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
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
Hill
150
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
Dieg
o
(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
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
-----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
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
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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.
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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
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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
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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.
Powered by Mimecast
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
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
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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
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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
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
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Importance: High
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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, 24PLN- 00356. 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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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.
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
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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:
>> 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]
>