Cities Index.
Item 12 Public Comment

Palo Alto City Council
March 16, 2026

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Item 12 Public Comment
Meeting
March 16, 2026
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Palo Alto City Council
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From: nick grabon
To: Council, City
Subject: Support for new housing near Geng Rd
Date: Monday, March 9, 2026 11:30:46 PM
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i
I am writing in support of new housing near Geng Rd. Housing prices are the dominant source of hardship for people in CA and Palo Alto. Additionally they influence the cost of labor which then makes everything more expensive. Everyone in the community then benefits when housing prices go down.

Nick
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From: James Lloyd
To: Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Council, City
Cc: Clerk, City; City Attorney; City Mgr; PlannerOnDuty Subject: public comment re item 12 for tonight"s Council meeting Date: Monday, March 16, 2026 9:59:28 AM
Attachments: Palo Alto - 2100-2400 Geng Road - HAA Letter - CC.pdf CalHDF v LCF.pdf
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Dear Palo Alto City Council,
The California Housing Defense Fund (“CalHDF”) submits the attached public comment re item 12 for tonight's Council meeting, the proposed 145-unit housing development project at 2100-2400 Geng Road, which includes 19 units affordable to low-income households.

Sincerely,
James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
[email protected]
CalHDF is grant & donation funded
Donate today - https://calhdf.org/donate/
Mar 16, 2026 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]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Cc: [email protected]; [email protected]; [email protected]; [email protected]; Dear Palo Alto City Council, 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

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

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

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).

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

From: Steve Levy
To: Council, City; Lait, Jonathan; Switzer, Steven; Armer, Jennifer Subject: Geng Road project
Date: Sunday, March 15, 2026 8:24:37 PM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Mayor Veekner and council members,
I watched the PTC and ARB hearings and impressed with the benefits of the project and the willingness of the applicant to respond to comments.

Please continue your positive record recently of approving housing consistent with city goals.

These are for sale units mostly large with BMR sale units.

Looking forward to watching from Ventura.

Steve
Sent from my iPad

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