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
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