City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: March 16, 2026
Report #:2510-5277
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 4075 El Camino Way [23PLN-00202]: Adoption of an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities).
RECOMMENDATION
Staff recommend the City Council take the following actions:
1. Find the project exempt from CEQA in accordance with CEQA Guidelines Section 15301;
2. Adopt the ordinance in Attachment B, amending Planned Community Ordinance 5116; and
3. Approve the Record of Land Use Action in Attachment C based on findings and subject to conditions of approval.
EXECUTIVE SUMMARY
The applicant requests approval of an amendment to Planned Community Ordinance 5116 to allow for the addition of 11 assisted living units at the existing Palo Alto Commons Assisted Living Facility located at 4075 El Camino Way.
Council previously reviewed a 16-unit proposal on May 5, 2025, and remanded the project to the Planning and Transportation Commission (PTC) for further consideration, recommending specific changes including a reduction in the number of units to between 11 and 13 units. The PTC reviewed a revised project that included 13 units, and recommended approval, with the recommendation that the project be reduced to add only seven units to the existing facility.
In response to the PTC review, the applicant has revised the project to propose an 11-unit addition. Additional items requested by Council and the PTC have also been addressed or otherwise included in the conditions of approval, as appropriate. These modifications help to
address some of the adjacent neighborhood residents’ expressed concerns related to privacy and operations. Therefore, staff recommend approval of the revised project, as currently proposed, and consistent with Council’s motion to explore an 11- to 13-unit project.
Adjacent residents have commented extensively on the proposed project throughout the process, as summarized below.
BACKGROUND
Palo Alto Commons, a 121-unit Assisted Living facility, was originally approved in 1987 as a Planned Community (PC) project under Ordinance 3775. In 2011, the Avant Independent Senior Living building was added through Ordinance 5116, which incorporated Ordinance 3775 by reference.1
Previous Council Review
On May 5, 2025,2 Council considered a proposed PC Amendment for a 16-unit addition with 172 square feet of additional support space. At the public hearing, 35 members of the public provided comments. Council continued the hearing for further deliberation to May 27, 2025. At this meeting, Council discussed prioritizing enforcement of the TDM plan (Attachment G), repairing the relationship between Palo Alto Commons and the neighborhood, and considering the PTC recommendation. Council made the following motion:
Refer this project back to the Planning and Transportation Commission for a review of a project between 11 to 13 units that would eliminate the 3rd floor units adjacent to Wilkie Way backyards.
The motion passed 4-3 (Councilmembers Reckdahl, Lauing, and Stone dissenting).
Councilmembers Reckdahl and Lauing spoke to their dissent, indicating that they believe even the motion’s proposed reduction would not sufficiently address neighbor concerns. Mayor Stone spoke to his dissent, indicating that he did not want to lengthen the review process and supported a previous motion that did not pass, which would have approved a project consistent with the PTC’s initial recommendation of seven additional units.
PTC Review
Following the Council hearing, the applicant revised the project to include the addition of 13 units instead of the previously proposed 16 units. PTC held a public hearing to consider the 1 Ordinance 3775: https://portal.laserfiche.com/Portal/DocView.aspx?id=104198&repo=r-704298fc; Ordinance 5116: https://portal.laserfiche.com/Portal/DocView.aspx?id=2179&repo=r-704298fc 2 May 5, 2025 Council report:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=6085&dbid=0&repo=PaloAlto revised design on September 24, 2025.5 At the hearing, several commissioners continued to express concerns, consistent with their prior motion, that the revised design did not sufficiently address impacts to neighboring residents. The PTC recommended approval of the project, with the proposed conditions, and with the following modifications:
Allow the addition of only seven units (units labeled 1-4 and 9-11), consistent with their December 2024 recommendation.
To not allow the proposed 172 square feet of ground floor office spaces. Require annual monitoring of conditions and public benefits, specifically including Section 3D of the original PC Ordinance 3775 (including an annual report of occupancy, vacancy status, number and age of occupants, number of employees, residents and employees who would use parking spaces and a copy of a renewal license for residential care facility).
Strike the language in Section 3, Finding 2, that referred to the old benefits from the original PC (specifically regarding bus improvements and prior payment benefits). Add a condition of approval that staff must park on-site, or off-site in private/paid parking and arrive by shuttle if spaces are not available (during construction and after as necessary to prevent spillover parking in the neighborhood). Include an appendix to the TDM plan that incorporates the proposed Parking Plan which may include specific requirements such as a valet with operating hours, and a plan to provide 986 parking spaces at all times, on-site or off-site with consequences for non- compliance.
This motion passed 5-1-1 (Hechtman dissenting, Ji recused). Hechtman spoke to his dissent, stating that he would prefer to see 11 units be approved, rather than only seven. However, he agreed with the other Commissioners that a two-story addition is better for the neighborhood context, and agreed that monitoring and regulating parking, construction logistics, and the TDM plan are a priority for this project.
ANALYSIS
Staff has reviewed the modified design and finds it generally consistent with relevant adopted plans, policies, and goals for the City. Staff also finds that the proposed project has been modified to balance expressed neighborhood concerns, as described below, while also adding senior assisted living units, consistent with several goals and policies set forth in the Comprehensive Plan, as described further in Attachment B. Staff’s recommendation differs 5 September 24, 2025 PTC report:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=7677&dbid=0&repo=PaloAlto 6 The reference to 98 spaces appears to have been an error as the intent was to require all of the parking spaces on site to remain and be available at all times. There are 97 existing spaces on site, 96 of which were required under the existing planned community zone district. The proposed ordinance reflects a requirement to maintain all 97 parking spaces.
from the PTC’s recommendation based on Council’s express direction to return with an 11 to 13 unit project. However, Council in its discretion may choose to support a reduced project, consistent with the PTC’s motion, or move forward with additional modifications, or denial based on specific findings.
Response to Prior Feedback
In response to feedback from the Council and PTC, the applicant revised the plans and project materials to:
Reduce the number of proposed units to 11, consisting of one new third-floor unit facing internally toward the Avant (and not Wilkie Way), seven new second-floor units, and three new first-floor units;
Eliminate the previously proposed 172 square feet of office space; Respond to neighbor’s expressed concerns regarding parking on residential streets by identifying a designated location for van parking when the facility’s van is not in use and by clearing three additional spaces on site to provide a total of 97 on-site parking spaces, one more than the 96 required in accordance with the existing PC; Include the required annual report in accordance with existing PC requirements (Attachment D) and implement commuter benefits as part of a Transportation Demand Management (TDM) plan; and
Respond to neighbor comments regarding the color scheme by revising the façade facing neighboring properties to green, while maintaining the ARB-recommended blue, cream, and gray color scheme on the remaining building elevations.
Although the project provides 11 units instead of the seven units that the PTC recommended, staff believes that the applicant has revised their plans to address most of the PTC’s recommendations and in alignment with the Council’s motion to explore an 11 to 13 unit project that minimizes impacts to the neighbors. Updates have also been made to the draft PC Ordinance (Attachment B) and Record of Land Use Action (RLUA) (Attachment C) to respond to PTC recommendations. Specifically, RLUA Section 3, Finding 2 removes reference to the old benefits from the original PC and a condition of approval has been added to address the recommended modifications to the TDM plan. The ordinance was also updated to reflect the most recent plans, which excludes the support space, and to incorporate modifications to the TDM plan.
The current plans utilize both the ARB-recommended color scheme, and a modified version of the existing color scheme. Neighbors, as well as some Council and PTC members, mentioned preferring the existing building’s green color. In response, the main portions of the façade facing Wilkie Way are now green, but the green was not incorporated on any other sides of the building. While this change to one façade of the building on the plans is intended to be responsive to adjacent residents, staff notes it differs from the rest of the building, which was recently painted in a blue, grey, and cream color scheme.
Parking and Transportation Demand Management Plan
On a recent site inspection, staff observed 94 usable spaces, and three spaces that were blocked off as storage areas and were therefore unusable. Although three parking spaces in the garage were unavailable, the number of available spaces was only two fewer than the 96 required spaces per the existing PC (41 spaces for The Avant and 55 spaces for Palo Alto Commons). Materials being stored in the three additional parking spaces have since been moved to accommodate a total of 97 on-site parking spaces. The proposed ordinance has been updated to require the applicant to maintain these 97 parking spaces on site.
Table 1: Palo Alto Commons and The Avant Parking
Required by PAMC
18.52 Required by PC 3775
and PC 5116
Observed Useable
Spaces
Palo Alto Commons 54 spaces 55 spaces 54 spaces
The Avant 33 spaces 41 spaces 40 spaces
Note: ADA spaces were not counted twice for the purpose of this table.
Staff also observed that the valet service was operational, consistent with the proposed parking plan, and parking spaces were available in both garages, including on both sides of the Palo Alto Commons gate. The applicant states the valet is available between 8:30 a.m. and 4:30 p.m.
Monday through Friday. The applicant has noted that these hours were intentionally designated to support peak activity periods, when residents, family members, healthcare providers, and guests are most frequently arriving and departing.
Shuttle Van Parking
Palo Alto Commons owns a shuttle van used to provide rides to its residents. The van did not have a designated location to park on site. Palo Alto Commons has now arranged to park the van at the Congregation Etz Chayim at 4161 Alma, approximately one mile from the site. While this is less desirable than an on-site location, the van does not fit into a standard parking space and there was not a feasible option on site to park the van without reducing parking or removing a tree. The van was observed at this off-site location as a part of the inspection and fit into the parking space on that site. As of 2023, Congregation Etz Chayim has 130 parking spaces, 120 of which are required under the PAMC, therefore, allowing the use of one space for this van would be allowed. Condition of approval #14 has been added to require recordation of a shared parking agreement to ensure that this off-site space remains available for the van.
When the van is on-site it is in active use and would load allow passengers to load in the designated non-red-curbed area near the site entrance.
Construction Logistics Plan
As a condition of approval, a construction logistics plan is required to handle construction staging and related impacts. The construction logistics plan is expected to provide a parking plan for construction-related equipment and vehicles in addition to other standard requirements such as deliveries, materials storage, and other items that may impact surrounding neighbors, including dust and noise mitigation. The Public Works Engineering standard condition of approval is included in the Record of Land Use Action and has been modified to Council and PTC’s additional concerns regarding employee parking during construction. While the applicant has not yet provided the construction logistics plan, they have indicated that they have already started discussions with their general contractor to identify a nearby off-site location for construction staging to ensure that on-site parking remains available for the ongoing operational use of the site, such as employee parking.
FISCAL/RESOURCE IMPACT
The processing of this application has no fiscal impact, as applicants are responsible for staff and consultant costs through applicable fees through the deposit-based cost recovery program.
The proposed addition requires payment of development impact fees, which are currently estimated at $221,554.18.
STAKEHOLDER ENGAGEMENT
All previously submitted written comments on this project are included in Attachment E. In general, the key concerns raised include:
• Loss of privacy
• Reduced access to natural sunlight
• Insufficient parking
• Opposition to any zoning code exceptions for the proposed addition • Concern that WellQuest, as a for-profit entity, does not prioritize the interests of neighboring residents
• Potential negative impacts on property values and overall quality of life • Questions about compliance with conditions of approval included in PC-3775 The City has encouraged the applicant to maintain open communication with the neighbors and requested that the applicant provide an update on the most recent plan modifications in advance of this Council hearing. Staff is not aware of any additional communication that has occurred between the applicant and adjacent neighbors except that the applicant provided the City with a flier related to commuter benefits and off-site parking improvements they have started implementing and stated an intent to send to neighboring residents. At the time of publication of this report, the applicant had not confirmed that this flier had been sent.
However, the applicant has made modifications to their plans in response to neighbor comments, such as eliminating third floor units facing neighbors, in addition to modifying their operations to address some of the expressed concerns raised by residents regarding ongoing operations, particularly those related to parking and compliance with existing conditions.
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. The City, acting as the lead agency, has determined that the project is exempt from CEQA in accordance with CEQA Guidelines Section 15301 (existing facilities). Attachment F summarizes the project’s eligibility for a Class 1 exemption and why none of the exceptions to the exemptions apply to this project.
ATTACHMENTS
Attachment A: Location Map
Attachment B: 4075 El Camino Ordinance
Attachment C: Draft Record of Land Use Action
Attachment D: Applicant Project Description Letter and Annual Report Attachment E: Zoning Comparison
Attachment F: Public Comments
Attachment G: Project Plans, TDM Plan, and Environmental Documents APPROVED BY:
Jonathan Lait, Planning and Development Services Director