City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: March 16, 2026
Report #:2512-5734
TITLE
QUASI-JUDICIAL. 2100-2400 Geng Road [24PLN-00356 & 24PLN-00357]: Request for Approval of Applications for Site and Design, a Conditional Use Permit, and a Vesting Tentative Map to Construct 145 For Sale Townhome Units. Thirteen Percent of the Units Would Be Deed Restricted to Low Income Households. The Project is Proposed in Accordance with Builder’s Remedy (California Government Code Section 65589.5(d)(5)). A Senate Bill 330 Pre-Application was Filed on July 8, 2024. The Project Also Includes Adoption of a Parkland Improvement Ordinance to Authorize Tree Removals in the Baylands Athletic Center, Which Would be Impacted by the Project. CEQA Status: Exempt from CEQA in Accordance with CEQA Guidelines Section 15183 (Comprehensive Plan Consistency).
RECOMMENDATION
Staff Recommends that City Council:
1. Consider the project exempt from CEQA in accordance with CEQA Guidelines Section 15183 (Comprehensive Plan Consistency) as documented in Attachment G;
2. Approve the Site and Design, Conditional Use Permit, and Vesting Tentative Map Applications based on findings and subject to conditions of approval in the Draft Record of Land Use Action (RLUA) in Attachment B; and
3. Adopt the Parkland Improvement Ordinance in Attachment C authorizing the proposed work and modifications in the Baylands Athletic Center within the City’s Baylands open space.
EXECUTIVE SUMMARY
The project proposes 145 townhome units for sale with thirteen percent of the units (19 units) deed restricted to serve low-income households. The residential development would be located on two contiguous parcels located at 2100-2400 Geng Road totaling 480,230 square feet (approximately 11-acres). A Vesting Tentative Map is requested to merge these parcels and
create 145 for-sale condominium units. The project would replace four existing office buildings which are currently occupied by multiple office tenants.
A Parkland Improvement Ordinance would authorize non-native tree removals along the project site’s shared property line with the Baylands Athletic Center, a City owned public recreation facility within the City’s Baylands Nature Preserve, related to grading and construction impacts.
The applicant filed a compliant pre-application in accordance with Senate Bill (SB) 330 on July 8, 2024 (24PLN-00181). Therefore, the project analysis is based on the applicable standards at the time the pre-application was submitted. In addition, the project is considered a “builder’s remedy project” as defined in the recently adopted Assembly Bill (AB) 1893. Accordingly, the project may not be denied on the basis of inconsistency with the Zoning Ordinance or Comprehensive Plan land use designation. The project is further afforded numerous protections by state law, detailed below.
Consistent with Section 15183 of the CEQA Guidelines, the City prepared an Initial Study checklist and determined that the project is consistent with the Certified Environmental Impact Report for the 2030 Comprehensive Plan (SCH #2014052101).
BACKGROUND
The project has undergone multiple public hearings, and the current project plans incorporate feedback from various boards and commissions, described here.
Planning and Transportation Commission (PTC)
In accordance with the Site and Design Review process, the PTC held a public hearing to provide a recommendation on this project on December 10, 2025.1 The PTC recommended approval of the proposed project to Council (7-0), making the following motion:
Recommend approval of the project to City Council based on the findings with an added condition of approval for compliance with the Dark Skies Ordinance and ask that staff:
Work with the applicant to increase the percentage of native trees on-site; and Consider the suggested language changes recommended by Chair Akin and Commissioner Hechtman.2
The landscaping plan has been refined to increase the native plantings. The recommended language changes were incorporated into the RLUA, see Attachment B. 1 December 10, 2025, PTC Staff Report (Agenda Item 2):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84084&dbid=0&repo=PaloAlto&searchid=d35f7bd7 -fd98-43f0-99da-2bb8fe1dab66
2 This related to minor corrections and references in the record of land use action.
Architectural Review Board
On October 16, 2025, the Architectural Review Board (ARB) held an early hearing to provide feedback on the proposed project design. The project applicant addressed most of the ARB comments and returned to the ARB for a formal recommendation on January 15, 2026. A summary of design refinements to address ARB comments is included in the January 15, 2026, staff report.5 The ARB recommended approval of the proposed project to Council (3-0), with Vice Chair Adcock and Board Member Hirsch absent.
Parks and Recreation Commission (PRC)
On December 16, 2025, the PRC reviewed the Draft Parkland Improvement Ordinance for the project related impacts from grading and construction activity to approximately forty-five (45) non-native Blue Gum Eucalyptus (Eucalyptus globulus) trees located on the project’s shared property line with the Baylands Athletic Center, a City owned public recreation facility within the City’s Baylands Nature Preserve.6 The PRC recommended approval of the Park Improvement Ordinance to Council (6-0), with Commissioner Deng absent, making the following motion:
Recommend City Council adopt the Park Improvement Ordinance at Baylands Athletic Center for the Tree Removals associated with the 2100 Geng Road development project, with an addition that staff will provide another finding that includes a City commitment to canopy (Baylands tree species) in the vicinity of the impact.
Staff incorporated this additional finding to ensure the City commits to using the tree replacement funds to replant native trees within the vicinity of the removals, rather than retaining the funds without providing on-site canopy replacement.
Project Description
The proposed project is a request for approval of a Site and Design application, Conditional Use Permit, and Vesting Tentative Map for development of 59 three-story buildings at a height of 42 feet containing 145 for sale townhome units. Thirteen percent of the units (19 units) would be deed restricted to serve households meeting low income or below. The project would replace the four existing office buildings currently located on the project site totaling approximately 192,000 square feet. The vesting tentative map would merge two existing lots to create a single 480,230-square-foot (approximately 11-acre) parcel and subdivide that lot for condominium purposes. A Conditional Use Permit is required for the residential use within the ROLM(E) Zone District. The project site has frontage on Geng Road and an easement connecting to East Bayshore Road. Driveways are proposed at both locations, each providing ingress and egress and emergency vehicle access to the site. Parking would be above-grade parking, with 333 5 January 15, 2026, ARB Staff Report (Agenda Item 2):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85239&dbid=0&repo=PaloAlto 6 December 16, 2025, PRC Staff Report (Agenda Item 4):
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=84149&dbid=0&repo=PaloAlto spaces. Of those spaces, 290 spaces would be provided in the townhome garages (70 tandem spaces) and 43 parking spaces would be provided along the private streets, including 4 accessible spaces. One (1) electrical vehicle parking space would be installed in each garage for the 145 units. Associated site improvements include rooftop amenity spaces, 28,294 sf of common open spaces and 62,108 sf of private open spaces for a total of 90,402 sf of usable open spaces, landscaping, and utility improvements.
The applicant submitted a SB 330 pre-application on July 8, 2024 (24PLN-00181). Therefore, the project analysis is based on the applicable standards at the time the compliant SB 330 pre- application was submitted. The project is also being proposed in accordance with California Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy) and qualifies for additional protections as a “builder’s remedy project,” under AB 1893. The applicant’s project description is provided in Attachment G and includes a list of waivers requested in accordance with State Density Bonus Law. As detailed further in this report, if the project is designed to comply with all relevant objective standards, after application of density bonus incentives, concessions, and waivers, the City cannot impose conditions that would preclude construction of the project as proposed.
Requested Entitlements, Findings, and Purview
The following discretionary applications are being requested and subject to Council purview:
Site and Design Review: The process for evaluating this type of application is set forth in Palo Alto Municipal Code (PAMC) Chapter 18.30(G). Site and Design applications are reviewed by the PTC and ARB, and recommendations are forwarded to the City Council for final action. Site and Design projects are evaluated against specific findings that include both the ARB findings (ARB purview) and Site and Design findings (PTC purview).
All findings must be made in the affirmative to approve the project. Failure to make any one of the findings requires project redesign or denial. Findings for Council to approve this site and design application are provided in Attachment B. Conditional Use Permit (CUP): The process for evaluating this type of application is set forth in PAMC Section 18.77.060. CUP applications are reviewed by staff and the Director will prepare a written decision to approve, approve with conditions, or deny the application based on the Findings set in PAMC Section 18.76.010(c).
Notwithstanding, in accordance with PAMC 18.40.170 the Director may forward the decision to Council. Therefore, the findings for approval of a CUP are included in Attachment B.
Vesting Tentative Map: The process for evaluating this type of application is set forth in Title 21 of the PAMC and California Government Code 66474. The process for approval of a Vesting Tentative Map for a condominium subdivision is outlined in PAMC Sections
21.12.010 and 21.13.020. Vesting Tentative Maps require PTC review. The PTC reviews whether the amended subdivision is consistent with the Subdivision Map Act (in particular, Government Code 66474, Title 21 of the PAMC, the Palo Alto Comprehensive Plan, and other applicable provisions of the PAMC and State law. The PTC’s recommendation is forwarded to the City Council for final approval. Findings for Council to approve the Vesting Tentative Map are provided in Attachment B. Parkland Improvement Ordinance: The process for evaluating this type of application is set forth in Article VIII of the Charter of the City of Palo Alto and PAMC Section
22.08.005. This process requires a recommendation by the Parks and Recreation Commission, which is forwarded to City Council for final action. Council must approve and adopt a plan covering the proposed improvements before any substantial building, construction, reconstruction or development is approved on dedicated parkland. The draft ordinance is provided in Attachment C.
Purview of the formal application is limited by the following State law in the following ways:
Housing Accountability Act (Government Code 65589.5): The project constitutes a “housing development project,” as well as “housing for very low, low-, or moderate income households” under the Housing Accountability Act. The Housing Accountability Act Section 65589.5(d) states that a city cannot deny such a project or impose conditions of approval that would render it infeasible unless it makes specified findings.
Among those findings are: (1) that the project would have a specific, adverse impact upon the public health or safety that cannot be mitigated. Because the project is a “builder’s remedy project,” as defined in AB 1893, the City is further limited to only enforcing those objective standards that exist in a zone district or land use designation that allows the density requested. If there are no such zoning districts or general plan designations in the City, then the applicant may identify any City standards that facilitate the project and only those standards shall apply. If the project meets these identified standards, the City cannot impose conditions of approval that preclude the project from being constructed as proposed by the applicant. Because the project is a “builder’s remedy project,” as defined in AB 1893, the “base density” for purposes of State Density Bonus Law shall be the maximum density permitted for builder’s remedy projects (e.g. three times the density permitted in the zoning code or general plan). The project applicant is also able to utilize incentives, concessions, and waivers under State Density Bonus Law when demonstrating compliance with the enforceable standards.
ANALYSIS
Staff evaluated the project in accordance with the Comprehensive Plan, Zoning Ordinance, and other applicable goals and policies of the City and found the project consistent, or otherwise deviates in a manner permissible under State law.
Consistency with the Comprehensive Plan, Area Plans, and Guidelines The Comprehensive Plan land use designation for the project site is Research/Office Park, which states: "Office, research and manufacturing establishments whose operations are buffered from adjacent residential uses… in some locations, residential and mixed-use projects may also locate in this category. Maximum allowable FAR ranges from 0.3 to 0.5, depending on site conditions. Consistent with the Comprehensive Plan, multifamily housing may be allowed in specific locations.” Because one of the two parcels on the project site is identified as a Housing Inventory site in accordance with the City’s adopted Housing Element, the proposed land use is consistent with the Comprehensive Plan.9
The proposed Vesting Tentative Map is consistent with the Comprehensive Plan, in that the site allows “Multifamily” land uses and will be developed as a multifamily development. The map facilitates the redevelopment of an existing parcel within the City’s urban service area which is consistent Policy L-1.2 of the Comprehensive Plan as well as the Housing Element, as discussed further below.
The project complies with most of the goals and policies set forth in the adopted elements of the Comprehensive Plan, but it does not conform to the maximum floor area ratios. This is permissible under the Builder’s Remedy provisions established in AB 1893, as further detailed in Attachment B. Comprehensive Plan consistency is not a valid basis for denying this project.
Housing Element Consistency
One of the two parcels on which the proposed project would be located is identified as a housing inventory site. The Housing Element site inventory anticipated the development of 175 units on this proposed site at a moderate-income level. The project is a 145-unit development, of which 126 units will be market rate (above-moderate income) and nineteen units (13%) are designated to be provided at below-market rate (BMR) at a rate affordable to low-income households. Because none of the units are provided at moderate income, as anticipated in the Housing Element, approval of this project would result in a shortfall of capacity for moderate income units in the Housing Element sites inventory and this shortfall will likely exceed the City’s “buffer” for that income level. As a result, if the project is approved, the City will likely need to identify alternative sites for moderate income units within 180 days following the approval. It is not unusual for sites to be developed in a manner different from the projections in the site inventory. Staff have begun work on the identification of alternative sites in anticipation of this shortfall.
The development would add new residential units that contribute to the City’s Regional Housing Need Allocation (RHNA), including 19 affordable housing units, consistent with Goal 2 of the Housing Element, which states, “assist in the provision of safe, attainable, and sustainable housing, especially affordable housing, to meet the needs of all economic segments of the community.”
Baylands Master Plan and Bayland Design Guidelines
The project is located within the boundaries of the Baylands Master Plan on the area identified as Private Lands. The project is subject to Site and Design review, as detailed in this report, consistent with the Baylands Master Plan Policy 1 for Private Lands. The project also includes 9 Housing Inventory Site (APN 008-02-035) projected at 175 units at moderate income level. extensive tree planting especially along the perimeter of the property to aid in screening of the new development.
Site Assessment and Design Guidelines
The Site Assessment and Design Guidelines, Palo Alto Baylands Nature Preserve, developed in 2005, are intended to be used when designing or reviewing projects located in any part of the Baylands—including projects on privately-owned land. Conformance with these guidelines ensures compatibility with the special aesthetic qualities and environmental conditions unique to the Baylands. The following design principles are suggested to reflect and preserve the Baylands’ unique landscape character and have been used to review this application:
Use only muted, natural colors. Choose materials and finishes that will weather without degrading.
Preserve the horizon line with low and horizontal elements. Mount fences, enclosures, and identity signs low to the ground. Reduce the size and mounting heights of regulatory sign.
Following the October 16, 2025, ARB meeting, the applicant revised the material palette to utilize natural, muted colors over the previously proposed high contrast dark and light façade colors as recommended by staff and the ARB. The ARB was supportive of the revised color palette as it better reflects and preserves the Baylands’ unique landscape character. No signs are proposed as part of the project. Any future signage would be evaluated in accordance with these guidelines if and when proposed. Therefore, staff finds the project to be consistent with the Site Assessment and Design Guidelines for the Palo Alto Baylands Nature Preserve.
Palo Alto Comprehensive Airport Land Use Plan (CLUP)
The CLUP is intended to protect the general welfare of residents within the areas surrounding airports. The project site is located within the Traffic Pattern Zone, which is routinely overflown by aircraft. However, the potential for aircraft accidents in this area is relatively low and land use restrictions are minimal. Santa Clara County planning staff confirmed that referral to the Santa Clara County Airport Land Use Commission is not required. The proposed 145-unit townhome development complies with the density limits established in the Comprehensive Plan and zoning, and there are no residential unit caps within the Traffic Pattern Zone. The development would also comply with the maximum height limit of 154 feet.
Palo Alto Airport staff provided recommended conditions of approval that the project secure a Determination of No Hazard from the Federal Aviation Administration and the applicant record of an Avigation Easement and Deed Notice with the Vesting Tentative Map to ensure prospective buyers are made aware of the airport's existence and any potential impact that the airport activity has on surrounding land uses. These conditions are reflected in Attachment B.
Zoning Consistency
Attachment D includes a summary of the project’s consistency with applicable zoning development standards, including the base ROLM (E)(D)(AD) standards. Notably, exclusively residential uses in the ROLM(E) District require compliance with the RM-20 development standards found in PAMC Chapter 18.13. Additionally, the project is required to comply with the objective development standards set forth under PAMC Chapter 18.24. While the project is inconsistent with some zoning development standards as identified in Attachment D, the applicant requests waivers to deviate from these standards in a manner that is consistent with the builder’s remedy provisions set forth under AB 1893 and state density bonus law.
Therefore, these inconsistencies are described for informational purposes, but they do not constitute a basis for denial of a builder’s remedy project. The project complies with the objective standards in PAMC Chapter 18.24 applicable to housing development projects within the ROLM(E) Zone District as detailed in Attachment E.
Multi-Modal Access & Parking
Valley Transit Authority (VTA) bus line 81 and ACE transit AE-F line are the nearest bus lines to the project site. The California Avenue Caltrain Station is located approximately 2.2 miles from the project site and nearby bicycle lanes are located on Embarcadero Road.
The project would include above-grade parking, with 333 spaces, exceeding zoning parking requirements. Of those spaces, 290 spaces would be provided in the townhome garages (including 70 tandem spaces) and 43 parking spaces would be provided along the private streets, including four accessible spaces. One electrical vehicle parking space would be installed in each garage for the 145 units. Access to the site would be provided from Geng Road as well as through an existing ingress/egress easement connecting to East Bayshore Road. Long-term bicycle parking is currently shown within each garage totaling 145 bike spaces. A centrally located bike rack on the project site provides 16 short-term bicycle spaces. The project is consistent with both vehicular parking, and long-term and short-term bike parking requirements of the Municipal Code.
Title 8 Consistency (Trees)
Due to the site’s location in a flood zone, the project must elevate grades to meet floodplain requirements, necessitating tree removals on both the project site and adjacent City property.
The Revised Preliminary Arborist Report prepared by HortScience and Bartlett Consulting in August 2025 (Appendix A2 of the Environmental Document) identifies the removal of 218 on- site trees including 83 protected trees, due to low suitability for preservation during construction. An additional 52 off-site trees are identified for removal, including 46 protected trees located on City property at the Baylands Athletic Center. However, staff notes that recent winter storms damaged three trees along the shared property line, necessitating their removal independent of the proposed development. Therefore, although the plans reflect removal of 52 off-site trees, only 49 total off-site trees would now be removed.
To mitigate the impacts of tree removals, the project proposes 648 new trees on-site, with over 50 percent native species, including a substantial proportion of coast live oaks and valley oaks.
These values were increased in response to the PTC’s recommendation to incorporate more native species. Tree replacement values for the project are detailed in the Tree Disposition Table (L 6.1) of the plan set in Attachment H.
The applicant evaluated an alternative site layout to reduce removals on City property.
However, this required shifting development inward that in turn eliminated dwelling units and reduced open space. Removal of this number of trees on City parkland requires approval of a Parkland Improvement Ordinance (PIO). The Parks and Recreation Commission recommended approval of PIO based on the current proposed plans and removal of the 52 trees currently proposed to be removed. The proposed Parkland Improvement Ordinance is included in Attachment C.
Title 16 Consistency (Affordable Housing Requirements)
The applicant requests a concession from PAMC Section 16.65.075(a)(2), which requires BMR units to be reasonably dispersed within residential projects and comparable in bedroom count and size to the average market-rate units. The applicant proposes to provide BMR units only in the row block townhomes and not in the detached townhomes or duplexes. Under State Density Bonus Law, concessions may allow deviations from development standards if the concession would result in cost reductions for the project. The applicant states that including BMR units in the four-bedroom detached townhomes would increase cost and reduce market returns, as these units are intended to be sold at a premium (Attachment G).
Title 21 Consistency (Subdivision Requirements)
Review and approval of a Vesting Tentative Map are governed by PAMC Title 21 and the State Subdivision Map Act (SMA). Except as otherwise provided in Title 21, all provisions, requirements and procedures set forth in the SMA shall be followed. The SMA provides “reverse” findings for map approval (Section 66474 of the Government Code). On December 10, 2025, the PTC recommended that Council approve the Vesting Tentative map, subject to the Conditions of Approval contained in Attachment B.
Private Street Width
The project includes new private streets that do not meet the 32-foot minimum width required in PAMC Section 21.20.240. The applicant requested a waiver under State Density Bonus Law to allow a 26-foot width. The proposed width would still comply with all safety requirements, including, but not limited to, fire safety and traffic safety.
Parkland Dedication
PAMC Chapter 21.50 provides that as a condition of approval of new condominiums or single- family subdivisions in Palo Alto, the City requires that the impact on the Palo Alto parks system be addressed either through dedication of additional parkland, or payment of fees in-lieu of dedication. The required land to be dedicated would be 336 square feet per unit (145) for a total of 48,720 square feet (1.12 acres). The fee is equivalent to the value of the land that the City would otherwise require be dedicated. The square footage required is calculated as specified above. The City uses a default land value of $5.7 million per acre, when calculating fees, but the land value may also be determined by an appraisal of the parcel being developed.
Although the parkland dedication requirement would apply to this site and payment of in-lieu fee as an alternative would typically be subject to Council’s discretion, on-site dedication is not feasible in this case. Providing land would reduce the project’s housing density, which is not permissible under the Builder’s Remedy. Accordingly, the applicant proposes to satisfy this requirement through the payment of in-lieu fees. Parkland Dedication in-lieu fees for the project total approximately $6,372,600.
Application Consistency
As detailed in Attachment B, staff finds that this project meets all required findings for a Site and Design application, Conditional Use Permit, and Vesting Tentative Map and facilitates development of a housing development project that is consistent with the City’s regulations, goals, and policies. Although the project does not comply with all aspects of the Comprehensive Plan and Municipal Code, the project deviates in a manner allowed in accordance with State law.
FISCAL/RESOURCE IMPACT
Processing of this application has limited fiscal impact as applicants are responsible for staff and consultant costs through applicable fees through the deposit-based cost recovery program. The proposed improvements are anticipated to increase the assessed value of the subject property, which will generate additional property tax for the City. Palo Alto receives approximately 9.4% of the additional property tax generated. This project is also subject to Development Impact Fees, currently estimated at $8,306,259.10, which includes the aforementioned Parkland Dedication fees and the Public Art fee.
STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post on March 6, 2026, which is 10 days in advance of the meeting. Postcard mailing occurred on March 4, 2026, which is 12 days in advance of the meeting.
Public Comments
As of the writing of this report, the City has received several comments from interested stakeholders which are included in Attachment F. Overall, most of the comments are inquiries about status updates on the project. One public comment voiced support of the project providing housing for the community.
ENVIRONMENTAL REVIEW
The subject project has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. An Initial Study (IS) Checklist to determine consistency with the Environmental Impact Report (EIR) (State Clearinghouse [SCH] #2014052101) certified in 2017 (“2017 EIR”) for the City of Palo Alto’s 2030 Comprehensive Plan was prepared for the project. Pursuant to CEQA Guidelines section 15183, the IS Checklist found that the Project is consistent with a Community Plan or Zoning with any project related effects substantially mitigated under uniformly applicable development policies or standards, see Attachment H.
The IS Checklist was published on December 3, 2025.
ATTACHMENTS
Attachment A: Location Map
Attachment B: Draft Record of Land Use Action
Attachment C: Draft Parkland Improvement Ordinance
Attachment D: Zoning Consistency
Attachment E: Objective Standards Consistency Analysis
Attachment F: Public Comments
Attachment G: Applicant’s Project Description
Attachment H: Project Plans and Environmental Review
APPROVED BY:
Jonathan Lait, Planning and Development Services Director