Cities Index.
Attachment F - Public Comments

Palo Alto City Council
March 16, 2026

Document
Attachment F - Public Comments
Meeting
March 16, 2026
Body
Palo Alto City Council
Original file
719 KB
Text extracted from the city's file for reading and search. Open the original on cityofpaloalto.primegov.com. That file is the official record.

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
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
This is a personal email address.

This is their first mail to some recipients.

Mark Safe Report
Powered by Mimecast
&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
This is their first email to your company.

Mark Safe Report

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
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.

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
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, 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

This message needs your attention
This is their first mail to some recipients.

Mark Safe Report
Powered by Mimecast

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
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:
>> 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]
>

← All documents from this meeting