community. For example, does the agreement include tenant care covenants, incentives and conditions? Does it include requirements to follow zoning restrictions and comply with neighborhood agreements? The concern is Palo Alto Commons will suffer the same fate as other businesses acquired and run by private equity. For example, after Adobe Animal Hospital was acquired by Sage Docusign Envelope ID: 0E532C4C-1EA2-49E1-AD20-11668C588C5E Item 13
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Comments
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Planning & Transportation Commission
September 17, 2025

Veterinary Centers (ultimate owner JAB Consumer Partners SCA SICAR, a private equity firm), it shut down the 24-7 hospital, increased service rates and lost experienced veterinarians. 1 Yelp reviews suggest this may already be happening at Palo Alto Commons:

May 13, 2022
“This place has gone downhill quickly ever since it was bought by WellQuest.

It used to be a place where people enjoyed to work and residents enjoyed to live. It's now a dreadful place to work and a place that is lacking in many areas in terms of care for the residents. …”
May 16, 2022
“This community USED TO BE the best senior living in the bay area but since the take over by Well Quest Living and the new director Li Li, it has deteriorated. …”
June 1, 2024
“These place is very unfair and racist, they don't even take the employee side they always listen to one side of the story without both side defend themself.one of the worst care quality plus the have lot of of residence and only two caregivers worst place ever.”
If the expansion of Commons proceeds, in addition to addressing the Wilkie neighbors’ concerns, the city should take steps to ensure care levels are appropriate and maintained, including specified nurse to tenant ratios and preference for Palo Alto residents.

Sincerely,
Daniel Hansen
Jeffrey Shore
1 The FTC has taken action against JAB to prevent further consolidation in veterinary services. https://www.ftc.gov/news-events/news/press-releases/2022/06/ftc-acts-protect-pet-owners-private-equityfirms-anticompetitive-acquisition-veterinaryservices#:~:text=The%20Federal%20Trade%20Commission%20today,Hart%2DScott%2DRodino%20Act.

Docusign Envelope ID: 0E532C4C-1EA2-49E1-AD20-11668C588C5E Item 13
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Comments
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From: Kai Porter
To: Planning Commission
Cc: Kallas, Emily
Subject: Comments on Palo Alto Commons project for 2025-09-17 PTC meeting Date: Wednesday, September 17, 2025 5:38:18 AM
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i
Dear Chair Akin, Vice Chair Chang, and Members of the Planning Commission, I agree with the previous PTC support for 7 internal residential units and opposition to 9 external residential units and 2 offices that face neighbors. I urge you to maintain your position. I have lived since 2005 at 4080 Wilkie Way. I have given public comment, both oral and written many times.

I have previously given detailed comments about the failure of Palo Alto Commons to address parking and congestion meaningfully in its January 5, 2025, TDM plan update. I had urged the City to enforce existing requirements. I have yet to see an updated plan.

After hearing repeated concerns from neighbors, PTC members, Council members, and others, I would have hoped that this private company would improve its practices if it hoped to get positive consideration of its expansion plans from the City Council and PTC. Instead, its own buses and vans keep blocking fire access and handicapped spaces, it stores construction materials and equipment in spaces that are supposed to be for visitors, etc. So even if the plans on paper improved, actual compliance with plans is not happening now every day. I again urge you to work with the City’s code enforcement department and any others responsible for holding this company accountable for following basic requirements that protect the safety of its residents from fire hazards, allow parking for visitors, especially those with disabilities, and that can reduce impacts on the neighbors. Any new TDM should build in even more enforcement measures.

I would like to add that in 1987, the Palo Alto Commons PC ordinance (PC3775) required it to prioritize local residents and to give an annual report on its efforts to do so.

This is not a burdensome requirement. After so many years it has not submitted any required reports. Residents brought this up repeatedly. Yet when we asked a few weeks ago, we discovered that they still have not submitted any report.

How can any of us trust this company? If Palo Alto Commons earns $15,000 per month per unit, then surely it can afford to find solutions to these continuing problems. Only after Palo Alto Commons demonstrates compliance with even basic, simple legal requirements should you consider any expansion proposals. And if you do, then expansion should be limited to 7 interior units and 9 units that face away from Wilkie Way neighbors.

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Attachment F - Public
Comments
Item 13: Staff Report Pg. 177 Packet Pg. 763 of 1140
Sincerely,
Kai Porter
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From: Nia Porter
To: Planning Commission
Cc: Kallas, Emily
Subject: Palo Alto Commons Project Comments
Date: Wednesday, September 17, 2025 2:27:41 AM
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i
Dear Chair Akin, Vice Chair Chang, and Members of the Planning Commission, I have lived at 4080 Wilkie Way, right behind 4075 El Camino Way, since 2007. I have delivered both written and spoken comments at many meetings about this project. Thank you to the previous PTC vote for the compromise proposal of 7 internal units without the 9 external units and 2 offices. I am disappointed that the City Council in May 2025 did not vote to agree with the PTC recommendation.

I and my family have met with Wellquest multiple times to express our concerns.

Wellquest kept saying that they could not afford to reduce the residential units below

16. Yet they said themselves they charge $15,000 per unit per month. Only when faced at the City Council meeting in May 2025 with a vote to agree with the PTC did they talk about going from 16 to 13 backyard-facing residential units. This reversal of position shows they were not completely honest before.

In addition, at the same meeting they already presented using the allotted time on the project that was publicly noticed. The City Council appeared ready to vote to approve only 7 internal units and 9 external. Project representatives should not be allowed to bring up a new different proposal. Yet the City Council let them.

Furthermore Wellquest repeatedly ignores ideas that would not increase costs. For example, neighbors repeatedly requested evergreen trees, and Wellquest repeatedly verbally promised to deliver that. Yet the Cycle 6 plans include Cercis Canadensis, a deciduous species. We encouraged planting mature trees to provide more screening more quickly, but we do not see that commitment in the new plans. Previously Wellquest verbally agreed to paint the back of the building a green color to blend in with trees to reduce its impacts on the neighbors. And yet, if you visit, you will see that the building is painted entirely gray and blue, front and back.

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Comments
Item 13: Staff Report Pg. 179 Packet Pg. 765 of 1140
In these and other ways, this company has repeatedly shown that although they claim to listen, but they just repeatedly make minimal no effort to respond meaningfully. I urge the PTC to vote again to maintain its previous position to only approve 7 interior units and 9 external ones.

Sincerely,
Nia Porter
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Comments
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From: Lily Lee
To: Planning Commission
Cc: Kallas, Emily
Subject: 475 El Camino Way Project - 9/24/25 PTC Mtg Public Comment Date: Wednesday, September 17, 2025 1:47:35 AM
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Dear Chair Akin, Vice Chair Chang, and Members of the Planning Commission, I have lived behind 4075 El Camino Way since 2003. In spite of original commitments, Palo Alto Commons has continued to pursue a project that betrays their original promise to the neighbors for stepdown constructions with smooth transition from residential to commercial and minimizing massing and density, as required by PAMC 18.16.090(b)(4) and 18.13.060(b)(2)(B).

When they reduced residential units from 18 to 16, they then added 2 more offices that were even closer to our back fences without calling attention to that in their summaries or presentations. I only discovered this when I looked closely at the plans.

I feel this switch was misleading. Even though Palo Alto Commons claims that they have reduced the added units to 13, the Cycle 6 new plans online still have those 2 offices. One of these is 10 ft 1 inch from our back fence. Another is 10 ft 9 inches from my neighbor’s back fence.

Furthermore, this project is defined as commercial by the City, and it violates the commercial requirements for a 3/6 angle with 10-foot setback (PAMC 18.38.150).

Even if it could be considered residential, it does not meet the 20 ft set back and 45 degree angle requirements for that.

The City created requirements such as these for new developments for the good of the community as a whole. If anyone can get exceptions any time they want, then these requirements will no longer achieve their original intended purpose, the City acts in an arbitrary and capricious manner, developers no longer have a level playing field, and the community changes in ways that can harm residents.

I would ask the PTC to please continue to support 7 interior residential units and to oppose 9 external residential units and 2 office units that face Wilkie Way backyards.

Thank you,
Lily Lee
4080 Wilkie Way
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From: jenny chen
To: Kallas, Emily
Cc: Planning Commission; Armer, Jennifer
Subject: Public Comment for 9/24 PTC Meeting on Palo Alto Commons (4075 El Camino Way) Date: Tuesday, September 16, 2025 10:30:57 PM
Attachments: 2025_09_24_PTC_Comment.pdf
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i
Hi Emily,
Please include the following public comment in the PTC Packet for the 4075 El Camino Way (Palo Alto Commons) project. This email should include the main comment, and there should be 5 attachments with appendicies in the replies. When you receive this, please confirm that all documents will make it as part of the PTC packet.

Sincerely,
Jenny
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Comments
Item 13: Staff Report Pg. 182 Packet Pg. 768 of 1140
Dear Chair Akin, Vice Chair Chang, and Members of the Planning Commission, We are writing to express our strong opposition to the proposed expansion of the Palo Alto Commons (the Commons) in its current form. This is now the fourth time the project has come before the Planning & Transportation Commission with only minimal changes, none of which address the fundamental issues that remain. The City Council directed the PTC to work with neighbors toward a compromise, and we continue to believe that the appropriate compromise is to allow the 7 internal units without the 9 external units and 2 offices.

We are providing specific comments on this latest iteration, along with a previously submitted letter to the City Council (attached) that details our concerns more fully.

Daylight Plane Violations
The proposed design continues to violate the daylight plane requirements under PAMC

18.38.150. The code specifies a 3/6 angle with a 10-foot setback for commercial developments. This project qualifies as commercial since it does not meet RHNA housing requirements. Even if it were considered housing—which we dispute—it would require a 20-foot setback at a 45º angle. The current design fails to comply with either standard.

In addition, allowing this project to rely on the outdated 1987 version of the Municipal Code rather than the current code sets a dangerous precedent. Such an interpretation could invite hundreds of projects citywide to claim the right to bypass present-day laws and Council policy. Staff has not fully presented Council with the significant legal consequences of this approach.

Staff has suggested that a 10-foot setback with a 45º daylight plane angle would make the project “consistent,” but this interpretation is inconsistent with the plain reading of PAMC 18.38.150, which falls under “special requirements.” A project cannot be deemed consistent with municipal code while violating its special requirements.

Additionally, the proposed massing conflicts with design standards regarding visual bulk and neighborhood character, violating PAMC 18.16.090(b)(4) and 18.13.060(b)(2)(B), which govern appropriate density transitions and context-sensitive design. There is still space on the front of the building facing El Camino Way to expand without having impacts on the neighbors that the Commons refuses to consider. 38+ Years of Noncompliance with PC Ordinance
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Since approval of its original PC ordinance in 1987 (PC3775), the Commons has failed to comply with its conditions. Even when these violations were raised before the City Council, the Commons acknowledged noncompliance but has still submitted the required data.

Parking Violations and Safety Issues
Parking violations have been persistent and well-documented, including in the consultant’s parking study. Recent issues include blocking fire access with buses and vans (Attachment M), misuse of handicap spaces, equipment stored in visitor spaces, and overflow parking onto public streets. Additional examples include:
● Visitor parking blocked with equipment (Attachment B) ● Misuse of handicap spaces (Attachment C)
● Parking in no-parking zones (Attachment D)
● Overflow onto public streets (Attachment E)
● Palo Alto Commons bus parked on Wilkie (Attachment G) ● Commons vehicles in visitor spaces (Attachment H)
● Commons staff parking in the neighborhood (Attachment I) ● Therapists and visitors directed to park on Wilkie by Commons staff ● Inconsistent valet services (Attachment J)
Violation of Original Agreements with Neighbors
In 1987, the Commons agreed—explicitly, as part of the PC process—to limit density and respect the surrounding R-1 neighborhood. The project was “downzoned to protect the neighbors from over-intrusion” and promised “comparable density and mass” with a “1-2-3 step-up closest to the property line.” The current proposal violates that promise.

Further, while the developers initially claimed they could only build 16 units or none at all due to financial infeasibility, they later admitted 13 units were possible. With unit costs reportedly up to $15,000 per month, it is difficult to believe this project is not financially viable. The Commons is part of FJ Management, a for-profit corporation based in Utah that operates the largest truck stop chain in America. Their shifting claims reflect a continued pattern of misrepresentation and profit-driven motives.

Bad Faith Negotiation Undermining Neighborhood Trust
Throughout this process, the Commons has demonstrated a pattern of bad-faith negotiation. Initially, they stated they would reduce the number of units from 18 to 16 as Item 13
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a compromise. Instead of modifying the building’s massing, they simply converted two rooms into offices while maintaining the same overall structure.

At the City Council meeting on May 27, the developers claimed that any proposal with fewer than 16 units “did not pencil out.” Yet, in an apparent effort to build more than 7 units, they later stated they would be willing to build 13 units. They maintain that 7 units are financially unfeasible. Given their inconsistent statements, it is difficult to take their claims at face value.

Our Request
We respectfully ask the Planning & Transportation Commission to recommend approval of only the 7 internal units, with no external units or office space adjacent to the R-1 neighborhood. This approach reflects both neighbor feedback and the PTC’s prior recommendation to Council, while avoiding the dangerous precedent of relying on outdated municipal code provisions from the time of the original construction.

Sincerely,
Janis Iourovitski Adrian Lee James Cham Jenny Chen Natalie Choo Lily Lee James Porter Kai Porter Nia Porter Jeffrey Shore Aaron Schultz Michael Ji Minami
Sakakibara
Tirumala
Ranganath
JP Napaa
Jinmei Tian Yanfeng Wang Mingzhuo Pei Barry Katz Cathy
Berwaldt
Maegan Chew Mona He Bill Moss Andie Reed Magdalena
Cabrera
Mircha Panduru Zhengjun Pei Ellen Hartog Susan Kemp Simon Weng Mark Greenbaum Penny Brennan Bert Davies Heather Davies Bella Davies Shashank Divekar Brian Xu Rob Cassin Suchana Costa Natacha Yanling Wang Kaiwen Xu Daniel Pei Xuhao Xie Jennie Chan Pengyi Ji Guizhi You Zhiying Chen Yaofang Zhao Lucy Wu
Devan Singh Batu
Buyukbezci
Edwin Ong Rebecca Sanders Mason
Rodriguez
Rand
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Jayashree Divekar Joanne So Maofeng Lan Esther Lan Hei Chu Lau Carol Gilbert Daniel Hansen DeAnna
Hansen
Julie Baskind Pearl Y
Jagdish Pamnani Iravati Pamnani Eva Dobrov Carol Bly Anne Mason Andy Dobrov Jim Bly Garrett Chan Marty Douglas Zeb
Burke-Conte
Tim Pense Rowan Pense Gordon Pense Adalaide Pense Nikki Pense Tim Zhang Greyson Assa Nick Massie Jen Owens Alex Fu
Freda Huang Eliot Jones Alex Cauthen Carly Davenport Nishanth Salinamakki
Manas Khadka Austin Tang Jetta Chu Gabe Uribe Trent Edwards Peter Chatain Jonathan
Victorino
Kareem
Hage-ali
Paul de Supinski Amantina
Rossi
Syler Peralta-Ramos Celine Wang Yichen Zhou Devan Shanker Akanksha Sharan
Dear Mayor Lauing and Members of the City Council,
I am writing to express my strong opposition to the proposed expansion of the Palo Alto Commons. This letter outlines serious concerns regarding ongoing code violations and patterns of irresponsible behavior that should be fully considered before any further action is taken. The issues outlined here speak not only to noncompliance with existing agreements, but also to a troubling disregard for neighborhood integrity and public trust.

Illegal Behavior
The Palo Alto Commons has a long history of failing to comply with city regulations and the terms of its original Planned Community (PC) ordinance approved in 1987 (PC-3775). These are not minor oversights—they are foundational requirements meant to safeguard the quality of life for nearby residents and ensure a fair, transparent relationship between developers and the City. Specific violations include:
● 38+ Years of PC Ordinance Violation: Since its original PC ordinance approved in 1987, the Palo Alto Commons has failed to comply with the requirements set out in the original PC (PC3775, Attachment A) in two fundamental ways.

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○ Failure to Prioritize Palo Alto Residents: Section 3(a)(9) of the ordinance clearly states that preference must be given to residents of Palo Alto and their families. This measure was meant to ensure that our community benefits from the services and housing offered. Yet, there is no evidence that the Commons has made any pro-active effort to honor this stipulation in practice.
○ Lack of Required Annual Reporting: Section 3(d) mandates that the operator submit annual reports detailing occupancy levels, staffing patterns, and parking usage. This data is essential for monitoring compliance and assessing community impacts. These reports have not been submitted.
○ Insufficient Parking: Section 3(b)(2) requires a minimum of 55 on-site parking spaces. However, the most recent parking study indicates not all spaces are currently available. This ongoing shortfall directly affects neighborhood congestion and quality of life.
○ No enforcement: Even more troubling is that these violations have been documented in the staff report and in a filed complaint (#16747006), yet no enforcement action has been taken. This lack of accountability erodes public confidence in the City’s oversight mechanisms.
● Parking Violations: The Palo Alto Commons have committed numerous parking related violations:
○ Blocking Visitor Parking with Equipment (Attachment B): Construction and maintenance equipment often blocks designated visitor spaces, including those in the underground garage, further reducing accessibility.

This occurred for several months.
○ Misuse of Handicap Spaces (Attachment C): The Commons’ shuttle routinely occupies handicap spots and reserves them with cones when not in use—an inappropriate and potentially unlawful practice. This has occurred for several months and continues to occur.
○ Parking in No Parking Zones (Attachment D): The shuttle van is frequently seen parked in zones marked for no parking. This behavior, noted even in the parking study, indicates a disregard for basic parking laws.
○ Overflow onto Public Streets (Attachment E): The facility’s lack of adequate parking has forced employees and visitors to park illegally across the street on El Camino Way. Only the Palo Alto Commons has illegal parking in front of it. This is also incredibly dangerous for bikers, as parked cars illegally block the bike lane.
● Municipal Code Violations: The proposed Palo Alto Commons expansion violates the Municipal Code in several ways:

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○ Daylight Plane Encroachment: The proposed expansion violates Palo Alto Municipal Code (PAMC) Section 18.38.150, which requires buildings adjacent to R-1 zones to follow a daylight plane to preserve neighbor access to light and air. Ignoring this regulation directly harms adjacent homeowners.
○ Design Incompatibility: The proposal eliminates prior architectural step-backs, which were designed to reduce visual bulk and preserve neighborhood character. This conflicts with PAMC Sections

18.16.090(b)(4) and 18.13.060(b)(2)(B), which govern appropriate density transitions and context-sensitive design.

Bad Neighbor Behavior
Beyond legal violations, the Commons has consistently demonstrated disregard for its residential neighbors and the spirit of community-based planning. Rather than being a cooperative presence, it has become a source of tension due to the following behaviors:
● Abandonment of Original Agreements (Attachment F): The original PC approval was contingent on a lower density design with a step-back architectural transition to respect the surrounding R-1 neighborhood. The proposed expansion disregards these commitments and would impose a larger, more intrusive building on the community. As early as 1978, the El Camino Way area was actually “downzoned to protect the neighbors from over intrusion.” The original developer in 1986 promised that the building would have “comparable density and mass” and proposed a “1-2-3 step-up closest to the property line” as a compromise.
● Persistent Parking Burdens: Since 1986, neighbors have expressed concern over parking shortages caused by the Commons. These issues remain unresolved nearly four decades later:
○ Palo Alto Commons Bus on Wilkie (Attachment G): While the Palo Alto Commons claims to have enough parking on site, their bus will often park on Wilkie.
○ Palo Alto Commons Vehicles in Visitor Parking (Attachment H): When not on Wilkie, the Palo Alto Commons Bus and Van will take up visitor parking, causing visitors to park on nearby streets.
○ Commons Staff Parking in Neighborhood (Attachment I): Numerous residents have observed staff members from the Palo Alto Commons parking along Wilkie Way and adjacent residential streets. Staff are easily identifiable by their uniforms—scrubs and badges bearing the facility’s logo. When approached, some staff have candidly shared that they were instructed by management to park in the neighborhood due to the lack of Item 13
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available spaces on-site. While neighbors are sympathetic to the staff, who are clearly left without sufficient alternatives, the resulting strain on street parking has led to significant disruption and frustration. Residents have also been informed that a dedicated off-site staff parking lot was previously available but has since been eliminated by the operator, further exacerbating the issue.
○ Additional Therapists Parking: Per the Palo Alto Commons’ own parking policy, these people are asked to park on the neighborhood streets. This directly contradicts assurances that parking is sufficient on-site.
○ Visitors Parking: Numerous people we know have told us that they park in our neighborhood to visit the Palo Alto Commons. In fact, when the facility’s own parking contact phone number was dialed, Commons staff used to recommend visitors park on Wilkie. Vice Chair Chang of the PTC had this experience, as described in the 6/12/24 PTC meeting. ○ Misleading Information on Parking: Past presentations to the PTC and ARB claimed underutilization of parking. However, the current parking study reveals that all spaces are already in use. No additional parking is proposed for the new development, compounding the problem. ○ Inconsistent Valet (Attachment J): In the new parking study attached in the staff report, the Palo Alto Commons stated that they have a valet helping reduce parking issues. While valet parking is purportedly offered, in practice the stand is frequently unstaffed. There is also no one depicted on page 4 of the parking study. In addition, most of the time, there is no valet. For example, when Mayor Lauing came to visit, there was no valet. ● Misleading Landscape Information: The ARB asked the Palo Alto Commons to work with the neighbors on the landscaping. Most of the neighbors wanted evergreen trees (one specifically requested Italian cyprus) and have stated this on the record. However, the Palo Alto Commons continues to plan on planting deciduous trees. In addition, their landscape architect told us that Italian cyprus do not grow in this region, even though one neighbor has them in her backyard. ● Diminished Public Benefit: When the project was originally built, the developers made an “in-lieu contribution of $205,200” (Attachment A) in 1987 dollars ($588,688 in 2024 dollars). When building the Avant, the Commons made a $100,000 contribution to Avenidas (Attachment K, PC5116). Yet the public benefit this time is “2 small trees,” “space for both recycling and compost bins,” and “bike parking” (Attachment L). They claim that the primary public benefit is more housing, but this project does not qualify for RHNA housing.

Conclusion
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The Palo Alto Commons has repeatedly violated the terms of its original development agreement, ignored City ordinances, and shown disregard for the neighborhood that surrounds it. To approve an expansion under these circumstances would not only reward noncompliance, but it would also set a dangerous precedent for future developments throughout the city.

Our community depends on the integrity of its planning process. If a project fails to honor prior commitments, meet regulatory standards, or respect its neighbors, it should not be allowed to grow further at our expense.

I respectfully urge the City Council to deny the proposed expansion until all existing violations are rectified and meaningful accountability is established.

Sincerely,
Kevin Ji
4072 Wilkie Way
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ATTACHMENT A
PC3775 (Original 1987 PC)
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ATTACHMENT B
Construction Equipment in Parking
Spaces over Several Months
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ATTACHMENT C
Cone Reserving Handicap Spot for Palo
Alto Commons Bus
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ATTACHMENT D
Palo Alto Commons Vehicles Illegally
Parking
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ATTACHMENT E
Illegal Street Parking from Overflow
Visitor Parking
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Parking on El Camino Way on the right side is illegal and only occurs in front of the Palo Alto Commons.

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ATTACHMENT F
1986/1987 Public Meeting Notes
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ATTACHMENT G
Palo Alto Commons Bus on Wilkie
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Attachment H
Palo Alto Commons Vehicles in
Visitor Parking
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ATTACHMENT I
Palo Alto Commons Staff in
Neighborhood
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ATTACHMENT J
Inconsistent Valet
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There is often no one at the valet stand.

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There is often no valet at all.

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ATTACHMENT K
Avant Public Benefit (PC5116)
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ATTACHMENT L
Current Public Benefit
(6/12/24 PTC Packet Page 182)
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ATTACHMENT M
Continued Illegal Bus Parking
(September 2025)
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Van in Fire Lane (8/31)
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Bus Blocking Fire Access Road
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Bus in ADA Spot with Cones
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From: Velasquez, Ingrid
To: Lait, Jonathan; Armer, Jennifer; Tran, Vickie; Kallas, Emily Cc: Nose, Kiely; Gaines, Chantal; City Mgr
Subject: FW: 5/27 City Council Palo Alto Commons
Date: Wednesday, May 28, 2025 10:59:52 AM
Attachments: Screenshot 2025-05-27 at 3.03.32 PM.png
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Hello,
Forwarding the comment below for awareness.

Thanks,
Ingrid
Ingrid Velásquez
Administrative Assistant
Office of the City Manager
(650) 329-2354| [email protected]
www.PaloAlto.gov
From: James Porter <[email protected]>
Sent: Tuesday, May 27, 2025 6:44 PM
To: Council, City <[email protected]>
Subject: 5/27 City Council Palo Alto Commons
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear City Council members,
Thank you for taking the time to listen to the concerns of residents in Palo Alto about the Palo Alto Commons a couple weeks ago. I wanted to summarize some of the feedback of the neighbors.

Palo Alto Commons has been and continues to be a bad neighbor. Despite many times issues were raised throughout this process, they have continued to not correct their behavior. As recently as 3 days ago, they are continuing to illegally block parking in their parking lot (see below image).

Only support the 7 interior units per PTC recommendation. While the Palo Alto Commons has failed to uphold their promise from 40 years ago, we acknowledge the need for senior housing in our community. But it should not be on the backs of the neighbors. This compromise allows for more units while having minimal disruptions on the neighbors.

Third Party Assessment of Parking Monthly. The previous PC required annual reporting of staff and visitor parking numbers to the city, but this requirement was never fulfilled. Given this ongoing non-compliance, we are requesting monthly reporting to ensure proper monitoring of their parking operations and adherence to city regulations.

Looking forward to hearing your decision on this issue shortly.

Sincerely,
James Porter, 4080 Wilkie Way
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From: Jean Pressey
To: Council, City
Subject: Palo Alto Commons
Date: Wednesday, May 21, 2025 4:52:45 PM
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i
Dear Mayor and Council,
I attended the hearing on May 5. I was surprised that the objections to the Commons' expansion all sounded the same, as though the neighbors were reading from a script.

And it seemed to be the same script they had used years ago, without recognizing the mitigations that have been made.

The Commons is not owned by an outside profit-making corporation, as you know. These 16 units are badly needed; their location at the rear of the building is due to the need to prevent patients with dementia from wandering.

I am sure that during the construction phase there will be parking and noise, but it is a fact that the value of real estate in Palo Alto simply does not decline.

The neighbors' worry about the latter is misplaced.

I urge you to approve the current 16-unit addition to the Palo Alto Commons.

Sincerely,
Jean Pressey
850 Webster Ave.

Palo Alto
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From: Patty Irish
To: Council, City
Subject: Support for The Commons application
Date: Wednesday, May 21, 2025 3:32:07 PM
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i
Dear Mayor and Council members,
I am Patty Irish and live on Webster in Palo Alto.

I write in support of the application by The Commons for 16 additional needed units for people who need Assisted Living and Skilled Nursing.

I have attended 4 presentations of the project - 2 at Council and 2 at the Planning Commission.

I have heard the owner respond to the requests of the neighbors.

Better parking, windows installed higher, actual building not built to add height and many other things. I believe they have done what they can to make it the best possible.

As we add new projects things will have to change some. And sometimes this even improves the neighborhood.

Please express your support for the quality of what the Rellers do for our community and give them the go ahead so they can get started making these important additions.

The neighbors in most cases were repeating the identical claims each time that ithey made almost 2 years ago. Not taking into account the 4 meetings and changes made on their behalf.

Thank you for all you do. As I watch your work I appreciate all the time and effort it all takes to try to help our City be the best it can be.

Housing and this project are key to our moving forward.

Patty Irish
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Patty Irish
850 Webster St. #628
Palo Alto, CA 94301
650-324-7407
650-245-3906 cell
How do you tell a story that has been told the wrong way for so long? Item 13
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From: Margaret Rosenbloom
To: Council, City
Subject: Palo Alto Commons Senior Housing Expansion Request Date: Wednesday, May 21, 2025 4:25:17 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor and City Councillors
I am writing in support of the proposal to add 16 new units at the back of the existing Commons structure at 4075 El Camino Way.

I was aware of the Commons expansion proposal when it was originally made some years ago and COULD NOT

BELIEVE THAT SUCH A CRITICALLY IMPORTANT BENEFIT FOR PALO ALTO SENIORS WAS STILL UNDER REVIEW.

I attended the Council meeting on May 5th and was appalled to witness first hand a shocking example of the notorious “Palo Alto Way.” I sat for an hour through a tedious procession of complainants, each coming forward to make duplicate points against the proposal. Many of the complaints were outdated, untrue, and unfair. The Wilkie Way residents seemed unaware of or chose to ignore all the accommodations the developer and Commons management have made to minimize their impact on the neighborhood.

For example, the Commons has opened up access to their underground garage, added valet service, and encourage ride sharing for their staff as possible. From the complaints, one would think the Commons is the only business operating in the neighborhood and responsible for every car parked in Wilkie Way. What about Goodwill and all the other businesses along El Camino Way?
The Wilkie Way residents clearly hold you all, City Councillors and Mayor, in utter contempt. They subjected you to a repeat barrage of all the tired old complaints they have made previously. They treated you as heartless imbeciles unaware of the mitigations already made by the Commons and unmindful of the desperate need the City has to accommodate its growing population of care-needing elders. They seemed unaware of the concept that tradeoffs are needed to solve difficult problems around housing.

As an elder myself - happily living in a wonderful senior housing community that provides me with a continuum of care - I am heartbroken at the delay, delay, delay the Commons expansion has been subjected to. The result of further delay will be fewer available spaces for a critical growing need. More elders will be denied the opportunity of moving to housing where they can enjoy the benefits of socialization, and peace of mind that they will get additional care when they need it.

I urge you to speedily finalize your review and approve the Commons expansion project.

Respectfully
Margaret Rosenbloom
850 Webster St
Palo Alto
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From: [email protected]
To: Council, City; Lait, Jonathan
Subject: 4075 El Camino Way
Date: Sunday, May 4, 2025 1:36:32 PM
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!
Dear Mayor Lauing,
Please accept the staff recommendations and approve the additional units.

This is one of many projects, past and future, where council will deal with opposition from neighbors.

One of the complaints raised about 4075 El Camino Way is hypocritical and embarrassing to me.

You will hear from residents, all of whom I believe live in homes built by for profit developers, complain that the proponent here is a for profit entity.

This is a non valid complaint
The more difficult issue is that there may be some inconvenience to some neighbors.

On the one hand residents do have the right to voice their perspective to council.

On the other hand if council either rejected or downsized to make infeasible housing when neighbors complained, we will not get much housing built.

Our history on this is not good as council members know with regard to mixed use, primarily market rate projects, which comprise by far the largest share of housing identified as in
our pipeline.

I will be interested to see how council handles this and upcoming housing projects.

Stephen Levy
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From: Deborah Goldeen
To: Council, City
Subject: Palo Alto Commons
Date: Friday, May 2, 2025 12:36:34 PM
I sympathize with the residents of Wilkie Way who will be negatively impacted by an expansion of Palo Alto Commons. Every time a modest tract home gets torn down in my neighborhood and replaced with a multi-story, 3,500 plus square foot, single family residence, I feel it. It’s awful. But I feel confident in the general understanding that basing decisions on the pretext that property owners have the right to insist that nothing ever changes is not only bad management, but also morally irresponsible.

All the unhappy residents of Wilkie Way plus a cohort of likeminded people will be showing up on Monday to kvetch to the council. I’m sorry I do not have their ear and cannot work to dissuade them taxing the time and patience of the council. But I don’t have to add to the burden. Even though I feel strongly that the Palo Alto Commons should be allowed to proceed without further ado, I won’t address the council in person.

If I had a magic wand, Wilkie Way would be narrowed and the residents could be pacified by the addition of another 250 square feet of property. I know. Not gonna happen and they will suffer, but not as much as the suffering that will result from not allowing Palo Alto Commons a very modest and carefully planned expansion.

Deborah Goldeen, Birch St., 94306
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From: Shashank Divekar
To: Council, City
Cc: Kallas, Emily; Lait, Jonathan; Jayashree Divekar
Subject: Palo Alto Commons - May 5 at Council
Date: Monday, May 5, 2025 6:56:43 PM
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Honorable Council Members,
Thank you for this opportunity. I'm Shashank Divekar, a 20-year resident of 4054 Wilkie Way. Like my neighbors, I support my neighbors’ concerns about Palo Alto Commons expansion that brings traffic and parking problems, loss of privacy in our backyards, loss of quality of life and so on.

Today, I speak from the heart also about our homes—the culmination of our life's work and dreams. This expansion threatens to drastically devalue Wilkie Way properties. My wife and I have poured everything into this house where our children grew up. It's not just our shelter; it's our single largest asset—the financial security we've sacrificed for decades to build. To see it diminished would be to watch our children's inheritance slip away through no fault of our own.

The collective loss we as neighbors face reaches millions. One neighbor has already sold and left, anticipating these changes. With each departure, our community weakens.

We support senior housing but believe there are better solutions. Palo Alto Commons, a for-profit Utah based company, could build the 7 internal units or develop on the front side without devastating our properties. Their profit shouldn't come at the cost of our life savings.

I ask you to help find a balance where Palo Alto Commons can grow while respecting neighbors. Please protect not just our property values, but the legacy we've built for our children and this community.

Thank you,
Shashank Divekar
(4054 Wilkie Way, Palo Alto, CA 94306)
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From: Sharon Hoffman
To: Council, City
Subject: support for Palo Alto Commons
Date: Monday, May 5, 2025 1:27:19 PM
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Dear council members,
I am writing in support of the proposed expansion at Palo Alto Commons. As a longtime Palo Alto homeowner who lives in the shadow of the proposed megadevelopment on Willow Rd, I am certainly sympathetic to the residents on Wilkie Way who are concerned about traffic, noise, and other impacts to their neighborhood. The prospect of significant change to our residential neighborhoods can be unsettling.

However, this particular proposal calls for a mere 16 new units to be built amidst an existing structure in order to better support our community's vulnerable seniors. A NIMBY approach, particularly during a regional housing crisis, does not paint our community in a positive light. I strongly encourage the council to support reasonable efforts -- like this one -- to facilitate complementary new housing wherever possible.

Thank you,
Sharon Hoffman
429 Ruthven Ave
Palo Alto
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From: Neilson Buchanan
To: Shikada, Ed; Council, City; Clerk, City
Cc: Baird, Nathan; Lait, Jonathan; Dave Price; Gennady Sheyner Subject: Palo Alto Commons
Date: Monday, May 5, 2025 12:24:06 PM
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i
There is no doubt in my mind that Palo Alto Commons provides vital, very high quality services. And there is profound need for additiional facilities as our friends and neighbors steadily age duing the next 10-20 years.

Therefore, I urge you to approve the proposed expansion with strong, ENFORCEABLE conditions to monitor the intrusion of all non-resident parked vehicles in nearby residential neighborhoods. The intrusion of parking for non-resident is not limited to Palo Alto Commons. It is a multifactor issue requiring professional planning.

Who has the responsbility to fund and manage the intrusion into residential neighborhoods?
This is a open question becuase neither the Office of Transportation, Planning Department or Police Department has a record of basic stewardship and attention to the Comprehensive Plan which establishes intent to promote commerce but not at the expense of residential neighborhoods.

Only the City Council can set accountability for the Comprehensive Plan and budget resources appropriately.

Neilson Buchanan
155 Bryant Street
Palo Alto, CA 94301
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650 329-0484
650 537-9611 cell
[email protected]
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From: Amie Ashton
To: Council, City
Subject: The Commons
Date: Monday, May 5, 2025 12:11:18 PM
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Honorable Mayor Lauing & City Council,
I am writing in support of The Commons expansion, adding 16 beds for the most infirm of seniors in our community. Putting the beds in a central location allows family members to easily visit and caretakers to easily access. We need more facilities like this in Palo Alto given our rapidly aging population and the tremendous need for the kind of intensive care The Commons provides. Council gave it an initial OK several years ago and it has been slowly moving through the Palo Alto Process ever since.

Staff supports project approval. A daylight plane is included to maintain separation from the property line. The building is overparked for what is required by city code. As much as many of us wish it weren't true, a person or business does not own the street or the street parking spaces as their private property. That space is shared public right of way. How many of us have garages that are unusable for vehicle parking necessitating that we park our cars on the street? I would guess a fair share. Further, until state, federal or local resources are dedicated to the important task of caring for an aging population, we only have private companies to do the work. This is the reality of our political and social situation.

This project is another reason why we need better/updated zoning to facilitate projects we want. PD and PHZ zonings are complicated beasts that do not make for good faith in the public process, something we need to be building to create the city we want.

Our city will have to deal with a lot of changes in the upcoming years. Moving forward with clarity, compromise, compassion, and understanding is how we get the best outcome.

Thank you,
Amie Ashton
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From: Kai Porter
To: Council, City; Kallas, Emily
Subject: Public Comment Item 14, 5/5/35 City Council Mtg Date: Monday, May 5, 2025 3:07:31 PM
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Dear City Council Members,
I have lived at 4080 Wilkie Way since 2005. I walked or biked to school for 6 years.

That has been scary due to the high congestion. I am concerned about increases to the parking congestion and traffic from the new expansion at Palo Alto Commons.

In addition, growing up, I did not like playing in the backyard, because I felt like everyone at Palo Alto Commons was looking down at me. More recently, I discovered that Palo Alto Commons has not followed rules for commercial buildings for daylight plane. That does not surprise me, because our backyard is almost always dark and cold.

I went to multiple meetings with developers and multiple City meetings to hear plans and to explain my experiences. In my previous comments to the Architectural Review Board, I gave many recommendations about the draft transportation demand management plan. I urged the City to enforce compliance better in the future. I do not feel that the developers have taken the neighbors’ concerns seriously. In addition, I agree with all comments submitted already from Kevin Ji.

Please do not reward their bad behavior by approving their current proposal for 16 new residential units and 2 new offices. I recommend the Planning and Transportation Commission (PTC) compromise for Palo Alto Commons to approve the interior 9 living units, disapprove the 7 rear-facing living units, and to move or shrink the 2 offices so they will not be less than 11 feet from our back fence.

Thank you for considering my comments.

Sincerely,
Kai Porter
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From: James Porter
To: Council, City; Kallas, Emily
Subject: May 5, 2025 City Council Agenda Item 14. Palo Alto Commons Expansion Date: Monday, May 5, 2025 2:44:53 PM
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i
Dear Major Lauing and City Council Members,
I have lived at 4080 Wilkie Way in back of Palo Alto Commons since 2003. We bought our house with the understanding that the commons building was "fully mature". I have supported more services for seniors and our neighborhood has already recently absorbed the significant impacts of the Avant project which serves more seniors.

However. I'm writing to express my opposition to the proposed expansion of Palo Alto Commons. I urge the Council to vote against the expansion project in its current form.

The current Palo Alto Commons configuration is quite massive, resulting in significant shading, cooling and loss of privacy in our back yard. Thank you to all the city council members who have visited our backyard to better understand the impacts of the expansion. We are okay with the current configuration as we were able to access this impact before our home purchase. Our appraisals over the years for refinance reflected a significant reduction in value ~$50,000 back in 2011 due to the large structure. We fear the expansion with its abandonment of the step-back design would result in significantly larger loss of value, privacy, light and home utility.

Palo Alto Commons originally committed to a “step-back” design along Wilkie Way to reduce the impact on adjacent residents. This approach was intended to preserve privacy and minimize the sense of mass and scale facing single-family homes. The stepback keeps us from losing all utility and value of our backyard due to the open areas of the structure which allowed some light through.

However, the current expansion plan proposes a near solid wall of construction that fills in the entire stepback area. This is a clear violation of past assurances. We respectfully ask that Palo Alto Commons honor its original promise and keep the step-back design to reduce the negative impact on Wilkie Way residents. I also have significant concerns with daylight plan and understand the new Wilkie-facing units would violate current daylight plan standards which would further devalue property, utility and privacy our Wilkie Way properties.

Both City Council (I believe in pre-screening) and the PTC recommended focusing on adding additional interior units or units on the el camino way side of the property. We have seen no proposals on expanding in these areas which would have far less impact financially, emotionally and otherwise on wilkie way residents. Internal expansion or additional units over the front of the building preserves the step-back design, lowers massing effects and privacy impacts of the project. Furthermore, PTC recommended removal of 2 offices facing the rear which also violated setbacks. No change to the plan was taken there either.

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In conclusion I urge you to vote no on this project unless modifications can be made to lessen the community impact of the project.

Thanks,
James
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From: Nia Porter
To: Council, City; Kallas, Emily
Subject: Palo Alto Commons public comment for May 5 City Council meeting Date: Monday, May 5, 2025 10:00:05 AM
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Dear Mayor Lauing and other City Council Members,
Thank you for visiting my backyard at 4080 Wilkie Way. I have appreciated that you have come to see for yourself what it has been like for me to grow up with the huge Palo Alto Commons building behind me. As a young girl, I have felt that having so many strangers staring at me felt frankly, well, creepy. If they add 16 more units and 2 offices, including one that will be less than 11 feet from my back fence, then our loss of privacy would be that much worse. When I invite friends over to study or celebrate my birthday in the backyard, I have hesitated, because I was worried they would feel the same way.

In school our teachers give us rules that we need to follow for the greater good of the entire classroom or school. I have spoken at multiple City meetings during the development of this project. I have discovered that Palo Alto Commons has not followed the rules for daylight plane, setbacks, reports for prioritizing local residents, parking its construction vehicles and vans, etc. It has also not honestly explained that its staff tell workers and visitors to park in the neighborhood. In addition, I agree with all comments submitted already from Kevin Ji.

Since you are the City Council, you have the authority and responsibility to make Palo Alto Commons follow all the rules, as everyone should, for the benefit of the neighbors in the broader community.

My long-time neighbor and middle school teacher, Mrs. McDaniel, remembers when the company originally promised they would not expand further, and she supported the project to help seniors because of that promise. Now she has moved out because of the expansion plans.

We have talked with the company Wellquest about ways to reduce the impact. I recommended to put more units on the front or to increase the distance of new units from our back fence. Wellquest said that would cost more. I also recommended taller and more dense screening trees. I’m glad that Wellquest finally agreed to plant evergreen instead of deciduous trees behind the fences of neighbors who prefer evergreen. I would still prefer to see taller older trees be planted right away and a greater number of trees. Finally, I recommended that painting the back green, similar to the color of leaves, could allow the building to blend in better. Charlene from Wellquest said to us at a PTC meeting that would be fine. It should not cost Wellquest any extra. But the new plan still shows the back is blue. That seems like such a simple change, so I hope they will consider it.

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Of course, I understand that seniors, such as my grandparents, need to have health care and other services when they are going through difficult times. Therefore, please vote for the Planning and Transportation Commission’s recommendation for Palo Alto Commons to add 9 interior living units, to remove the 7 units on the back of the building, and to move the offices farther from our back fence.

Thank you for reading my comments.

Sincerely,
Nia Porter
Resident of 4080 Wilkie Way since 2007
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From: Leif Erickson
To: Council, City
Cc: Leif Erickson
Subject: Please approve 16-unit expansion for Palo Alto Commons Date: Sunday, May 4, 2025 10:02:05 PM
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Dear Councilmembers,
I usually speak to the Council on behalf of our teens in Palo Alto, but in this case I speak as an advocate for our senior population, and I don't mean high school seniors.

With our population now tipped with more residents over 60 than those under 18, and 20 percent of the city's population now 65 or older, I believe safe and well-serviced senior housing should be one of our community's priorities.

Any decision you make is a balance of trade-offs. What should help you make a choice like approval for the 16-unit expansion at Palo Alto Commons, is this understanding of the growing needs of seniors in our community.

With this goal in mind, to add on to existing housing and services makes more sense than that starting from scratch at another location.

As president of the Palo Alto/University Rotary Club, I have seen the value of the Palo Alto Commons solution for the housing needs of our seniors. Our Rotary Club has had a long relationship with the Commons - one of our members volunteered as a long time board member and one Rotary member is a current resident, with perhaps more headed there in coming years. Recent speakers have shared a broader perspective on the need for a variety of solutions for affordable housing needs in our community.

Some of the Wilkie Way residents raise concerns about parking on their street, but the additional Commons elderly and memory care residents would not be drivers, and staffing increase is only anticipated to be 1-1/2 staff members. With the new El Camino bike lanes removing El Camino street parking city-wide, creative solutions for side street parking will be engaging the attention of City Council and Planning staff in a broader context, rather than project by project.

I appreciate that Commons expansion planners have met four times with neighborhood residents to listen and respond and adapt the plans to respect their requests - again seeking the balance that will best address our broader community.

Please choose to balance your decision with the housing needs of our seniors in mind.

Thank you,
Leif
--
Leif Erickson
cell: 408-406-0005
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From: Andie Reed
To: Council, City
Subject: Palo Alto Commons, 5/5/25
Date: Sunday, May 4, 2025 6:41:47 PM
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Dear Mayor Lauing, Vice Mayor Veenker, and Council Members:

I am Andie Reed and I live in Old Palo Alto, not a direct neighbor of the project, but share the plight. I agree with the Planning and Transportation Commission to limit this expansion to units that don’t infringe on neighbors.

To reiterate, 9 of the 16 proposed units face backyards and windows of Wilkie Way neighbors, who are rightfully incensed that the decreased daylight plane negates their previously hard-won agreements, by in-filling the very light and air and privacy rights that they had previously been assured would be protected.

Please note that these units do not reduce Palo Alto’s housing needs as per our RHNA obligations. This is an assisted living and memory care operation offering a very high-level of care; 3 meals, personal care, general supervision and safety, and social services, recreation and medical access. It’s a business, a highly valuable business, an important niche, but Well-Quest, the owner-operator of both Palo Alto Commons and Avant, also has a goal to make a profit.

I supported a close relative in a similar place for 10 years before she passed away recently, and I can attest to how many employees, contractors, outside services and deliveries come and go daily, not to mention guests and medical support personnel who visit residents. It’s a very busy operation, not a condo complex.

Which leads me to parking. Page 7 states that the “property contains a sufficient number of spaces for the expanded use”, but close neighbors' lived experience and documentation proves, even without expanding, that cars affiliated with the applicant take up available Wilkie Way parking. Palo Alto Commons has a history of non-compliance with their original TDM and Conditions of Approval. The new TDM in this application provides assurance that parking on adjacent streets will be discouraged going forward. I ask you, on what basis do we take this as a likely outcome? Perhaps a more valid analysis would include the whole property; Avant, independent senior housing, shares the same ownership and 2-1/2 acre site with Palo Alto commons. Anyone can use either property's parking spaces. The catch is that only 15 of the total 89 parking spaces are ungated. You have to call the front desk to get into the other 74 spaces behind locked gates. Seriously, most in-and-out services aren’t going to do that; they’ll park anywhere, including adjacent streets.

Additionally, PCs are required to provide a public benefit in return for advantages not otherwise permitted. This expansion is a new addition to the PC, but the applicant is not offering any new public benefit in their request for an expansion, sucking up air and light from their neighbors and exacerbating an already bad parking situation. The report states that merely adding more units is a Public Benefit, but if that were true, why did they provide public benefits originally in 1989 and again in 2011, when the Avant was built? For these reasons, I hope you will strongly consider the PTC alternative that allows growth that doesn’t step on long-time neighbors.

Thank you all for your hard work on behalf of the City of Palo Alto. --
Andie Reed
Palo Alto, CA 94301
530-401-3809
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From: Jennifer
To: Council, City
Subject: Palo Alto Commons
Date: Sunday, May 4, 2025 6:20:19 PM
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Dear Palo Alto Council members,
I would like to express my support for the decision the PTC made on December 2024, and that is NOT approving the units to be built against the backyards of Wilkie Way residents. The current tiered structure was a result of a compromise made 38 years ago between the Common's and the residents. The tiered structure has already caused some loss of sun light and loss of privacy for those residents. Back then the residents agreed to this sacrifice because the Common's had committed to build this way. The same residents could not have imagined 38 years later the Common's would renege on this promise/commitment. The new proposed units would cause the residents to lose most of their sunglights and privacy. This is totally unethical and unacceptable and maybe even illegal, given that this commitment was documented.

In addition, the Common's has been in code violation for the past 38 years. Also they have not provided adequate parking, causing many cars over flowing to the neighborhood. On paper, it may appear that they have sufficient number of parking spaces but in reality those parking spaces are either blocked or difficult to reach, therefore the number of parking spaces is very misleading and grossly overstated. They claimed to have implemented programs to solve the parking issue but when talking to some staff there, they have not heard of such programs. In addition, the Common's claimed to have implemented valet parking, but many times we didn't see a valet person on site.

The Common's is exhibiting signs of offering solutions, but only temporarily, as a method to gain approval for their project and only to renege later once they have achieved their goals.

They can not be trusted. They need to be held responsible for their proposed solutions on a permanent basis and there should be some kind of monitoring and material punishment if they are caught in violation.

Thanks,
Jennifer
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From: Glanckopf, Annette
To: Council, City
Subject: Palo Alto Commons Expansion
Date: Sunday, May 4, 2025 5:01:45 PM
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i
Dear Council Members:

This note is in support of the comments sent by Andie Reed. I ask you to accept the PTC recommendations.

Please scale back the proposed expansion of Palo Alto Commons to 7 units for the following reasons:
* The expansion will violate the set-backs for privacy and air space originally agreed on in the initial plan with onerous consequences for Wilkie Way residents. *The Palo Alto Commons operation has a history of non-compliance with their Conditions of Approval with respect to parking. Cars and transit vans currently spill out to Wilkie Way. Currently the project is under parked, and the proposed project with make it even worse.
* The 13 older homes whose backyards border the operation, have organized and held many meetings with City decision-makers, and have attended ARB and PTC meetings over the past couple of years, and so far, neither the applicant nor City staff is amenable to mitigating these issues.
* The parent company, Well Quest has profit as a goal. This new units proposed by this profit-making organization do not constitute “housing” per Palo Alto Regional Housing Needs Assessment (RHNA) and are not housing for the general public; they are very expensive units providing extensive personal services to their users and PROFIT to the owners..
* This isn't "housing" for the general public but provides a very high level of services at a very dear price.
thanks for considering my comments.

Annette Glanckopf
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From: Furman, Sheri
To: Council, City
Subject: Palo Alto Commons Item 14 on Monday 5: PAN Agrees with PTC Majority Date: Friday, May 2, 2025 5:01:47 PM
May 2, 2025
Subject Line: Palo Alto Commons Item on Monday 5: PAN Agrees with PTC Majority Dear Mayor Lauing, Vice Mayor Veenker and Council Members:

Thank you for your consideration of the impacts to the neighborhood from the proposed Palo Alto Commons expansion. This letter contains our views and those of all the members of PAN who voted to forward this to you at our May 1st meeting.

The question before you is whether Palo Alto Commons, an assisted living and memory care operation, should expand in a manner that takes away the air, light, and privacy of the residents on Wilkie Way. Nine of the 16 additional units proposed for the Commons would overwhelm the backyards and rear window views of these residents. When the project was originally built many years ago, the residents agreed to substantial but limited intrusions – but now that compromise is threatened.

These issues were brought up during the prescreening and at the ARB meetings and the PTC meetings, but the applicant made very minimal changes. The last PTC meeting resulted in a 3-2-2 vote to approve 7 of the 16 additional units and not allow the rear units that would greatly impact the Wilkie neighbors. The PTC pointed out that Palo Alto Commons can still build the additional units by placing them in other locations that would not create new impacts on Wilkie residents.

The 13 older homes whose backyards Palo Alto Commons borders have organized, held many neighborhood meetings and attended ARB and PTC commissions meetings over the past couple of years. Please pay attention to these residents’ concerns.

Also, do not be distracted by claims that reducing the number of units will affect Palo Alto’s housing needs. These units do not constitute “housing” per Palo Alto Regional Housing Needs Assessment (RHNA) and are not housing for the general public.

Rather, they are very expensive units operated by a for-profit entity called Well Quest (the parent company of Palo Alto Commons) and not a local business.

Another critical issue is parking, which frequently overflows from Palo Alto Commons into the adjacent neighborhood. Wilkie residents have provided photos and videos, as well as documented conversations with people who park on their crowded street (employees, service workers, and visitors), that proves Palo Alto Commons’ need for Item 13
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parking vastly overwhelms its onsite spaces. Even the transit vans for Palo Alto Commons often park on Wilkie Way! This incursion will only worsen under the proposed expansion. The very generic TDM associated with this application promises to “discourage” cars from Palo Alto Commons from parking on Wilkie and surrounding streets, but that has not been the case for the past decades. The operation has a history of non-compliance with their Conditions of Approval, per the staff report and the neighbors. You are no doubt aware that it’s unclear which, if any, TDMs in Palo Alto are successful. Please keep that in mind as you deliberate over this project’s proposed TDM and the likelihood it will be observed.

Thank you very much for your attention to these matters Respectfully,
Sheri Furman, PAN Co-Chair
Becky Sanders, PAN Co-Chair
Palo Alto Neighborhoods
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From: Penny Brennan
To: Council, City
Subject: NO on Palo Alto Commons Expansion
Date: Friday, May 2, 2025 2:58:23 PM
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Dear City Council Members,
I urge you to vote NO on Palo Alto Commons Expansion. The proposed project represents a dramatic, further incursion into the backyards and homes of Wilkie Way residents by a for-profit business enterprise located outside of our community. Palo Alto Commons already towers over the backyards of individuals who live on Wilkie Way. It blocks natural sunlight from the trees, gardens, and homes of Wilkie Way residents, intrudes on their privacy, and, as a 24/7 business enterprise, is an ongoing source of noise and nighttime light pollution for them. The proposed Palo Alto Commons Expansion will only exacerbate these conditions.

The proposed expansion will worsen the current parking crisis on Wilkie Way. The crisis has been caused by operation of the Palo Alto Commons business. The cars of Palo Alto Commons residents, visitors, and employees routinely fill available parking spaces on Wilkie Way leaving Wilkie Way residents no way to park in front of their own homes. Associated vehicle and foot traffic render the Wilkie Way homes an island amid the busy Palo Alto Commons business enterprise. Although Palo Alto Commons may claim to have done so, it has not made good faith efforts to effectively address the parking crisis on Wilkie Way. Predictably, the proposed Palo Alto Commons Expansion will make the Willkie Way parking crisis worse, and Palo Alto Commons will do little or nothing to resolve it.

Some claim that the Palo Alto Commons Expansion is beneficial because it adds more housing for health-challenged elders in our community. I note that by virtue of its price-point (which is in line with its web-page branding as "Luxury Senior Living in Palo Alto, California"), and its apparent lack of financial accommodations for low-income elders (such as the HUD-assisted housing program at Lytton Gardens, Palo Alto), Palo Alto Commons is a housing alternative only for wealthy health-challenged elders in our community. Palo Alto Commons' profits from housing these wealthy elders are flowing to WellQuest, a for-profit company headquartered in Salt Lake City, Utah.

WellQuest is investing nothing to promote better health and quality of life of Palo Alto residents.

In closing, please, I urge you to vote NO on the Palo Alto Commons Expansion. The expansion will inflict further harms on Wilkie Way residents, provide housing for only a select few (wealthy) elders, and send profits from care of these elders out of Palo Alto and into the coffers of an out-of-state, for-profit corporation. An expanded Palo Alto Commons will do nothing to give back to the Palo Alto community.

Sincerely,
Penny Brennan, PhD
Ventura Neighborhood
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From: Mona He
To: Council, City
Cc: Kallas, Emily; Lait, Jonathan
Subject: Opposition to Palo Alto Commons Expansion and Objection to the Expansion be Exempt From CEQA Date: Monday, May 5, 2025 1:51:48 AM
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Dear Honorable City Council Members,
My name is Mona He, and I reside at 4040 Wilkie Way. I am writing to express my strong opposition to the proposed expansion of Palo Alto Commons. I respectfully urge the Council to vote against this project in its current form. The expansion, as proposed, is deeply flawed both in process and in substance, and it fails to respect the interests and well-being of the Wilkie Way community.

1. Disregard for Council Guidance and Community Impact
During the August 8, 2023 City Council meeting, Palo Alto Commons was explicitly asked to focus its expansion along El Camino Way to minimize the impact on Wilkie Way residents.

Despite this, the revised plan places most new units along Wilkie Way, citing cost savings.

Prioritizing financial convenience over community livability is unacceptable. Wilkie Way residents should not be forced to absorb the consequences of a corporation’s profit-driven decision-making.

2. Improper Claim of CEQA Exemption
The project’s claim of exemption from the California Environmental Quality Act (CEQA) is inappropriate. Our legal counsel outlined this in a detailed letter submitted to the Planning and Transportation Commission (PTC) on December 9, 2024, which remains applicable as no meaningful changes have been made to the plan. The environmental impacts of this expansion must be thoroughly and transparently reviewed. The letter is attached in this email

3. Dismissal of PTC Recommendations
At its final meeting on December 12, 2024, the PTC recommended that the 9 units along Wilkie Way be removed from the plan. This recommendation was ignored entirely. Such disregard demonstrates not only a lack of respect for the city’s planning process, but also a belief that community and commission input can be bypassed or overridden.

4. Long Standing Pattern of Neglect and Poor Neighborhood Relations Palo Alto Commons has been an inconsiderate neighbor for years. Parking overflow continues to spill onto Wilkie Way, with visitors and employees regularly parking at Wilkie Way. Noise disturbances persist, and the building’s bright blue exterior—despite neighborhood objections —remains visually intrusive. These issues have been raised consistently without meaningful response, eroding community trust.

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5. Unmet Commitments Under Ordinance 3775
The proposed Transportation Demand Management (TDM) measures—such as carpooling and commuter incentives—are not new. They were required under Ordinance 3775, issued on October 26, 1987, and have never been implemented. If existing commitments have been ignored for nearly four decades, how can we trust that new promises will be fulfilled?

6. Ongoing Ordinance Violations and Lack of Transparency The City has received a formal code enforcement complaint (Case ID: 6747006). One of them is regarding violations of Section 3(d), which requires annual reporting on occupancy, staffing, and parking usage. These reports have not been provided since the ordinance was issued for almost forty years. Without reliable data, how can the City determine whether an expansion is warranted or justified? Data-driven decisions require transparency and accountability, both of which are lacking here.

7. Violation of Daylight Plane and Height Regulations
The current proposal violates Palo Alto Municipal Code Section 18.38.150(e) "Sites sharing any lot line with one or more sites in any RE, R-1, R-2, RM or any residential PC district shall be subject to a maximum height established by a daylight plane beginning at a height of ten feet at the applicable side or rear site lines and increasing at a slope of three feet for each six feet of distance from the side or rear site lines until intersecting the height limit otherwise established for the PC district", which governs height restrictions for developments adjacent to residential properties. The planned second and third story units along Wilkie Way exceed the allowable height under the daylight plane requirement, directly impacting our privacy and neighborhood character.

8. Support for Senior Housing—But Not at a few Residents’ Expense I support the City’s commitment to senior housing. However, it is neither fair nor sustainable for Wilkie Way residents to carry the entire burden for this expansion. Palo Alto Commons, as a for-profit corporation with substantial resources, has the means to redesign the project along El Camino Way—even if that comes at a higher cost. Responsible development must consider both community needs and long-term neighborhood integrity.

9. Broken Commitments to Step-Up Design
Palo Alto Commons originally committed to a “step-up” design along Wilkie Way to reduce the impact on adjacent residents. This approach was intended to preserve privacy and minimize the sense of mass and scale facing single-family homes. However, the current expansion plan completely abandons that commitment, instead proposing a solid wall of construction that fills in the entire step-up area. This is a clear violation of past assurances. We respectfully ask that Palo Alto Commons honor its original promise and keep the step-up design to reduce the negative impact on Wilkie Way residents.

In conclusion, this proposal reflects a pattern of disregard for city direction, community feedback, and legal compliance. I respectfully urge the Council to deny this expansion unless Item 13
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the plan is fundamentally restructured to:

Honor prior city and PTC recommendations,
Comply with existing ordinances and environmental review, and Demonstrate genuine accountability and transparency.

Thank you for your attention and for considering the voices of residents most directly impacted by this development.

Sincerely,
Mona He
4040 Wilkie Way
Palo Alto, CA
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J. Randall Toch
408.947.2492
[email protected]
Silicon Valley Office | 55 South Market Street, Suite 900, San Jose, California 95113-2324 phone 408.287.9501 fax 408.287.2583 www.hogefenton.com
December 9, 2024
Via E-Mail only ([email protected]) Honorable Members of the City of Palo Alto
Planning and Transportation Commission
250 Hamilton Ave.

Palo Alto, CA 94301
Re: Meeting Date: December 11, 2024
Agenda Item: 2
Project Description: Proposed Zoning Amendment and
Architectural Approval for Palo Alto Commons
Subject Property: 4075 El Camino Way, Palo Alto, California Report #: 2410-3649
Our Clients: Mona He and Grace (Yan Feng) Wang
Objection to Proposed Categorical Exemption of Project under CEQA Dear Honorable Members of the City of Palo Alto Planning and Transportation Commission:

This law firm represents Mona He and Grace (Yan Feng) Wang who own single story residences on Wilke Way. The residences are adjacent to the real property situated at 4075 El Camino Way, Palo Alto (the “Subject Property”). For the reasons stated in this letter, Ms. He and Ms. Wang object to the proposed categorical exemption of the project under CEQA, and oppose the project itself in its current form.

The project under consideration by the Commission as Agenda Item No. 2 is defined in the staff report for the December 11, 2024 Planning & Transportation Commission Meeting (the “Staff Report”) under the heading “PROJECT DESCRIPTION” as follows: “an amendment to the existing PC Zone District (PC-5116) . . .” (the “Project”).1 I. The Project is a proposed Zoning Amendment which would alter multiple aspects of the City of Palo Alto Municipal Code. (It is not a mere application for a permit to allow minor physical alterations to an existing facility.) The California Environmental Quality Act Requires Environmental Review of Proposed Zoning Amendments. 1 See City of Palo Alto Planning & Transportation Commission Staff Report, Item No. 2, Page 2 of 10 (Packet Pg. 11)
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Honorable Members of the City of Palo Alto Planning
and Transportation Commission
December 9, 2024