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 space s. All units will be offered for -sale with either three- bedroom or four - bedroom 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 S tate 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 tradit ional 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.
2100-2400 Geng Road | Project Description
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 resul t 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. 2100-2400 Geng Road | Project Description
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 S tate 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. 2100-2400 Geng Road | Project Description
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 pull- apart 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 2100-2400 Geng Road | Project Description
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 r equire 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, 2100-2400 Geng Road | Project Description
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 6 th 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, t here 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 s ame 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 ty pology 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 mixed- income 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.