Agenda packet — Palo Alto City Council, April 13, 2026 (part 2 of 2)

Objective Design Standards Checklist
The Objective Design Standards Checklist is a tool to evaluate a project’s compliance with the Zoning Ordinance (Chapter 18.24). The Checklist is not the Zoning Ordinance. Applicants shall be responsible for meeting the standards in the Zoning Ordinance. To simplify evaluation of the Zoning Ordinance, language in the Checklist may vary from the Zoning Ordinance. (Note: sf = square feet) If a standard is not applicable to applicant’s project, please write N/A in Applicant’s Justification column.

18.24.020 Public Realm/Sidewalk Character
Check Standard Sheet # Notes
(b)(1) Sidewalk Widths
(A) In the following districts, public sidewalk width (curb to back of walk) is at least:
Commercial Mixed-Use District: CN, CS, CC, CC(2), CD-C, CD-S, CD-N, PTOD: 10 ft El Camino Real: 12 ft
San Antonio Road, from Middlefield Road to East Charleston Road: 12 ft And consists of:

AP1.00
Complies.
2 feet 6 inches foot Public
Access Easement on El Camino
Real – to create an effective 12-
foot sidewalk
Pedestrian clear path width of 8 foot minimum: 12 feet ☐
Landscape or furniture area width of 2 foot minimum: 11.5 feet ☐
If the existing public sidewalk does not meet the minimum standard, a publicly accessible extension of the sidewalk, with corresponding public access easement, shall be provided.
☐
(B) Public sidewalks or walkways connecting through a development parcel (e.g. on a through lot with a public access easement, leading to a commercial entry) must be at least 6 feet wide.

(C) The width of walkways designed to provide bicycle access (e.g. pathway to bike racks/lockers) must be at least 12 feet wide, consisting of: AP1.00 Complies.
2 feet 6 inches foot Public
Access Easement on El Camino
Real – to create an effective 12-
foot sidewalk
☒
Pedestrian clear path width (8 feet min.): 8 ft
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Clear space/buffer – (2 feet min. on each side of path, ground cover is allowed): 11.5 feet and 4 feet
Check Standard Sheet # Applicant’s Justification
(B)(2) Street Trees

1. One street tree provided for every 30 linear feet of public sidewalk length and located within six feet of the sidewalk. L2.1 Complies a. Length of parcel frontage/public sidewalk length: 412 feet b. Street Trees required (i.e. frontage/30 feet): 14 trees ☒
c. Street Trees provided: 17 (5 existing + 12 new)
(B)(3) Accent Paving
Parcels abutting University Avenue between Alma Street and Webster include accent paving along the project frontages, as indicated below: N/A Brick paving at corners ☐
Brick trim mid-block
☐ Parcel abutting California Avenue between El Camino Real and Park Blvd include decorative glass accent paving along project frontages
(B)(4) Mobility Infrastructure
☒
(A) On-site micromobility infrastructure (e.g. bike racks/lockers) is located within 30 feet of the primary building entry and/or on a path leading to the primary building entry; OR
AP2.01 Complies
Pick One☐ Existing micromobility infrastructure (e.g. bike racks/lockers) is already located within 50 feet of project site and located in a public right-of-way.

Pick One
☒
(B) Primary building entries shall provide at least one seating area or bench within 30 feet of building entry and/or path leading to building entry. On arterials (see Map T-5), except Downtown, seating areas or benches shall not be located between the sidewalk and the curb; OR
AP2.01 Complies
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☐ Existing seating areas or benches that are already located in the public right-of-way within 50 feet of the building entry.

18.24.030 Site Access
Check Standard Sheet # Applicant’s Justification
(b)(1) Through Lot Connections
☐
Through lots located more than 300 feet from an intersecting street or pedestrian walkway shall provide a publicly accessible sidewalk or pedestrian walkway (with public access easements) connecting the two streets.

N/A
(b)(2) Building Entries
☒
Primary Building Entries shall be located from a public right-of-way. If there is no public right-of-way adjacent to the building, entries shall be located from a private street or Pedestrian Walkway.

AP2.01 Complies
(b)(3) Vehicle Access
☒ (A) Vehicle access shall be located on alleys or side streets when they abut the property. AP2.01 Complies
☒
(B) Except for driveway access and short-term loading spaces (e.g. taxi), off-street parking, off-street vehicle loading (delivery trucks), and vehicular circulation areas are prohibited between the building and primary building frontage.

AP2.01 Complies
(b)(4) Loading Docks and Service Areas
Loading and service areas shall be integrated into building and landscape design and located to minimize impact on the pedestrian experience as follows: AP2.01 Loading provided. ☐ (A) Loading docks and service areas shall be located on façades that do not face a primary building frontage
☐
(B) Loading docks and service areas located within setback areas shall be screened by a solid fence, or wall, or dense landscaping and separated from pedestrian access to the primary building entry to avoid impeding pedestrian movement/safety.

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18.24.040 Building Orientation and Setbacks
Check Standard Sheet # Applicant’s Justification
(b)(1) Building Corner Elements (less than 40 feet in height) Corner buildings less than 40 feet in height and end units of townhouses or other attached housing products that face the street shall include all of the following features on their secondary building frontage:
(A) height and width of corner element shall have a ratio greater than 1.2:1. For townhomes, the width would be equal to the smaller side of one unit? Building above 40 feet a. Secondary building frontage height: _____ feet
b. Secondary building frontage length: _____ feet
☐
c. Secondary building frontage height to width ratio: ___ (B) minimum of 15% fenestration area.
a. Total secondary building frontage façade area: ___ sf b. Secondary building frontage façade fenestration area: ___ sf ☐
c. Percent of fenestration area _____ %
Check All
☐ (C) At least one facade modulation with a minimum depth of 18 inches and a minimum width of two feet.
(b)(2)(A) & (B) Treatment of Buildings Corners on Corner Lots (40+ feet in height) Corner Buildings 40 feet or taller in height shall include at least one of the following special features:

A. Street wall is located at the minimum front yard setback or build-to line for a minimum aggregated length of 40 feet on both facades meeting at the corner and includes one or more of the following building features:
☒ i. An entry to ground floor retail or primary building entrance located within 25 feet of the corner of the building. AP3.00 Complies
Check One or More
within A or B
☒ ii. A different material application and/or fenestration pattern from the rest of the façade. AP3.00 Complies
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☐ iii. A change in height of at least 4 feet greater or less than the height of the adjacent/abutting primary façade.

B. An open space with a minimum dimension of 20 feet and minimum area of 450 sf. The open space shall be at least one of the following
☐ i. A publicly accessible open space/plaza.
☐ ii. A space used for outdoor seating for public dining.

Check One or
More within A or B
☐
iii. A residential Common Open Space adjacent to a common interior space (i.e. lobby, retail, etc.) and less than two feet above adjacent sidewalk grade.

Fences and railing shall be a minimum 50% open/transparent. (b)(3) Primary Building Entry
The primary building entry meets at least one of the following standards:
☒ A. Faces a public right-of-way. AP3.00
☒ B. Faces a publicly accessible pedestrian walkway. AP3.00 Complies C. Is visible from a public right-of-way through a forecourt or front porch that meets the following standards:
i. For residential buildings with fewer than seven units, building entry forecourts or front porch minimum dimensions of (min. 36 sf and min. dimension of 6 feet required): ___ sf and ___ ft. min. dimension Check One or More
☐ ii. For commercial buildings or residential buildings with seven or more units, building entry forecourts or front porch minimum dimensions of (min. 100 sf and a min. width of 8 feet required): ___ sf and ___ ft. min. width
(b)(4) Ground Floor Residential Units
A. Finished Floor Height for Ground Floor Units
☐
The finished floor of ground floor residential units, when adjacent to a public right-of- way, must be within the minimum and maximum heights according to setback distance from back of walk identified in Figure 2a and 2b of the Zoning Ordinance. Calculate minimum ground floor finished floor height: AP2.01 No ground floor units Item 8
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☐ Setback adjacent to public right of way: 20 feet
☐
Minimum ground floor finished floor height: ___0__ feet 𝒚 = ―
𝟒 𝟏𝟓 (𝒙) + 𝟏𝟔
𝟑 where 𝑥 = setback length from back of walk, in feet
and 𝑦 = ground floor finished floor height, in feet

☐ Sites with slopes greater than 2% along building façade – Average height of finished floor: _____ feet
Check All that Apply
☒ Sites located in flood zones – the minimum ground floor finished floor height shall be defined by FEMA, less flood zone elevation: _11____ feet B. Setback Trees
Ground floor units with a setback greater than 15 feet must have at minimum an average of one tree per 40 linear feet of facade length, within the setback area. AP2.01 No ground floor units Facade length:

Trees required: tree(s) (i.e. façade length / 40)
☐
Trees provided: tree(s)
C and D. Front Setback
☐ C. Ground floor residential entries are setback a minimum of 10 feet from the back of public sidewalk; OR AP2.01 No ground floor units Pick One☐
D. Where no minimum building setback is required, all ground floor residential units must be set back a minimum 5 feet from back of public sidewalk.

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Check Standard Sheet # Applicant’s Justification
E. Unit Entry
A minimum 80% of ground floor residential units that face a public right-of-way or publicly accessible path, or open space shall have a unit entry with direct access to the sidewalk, path, or open space for minimum.

AP2.01 No ground floor units
a. Total number of ground floor residential units facing a public right-of-way, publicly accessible path, or open space: 145 units
b. 80% of total units in (a): 116 units
☐
c. Subset of number of units in (a) that have a unit entry with direct access to the sidewalk, path, or open space: 145 entries
(b)(5) Front Yard Setback Character
Required setbacks provide a hardscape and/or landscaped area to create a transition between public and private space. The following standards apply, based on intended use and exclusive of areas devoted to outdoor seating, front porches, door swing of building entries, and publicly accessible open space and meet the following:
(A). Ground-floor retail or retail like uses have a minimum of 10% of the required setback as landscape or planters. N/A
i. Minimum setback area (setback x frontage x 10%): ____ sf☐ ii. Landscape or planter area in required setback: ____ sf (B). Ground-floor residential uses have a minimum of 60% landscaped area in the required setback area.
i. Minimum setback area (setback x frontage x 60%):

Check All that Apply
☐
ii. Landscape area in required setback:
(b)(6) Side Yard Setback Character
☐
(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.

N/A
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18.24.050 Building Massing
Check Standard Sheet # Notes
(b)(1) Upper Floor Step Backs and Daylight Planes
(A) When the height of the subject building is more than 20 feet above the average height (i.e. average of low and high roof elevations) of an adjacent building(s), an upper floor step back shall start within two vertical feet of the average height of the adjacent building. The step back shall be a minimum depth of six feet along both the façade on the primary building frontage and the façade facing the adjacent building, and the step shall occur for a minimum of 70% of each façade length.

AP3.21
Stepbacks occur on floor three
(24 feet). However, in some
locations the full 6 feet in depth
is not provided, in others more
than the 6 feet stepback is
provided.
i. Proposed building height: 85 feet
ii. Average building height of the adjacent building(s): 33.75 feet ☒
iii. Building height where upper floor step back begins: 24 feet ☐ (B) Notwithstanding, subsection (A), when adjacent to a single-story building, the upper floor step back shall occur between 33 and 37 feet in height. ☒
(C) If a project meets the following criteria, a daylight plane with an initial height of 25 feet above grade at the property line and a 45-degree angle shall be required. This daylight plane is required if all of these criteria are met:
i. The project is not subject to a daylight plane requirement, pursuant to district regulations in Title 18; and
ii. The project proposes a building which is more than 20 feet above the average height (i.e., average of low and high roof elevations) of an adjacent building(s); and
iii. The project abuts residential units in the side or rear yard.

AP3.01
AP3.02
AP3.03
The building does not comply
with daylight planes.
(b)(2) Privacy and Transitions to Residential Uses
When a building abuts a residential use on an interior side and/or rear property line, the building shall break down the abutting façade and maintain privacy by meeting all of the following:

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☒ (A) Landscape Screening. A landscape screen that includes a row of trees with a minimum one tree per 25 linear feet and continuous shrubbery planting. This screening plant material shall be a minimum 72 inches (6 feet) in height when planted. Required trees shall be minimum 24” box size.

AP2.01 Complies
☒ (B) Façade Breaks. A minimum façade break of 4 feet in width, 2 feet in depth, and 32 sf of area (i.e. 8 ft tall minimum) for every 36 to 40 feet of façade length AP3.01
AP3.02
AP3.03
Does not comply. While the
project provides some façade
breaks, the proposed facades
breaks do not meet the
minimum requirements for a
breaks.
☒
(C) Maximum Amount of Transparent Windows. Within 40 feet of an abutting structure, no more than 15% of the facing façade area shall be windows or other glazing. Additional windows are allowed in order to maintain light, if fixed and fully obscured
AP3.01
AP3.02
AP3.03
Complies
(D) Windows. Within 30 feet of facing residential windows (except garage or common space windows) or private open space on an adjacent residential building, facing windows on the subject site shall meet the following:
(i) Window sills at and above the 2nd floor shall be at least five feet above finished floor; or
(ii) Windows shall have opaque or translucent glazing at or below five feet above finished floor; or
(iii) Windows shall be angled up to 30 degrees (parallel to window) to face away from the adjacent privacy impacts; and
(iv) Landscape screening shall be 24-inch box size or larger and eight+ feet height at planting; 50% evergreens; and located to align with proposed second floor windows at maturity.

AP3.01
AP3.02
AP3.03
Complies
Check All
(E). Balconies: Within 30 feet of residential windows (except garage or common space windows) or private open space on an adjacent residential building, balconies and decks on the subject site shall be designed to prevent views:
(i) No sight lines to the adjacent property window or open space are permitted within five feet above the balcony or deck flooring and a 45- degree angle downward from balcony railing.
(ii) Submit section view of proposed balcony/deck and abutting residential windows and/or private open space.
(iii) Provide balcony/deck design measure which may include:

AP3.01
AP3.02
AP3.03
Complies
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a. Minimum 85% solid railing
b. Obscure glass railing
c. Barrier with min. 18" horizontal depth from railing (e.g. planter) (b)(3)(A) & (B) Maximum Façade Length - facing a street or public path Buildings 70 feet in length or greater and greater than 25 feet in height For building facades 70 feet in length or greater and facing a public street, right- of-way, or publicly accessible path shall not have a continuous façade plane greater than 70% of the façade length without an upper floor modulation, of at least 2 feet in depth
Largest façade length featuring continuous plane: 61 feet Total Façade length: 390 feet
☒
Percent of façade length without upper floor modulation (a/b) (maximum 70%): 15 %
Buildings 250 feet in length or greater
(A) Buildings 250 feet in length or greater, which face a public street, right-of- way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 400 sf and a width greater than or equal to two times the depth
AP2.03
AP2.04
AP2.05
AP2.06
AP2.07
Does not Comply
Total Building length: 391 feet
☐
Number of vertical façade breaks: 5 breaks
Width: 42 feet, Depth: 8 feet, Area: 336 sf
Buildings between 150 feet and 250 feet in length
(B) Buildings 150 to 250 feet in length, which face a public street, right-of-way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 64 sf and a minimum width of 8 feet and minimum depth of 4 feet.

Total Building length:

Pick One Category
☐
Number of vertical façade breaks:

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Width:

Check Standard Sheet # Applicant’s Justification
(b)(4) Special Conditions: Railroad Frontages
All parcels with lot lines abutting railroad rights-of-way shall meet the following standards on the railroad-abutting façade(s): N/A
☐ (A) A minimum facade break of at least 10 feet in width and six feet in depth for every 60 feet of façade length.

Check
All
☐ (B) For portions of a building 20 feet or greater in height shall not have a continuous façade length that exceeds 60 feet.
(b)(5) Diversity of Housing Types
☒
A diversity of housing types (e.g. detached units, attached rowhouses/townhouses, condominiums or apartments, mixed use) are required for projects on large lots:
Less than one acre lots: minimum 1 housing types
1 to 2-acre lots: minimum 2 housing types; or
More than 2-acre lots: minimum 3 housing types
Does not Comply. 2.6 acre lot
with only residential and
residential accessory uses
proposed.

18.24.060 Façade Design
Check
Two or
More
Standard Sheet # Applicant’s Justification
(c)(1) Base-Middle-Top
☒
Buildings three stories or taller and on lots wider than 50 feet shall be designed to differentiate a defined base or ground floor, a middle or body, and a top, cornice, or parapet cap. Each of these elements shall be distinguished from one another for a minimum of 80% of the façade length through use of three or more of the following four techniques:
☐
i. Variation in Building Modulation: Building modulation shall extend for a minimum 80% of the façade length feet, and shall include one or more of the following building features.

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☒ a. Horizontal shifts. Changes in floor plates that protrude and/or recess with a minimum dimension of 2 feet from the primary facade.

AP2.02
AP2.03 Complies
☐
b. Upper floor step backs. A horizontal step back of upper-floor façades with a minimum 5 foot stepback from the primary façade for a minimum of 80% of the length of the façade
Check one or more if
selected
☐
c. Ground floor step back. A horizontal shift of the ground floor facade with a minimum depth of 2 feet for a minimum 80% of the length of the façade.

Ground floor step backs shall not exceed the maximum setback, where stated ☒ ii. Variation in Façade Articulation: Façade articulation modulation shall include one or more of the following building features. Complies
☒
a. Horizontal and/or Vertical Recesses or Projections. Recesses or projections such as a pattern of recessed grouping of windows, recessed panels, bay windows or similar strategies. The recess or projection shall be a minimum 4 inches in depth.

AP3.00
AP3.01
AP3.02
AP3.03
☒
b. Horizontal and/or Vertical Projections. Projections such as shading, weather protection devices, decorative architectural details, or similar strategies.

AP3.00
AP3.01
AP3.02
AP3.03
Check one or more if
selected
☐
c. Datum Lines. Datum lines that continue the length of the building, such as parapets or cornices, with a minimum 4 inches in height or a minimum 2 inches in depth and include a change in material
☒ iii. Variation in two of the following:

AP3.00
AP3.01
AP3.02
AP3.03
Complies
☒ a. Fenestration Size
☒ b. Fenestration Proportion
☒ c. Fenestration Pattern
Check two if
selected
☐ d. Fenestration Depth or Projection
☒ iv. Variation in two of the following: AP3.00
AP3.01 Complies
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AP3.02
AP3.03
☒ a. Façade Material
☒ b. Facade Material Size
☐ c. Façade Texture and Pattern
Check two if
selected
☒ d. Façade Color
(c)(2) Façade Composition
Building facades shall use a variety of strategies including building modulation, fenestration, and façade articulation to create visual interest and express a variety of scales through a variety of strategies. All facades shall include a minimum of three of the following façade articulation strategies to create visual interest:
☒ A. Vertical and horizontal recesses such as a pattern of recessed grouping of windows or recessed panels. The recess shall be a minimum 4 inches in depth.

AP3.00
AP3.01
AP3.02
AP3.03
Complies
☒ B. Vertical and horizontal projections such as shading and weather protection devices or decorative architectural details. Projections shall be a minimum 4 inches in depth. ☒
C. Datum lines that continue the length of the building, such as cornices, with a minimum 4 inches in depth, or a minimum 2 inches in depth and include a change in material.
☒ D. Balconies, habitable projections, or Juliet balconies (every 20 to 40 feet) with a minimum 4 inches in depth.
☒ E. Screening devices such as lattices, louvers, shading devices, or perforated metal screens.
☐ F. Use of fine-grained building materials, such as brick or wood shingles, not to exceed 8 inches in either height or width.

Check Three or More
☒ G. Incorporate a minimum of three colors, materials, and/or textures across the whole building.
(c)(3) Compatible Rhythm and Pattern
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(A) Buildings shall express a vertical rhythm and pattern that reflects the size and scale of a housing unit and/or individual rooms and spaces.

This may be achieved with building modulation to create vertically oriented façades (height greater than the width of the façade), façade articulation and fenestration repetitive vertically oriented patterns. Depending on the length of the façade, the following standards apply:
☐
i. For continuous façades less than 100 feet in length, the façade shall have vertically oriented patterns of vertical recesses or projections, façade articulation, and/or fenestration.
ii. For continuous façades 100 feet or greater in length, the façade shall include either:
☒
a. A vertical recess or change in façade plane with a minimum 2 feet deep vertical shift modulation for a minimum 4 feet in width to establish a vertical rhythm between 20 to 50 feet in width; OR
AP3.00
AP3.01
AP3.02
AP3.03
Complies
Check One☐ b. A vertical recess or projection with a minimum depth of 2 feet that establishes the vertical rhythm between 10 to 16 feet in width
(B) Residential mixed-use buildings
☐ i. Vertical Patterns and Modulation: Façades shall use vertical patterns of building modulation, façade articulation, and fenestration.

Check One or
More☐
ii. Horizontal Patterns and Modulation: Façades that use horizontal articulation and fenestration patterns shall use a vertical massing strategy with a minimum 4 feet wide and 2 feet deep vertical shift in modulation at least once every 50 feet of façade length.
(C) Storefronts
☐ Storefront uses must express a vertical rhythm not to exceed 30 to 50 feet in width. (c)(4) Emphasize Building Elements & Massing
(A)(i) Building Entries within Façade Design. Primary building entries shall be scaled proportionally to the number of people served (amount of floor-area or number of units accessed). Building entries shall meet the following minimum dimensions:
☐ a. Individual residential entries:
☒ b. Shared residential entry, such as mixed-use buildings: AP3.00 AP3.01 Complies
Check All☐ c. Commercial building entry:

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☐ d. Storefront entry:
(ii) Primary building entries (not inclusive of individual residential entries) shall include a façade modulation that includes at least one of the following:
☐ a. Recess or projection from the primary façade plane (minimum 2 feet).

Check
One or
More☒ b. Weather protection that is a minimum 4 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods AP3.00
AP3.01 Complies
(c)(5) Storefront/Retail Ground Floors
A. Ground floor height shall be a minimum 14 feet floor-to-floor OR shall maintain a 2nd floor datum line of an abutting building.

AP3.00
AP3.01 Complies
a. Ground floor height (minimum 14 feet): 15 feet; OR☒
b. Height of 2nd floor datum line of abutting building:

B. Transparency shall include a minimum 60% transparent glazing between 2 and 10 feet in height from sidewalk, providing unobstructed views into the commercial space. a. Façade area between 2 feet and 10 feet:
b. Transparent glazing area between 2 feet and 10 feet:
☐
c. Percentage of transparent glazing (minimum 60%):
☐ C. If provided, bulkheads and solid base walls measure between 12 and 30 inches from finished grade
D. Primary entries shall include weather protection by recessing the entry, providing an awning or using a combination of these methods.
a. Weather protection width (minimum 6 feet): 20 feet AP3.00 AP3.01 Complies☒
b. Weather protection depth (minimum 4 feet): 4 feet AP3.00 AP3.01
☐
E. Awnings, canopies and weather protection: (i) When transom windows are above display windows, awnings, canopies and similar, weather protection elements shall be installed between transom and display windows. These elements should allow for light to enter the storefront through the transom windows and allow the weather protection feature to shade the display window. (ii) Awnings may be fixed or retractable AP3.00
AP3.01 Complies
(c)(6) Other Non-Residential Ground Floors
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☐ (A) Ground floor height must be a minimum 14 feet floor-to-floor OR match the 2nd floor datum line of an abutting building N/A
☐ Ground floor height (minimum 14 feet): _____ feet; OR Pick
One☐ Height of 2nd floor datum line of abutting building:
(B) Minimum of 50% transparent glazing between 4 and 10 feet in height from sidewalk or terrace grade, providing unobstructed views into the commercial space Façade area between 2 feet and 10 feet:

Transparent glazing area:
☐
Percentage of transparent glazing (minimum 50%):
(C) Primary entries include weather protection that is a minimum 6 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods.

Weather protection width (minimum 6 feet): ☐
Weather protection depth (minimum 4 feet):
(c)(7) Parking/Loading/Utilities
(A) Entry Size
No more than 25% of the site frontage facing a street shall be devoted to garage openings, carports, surface parking, loading entries, or utilities access. On sites with less than 100 feet of frontage, no more than 25 feet.

AP3.00
AP3.01 Complies
Site frontage: 128 feet Matadero / 240 feet Kendall
Frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access: 14% Matadero / 8% Kendall
☒
Percent of frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access 10.7% and 83%
(B) Above Ground Structured Parking
☒
Above grade structured parking levels facing a public right-of-way or publicly accessible open space/path, with the exception of vehicular alleys, must be lined with commercial or habitable uses with a minimum depth of 20 feet
AP3.01
AP3.02 Does not comply
(C)&(D) Partially Sub-Grade Structured Parking
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☐ Partially sub-grade parking must not have an exposed façade that exceeds 5 feet in height above abutting grade at back of sidewalk. N/A
☐ Partially sub-grade parking must be screened with continuous landscaping and shrubbery with minimum height of 3 feet and be located within 10 feet of the sub-grade parking.

18.24.080 Open Space
Check Standard Sheet # Applicant’s Justification
(b)(1) Private Open Space
☒
(A) Floor area includes clear space with a minimum dimension of a circle with a six- foot diameter.

Does not comply. Some of the
units with balconies can not
have a clear space with a
minimum dimension of a circle
with a 6 foot diameter.
☒ (B) Minimum clear height dimension of 8’-6” feet. Complies ☒ (C) Directly accessible from a residential unit. Complies ☐ (C) Balconies are not located within the daylight plane. (b)(1)(E) Private Open Space - Ground Floor Patios
☐
(i) RM-20 and RM-30 districts: Minimum 100 sf of area, the least dimension of which is 8 feet for at least 75% of the area.
☐
(ii) RM-40 districts: Minimum 80 sf of area, the least dimension of which is 6 feet for at least 75% of the area
☐
(iii) Street facing private open space on the ground floor shall meet the finished floor height for ground floor residential standards in section 18.24.040(b)(4) (b)(2) Common Open Space
☒ (A)&(B) Minimum 200 sf of area. Area shall include a space with a minimum dimension of a circle with a 10-foot diameter.

AP2.03
AP2.06 Complies
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☒ (C) A minimum of 60% of the area shall be open to the sky and free of permanent weather protection or encroachments. Trellises and similar open-air features allowed AP2.03
AP2.06
☒
(D) Notwithstanding subsection (1), courtyards enclosed on four sides shall have a minimum dimension of 40 feet and have a minimum courtyard width to building height ratio of 1:1.25
AP2.03
AP2.06
☒ (E) Common open space provides seating. AP2.03
AP2.06
☒ (F) Common open space has a minimum 20% of landscaping. AP2.03 AP2.06
☒ (G) Planting in above grade courtyards has minimum soil depth of 12 inches for ground cover, 20 inches for shrubs, and 36 inches for trees.

18.24.090 Materials
Check Standard Sheet # Applicant’s Justification
☒
(b)(1) Primary, secondary, and accent materials are allowed or prohibited as in the Residential and Residential Mixed-use Material List, which may be updated from time to time by the Director of Planning with a recommendation by the ARB. See webpage for list - https://www.cityofpaloalto.org/News-Articles/Planning-and-Development- Services/Multifamily-Mixed-Use-Objective-Standards
Materials Comply

18.24.100 Sustainability and Green Building Code
Check Standard Sheet # Applicant’s Justification
☒
(b) See Chapter 16.14: California Green Building Standards additional requirements for green building and sustainable design. Notwithstanding Section 18.24.010(c), these regulations may not be modified through alternative compliance.

Project complies with Calgreen
Tier 2.

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From: James Lloyd
To: Planning Commission
Cc: Clerk, City; City Attorney; City Mgr; PlannerOnDuty Subject: public comment re item 2 for tonight"s Planning Commission meeting Date: Wednesday, February 11, 2026 12:52:29 PM
Attachments: Palo Alto - 3606 El Camino Real - HAA Letter.pdf CalHDF v LCF - compressed.pdf
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Palo Alto Planning Commission,
Please see attached our public comment regarding item 2 for tonight's Planning Commission meeting, the proposed 321-unit housing development project at 3606 El Camino Real, which includes 38 units affordable to low-income households.

Sincerely,

James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
CalHDF is grant & donation funded
Donate today -
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Feb 11, 2026 City of Palo Alto
250

Hamilton

Avenue
Palo Alto, CA 94301 Re: Proposed Housing Development Project at 3606 El Camino Real By email: [email protected] Cc: [email protected]; [email protected]; [email protected]; [email protected]; Dear Palo Alto Planning Commission, The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation

abide

the

Housing

Accountability

Act

(“HAA”)

and

130

when

evaluating

the

proposed

321-unit

housing

development

project

3606

Camino

Real,

which

includes

38 units

affordable

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

certain

percent

the

total

units

lower-income

households,

defined

Health

and

Safety

Code

Section

50079.5)

the

grounds

does

not

comply

with

the

city’s

zoning

and

general

plan

the

developer

submitted

either

statutorily

defined

"preliminary

application"

"complete

development

application"

while

the

city's

housing

element

was

not

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

non-compliant

municipalities

enforce

their

zoning

rules

against

qualifying

affordable

housing

projects.

(See,

e.g.,

California

Housing

Defense

Fund

City

Cañada

Flintridge
,

Case

Number:

23STCP02614

(attached),

for

recent

court

decision

affirming

the

plain

language

the

statute

this

regard.)

The

City’s

Housing

Element

was

not

substantial

compliance

with

state

law

when

the

preliminary

application

under

330

was

submitted.

The

City

must

therefore

allow

the

project

developed

proposed.

2 These

code

section

numbers

correspond

the

HAA

existed

when

the

preliminary

application

for

the

project

issue

was

submitted

(i.e.

before

1893

went

into

effect).

1 AB 1893, effective January 1, 2025, has amended the “Builder’s Remedy” provisions of the HAA.

However,

the

1893

allows

for

vested

Builder’s

Remedy

applications

proceed

under

the

version

the

law

the

new

version

the

law.

2201 Broadway, PH1, Oakland, CA 94612 www.calhdf.org

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CalHDF also notes that the City’s Housing Element has planned for 37 units on the project site,

including

12 lower-income

housing

units.

Failure

approve

this

project

would

risk

de-certification

the

City’s

Housing

Element

the

California

Department

Housing

and

Community

Development.

Furthermore, the project is eligible for a statutory exemption from CEQA review under AB 130

(Pub.

Res.

Code,

21080.66).

Caselaw

from

the

California

Court

Appeal

affirms

that

local

governments

err,

and

may

sued,

when

they

improperly

refuse

grant

project

CEQA

exemption

streamlined

CEQA

review

which

entitled.

(
Hilltop

Group,

Inc.

County

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

this

public

benefit:

will

provide

badly-needed

affordable

housing;

will

bring

new

customers

local

businesses;

will

increase

the

city’s

tax

revenue;

and

will

reduce

displacement

existing

residents

reducing

competition

for

existing

housing.

will

also

help

cut

down

transportation-related

greenhouse

gas

emissions

providing

housing

denser,

urban

areas,

opposed

farther-ﬂung

regions

the

state

(and

out

state).

While

one

project

will

solve

the

statewide

housing

crisis,

the

proposed

development

step

the

right

direction.

CalHDF

urges

the

City

approve

it,

consistent

with

its

obligations

under

state

law.

CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased

access

housing

for

Californians

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 2 of 2

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From:

To: Planning Commission
Cc: Switzer, Steven; Armer, Jennifer
Subject: 3606 ECR agenda item
Date: Wednesday, February 11, 2026 10:48:52 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
!
Dear Commissioners,
I support the staff recommendation to approve the Vesting Tentative Map.

This project is in the expanded ECR focus area approved by PTC and council.

It will bring more than 300 new housing units on an excellent site and will include roughly 40 units reserved for low income residents as required by law.

Given the financial (and legal) challenges facing 100% BMR projects, this project like the approved 3150 ECR project are the most practical current way to increase our stock of BMR housing.

The PTC and council have developed some momentum on new housing.

Please keep this going tonight while adding your comments to council.

Thanks
Stephen Levy
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From: [email protected]
To: Planning Commission
Cc: Switzer, Steven; Armer, Jennifer
Subject: 3606 ECR agenda item
Date: Wednesday, February 11, 2026 10:48:56 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
!
Dear Commissioners,
I support the staff recommendation to approve the Vesting Tentative Map.

This project is in the expanded ECR focus area approved by PTC and council.

It will bring more than 300 new housing units on an excellent site and will include roughly 40 units reserved for low income residents as required by law.

Given the financial (and legal) challenges facing 100% BMR projects, this project like the approved 3150 ECR project are the most practical current way to increase our stock of BMR housing.

The PTC and council have developed some momentum on new housing.

Please keep this going tonight while adding your comments to council.

Thanks
Stephen Levy
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From: [email protected]
To: Architectural Review Board; Switzer, Steven
Subject: 3606 ECR
Date: Tuesday, December 2, 2025 7:43:59 AM
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
!
Dear Chair Chen and board members,
I look forward to supporting this project when it gets to the city council.

I also look forward to your comments, which usually make projects better.

From the perspective of meeting our city's housing goals this site and project have many positives:
--it is on a site designated for substantial housing and approved by ARB and council in the expanded ECR Focus Area.
--the site is close to the Cal Ave shopping area and train station as well as very close to the Stanford Research Park and accessible to ECR bus lines. --It is similar in many ways to the 3150 ECR project approved by ARB and council and will bring a substantial number of new units on a single site --the site is adjacent to two schools that are facing cutbacks from declining enrollment and will help preserve these neighborhood schools at full service levels. --the 37 BMR units, that are reserved for low income HH, will make a positive contribution to meeting our low income housing goals in a very desirable area.

As always I am aware of the tension between making major changes to a proposal and affecting the economic viability of the application.

Thank you for your hard and thoughtful work.

Stephen Levy
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From: Velasquez, Ingrid
To: Lait, Jonathan; Tran, Vickie; Switzer, Steven
Cc: Nose, Kiely; Gaines, Chantal; City Mgr
Subject: FW: 3606 El Camino Real Application #: 24PLN-00162 Date: Tuesday, February 17, 2026 9:21:08 AM
Attachments: image001.png
image002.png
image003.png
Hello all,

Forwarding the message below for awareness.

Thanks,

Ingrid

Ingrid Velásquez
Administrative Assistant
Office of the City Manager
(650) 329-2354| [email protected]
www.PaloAlto.gov

From: Ken Nishimura <[email protected]>
Sent: Thursday, February 12, 2026 3:24 PM
To: Council, City <[email protected]>; Switzer, Steven <[email protected]> Subject: 3606 El Camino Real Application #: 24PLN-00162

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Dear Palo Alto City Council - I read with some interest an article in the local newspaper regarding the proposed merger of parcels and construction of a large residential complex on 3606 El Camino Real between two streets, Matadero and Kendall. The Planning Commission correctly f ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ i
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Dear Palo Alto City Council -
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I read with some interest an article in the local newspaper regarding the proposed merger of parcels and construction of a large residential complex on 3606 El Camino Real between two streets, Matadero and Kendall.

The Planning Commission correctly found that there are serious concerns regarding traffic circulation which would be realized should this development come to fruition. Specifically, the ingress and egress of a large number of vehicles to/from Matadero so close to the intersection with El Camino presents significant hazards to cyclists who use Matadero as a thoroughfare.

Given the limited number of crossings across the Caltrain tracks -- a topic of significant concern in of itself -- cyclists who are in general trying to go from Downtown to the southwest side of the city to access the industrial parks or Foothill Expressway have limited options. I personally use the California Avenue underpass and ride along Park Avenue and cross El Camino at Matadero to join the Bol Park path, reversing the route to go home. Note that this is the first available "through" crossing of El Camino south of Page Mill with a traffic signal.

The intersection of Matadero and El Camino is not engineered to handle the volume of traffic anticipated by a large residential complex; light cycles are long and cars would back up into the complex parking lot which then presents a hazard to cyclists as drivers would be motivated to "make the light" rather than be aware of cyclists. This cycling route is used by bike commuters as well as students going to nearby schools. Pedestrians also use this route as evidenced by a school crossing guard at this intersection.

I urge the Council to require a significant modification to the plans prior to approving a parcel merger, specifically one which mitigates ingress/egress onto streets which would create hazards for cyclists and pedestrians.

Regards,

Ken Nishimura
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From: Switzer, Steven
To: Star Teachout
Cc: Planning Commission; Architectural Review Board; John King; City Mgr Subject: RE: 3606 ECR Driveway already exists
Date: Tuesday, December 9, 2025 4:47:00 PM
Attachments: image001.png
image002.png
Hi Star,

Thanks for your continued interest in the project located at 3606 El Camino Real that just went before the Architectural Review Board at their December 4, 2025, Meeting .

The City’s Objective Standards (PAMC 18.16.090) provides parameters for parking design.

Where possible it is recommended that parking is accessed from side streets or alleys (PAMC

18.16.090(b)(6)(I)). The project proposes a design that would align with screening the parking and having it accessed from a side street.

Because this is a “builder’s remedy project” under AB 1893, the City is limited to enforcing only those objective standards that apply in a zone or land use designation that allows the requested density. In the El Camino Real Focus Area, there is no requirement that driveways be located on El Camino Real.

The applicant may also use incentives, concessions, or waivers under State Density Bonus Law when demonstrating compliance with the enforceable standards. For example, even if the City requested a driveway relocation, the applicant could lawfully seek a waiver/concession to keep the current design.

Since the applicant is invoking AB 130, the project qualifies for a statutory environmental exemption. AB 130 (effective June 30, 2025) is a significant reform to California Housing Law and CEQA. In short, these reforms limit CEQA review but still require that a qualified environmental professional identify any Recognized Environmental Conditions or contamination concerns. If issues are found, the applicant must implement mitigation before the project can move forward.

The City is still evaluating the project and your comments have been added to the project file.

For more information I have added a few helpful links below:

“Builder’s Remedy” and Housing Elements.

AB 130 Legislation
Governor Newsom signs into law groundbreaking reforms to build more housing, boost Item 8
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affordability | Governor of California

As we continue to process the application, feel free to check the project’s webpage for updates:

3606 El Camino Real – City of Palo Alto, CA

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]

www.PaloAlto.gov

From: Star Teachout <[email protected]>
Sent: Tuesday, December 9, 2025 4:08 PM
To: Switzer, Steven <[email protected]>
Cc: Planning Commission <[email protected]>; Architectural Review Board <[email protected]>; John King <[email protected]>; Council, City <[email protected]>
Subject: 3606 ECR Driveway already exists

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Steven,

I assume you already know this, but there is probably no need for an encroachment permit for 3606 ECR as there is already a well-placed driveway/curb cut at approximately the middle of the el Camino Real frontage for this project. It would require an amendment to widen it, but it is well placed--does not interfere with the bus stop closer to Matadero, and there is also a break in the bike lane striping (and no white bollards), as if anticipating this project having a front driveway. I would imagine this is a positive for the developers. This also addresses the ARB comments about breaking up the continuous, visual mass from Matadero to Kendall of the current design.

Since the ARB meeting was the first I attended, were you aware of the existing driveway, and Item 8
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has it gotten discussed in any presentations/analyses so far? If so, what might be the objections to using this placement (per my 8 December email below)?

Thanks for helping me understand the parameters of this project, Star Teachout

++++++++++++++++++++++++++++++++
Record of other emails on this matter...

8 December email:

Hello Steven,

I apologize if I am late to evaluating the 3606 El Camino Real development project. In response to your 4 Dec 2025 reply, it would be helpful if you would offer the statutes/codes/standards which support your claims that a driveway on ECR would not be allowed due to city standards and state regulations related to bike lanes. In the best possible world, we would be able to develop properties for increased housing with the support of our community. Towards that aim, providing information educates all of us with hopefully the least amount of community strife, especially with the complexities of Builder’s Remedy. To be clear, I am not asking for any of the following:

- The item 5 list is not presupposing they be conditions of approval, rather, asking what legal mitigations the city can undertake after
the project is approved [to prevent traffic hazards]
- CEQA compliance
- Reduced density
- Typical zoning compliance
- Anything that (I think) makes the project infeasible.

Driveway on El Camino Real
Did the City of Palo Alto refuse to allow a driveway onto ECR? If so, please provide a link to that discussion or notes. Was a County of Santa Clara encroachment permit denied, and if so appealed? If so, could you provide me with the dates related to that process? I have found nothing in the codes listed below that prevent adding a driveway onto el Camino Real, even through a bike lane. As previously mentioned, there will be driveways/egress from both 3150 and 3400 el camino real developments. Nor have I seen any requirement for even a traffic study, unless the city were asking the applicant for that [no information I could find on such a request]. Considering the potential for extreme disruption and associated safety hazards for pedestrians, cyclists, and even drivers along Matadero and Kendall, this seems like an Item 8
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essential route to pursue.

1. AB 3177 [supports land dedication for adding a service lane in the development plan on both Matadero and Kendall, constricted/safe routes to schools roadways to prevent harm to pedestrians, cyclists, and drivers]
AB 3177 does allow cities to impose such a land dedication requirement in the following limited instances:
• When a housing development both (i) is not located in a transit priority area and (ii) has a linear street frontage of 500 feet or more;
• Where the city makes a finding that the land dedication requirement is necessary to preserve the health, safety, and welfare of the public, including pedestrians, cyclists, and children; or
• To construct public improvements, including, but not limited to, sidewalk and sewer improvements.

2. Project Development Procedures Manual (PDPM):
https://dot.ca.gov/programs/design/manual-project-development-procedures-manual-pdpm

3. Chap 17: Encroachments and Utilities: https://dot.ca.gov/-/media/dot- media/programs/design/documents/pdpm-chapter17-a11y.pdf

4. Chapter 500 - Specific Encroachment Permits: https://dot.ca.gov/-/media/dot- media/programs/traffic-operations/documents/encroachment-permits/epm-chapters-all- ada-a11y.pdf

Thank you for clarifying anything I may have misinterpreted in these documents, Star Teachout

+++++++++++++++++++++++

4 Dec email to ARB: sent separately after the ARB public meeting.

+++++++++++++++++++++++
4 Dec email exchange with Palo Alto planner Switzer:

On Dec 4, 2025, at 9:16 AM, Switzer, Steven <[email protected] >
wrote:

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Hi Star,

Having the two driveways into the garage enter onto El Camino Real would be in conflict with our standards. Driveways are meant to be on cross streets rather than entering onto a freeway like El Camino Real. Further, Caltrans recently added bike lanes along that stretch of El Camino Real. Changing those bike lanes would be unlikely to occur.

Since this is a Builder’s Remedy project, it is afforded a lot of protections from compliance with zoning standards. The items you listed in #5 are unlikely to be conditions of approval for the project because of this

Follow the link to read more information on “Builder’s Remedy” and Housing Elements.

<image001.png> Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]

www.PaloAlto.gov

<image002.png>

From: Star Teachout <[email protected]>
Sent: Wednesday, December 3, 2025 6:10 PM
To: Switzer, Steven <[email protected]>
Subject: Re: 3606 ECR questions

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Thank you for the prompt reply. My highest priority questions are 3 and 5, the ones you did not answer. I assume the city has some oversight on the arterial roads and traffic those experience.

++++++++++++++++++

3 December email:

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On Dec 3, 2025, at 5:18 PM, Switzer, Steven
<[email protected]> wrote:

Hi Star,

My answers are below in bold.

Due to the nature of a builder’s remedy project, there are numerous state law constraints on what the City can impose on a project.

<image001.png>
Steven Switzer
Senior Historic Planner
Planning and Development Services
Department
650-329-2321 | [email protected]

www.PaloAlto.gov

<image002.png>

From: Star Teachout <[email protected]>
Sent: Wednesday, December 3, 2025 1:58 PM
To: Switzer, Steven <[email protected]>
Subject: 3606 ECR questions

Hello Steven,

I mistakenly arrived this morning to voice some concerns about the 3606 ECR development. Since I have a few more hours, if you have time could you please share any answers to the following questions? Incidentally, although losing the Fish Market has been a significant impact on our south PA neighborhood (and probably McDonalds for many too), looking over the 3150 ECR development I am struck at what a great plan it is. The 3606 seemed to want to copy many parts of it, but it is poorly executed and in my opinion the wrong building (scale) in the wrong place.

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1. RM30/RM40 heights violated: Since 3606 el Camino Real qualifies as a Builders’ Remedy project, does that mean the RM-30 and RM-40 portions of the development are allowed to exceed the city’s 30 and 40 ft height limits, despite there being residential properties across the street?

Seven stories along el Camino may be fine, but extending those 7 stories into the neighborhood (T-configuration/footprint), eclipsing the sky view of the nearby apartments and houses is extreme. Were renters notified of this development?

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 November 21, 2025, which is 14 days in advance of the meeting. Postcard mailing occurred on November 19, 2025, which is 16 days in advance of the meeting.

The project site is also located within the El Camino Real Focus Area that allows a maximum height of 85 feet. The RM-30 and RM- 40 lots are part of that focus area.

2. Minimal Underground Parking:

The height of the development is
definitely out of scale for apartments surrounding this proposal. Unlike Creekside (3400 ECR) and the Fish Market/McDonald’s site (3150 ECR) which have mostly underground parking, can the city of PA require mostly underground parking for this project too?

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. Further, the project applicant is also able to utilize incentives, concessions, and waivers under State Density Bonus Law when demonstrating compliance with the enforceable standards. This allows the applicant to deviate from certain standards. The City cannot require underground parking.

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3. No Entrance/Exits on ECR: Unlike the aforementioned projects, why are there no exits from this development onto el Camino Real (as per 3400 and 3150 ECR)? It is unbelievable that this project would subject the neighborhoods to this much traffic for those avoiding ECR traffic, especially with the No Right Turn on Red rule at Matadero. Kendall (curvy and narrow) and Matadero (no bike lanes, parking on sides allowed, major route to schools) are not designed for this volume.

As you know, Barron Park is landlocked on 2 sides so all traffic short- cutting through the neighborhood streets coming from Creekside and 3606 (as currently proposed) will travel down 3 streets—Whitsell, Kendall, Barron--through this sidewalk-less neighborhood.

There are also issues with the Matadero driveway passing between 2 smaller apartment buildings, posing some dangers for those living there.

4. Parking: Why should a developer be allowed to not provide parking for all its residents but be allowed to lease parking?!!
Plans indicate 321 residential units and the required parking spaces in the El Camino Real Focus Area are 1 space per 1 unit.

The project is proposing 391 spaces and compliant with the zoning code.

5. Protections
: What with all the proposed developments happening
between Page Mill and Los Robles, does the city have some authority to enact any of the following:

a. Retain the driveways on both Matadero and Kendall for service vehicles (garbage, deliveries, EMS), but disconnect them from the residential parking.

b. If (a) is not possible, impose a R turn driveway exit only from 3606 ECR on the Matadero side (ie, no L turn) and a L turn only (ie, no R turn exit) onto Kendal to protect the neighborhoods from all the cut through traffic? This would probably require a short bike lane/sidewalk on Kendall between ECR and Whitsell to protect children enroute to school.

c. If (a) is not possible, could the city (with neighborhood approval) make Whitsell a cul-de-sac at Matadero to prevent both 3400 and 3606 ECR development traffic from using it as a short cut, thus protecting Item 8
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pedestrians and cyclists. This adds some traffic to Kendall and Josina, but really only from the few houses on the first block of Whitsell.

d. Install speed bumps on Kendall, Whitsell, Barron, and Josina as needed.

e. Enact No Right Turn between 8:30 and 9:30 am Mon-Fri on Matadero and Kendall.

f. Remove the ECR cross-lane access at Kendall, which is already dangerous, and make Barron a fully-signaled intersection (not just a signaled cross-walk when pushed).

g. Barron Ave is extremely restricted between ECR and Whitsell— narrow, tree-lined. Perhaps it too needs a no turns between 8:30 - 9:30 am?

H. Matadero is already impacted by traffic and the No R on Red law at ECR. What with the many large proposed developments, could the city remove this restriction at Matadero? [12/8/25: Negotiate with the county/state]

i. All of these larger developments do not provide for all the potential parking needed, even 3150 which is a pretty stellar development.

Where are all the approximate 300 drivers going to park when ECR no longer allows it? Some people may not use cars, but from my experience as a cyclist, even my able-bodied, clever neighbors still hop in their cars to travel 1 mile! [12/8/25: Parking permit program]

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.

In order to be eligible for AB 130 a project must comply with Public Resources Code (“PRC”) Section 21080.66. This section offers a statutory exemption for certain housing development projects from CEQA requirements, aiming to speed up the approval process. 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 as detailed in the staff report.

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Thanks for any useful input to guide our city into healthy development which considers both the needs of future and current residents.

Star Teachout
3550 Whitsell Avenue

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From: Switzer, Steven
To: "Star Teachout"
Subject: RE: 3606 ECR questions
Date: Wednesday, December 3, 2025 5:18:00 PM
Attachments: image001.png
image002.png
Hi Star,

My answers are below in bold.

Due to the nature of a builder’s remedy project, there are numerous state law constraints on what the City can impose on a project.

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]

www.PaloAlto.gov

From: Star Teachout <[email protected]>
Sent: Wednesday, December 3, 2025 1:58 PM
To: Switzer, Steven <[email protected]>
Subject: 3606 ECR questions

Hello Steven,

I mistakenly arrived this morning to voice some concerns about the 3606 ECR development.

Since I have a few more hours, if you have time could you please share any answers to the following questions? Incidentally,
although losing the Fish Market has been a significant
impact on our south PA neighborhood (and probably McDonalds for many too), looking over the 3150 ECR development I am struck at what a great plan it is. The 3606 seemed to want to copy many parts of it, but it is poorly executed and in my opinion the wrong building (scale) in the wrong place.

1. RM30/RM40 heights violated: Since 3606 el Camino Real qualifies as a Builders’ Remedy Item 8
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project, does that mean the RM-30 and RM-40 portions of the development are allowed to exceed the city’s 30 and 40 ft height limits, despite there being residential properties across the street?

The project site is also located within the El Camino Real Focus Area that allows a maximum height of 85 feet. The RM-30 and RM-40 lots are part of that focus area.

2. Minimal Underground Parking:

The height of the development is definitely out of scale for apartments surrounding this proposal. Unlike Creekside (3400 ECR) and the Fish Market/McDonald’s site (3150 ECR) which have mostly underground parking, can the city of PA require mostly underground parking for this project too?

3. No Entrance/Exits on ECR:

Unlike the aforementioned projects, why are there no exits from this development onto el Camino Real (as per 3400 and 3150 ECR)? It is unbelievable that this project would subject the neighborhoods to this much traffic for those avoiding ECR traffic, especially with the No Right Turn on Red rule at Matadero. Kendall (curvy and narrow) and Matadero (no bike lanes, parking on sides allowed, major route to schools) are not designed for this volume.

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As you know, Barron Park is landlocked on 2 sides so all traffic short-cutting through the neighborhood streets coming from Creekside and 3606 (as currently proposed) will travel down 3 streets—Whitsell, Kendall, Barron--through this sidewalk-less neighborhood.

There are also issues with the Matadero driveway passing between 2 smaller apartment buildings, posing some dangers for those living there.

4. Parking
: Why should a developer be allowed to not provide parking for all its residents but be allowed to lease parking?!!
Plans indicate 321 residential units and the required parking spaces in the El Camino Real Focus Area are 1 space per 1 unit. The project is proposing 391 spaces and compliant with the zoning code.

5. Protections
: What with all the proposed developments happening between Page Mill and Los Robles, does the city have some authority to enact any of the following:

a. Retain the driveways on both Matadero and Kendall for service vehicles (garbage, deliveries, EMS), but disconnect them from the residential parking.

d. Install speed bumps on Kendall, Whitsell, Barron, and Josina as needed.

e. Enact No Right Turn between 8:30 and 9:30 am Mon-Fri on Matadero and Kendall.

f. Remove the ECR cross-lane access at Kendall, which is already dangerous, and make Barron a fully-signaled intersection (not just a signaled cross-walk when pushed).

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g. Barron Ave is extremely restricted between ECR and Whitsell—narrow, tree-lined.

Perhaps it too needs a no turns between 8:30 - 9:30 am?

H. Matadero is already impacted by traffic and the No R on Red law at ECR. What with the many large proposed developments, could the city remove this restriction at Matadero?

i. All of these larger developments do not provide for all the potential parking needed, even 3150 which is a pretty stellar development. Where are all the approximate 300 drivers going to park when ECR no longer allows it? Some people may not use cars, but from my experience as a cyclist, even my able-bodied, clever neighbors still hop in their cars to travel 1 mile!

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.

Thanks for any useful input to guide our city into healthy development which considers both the needs of future and current residents.

Star Teachout
3550 Whitsell Avenue

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From: Fei Li
To: Switzer, Steven
Subject: Re: 3606 El Camino Project
Date: Thursday, November 20, 2025 3:22:31 PM
Attachments: image001.png
image002.png
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi Steven,
Thank you for taking the time getting back to me, I really appreciate it. I will check the website on regular basis to stay informed.

Hope you have a wonderful holiday season.

Fei
On Thu, Nov 20, 2025 at 11:38 AM Switzer, Steven <[email protected] > wrote:

Hi Fei,
For project updates, feel free to contact me or visit the project’s webpage: 3606 El Camino Real.

We are tentatively scheduled for the upcoming December 4th Architectural Review Board (ARB) Meeting. You are welcome to attend that meeting at 8:30 am via zoom or in- person to provide comments. Alternatively, you can provide written comments on the project prior to the public hearing.

As for demolition, the project would need to be approved prior to obtaining any permits for demolition. It is hard to give an exact timeline, but it is unlikely that it would occur within the next year. Your property manager/landlord would also be a great resource to contact about how to plan for a potential move.

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]
www.PaloAlto.gov
From: Fei Li <[email protected]>
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Sent: Thursday, November 13, 2025 12:46 PM
To: Switzer, Steven <[email protected]>
Subject: 3606 El Camino Project
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Good afternoon Steven,
Hope this email finds you well. I am a resident of 528 Kendall Ave, Palo Alto, CA 94306 and I noticed a recent update on
3606 El Camino Project
https://www.paloalto.gov/Departments/Planning-Development-Services/Current- Planning/Projects/3606-El-Camino-Real
Do you have a rough time line you you can share with me about the demolition so that I can plan accordingly?
Thank you and I am looking forward to hearing from you.

Best regards,
Fei
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From: Fei Li
To: Switzer, Steven
Subject: Re: 3606 El Camino Real Project started?
Date: Monday, June 9, 2025 11:44:41 AM
Attachments: image002.png
image001.png
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Hi Steven,
Thanks for the information, have a great day!
Fei
On Mon, Jun 9, 2025 at 11:32 AM Switzer, Steven <[email protected] > wrote:

Thanks for the image.

The project is still under review, so no work has been approved with regards to the planning entitlement.

The truck pictured might be related to another item that is out of the project scope.

Steven Switzer
Historic Preservation Planner
Planning and Development Services Department
650-329-2321 | [email protected]

www.PaloAlto.gov

This message needs your attention
This is a personal email address.

Mark Safe Report
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From: Fei Li <[email protected]>
Sent: Saturday, June 7, 2025 1:31 PM
To: Switzer, Steven <[email protected]>
Subject: 3606 El Camino Real Project started?

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi Steven,

I am a resident of 528
Kendall Ave, Palo Alto, CA 94306, which is part of 3606 El Camino Real project. I reached to your team before regarding to the project and I noticed people started working on the empty land in front of it this weekend.

Is the project started already? And do you have an estimation when will 528 Kendall Ave building be demolished?
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Thank you,

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Fei
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From: Art Liberman
To: Switzer, Steven
Cc: Helen Wang; Kellie Stafford; Kristan Green; John King; Dror Katzav; Mircea Subject: Re: ARB 12/4/25 24LPN-00162
Date: Monday, November 24, 2025 6:00:56 PM
Attachments: image002.png
image001.png
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
i
Mr. Switzer - the plans for 3606 El Camino show the entry and exit from parking for all the apartments going onto Matadero Avenue (Site Plan). Matadero Avenue is a narrow street with space for one traffic lane in each direction. It is a collector street, being one of only two streets that go into and out of Barron Park that have signalized intersections on El Camino. Furthermore, Matadero is a designated Bicycle Boulevard by the City of Palo Alto and is also a safe route for children who walk to and from school (iit is on the Walk and Roll Map for Barron Park Elementary School). Because there are Bicycle Lanes on El Camino, the City of Palo Alto has instituted No Right Turn on Red at this and every signalized intersection with El Camino. Unless this plan is changed, i think you and anyone with any knowledge of the neighborhood would know that the backup and gridlock on Matadero would become horrendous each and every morning! In fact, people living at this address may not be able to leave their apartment. The Creekside Inn project, across Matadero Avenue from this project initially had exit and entrance from parking on Matadero Avenue but they changed their plans to have entrance and exit from El Camino. Something similar needs to change for this project as well.

Art Liberman
member of PABAC
On Monday, November 24, 2025 at 01:58:36 PM PST, Switzer, Steven <[email protected]> wrote:

Hi Micrea,

The plans are quite large to send via email. However, the plans are available online at the following webpage:

https://www.paloalto.gov/Departments/Planning-Development-Services/Current- This message needs your attention
This is a personal email address.

This is their first mail to some recipients.

Mark Safe Report
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Planning/Projects/3606-El-Camino-Real

A staff report will be published later this week detailing the project’s consistencies and inconsistencies with applicable standards.

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]

www.PaloAlto.gov

From: Mircea <[email protected]>
Sent: Monday, November 24, 2025 12:13 PM
To: Switzer, Steven <[email protected]>
Cc: Helen Wang <[email protected]>; Kellie Stafford <[email protected]>; Liberman, Art <[email protected]>; Kristan Green <[email protected]>; John King <[email protected]>; Dror Katzav <[email protected]> Subject: ARB 12/4/25 24LPN-00162

CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Steven,
Could you please send me an email with the submitted plans and any reports that quantify why the development is entitled as a 7-story building with 13% BMR? It appears this may involve an infill exception under AB 130, and I would like to review the basis for that determination.

I’m also interested in understanding how the transition to residential has been addressed on CN, RM-30, RM-40 and what is the zoning used for the entire project?
Thanks,
Mircea
650-996-1114
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From: Penny Brennan
To: Switzer, Steven
Subject: Re: Public Comment on Major Arch Review App for 3606 El Camino [24PLN-00162] (12-4-25 meeting) Date: Thursday, December 4, 2025 5:32:29 PM
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i
Hi Steven,
Thank you for your response to my comments. Unfortunately, because I was alloted only 2 minutes to speak, I was unable to read out the points regarding hazards posed by this project to children bicycling to Barron Park, Fletcher, and Gunn schools, and potential earthquake and fire emergency issues related to this very large, high density building. I hope that the ARB will read my email that included these points and that the information my email contained will reach City Council along with other material pertaining to the proposed project. If you think it will not reach City Council, do you advise me sending a new email to them so that my opinions will be read by them?
I have one additional comment after attending the ARC meeting this morning. During the meeting I was somewhat shocked to learn that the building designers have placed the main entry/exit for cars, people, Uber/Lyft pick-ups, and deliveries at the Matadero side of the building, close to the intersection of Matadero and El Camino. The designers and Board seemed unconcerned about, or perhaps unaware of, the narrowness of Matadero there, Matadero as an already conjested traffic corrider at certain times of day, and as a major bicycling route for Ventura kids going to/coming from school, and the fact that that entry way will face another housing project of major size, at the site of what is now the Creekside Hotel. Is the plan for the Creekside Hotel property to also have its main entry on Matadero near the intersection of Matadero and El Camino? The current placement of the main entrance to 3606 El Camino on Matadero, near the intersection of Matadero and El Camino, is quite problematic.

Thank you for considering my comments and your help steering them to the proper recipients.

Best regards,
Penny
On Thu, Dec 4, 2025 at 9:58 AM Switzer, Steven <[email protected]> wrote:

Hi Penny,
This message needs your attention
This is a personal email address.

Mark Safe Report
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Thank you for the public comment on this item. I will add it to the project file.

While it past the time to be added with the posted agenda packet, I would invite you to speak at the meeting today and voice your comments.

We will send these public comments to the ARB with the next meeting packet.

Steven Switzer
Senior Historic Planner
Planning and Development Services Department
650-329-2321 | [email protected]

www.PaloAlto.gov

From: Penny Brennan <[email protected]>
Sent: Thursday, December 4, 2025 12:15 AM
To: Architectural Review Board <[email protected]>
Cc: Switzer, Steven <[email protected]>
Subject: Public Comment on Major Arch Review App for 3606 El Camino [24PLN-00162] (12-4-25 meeting)

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Dear Architectural Review Board:

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I am writing with reference to the Major Architectural Review Application for 3606 El Camino Real [24PLN-00162], to be discussed at the 12-4-25 meeting of the Architectural Review Board.

My name is Penny Brennan. I live about half-way down East Matadero Ave, across El Camino from the proposed building site, in the Ventura neighborhood.

It appears from the addresses of the to-be-demolished buildings that the footprint for the proposed project will span El Camino between Matadero Ave and Kendall Avenue, lengthwise; depth-wise it will span almost 2 blocks from El Camino toward Whitsell.

I oppose the proposed project for several reasons:

1. A high density (321 units), 7-story building at this location would be at dramatic odds with the appearance and character of the Barron Park and Ventura neighborhoods it would be placed in and adjacent to. If it is designed similarly to most of the recently built developments along El Camino, it will have a modern, concrete-and-glass urban design completely at variance with the almost rural, single-family residential character of the surrounding Barron Park neighborhood and with the post-WW II Palo Alto "working class" character of the Ventura neighborhood across the street from it.

2. A 7-story building at this location is going to tower and loom over that part of the Barron Park and Ventura neighborhoods. For example, from my kitchen window, which faces El Camino, I look out now at my neighbors' trees and the sky above them. If the proposed building is constructed, this view will be replaced by a view of six stories of concrete siding and glass windows.

3. I estimate that a building with 321 units will represent a population of at least 600-1300 individuals. Likely residents of each unit will own 1-2 cars, translating to 300-600 vehicles that will require parking and egress to and from the building complex.

a. What is the parking plan for all of these cars? There are no, or almost no, available parking places along the streets bordering the proposed project (El Camino, Matadero, and Kendall), and parking has become severely limited on the streets across the street from the proposed site (Margarita, E. Matadero, and Wilton) due to recent implementation of dedicated bike lanes along El Camino and the popularity of restaurants (such as the Hong Item 8
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Kong Restaurant) and other businesses across the street from the proposed site.

b. Egress of 300-600 cars to and from the proposed building site on to El Camino via Matadero and Kendall will be problematic. These are both very narrow streets, already well- populated with cars seeking access to and from the Barron Park neighborhood.

c. I am concerned about the safety of bicyclists who would need to share the Matadero, Kendall, and Whitsell roads with the 300-600 new vehicles the proposed building would bring. The Matadero-El Camino intersection, and the narrow Matadero street beyond it, are already hazardous for the many children who ride their bikes from the Ventura neighborhood to their Barron Park Elementary, Fletcher Middle, and Gunn High schools.

The danger will only increase if these and other bicyclists must compete for safe space with the 300-600 additional cars the proposed 321 unit, 7-story development will bring.

4. I am also concerned about earthquake and fire safety related to development of such a tall, high density building in the Barron Park and Ventura neighborhoods. To what extent might neighboring and nearby residents in 1-2 story homes be put at risk of physical harm by catastrophic earthquake and fire events in the proposed very tall, high-density building? How might evacuation, rescue, and other emergency efforts be hampered by the size, density, and poor egress of the proposed building? In the event of earthquake and fire emergencies, does Palo Alto have sufficient emergency services resources to respond adequately to emergency needs of the 600-1300 residents in this building in addition to the needs of existing residents in the Barron Park and Ventura neighborhoods?

Thank you for considering my concerns as you make decisions about the suitability of the proposed project for the Barron Park and Ventura neighborhoods of Palo Alto.

Sincerely,
Penny Brennan, PhD
Ventura Neighborhood
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From: Penny Brennan
To: Planning Commission
Cc: Armer, Jennifer; Switzer, Steven
Subject: "NO" on 3606 El Camino proposed project
Date: Thursday, February 5, 2026 9:01:28 AM
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Dear Members of the Palo Alto Planning and Transportation Commission,

I am writing to ask that you send a "NO" recommendation to the Palo Alto City Council regarding approval of the proposed 3606 El Camino building project.

The plan to build a 7-story, 321- unit building at 3606 El Camino Real was passed on to City Council for approval by the Architectural Review Board (ARC) on December 4, 2025. In the December 4 meeting, ARC did not consider serious safety hazards that the project poses to Palo Alto residents who live nearby in the Barron Park and Ventura neighborhoods. I am hoping you will do so.

As you know, the site of the proposed 3606 El Camino project spans the length of El Camino between Kendall Avenue and Matadero Avenue. Both of these are narrow, 2-lane roads. The proposed project sits diagonally on the busy, 4-lane intersection of El Camino Real and Matadero-Margarita Avenues.

The new dedicated bike lanes along El Camino Real prevent placement of the building's main entry/exit on El Camino Real. The building's designers have sited its main entry/exit on Matadero Avenue, close to the intersection of El Camino Real and Matadero-Margarita Avenues. The renderings shown by the designers during the December 4 ARC meeting suggested that Matadero Avenue is a boulevard of the same size and dimensions as El Camino Real. It is not. It is a narrow, 2-lane road, with no sidewalks and little parking; cars frequently park blocking the bike lanes, along its length stretching to Bol Park.

At the December 4 ARC meeting there was no discussion among ARC members of safety hazards posed by the placement of the main entry/exit of a 7-story, 321 unit building on Matadero Avenue, proximal to the busy intersection of El Camino Real and Matadero- Margarita Avenues. Every one of the building residents' > 300 vehicles, and those of their visitors, as well as delivery trucks, service providers, Ubers/Lyfts, building maintenance, and other vehicles will have to enter and exit the building through this Matadero main entry/exit.

ARC did not discuss how pedestrians can safely negotiate through/past this busy, vehicle- heavy entry/exit.

Note that the new Creekside Inn housing development will be sited at the other corner of El Camino Real and Matadero Avenue, across the street from 3606 El Camino's Matadero main main entry/exit. The Creekside Inn development cannot site its main entry on El Camino Real due to the new El Camino Real dedicated bike lanes. Is it the plan to also site the Creekside Inn project's main entry/exit on Matadero Avenue, so that it will be directly across the street from 3606 El Camino's main entry/exit?
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The intersection of El Camino Real and Matadero-Margarita is going to become an extremely hazardous traffic nightmare. There will be a back up of the many vehicles that need to access the 3606 El Camino building's Matadero Avenue building entrance via the southbound lane of El Camino Real, and many of these vehicles already disregard the rule that prohibits occupation of/right turns on red over the dedicated bike there. This will pose ongoing danger to bicyclists traveling southbound along El Camino Real. It is not clear how these vehicles, or northbound vehicles making lefts off El Camino on to Matadero, can make their next left, into the Matadero main entry/exit, without blocking the considerable traffic headed up Matadero toward El Camino Real to exit the Barron Park neighborhood. Note that, if you miss your left turn into the Matadero main exit/entry, there are no good U-turn opportunities later down Matadero to correct your course. The Barron Park region of Palo Alto is semi-rural in road structure, featuring narrow, often winding roads without sidewalks. Drivers will seek U-turn opportunities by driving further down the narrow Matadero road toward Bol Park, or into the narrow Barron Park neighborhood streets, to use residents' driveways to make their U-turns back toward the 3606 El Camino building. Speeding cars on Barron Park streets are already hazardous for pedestrians and bicyclists. Incursion of more vehicles whose drivers seek U- turns back to 3606 El Camino will only increase this danger.

My biggest concern is for the safety of bicyclists, most of them children, who must cross the El Camino Real - Matadero/Margarita intersection to travel down narrow Matadero, then other narrow, winding Barron Park streets, to reach their destinations of Barron Park Elementary, Fletcher Middle, and Gunn High schools. This intersection is already harrowing, and biking through Barron Park roads is already dangerous for the children who commute to Barron Park Elementary, Fletcher Middle, and Gunn High schools, as well as adults bicycling to Stanford and adjacent Industrial Park businesses. The increased volume of vehicles on these roads, and traffic problems caused by the siting of the 3606 El Camino building main entry/exit on Matadero Avenue, are going to vastly increase this danger.

I have one other concern regarding safety of the proposed 7-story, 321 unit building at 3606 El Camino. I am very concerned about earthquake and fire safety related to construction of such a tall, high density building at this location. To what extent might neighboring and nearby residents in 1-2 story homes be put at risk of physical harm by catastrophic earthquake and fire events in the proposed 7-story, 321-unit building? How might fire fighting, evacuation, rescue, and other emergency service efforts be hampered by the height, density, poor egress, and narrow streets surrounding the proposed building? In the event of earthquake and fire emergencies, does Palo Alto have sufficient emergency services resources to respond adequately to emergency needs of the 600-1300 residents in this building, plus the needs of the several hundred residents of the adjacent Creekside Inn building(s), in addition to the needs of the existing residents, living in 1-2 story homes, in the Barron Park and Ventura neighborhoods? I am concerned that the very tall, high density 3606 El Camino project endangers the lives and safety of its neighbors by placing excessive burden on existing emergency service resources allotted to this region of the city of Palo Alto.

I urge you to recommend "NO" to City Council regarding the proposed 3606 El Camino project, on grounds of the serious safety hazards it poses Palo Alto residents in the Barron Park and Ventura neighborhoods.

Sincerely,
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Penny Brennan, PhD
Ventura Neighborhood
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April 13th 2026
3606 El Camino Real Proposed Multifamily Project
Developer Letter
Dear Honorable Councilmembers,
We are pleased to present 3606 El Camino Real, a 321-unit multifamily residential development that directly responds to Palo Alto's critical housing needs and the City's long-term vision for El Camino Real. This project was filed in February 2024 under California's Builder's Remedy provision — a state law that allows housing projects to proceed outside of local zoning restrictions in jurisdictions whose Housing Element had not yet received HCD certification. At the time of filing, Palo Alto's Housing Element had not been certified, which occurred in August 2024. The project also invokes State Density Bonus Law and Assembly Bill 130, which provides a CEQA exemption for qualifying infill housing projects.

While this is not a conventional entitlement pathway, we have taken care to design a project that is thoughtful, appropriately scaled, and reflective of the City's vision for El Camino Real. The project delivers 321 units of new housing — including 37 units affordable to low-income households at or below 80% AMI, consistent with AB 1893's affordability requirements. We recognize that the project's affordability component has evolved since the original filing, and we are committed to delivering these 37 BMR units as a meaningful contribution to the City's housing goals.

Beyond housing, the project offers tangible community benefits: it activates an underutilized commercial stretch of El Camino Real with an architecturally engaging building; it improves streetscape conditions at the entrance to the Barron Park neighborhood, including adding sidewalks where none currently exist; and it is broadly consistent with the El Camino Real Focus Area Plan and its Objective Design Standards.

To date, the project has gone through two formal public review processes. At the Architectural Review Board, we received design feedback that we incorporated into the current plans — including a fin design motif at the Kendall corner, an accentuated massing break along El Camino Real, enhanced landscaping on the south side to transition the building into the neighborhood, and improved connections to the tertiary courtyard. Those changes strengthened the design and are reflected in the current submittal.

At the Planning and Transportation Commission, questions were raised regarding the project's garage access locations. The vehicle access follows Palo Alto's Objective Design Standards (ODS

18.24.030(b)) which states that “Vehicle access shall be located on alleys or side streets when they abut the property.” This project benefits from distribution through two separate points of vehicular entry — one on Matadero Avenue and one on Kendall Avenue. This approach reflects Item 8
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standard traffic engineering practice: locating driveway access on side streets rather than arterials reduces conflict points on high-volume roadways, and distributing access across two locations spreads traffic more evenly across the surrounding street network. The Palo Alto objective design standard is particularly sensible for this site, because vehicle access on El Camino Real would introduce substantial conflicts. El Camino Real has also been the subject of recent public investment in separated bicycle infrastructure; an additional driveway cut along that frontage would introduce a new vehicle-bicycle conflict point along those facilities. Further, an independent review conducted by Hexagon Transportation Consultants evaluated the entry locations and confirmed that the Matadero and Kendall entries are appropriately sited relative to traffic distribution and street safety. We have further reinforced both entries with internal stop signs and visual and audio warnings to alert pedestrians and cyclists when vehicles are exiting. Combined with new sidewalk improvements along the project frontage on Matadero and Kendall, these elements represent a meaningful net safety enhancement for the surrounding neighborhood.

We are grateful to City Council, City staff, the ARB, and the PTC for the time and rigor they have brought to reviewing this project. We look forward to your support for bringing 321 new homes to Palo Alto.

Sincerely,
Alex Giovannotto
Vittoria Management, Inc.

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3606 El Camino Real
Design Updates
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Building Massing and Façade Articulation
ARB members expressed concern
that the building appears too long
and visually massive and
encouraged additional façade and
roofline breaks to reduce perceived
bulk.
1 1
2 Increased contrast at the
recessed massing break to more
clearly articulate the change in
plane and strengthen the
building’s visual breakdown.
2 Added roofline breaks to
reduced the perceived bulk of
the building.

ARB Comment
Design Response
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Transition to Neighborhood
ARB members expressed concern about the
transition to adjacent lower-scale residential
areas and recommended strategies to reduce
impacts on neighboring properties.
1 1 Updated the podium level to include
landscaping along the south side to
soften the visual experience of 3606.

The building perimeter is lined with
trees to further soften the project’s
edge and enhance the transition to
neighboring properties.

ARB Comment
Design Response
2 2
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Street- Facing Experience along Kendall
While parking is well screened from El
Camino Real, ARB members noted that the
Kendall-facing façade lacks sufficient
articulation and encouraged additional
façade breaks and design features to
enhance the pedestrian experience and
better screen the garage.

The Kendall/ECR corner was
enhanced to create a more prominent
corner presence and incorporate the
fin motif used at the Matadero corner,
fostering a more welcoming
pedestrian experience, adding design
interest, and maintaining the
effectiveness of the garage screening.

ARB Comment
Design Response
1 1
Existing Condition
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Open Space and Amenity Design
ARB members noted that some third-floor
amenities appear underutilized or inaccessible
and recommended better connectivity, expanded
roof decks, and improved usability of shared open
spaces.
1 1 Shifted the floor plans to allow access
from the corridor to the small courtyard
on the south leg of the building.

Ensured that residential patios on the
podium provide as much usable
outdoor space as possible.

ARB Comment
Design Response
2 2
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April 25, 2025
Palo Alto Planning Department
250 Hamilton Avenue - 5th Floor
Palo Alto, CA 94301
Re: Invocation of “Builder’s Remedy 2.0” Under AB 1893, and CEQA Compliance for the Housing Development Project at 3606 El Camino Real (24PLN-00162) Dear All:

This firm represents Vittoria Management, Inc. (the “Applicant”) in connection with its application for a housing development project consisting of 335 multifamily units (the “Project”) at 3606 El Camino Real (the “Project Site”) in Palo Alto (the “City”). The City determined the Project’s application complete for Permit Streamlining Act purposes on December 23, 2024. As explained in more detail in our previous communication, the Project is protected by the Housing Accountability Act (the “HAA”) inclusive of the Builder’s Remedy provision. The Applicant has also secured vested rights to develop the Project pursuant to the Housing Crisis Act of 2019 (“SB 330”), and the Project Site has been included in the City’s housing site inventory for its 6 th cycle
Housing Element.1 The purposes of this letter are to:

1. Document the Project’s eligibility for and affirmatively invoke the protections of Assembly Bill (“AB”) 1893, also known as “Builder’s Remedy 2.0”; and

2. Document the Project’s eligibility for the protections of AB 1633 and the “Infill Exemption” from the California Environmental Quality Act (“CEQA”), pursuant to CEQA Guidelines Section 15332.

AB 1893’s Protections and Its Applicability
AB 1893 went into effect on January 1, 2025 and provides significant new protections for Builder’s Remedy projects. Importantly, its new protections extend to proposals, including the Project, that

1 See the City’s 2023-2031 Housing Element, Appendix D: Site Inventory, available at:
https://paloaltohousingelement.com/wp-content/uploads/2024/08/Appendix-D_Site-Inventory.pdf.

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predate AB 1893’s effective date.2 AB 1893 allows Builder’s Remedy projects to include 13% low income units, 3 and for in- process projects switching to Builder’s Remedy 2.0 to make modifications to their proposal even if they exceed a 20% change in units or square footage.4

The Applicant is hereby electing to convert to Builder’s Remedy 2.0 and include 13% low income units (37 total units when calculated as a portion of the base maximum density per AB 1893) in the now -revised Project. The Applicant reserves all rights it has including under the HAA as amended by AB 1893, or any other state or local laws, to return to its original proposal for the Project if warranted at a later time.

In addition to the above-described provisions, AB 1893 includes the following notable protections, of which we wish to remind the City:

• Local agencies may not require a Builder’s Remedy 2.0 Project to apply for or receive approval of a general plan amendment, specific plan amendment, rezoning, or other legislative approval.
5 Local agencies also may not require a Builder’s Remedy 2.0 Project to apply for or receive any approval or permit not generally required of a non- Builder’s Remedy project of the same type and density.6

• Local agencies may not adopt or impose any requirements (including fees), or undertaking any course of conduct, with respect to Builder’s Remedy 2.0 Projects that do not apply to other projects.7

• Builder’s Remedy 2.0 Projects are deemed consistent with all applicable local standards and plans, and may not be treated as nonconforming uses. 8 • Prior to AB 1893, the HAA provided only that jurisdictions could not “disapprove” Builder’s Remedy projects, or condition such projects in a manner that rendered the affordable portion of the project infeasible. AB 1893 has significantly expanded the scope

2 See Gov. Code § 65589.5(f)(7)(A) (as amended by AB 1893) (“For a housing development project application that is deemed complete before January 1, 2025, the development proponent for the project may choose to be subject to the provisions of this section that were in place on the date the preliminary application was submitted, or, if the project meets the definition of a builder’s remedy project, it may choose to be subject to any or all of the provisions of this section applicable as of January 1, 2025.”). See also Gov. Code § 65589.5(h)(5) (“Notwithstanding any other law, until January 1, 2030, ‘deemed complete’ means that the applicant has submitted a preliminary application pursuant to Section 65941.1 or, if the applicant has not submitted a preliminary a pplication, has submitted a complete application pursuant to Section 65943.”) (emphasis added). 3 Gov. Code §§ 65589.5(d); (h)(3)(C)(i)(III) (as amended by AB 1893). 4 Gov. Code § 65589.5(f)(7)(B) (as amended by AB 1893). 5 Gov. Code § 65589.5(f)(6)(D)(i) (as amended by AB 1893). 6 Gov. Code § 65589.5(f)(6)(D)(ii) (as amended by AB 1893). 7 Gov. Code § 65589.5(f)(6)(E) (as amended by AB 1893). 8 Gov. Code § 65589.5(f)(6)(D)(iii) (as amended by AB 1893).

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of prohibited actions. In addition to prohibiting a local agency from voting to disapprove a Builder’s Remedy 2.0 Project, AB 1893 also notably prohibits local agencies from:

o Taking a “final administrative action” (other than a vote) that functions as a project disapproval;
9 o Subjecting a Builder’s Remedy 2.0 to more than five hearings;10

o Wrongfully determining that a Builder’s Remedy 2.0 Project preliminary application has expired or failed to establish vested rights in contravention of the Permit Streamlining Act;
11 o Maintaining a “course of conduct undertaken for an improper purpose” that functions as an “effective disapproval” of a Builder’s Remedy 2.0 Project. 12 • AB 1893 also expands the HAA’s prohibition on unlawful conditioning. The local agency is now prohibited from imposing any condition that would render the Builder’s Remedy

2.0 Project as a whole infeasible (rather than just the affordable component of the project).
13 The local agency is also now specifically prohibited from imposing a combination of conditions that would render the Builder’s Remedy 2.0 Project infeasible.14

The Project qualifies for AB 1893, as documented in the following chart:

Summary of AB 1893 Criteria Project Consistency
Affordability (Gov. Code §
65589.5(h)(11)(A)).

The project is a housing development project
that provides housing for very low, low-, or
moderate-income households.

Gov. Code § 65589.5(h)(3): 55 years for
rental units, 45 years for ownership units.
“Housing for mixed-income households” =
Does the project satisfy one of the applicable
affordability percentage requirements?
• Yes, the Project includes 13% low
income units, calculated as a portion
of the base maximum.

Will the affordability of these units be ensured
for the required period?

9 Gov. Code § 65589.5(h)(6)(A) (as amended by AB 1893). 10 Gov. Code § 65589.5(h)(6)(E) (as amended by AB 1893). 11 Gov. Code § 65589.5(h)(6)(H) (as amended by AB 1893). 12 Gov. Code § 65589.5(h)(6)(D) (as amended by AB 1893). 13 Gov. Code § 65589.5(d) (as amended by AB 1893).
14 Gov. Code § 65589.5(f)(6)(B) (as amended by AB 1893).

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Summary of AB 1893 Criteria Project Consistency
• At least 7 % “extremely low income” ;
or
• At least 10 % “very low income”; or
• At least 13% “low income” ; or
• Project contains 10 or fewer units, on a
site smaller than 1 acre, proposed at
minimum density of 10 du/acre
• Yes, the Applicant will ensure
affordability of the rental units for 55
years.

Housing element compliance (Gov. Code §
65589.5(h)(11)(B)).

When application was “deemed complete”
(this includes submission of SB 330
preliminary application or formal
application)15 the jurisdiction did not have a
housing element that was in substantial
compliance16 with this article.

At the time of preliminary application
submittal (or, if no preliminary application
was submitted, the time of submission of a
complete formal application), was the
jurisdiction’s housing element certified as
substantially compliant by HCD or a court of
competent jurisdiction?
• No – project qualifies for this
requirement.

Maximum density (Gov. Code §
65589.5(h)(11)(C)).

Must comply with the greatest of the
following densities (plus can add any density
bonus per State Density Bonus Law):
(i) The density does not exceed the greatest
of the following densities:
(I) Fifty percent greater than the minimum
density deemed appropriate to
accommodate housing for that jurisdiction
as specified in subparagraph (B) of
paragraph (3) of subdivision (c) of Section
Does the project comply with the applicable
maximum density?
• Yes – Explanation below
Using the options at left, we have identified
the highest density for each APN of the
Project Site, and calculated a weighted
average by percentage of the site that each
APN represents to determine the base
maximum density per AB 1893, as follows:

APN 137-08-016 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre

15 Gov. Code § 65589.5(h)(5).
16 See Gov. Code § 65589.55(a) (“For purposes of a local agency’s approval, conditional approval, or disapproval of a housing development project pursuant to subdivision (d) of Section 65589.5, a housing element or amendment shall be considered in substantial compliance with this article only if the element or amendment was in substantial compliance, as determined by the department or a court of competent jurisdiction, when a preliminary application, including all of the information required by subdivision (a) of Section 65941.1, was submitted or, if a preliminary application was not submitted, when a complete application pursuant to Section 65943 was submitted.”).

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Summary of AB 1893 Criteria Project Consistency
65583.217 (this is known as the “Mullen
density”).
(II) Three times the density allowed by the
general plan, zoning ordinance, or state
law, whichever is greater.
(III) The density that is consistent with the
density specified in the housing element.

Add 35 du/acre to the maximum
summarized above, if any portion of the site
is located within any of the following:
(I) One-half mile of a major transit stop.18
(II) A very low vehicle travel area.
(III) A high or highest resource census
tract, as identified by the latest edition of
the “CTCAC/HCD Opportunity Map.”19
• 5,199 square feet/113,907 square feet
x 80 = 3.651 du/acre

APN 137-08-070 = 40 per zoning x 3 = 120
du/acre + 35 for “high resource” tract = 155
du/acre
• 5,103 square feet/113,907 square feet
x 155 = 6.944 du/acre

APN 137-08-077 = 40 per comp plan x 3 =
120 du/acre + 35 for “high resource” tract =
155 du/acre
• 38,058 square feet/113,907 square feet
x 155 = 51.788 du/acre

APN 137-08-079 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 10,194 square feet/113,907 square feet
x 80 = 7.160 du/acre

APN 137-08-080 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 28,350 square feet/113,907 square feet
x 80 = 19.911 du/acre

17 “The following densities shall be deemed appropriate to accommodate housing for lower income households: (i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre. (iii) For a suburban jurisdiction: sites allowing at least 20 units per acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.” Gov.

Code § 65583.2(c)(3)(B).
18 “‘Major transit stop’ means a site containing any of the following: (a) An existing rail or bus rapid transit station. (b) A ferry terminal served by either a bus or rail transit service. (c) The intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.” Pub. Res. Code § 21064.3.
19 See HCD, 2024 CTCAC Opportunity Map (https://belonging.berkeley.edu/final-2024-ctcac-hcd-opportunity- map).

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APN 137-08-081 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 16,275 square feet/113,907 square feet
x 80 = 11.430 du/acre

APN 137-08-088 = 30 Mullen + 50% = 45
du/acre + 35 for “high resource” tract = 80
du/acre
• 10,838 square feet/113,907 square feet
x 80 = 7.612 du/acre

3.651 + 6.944 + 51.788 + 7.160 + 19.911 +

11.430 + 7.612 = 108.496 du/acre base
maximum for the Project under AB 1893,
prior to using any State Density Bonus Law
bonus. This yields a 284 unit “base”
maximum.

The affordability requirement for AB 1893 is
a portion of the “base” maximum, making the
13% low income requirement equal to 37
units.

The Project achieves the currently proposed
335 units, because 13% low income units
achieves an up to 24.5% density bonus, and
284 (the base) + 70 (the maximum bonus) =
354 which is greater than the currently
proposed 335.

Minimum density (Gov. Code §
65589.5(h)(11)(D)).
(i) On sites that have a minimum density
requirement and are located within 1/2 mile of
a commuter rail station or a heavy rail station,
cannot go below the minimum.
(ii) On all other sites with a minimum density
requirement, the density of the project shall
Does the site have a minimum density
requirement under the local zoning
ordinance? If so, does the project satisfy the
statutory minimum density requirements? If
not, can it be revised to do so?
• Not applicable here – project
qualifies
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not be less than the local agency’s minimum
density or 1/2 of the “Mullen density,”
whichever is lower.20
Site restrictions (Gov. Code §
65589.5(h)(11)(E)).

The project site does not abut a site where
more than one-third of the square footage on
the site has been used, within the past three
years, by a heavy industrial use, or a Title V
industrial use, as those terms are defined in
Section 65913.16.21
Does the project site abut a disqualifying
industrial site?
• No

The Project’s Eligibility for the Protections of AB 1633 and a CEQA Infill Exemption We first note for informational purposes that the Project is eligible for the protections of AB 1633, which became effective January 1, 2024, as documented in more detail in the below chart. Under AB 1633, it is now a violation of the HAA to fail to grant qualifying projects a CEQA exemption, where there is substantial evidence in the record that the project is eligible for such an exemption.

AB 1633 limits the City’s authority to require analysis that is not legally required and beyond the limited scope of its discretion.

20“The following densities shall be deemed appropriate to accommodate housing for lower income households: (i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area:
sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre. (iii) For a suburban jurisdiction: sites allowing at least 20 units per acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.” Gov. Code § 65583.2(c)(3)(B).
21 Gov. Code § 65913.16(b): (4) “Heavy industrial use” means a use that is a source, other than a Title V source, as defined by Section 39053.5 of the Health and Safety Code, that is subject to permitting by a district, as defined in Section 39025 of the Health and Safety Code,21 pursuant to Division 26 (commencing with Section 39000) of the Health and Safety Code or the federal Clean Air Act (42 U.S.C. Sec. 7401 et seq.). A use where the only source permitted by a district is an emergency backup generator, and the source is in compliance with permitted emissions and operating limits, is not a heavy industrial use. […] (11) “Title V industrial use” means a use that is a Title V source, as defined in Section 39053.5 of the Health and Safety Code.21 Item 8
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(1) “[S]ubstantial evidence in the record before the local agency that the housing development project is not located . . .” in the following areas:22 Within specified areas of a coastal
zone23
There are not any parts of Palo Alto that are in the
coastal zone.
“Either prime farmland or farmland of
statewide importance . . . designated
on the maps prepared by the Farmland
Mapping and Monitoring Program of
the Department of Conservation, or
land zoned or designated for
agricultural protection or preservation
by a local ballot measure that was
approved by the voters of that
jurisdiction.”
24 The Project site is not designated prime farmland or farmland of statewide importance by the California
Department of Conservation.
25 The Project site is not
zoned or designated for agricultural protection, but
rather is zoned for urban uses and surrounded by
other urban uses.

Wetlands26 The Project site is primarily developed with urban uses and does not contain wetlands.

A hazardous waste site listed on the
Cortese List “or a hazardous waste site
designated by the Department of Toxic
Substances Control,” unless the
Department of Toxic Substances
Control has cleared the site for
residential or residential mixed uses.
27 The Project site is not listed.28
Within a state-delineated earthquake
fault zone, “unless the development
complies with applicable seismic
protection building code standards
adopted by the California Building
The Project site is not located within a state-
delineated earthquake fault zone.30

22 Gov. Code § 65589.5 .1(a)(1): On a site specified in subparagraphs (A) to (C), inclusive, or subparagraphs (E) to (K), inclusive, of paragraph (6) of subdivision (a) of Section 65913.4.” 23 Gov. Code § 65913.4(a)(6)(A) (as amended by SB 423 (2023)). 24 Gov. Code § 65913.4(a)(6)(B).
25 See https://maps.conservation.ca.gov/DLRP/CIFF/, last accessed April 13, 2025. 26 Gov. Code § 65913.4(a)(6)(C) (“as defined in the United States Fish and Wildlife Service Manual, Part 660 FW 2 (June 21, 1993)”).
27 Gov. Code § 65913.4(a)(6)(E).
28 California Environmental Protection Agency Cortese List: https://calepa.ca.gov/sitecleanup/corteselist/, last visited April 12, 2025.
30 See https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf, last accessed April 13, 2025.

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Standards Commission . . ., and by any
local building department . . ..”29
“Within a special flood hazard area
subject to inundation by the 1 percent
chance of flood,” unless the project
has been issued a Letter of Map
Revision or flood plain development
permit.
31 The Project site is located within the X flood zone
which is not a special flood hazard area.32
Within a floodway, unless the project
has received a no-rise certification.33
The Project site is not located within a floodway.34
“Lands identified for conservation in
an adopted natural community
conservation plan . . ., habitat
conservation plan . . ., or other adopted
natural resource protection plan.”
35 The Project site is designated as an urban area and is not identified for conservation.
“Habitat for protected species
identified as candidate, sensitive, or
species of special status by state or
federal agencies, fully protected
species, or species protected by the
Federal Endangered Species Act . . .,
the California Endangered Species Act
. . ., or the Native Plant Protection Act
. . ..”
36 The Project site is mostly improved with urban uses
and surrounded by urban uses, and the vacant portion
of the Project site appears to be regularly mowed,
and is fenced. We do not anticipate the Project site
contains such habitat.
“Lands under conservation
easement.”37
We do not understand there to be any conservation
easements recorded on the Project site, based on the
Project’s title report.

29 Gov. Code § 65913.4(a)(6)(F).
31 Gov. Code § 65913.4(a)(6)(G).
32 See https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd, last accessed April 13, 2025.
33 Gov. Code § 65913.4(a)(6)(H).
34 See https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd, last accessed April 13, 2025.
35 Gov. Code § 65913.4(a)(6)(I).
36 Gov. Code § 65913.4(a)(6)(J).
37 Gov. Code § 65913.4(a)(6)(K).

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“Within a very high fire hazard
severity zone, as determined by the
Department of Forestry and Fire
Protection.”
38 The Project site is not located within a Very High
Fire Hazard Severity Zone within the State
Responsibility Area as determined by CALFire.
39 (2) The project’s parcel(s) is legal and located “within an urbanized area40 and meets one or the more of the following criteria . . ..”41
Located within 0.5 mile “walking
distance” of “a high quality transit
corridor,” as defined in Public
Resources Code Section 21155(b), or
“a major transit stop,” as defined in
Pub. Res. Code Section 21064.3.
42 N/A. Analysis not required because the Project
qualifies under one or more other criteria.
“[L]ocated in a very low vehicle travel
area”43
N/A. Analysis not required because the Project
qualifies under one or more other criteria.
“[P]roximal to six or more amenities .
. . as of the date of the” application’s
submittal.
44 A project is proximal an amenity if it
is within:
• .5 mile of “[a] bus station” or “[a]
ferry terminal”; OR
1 mile of “[a] supermarket or grocery
store,” “public park,” “community
center,” “pharmacy or drugstore,”
“medical clinic or hospital,” “public
The Project is within 1 mile of the Stanford/Palo Alto
Community Playing Fields; Grocery Outlet; Barron
Park Elementary School; Cornelis Bol Park; and
likely others. Analysis not required because the
Project qualifies under one or more other criteria –
see row immediately below.

38 Gov. Code § 65589.5.1(a)(1)(B) (“Within a very high fire hazard severity zone, as determined by the Department of Forestry and Fire Protection pursuant to Section 51178, or within a high or very high fire hazard severity zone as indicated on maps adopted by the Department of Forestry and Fire Protection pursuant to Section 4202 of the Public Resources Code.”).
39 See https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-and-mitigation/fire-hazard-severity- zones, last accessed April 13, 2025.
40 A parcel is within an urbanized area if it meets the definition provided in Public Resources Code Section 21071.

Gov. Code § 65589.5 .1(b)(5). The Project site is located in an urbanized area because Palo Alto is a qualifying incorporated city because its population, when combined with the populations of contiguous cities Menlo Park and East Palo Alto, is greater than 100,000.
41 Gov. Code § 65589.5.1(a)(2).
42 Gov. Code § 65589.5.1(a)(2)(A).
43 Gov. Code § 65589.5.1(a)(2)(B).
44 Gov. Code § 65589.5.1(a)(2)(C).

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library,” or school serving any grade -
kindergarten to 12th grade.45
75% of the project site’s perimeter (or
3 sides of a 4 sided project site) is
adjoined by urban uses.
46 The Project Site is fully surrounded by urban uses, as shown on Google Maps.

(3) The project’s density meets the following criteria
“[M]eets or exceeds 15 dwelling units
per acre.”47
The Project far exceeds the requirement for at least
15 du/ac.
(4) “There is substantial evidence in the record that”
• The “project is eligible for an
exemption”48; AND
• That any categorical exemption
sought is not barred by an
applicable exception.49
We anticipate that the Project qualifies for the Class
32 Urban Infill Exemption, see the discussion below.

We anticipate that the City will find the Project eligible for a Class 32 Infill Exemption, because it meets the Class 32 Infill Exemption criteria and is not subject to any of the exceptions, as documented below.

1. The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.

45 Gov. Code § 65589.5.1(b)(4).
46 Gov. Code § 65589.5.1(a)(2)(D).
47 Gov. Code § 65589.5.1(a)(3).
48 Gov. Code § 65589.5.1(a)(4)(A)
49 Gov. Code § 65589.5.1(a)(4)(B).

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As revised to proceed under Builder’s Remedy 2.0, the Project is consistent as a matter of law. AB 1893 provides that any project that complies with AB 1893 “shall be deemed consistent, compliant, and in conformity with an applicable plan, program, policy, ordinance, standard, requirement, redevelopment plan and implementing instruments, or other similar provision for all purposes.” 50 On February 7, 2025, San Jose received a Technical Assistance letter from the Department of Housing and Community Development (HCD) that says due to AB 1893, lead agencies cannot rely on subdivision (a) of CEQA Guidelines section 15332 to preclude a projec t that meets the definition of “ Builder’s Remedy” from utilizing a Class 32 Infill Exemption. Builder’s Re medy projects that meet all other criteria for a Class 32 Infill Exemption, and for which none of the exceptions criteria in Section 15300.2 of the CE QA Guidelines apply, are eligible for a Class 32 Infill Exemption.

2. The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses.

The Project Site is approximately 2.61 acres, and is entirely surrounded by urban uses.

3. The project site has no value as a habitat for endangered, rare, or threatened species.

The Project Site is not identified in any regional, state, or federal plans for habitat or conservation.

The Project S ite is developed with urban uses and is surrounded by urban development and significant roadways including El Camino Real, and has no anticipated value as habitat for threatened, rare or endangered species. The vacant portion of the Project Site is regularly mowed and is surrounded by other urban development.

4. Approval of the project would not result in any significant effects relating to traffic, noise, air quality or water quality.

The Project does not entail any unusual methods of construction or particularly impactful use, and we anticipate that the Project will be found not to cause significant traffic, noise, air quality, or water quality impacts.

5. The site can be adequately served by all required utilities and public services.

The Project would not propose unusually intensive uses, and will be required to comply with all local regulations governing the provision of utilities and public services.

Exceptions to Categorical Exemptions
51:

50 Govt. Code §65589.5(f)(1)(D)(iii).
51 CEQA Guidelines § 15300.2.

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1. The project will not have a significant cumulative impact resulting from “successive projects of the same type in the same place, over time.” 52 The Project is a single residential development, and there is no plan to propose “successive” development on the Project Site. Accordingly, we anticipate the City will conclude that the Project will not have any new cumulative impacts related to “successive projects of the same type in the same place, over time.”

2. The project will not “have a significant effect on the environment due to unusual circumstances.”
53 There are no unusual circumstances related to the Project. In determining whether the “unusual circumstances” exception applies, the only questions are (a) whether there is any substantial evidence to support the City’s conclusion that the Project does not have unusual features that distinguish it from other comparable Class 32 infill projects, and (b) whether any project opponents have shown that “the project will have a significant environmental effect.” 54 The Project is a typical infill housing development project and we anticipate that substantial evidence will demonstrate that the Project will not have a significant effect on the environment.

Further, no opponents have demonstrated that the project “will have” significant environmental effects.

3. The project will not “result in damage to scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, within a highway officially designated as a state scenic highway.”
55 The Project has no effect on scenic highways.

4. The project is not “located on a site which is included on any list compiled pursuant to Section 65962.5 of the Government Code.”56
The Project Site is not listed on the Cortese List and it is not designated by the Department of Toxic Substances Control as a hazardous waste site.57

52 CEQA Guidelines § 15300.2(b).
53 CEQA Guidelines § 15300.2(c).
54 Walters v. City of Redondo Beach (2016) 1 Cal.App.5th 809, 822-23 (emphasis in the original). 55 CEQA Guidelines § 15300.2(d).
56 CEQA Guidelines § 15300.2(e).
57 California Environmental Protection Agency Cortese List: https://calepa.ca.gov/sitecleanup/corteselist/, last visited April 12, 2025.

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5. The project will not cause a substantial adverse change in the significance of a historical resource.”
58 The Project Site is not a designated as historic. This exception may only be applied to the extent that designation had already been made on or before the Project’s complete application was submitted.
59 As outlined in this letter, the Project is eligible for AB 1633 and a Class 32 Infill Exemption. The Applicant would like to move forward with the process to complete CEQA, including any specific studies required, and look forward to discussing with the City as soon as possible. We appreciate the City’s attention to this Project.

Sincerely,

HOLLAND & KNIGHT LLP

Genna Yarkin
Chelsea Maclean

58 CEQA Guidelines § 15300.2(f).
59 Gov. Code § 65913.10.

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This firm represents Vittoria Management, Inc. (the “Applicant”), on behalf of whom we are pleased to provide the enclosed formal application for redevelopment of the property at 3606 El Camino Real (the “Project Site”) in Palo Alto, California (the “City”). 1 The project proposes to redevelop the Project Site with 335 multifamily units (the “Project”) , providing high-quality housing in a contemporary architectural style that will create visual interest and enhance the El Camino corridor, while contributing to the City’s achievement of the City’s regional housing needs allocation. As a housing development project, the Project is subject to Senate Bill (“SB”) 330 and protected by the Housing Accountability Act (“HAA”).
2 The purpose of this letter is to transmit the project’s formal planning application. The application provides the information required by the City’s Preliminary ARB Submittal Requirements Checklist and Major/Minor Architectural Review Submittal Requirements Checklist, which we understand to be the City’s requirements for the Project’s formal planning application.

I. SB 330 and the “Builder’s Remedy” Provision of the HAA Pursuant to SB 330, t he Applicant submitted a preliminary application on January 30 2024, with the information required by Government Code Section 65941.1 and paid the City’s required fee on February 15, 2024. Accordingly, the Applicant obtained a vested right to develop a housing 1 The Project Site is composed of APNs: 137-08-16, 137-08-88, 137-08-79, 137-08-80, 137-08-81, 137-08-77, 137- 08-70.
2 Gov. Code § 65589.5. The Project qualifies as a housing development project protected by the HAA because the Project proposes all residential units. Gov. Code § 65589.5(h)(2)(A).

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development project in accordance with the applicable “ordinances, policies, and standards” in effect as of February 15, 2024, subject to a requirement to submit a formal application within 180 days, or by August 13, 2024.
3 The enclosed formal application materials are hereby submitted in satisfaction of that requirement.

An applicant’s vested rights include a right to proceed under the City’s housing element compliance status in effect at the time of the submittal of the Project’s SB 330 preliminary application.4 The compliance status of a jurisdiction’s housing element is determined by the Department of Housing and Community Development (“HCD”) and “HCD’s determination of substantial compliance with the Housing Element [l]aw, or lack thereof, is entitled to deference.”5 As confirmed by HCD, when a preliminary application submittal “occurs at a time when the jurisdiction does not have a compliant housing element, any potential benefits afforded to the applicant as a result of the jurisdiction’s noncompliant status . . . remain throughout the entitlement process even if the jurisdiction subsequently achieves compliance during the entitlement process.”6

Our cover letter for the Project’s SB 330 preliminary application explains in detail why the City’s housing element was not in substantial compliance with H ousing Element law at the time of the Project’s SB 330 preliminary application submittal. Additionally, the Applicant submitted an SB 330 preliminary application prior to the City’s adoption of the City’s housing element on April 15, 2024 and HCD has not yet certified the adopted housing element . Therefore, Applicant’s SB 330 preliminary application vested against the City’s non-compliant housing element and the City must process Applicant’s appl ication for a housing development project regardless of whether the Project complies with the City’s zoning or general plan. 7 The proposal of a housing development project that does not comply with a jurisdiction’s applicable general plan designation or zoning, and which is made while a jurisdiction’s housing element is not in substantial compliance with Housing Element law, is informally known as the “Builder’s Remedy.” As explained in our prior letter, the City is prohibited from disapproving a qualifying Builder’s Remedy project “on the grounds it does not comply with the municipality’s zoning and general plan.”
8 To qualify as a Builder’s Remedy project, the project must include

3 Gov. Code § 65589.5(o)(1); § 65941.1(d).
4 California Housing Defense Fund v. City of La Cañada Flintridge, Los Angeles County Superior Court Case No. 23STPC02614, Order on Petitions For Writ of Mandate and Complaints for Declaratory Relief (“Builder’s Remedy Order”), (Mar. 4, 2024), at 15-16.
5 Id. at 19 (citations omitted).
6 See HCD, “3030 Nebraska Avenue, Santa Monica – Letter of Technical Assistance” (Oct. 5, 2022).

Available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/santa-monica-TA- 100522.pdf.
7 California Housing Defense Fund, Builder’s Remedy Order, at 33 (holding that “the City is required by law to process the application pursuant to the Builder’s Remedy provision of the HAA” and that is is an abuse of discretion to find “that the Builder’s Remedy does not apply”).
8 California Housing Defense Fund, Builder’s Remedy Order, at 1; Gov. Code § 65589.5(d).

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housing “for very low, low-, or moderate-income households,” at the statutorily prescribed levels.9 For purposes of the HAA, housing “for very low, low-, or moderate-income households” includes projects in which at least 20% of the units are rented at affordable rents to lower -income households.10

Here, the Project will reserve 20% of the Project’s units as affordable to lower income households Therefore, because the Project will provide the requisite levels of affordable units and the City’s housing element was out of compliance at the time the Project’s SB 330 preliminary application was submitted, the City may not deny the Project for noncompliance with the existing general plan designation or zoning. For this reason, the Project is not required to, and is not designed to comply in all respects with the Project site’s zoning or general plan designations. The Project design may continue to evolve throughout the processing of the Project’s application because a project’s vested rights are maintained as long as “the number of residential units or square footage of construction” does not change by more than 20%.
11 II. State Density Bonus Law – Right Reserved

By providing 20% of the Project’s units affordable to lower income households, the Project is entitled to the benefits of the State Density Bonus Law (“SDBL”), Gov. Code § 65915. This letter reserves the right to apply for certain benefits under the SDBL at a later date. Pursuant to the SDBL, the Project’s affordability level entitles the Project to all of the following separate categories of benefits:

• (1) A 35% density bonus over the base density;
• (2) Two mandatory concessions or incentives;
• (3) Any required physical waivers of development standards to accommodate the Project; and
• (4) Applicable mandatory residential parking standards.

Because the Project is a qualifying Builder’s Remedy project, the Project is not limited by existing zoning or general plan standards and the City must process the Project’s application consistent with the requirements under state housing law .
12 Although the Project is not required to exercise
the Project’s right to a density bonus, the Applicant reserves the right to apply for density bonus units, up to the maximum, and other protections for which it is eligible. The Project is not required to utilize a density bonus in order to qualify for incentives, concessions, waivers, and parking reductions. Applicant reserves the right to identify and apply for SDBL concessions or incentives, waivers, and parking reductions at a later date.

9 Gov. Code § 65589.5(d).
10 Gov. Code § 65589.5(h)(3).
11 Gov. Code § 655895(o)(2)(E).
12 Gov. Code § 65589.5(f)(1) (any objective policies, standards, or conditions applied to the project must “be applied to facilitate and accommodate development at the density . . . proposed by the development”).

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Please note that the City’s authority to review the “completeness” of the Project’s formal development application is strictly limite d to determining whether the application provided the material contained on the City’s official submittal requirements checklist(s), as they existed at the time of submittal.
13 Additionally, “[i]n any subsequent review of the application determined to be incomplete, the local agency shall not request the applicant to provide any new information that was not stated in the initial list of items that were not complete.” 14 We look forward to receiving the City’s response to the enclosed formal application and welcome further advisory comments in addition to the completeness determination.

Thank you for your attention to this matter, we look forward to working with the City on bringing this project to fruition.

Sincerely yours,

HOLLAND & KNIGHT LLP

Genna Yarkin
Chelsea Maclean

13 Gov. Code § 65943(a); see also Gov. Code §§ 65940, 65941, 65941.5. 14 Gov. Code § 65943(a).

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If you need assistance reviewing the above documents, please contact the Project Planner or call the Planner-on-Duty at 650-617-3117 or email [email protected]
1 0
8 9
3 Project Plans
In order to reduce paper consumption, a limited number of hard copy project plans are provided to Councilmembers for their review. The same plans are available to the public, at all hours of the day, via the following online resources.

Directions to review Project plans and environmental documents online:

1. Go to: bit.ly/PApendingprojects

2. Scroll down to find “3606 El Camino Real” and click the address link

3. On this project-specific webpage you will find a link to the project plans and other important information
Direct Link to Project Webpage:
https://www.paloalto.gov/Departments/Planning-Development-Services/Current-Planning/Projects/3606-El- Camino-Real
Materials Boards:

Color and material boards will be available to view in chambers during the hearing.

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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: City Manager
Meeting Date: April 13, 2026
Report #:2604-6202
TITLE
Approval of City Council Values (as Recommended by Policy & Services Committee), 2026 Objectives, Ad Hoc Purpose Statements, and Committee Workplans (Continued from 3/9/2026 - On March 9, 2026, the Council Received Presentations and Public Testimony; the Item Will be Continued to April 13 for further Council Deliberation and Action - No Public Testimony Will be Heard on April 13.)

RECOMMENDATION
Staff recommends that the City Council approve: (c) Ad Hoc Purpose Statements and Committee Workplans.

BACKGROUND
On March 9, 2026, the City Council considered this item, took action to approve revised Council values and 2026 City Council Group 1 objectives and voted to continue the item to a date uncertain for discussion and action on ad hoc purpose statements and committee workplans.

At the March 9, 2026 meeting, City Council heard the staff presentation and public comments.

The original staff report and attachments are available online here (Agenda Item Number 11):
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=18679

ATTACHMENTS
None.

APPROVED BY:

Ed Shikada, City Manager
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CITY COUNCIL
Colleague’s Memo
Sponsor(s): Vice Mayor Stone & Councilmember Reckdahl
Meeting Date: April 13, 2026
TITLE
Colleagues Memo on Mitigating Impacts of Property Aggregation in Residential Districts ISSUE
In recent years, some Palo Alto neighborhoods have experienced dramatic transformation due to large-scale real estate aggregation by high-wealth individuals and investment entities. In some cases, a single owner has acquired more than ten homes within a concentrated area, investing over $100 million to consolidate parcels into expansive private compounds. These acquisitions often result in:
Multiyear construction projects that congest neighborhood streets, block driveways, and generate persistent noise and disruption.
Non-residential uses of residential parcels, such as illegal conversions to private schools or facilities without a CUP, raise questions about zoning enforcement. Extended vacancies, with homes left unoccupied during and after construction, contributing to neighborhood destabilization and limiting housing supply. Enhanced private security that alter the sense of privacy and community within surrounding blocks.

Residents in affected neighborhoods describe these changes as fundamentally altering community character and disrupting the close-knit social fabric that historically defined Palo Alto’s residential districts. These developments highlight the need for city policies that ensure neighborhood protections, limit excessive impacts from property aggregation, and safeguard the availability of housing.

BACKGROUND & DISCUSSION
The aggregation of multiple parcels in low density zones (R-1, R-2, RMD, and RE) has raised growing concerns about neighborhood livability and community stability. Large-scale acquisitions often follow a pattern: homes are purchased at above-market rates, taken off the housing market, and subsequently remodeled, demolished, or consolidated into private compounds. While these projects may be legally permissible under current zoning, their Item 10
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cumulative impacts extend beyond the scope of a single parcel and ripple through the surrounding community.

Neighborhood Impacts. Residents report that extended construction timelines tied to aggregated properties disrupt daily life. Multi-year projects can congest streets with staging and equipment, block driveways, and subject neighbors to ongoing noise and dust. These disruptions are compounded when the same owner initiates multiple, overlapping projects in the same vicinity. Additionally, heightened private security associated with such compounds can create an atmosphere of exclusion and unease, altering the character of traditionally open and neighborly blocks. When private security guards are not identifiable, it produces the unsettling situation of unrecognized individuals lingering in residential areas without clear purpose.

Housing Supply Concerns. Properties within these aggregations are often left vacant for extended periods, either awaiting redevelopment or maintained as non-primary residences.

This practice reduces the available housing stock in Palo Alto at a time when the city is trying to accelerate housing production and address affordability concerns. In some cases, aggregated parcels have been converted to non-residential uses, such as private institutional facilities or private security offices, raising additional enforcement and zoning concerns.

POLICY RESPONSE
To mitigate these impacts, we recommend the council consider the following recommendations as a framework in order to address the aforementioned consequences of property aggregation in our residential neighborhoods.

Aggregation Oversight Overlay
Regulates properties when a single owner (including related LLCs, trusts, other corporate structures, affiliates, or entities working in concert) acquires three or more parcels located within a 500-foot radius of the applicant’s real property in low-density zones (R-1, R-2, RMD, and RE).

Construction Oversight and Compliance Requirements Under the Aggregation Oversight Overlay
Construction Management and Circulation Plan Requirements oAny property owner undertaking construction activity subject to the Aggregation Oversight Overlay that is expected to last more than 180 days within a 1-year period shall submit a Construction Parking and Circulation Plan to the City as part of the standard building permit process. The plan shall include, at minimum:
A designated daily mobilization schedule, including permissible construction delivery and staging hours;
Measures to prevent sidewalk and bicycle lane obstructions, including explicit prohibitions on double parking, and daylighting zone violations; and
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Construction-related parking and staging shall be confined to the site’s frontage along the public right-of-way, unless otherwise authorized by City staff based on demonstrated need and a plan to mitigate impacts on surrounding residents. Any such allowances should also support efficient construction timelines and reduce the overall duration of neighborhood disruption.
Maximum Construction Duration
oTime. Any construction project undertaken on a property regulated under the Aggregation Oversight Overlay, including new construction, major remodels, or phased additions, shall be completed within 24 months from the date of issuance of the first building permit associated with the project. oExtensions. The property owner may request an extension of up to 6 months upon demonstrating to the City that delays were caused by circumstances outside the owner’s control (e.g., force majeure, documented material shortages, etc.).
oViolations of Exceeding Time Limit. Failure to complete construction within the prescribed timeframe, including any authorized extension, shall constitute a violation of the Aggregation Oversight Overlay, enforceable through the private right-of-action provisions, and shall also subject the project to standard City code enforcement actions.
Temporary Moratorium on New Construction and Major Remodels oMoratorium Period. Following the completion of any construction project with a duration exceeding 12 months, no new construction project or major remodel may commence on the same parcel, or any other parcel subjected to the Aggregation Oversight Overlay, for a period of 36 months, measured from the date of final inspection or certificate of occupancy.
oExceptions. The City may authorize an exception to the moratorium only where necessary to address urgent health and safety conditions, code compliance deficiencies, or catastrophic property damage beyond the owner’s control (e.g., fire, earthquake, flooding). Discretionary improvements, aesthetic upgrades, or voluntary expansions shall not qualify.
Enforcement
oTo ensure compliance with construction-related obligations under the Aggregation Oversight Overlay, any owner or tenant of real property located within 500 feet of a regulated parcel shall have standing to bring a civil action as described in the Private Right-of-Action Enforcement section below. oBuilding permits shall not be issued during the moratorium period unless an exception is authorized by the City.

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Vacancy Restrictions
For all parcels regulated under the Aggregation Oversight Overlay, restrict vacancies beyond six (6) months per year.
For purposes of this section, “residential purposes” shall mean occupancy by the same individual or household for at least 183 days within a twelve (12) month period.

Private Right-of-Action Enforcement
Staff has expressed concern that adding new regulations with existing enforcement capacity could further strain code enforcement personnel and risk frustrating residents if violations go unaddressed. To address this, this memo directs staff to return with a draft ordinance establishing a private right-of-action to enhance enforcement of the Aggregation Oversight Overlay. The ordinance should enable impacted residents to initiate enforcement actions directly, providing an additional mechanism to ensure compliance where City resources are limited. The ordinance shall provide that:
Standing
oAny owner or tenant of real property located within 500 feet of a parcel subject to the Aggregation Oversight Overlay may bring a civil action against the owner of a regulated parcel for violations of this section.
Available Remedies
oThe ordinance shall authorize courts to issue injunctive relief, monetary penalties, and attorney’s fees for prevailing plaintiffs, as necessary to ensure compliance.
Notice Requirement
oPrior to filing suit, the complainant shall provide written notice to the City and to the property owner, allowing a reasonable period for voluntary correction.

Failure by the owner to cure within the specified timeframe shall permit the complainant to proceed with civil action.

Private Security Policies
All vehicles used for private security purposes within the City shall display clear and visible signage or markings identifying them as private security vehicles. In addition, any company or individual providing private security services shall obtain a City-issued permit for each vehicle used in such operations.
oEach permit shall include:
An identifiable mark or hang tag issued by the City that must be prominently displayed on the vehicle at all times while conducting security patrols or related activities; and
A listing of the specific properties or areas authorized under the permit as the scope of the security operation.
Private security personnel operating within the City shall, upon request from a member of the public or law enforcement, clearly identify themselves by stating they are Item 10
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permitted by the City to provide private security for the permitted property or area name. All private security vehicles shall comply with the City’s no-idling ordinance and all applicable noise and traffic regulations. Failure to maintain visible identification, provide proper identification upon inquiry, or comply with City ordinances may result in suspension or revocation of the City-issued permit.
Private security shall in no way harass or intimidate members of the public, or otherwise imply that public right of ways is private property. Violations may result in suspension or revocation of the City-issued permit.

RECOMMENDATION
Direct staff to explore a regulatory framework for property aggregation in R-1, R-2, RMD, and RE zones based on the recommendations in this memo. Staff should return to the Policy and Services Committee with policy options and analysis of legal and enforcement feasibility.

FISCAL/RESOURCE IMPACT
Depending on specific approaches to the issues addressed, staff anticipates that the resources required to develop the proposed regulations could be substantial and potentially affect other priorities established for the year. Both research and program design work will be required, due to the application of largely unprecedented land use regulations and anticipating that such regulations could be challenged. Staff from the City Attorney’s Office, Planning and Development Services, and Police Department would be primarily responsible for performing this work.

Specifically:
The proposal would establish a new level of land use regulation that relies on the principle that ownership in one property would trigger regulatory requirements for other properties. Staff will need to evaluate options for codifying such regulation. The City Attorney's Office would be responsible for researching and preparing memoranda on applicable Constitutional and statutory requirements related to proposed land use and building restrictions and regulations of private security services. The City Attorney's Office would also work with Planning and Development Services staff to draft ordinances and administrative regulations.
Enforcement could also require additional staff resources. The proposed authorization of a private right of action would reduce, but not completely eliminate, potential resource impacts. If/when the City receives complaints about potential violations, the City's Code Enforcement Division would be responsible for investigation. If the proposal that a private right of action be a primary enforcement method is not accepted, investigations could present a significant challenge particularly where title to properties is held by multiple entities. Establishing ownership and/or control under such circumstances could be complex and difficult. Code enforcement, planning, and legal staff would also be responsible for responding to questions concerning the new ordinance and its applicability, which may require some investigative work.

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Existing City regulations enable longer construction timeframes, with a primary goal of facilitating completion rather than stipulating specified timeframes. Implementation of the proposed regulations would require setting up a tracking process that does not currently exist. Setting shorter timeframes as proposed can also reasonably be expected to generate similar interest in regulating construction activity in other neighborhoods, which would be a significant undertaking. Should Council wish to proceed with only the application proposed, this specific direction would help limit the resources required. The State of California currently retains responsibility for the licensing of private security service providers. Research will be required to determine the scope of the City’s discretion to further regulate security company activities, as other municipalities have done, and any other constraints on City regulation. This includes, for example, the proposal that security personnel be required to identify themselves to members of the public. The City Attorney’s Office would be responsible for performing this research and the Police Department would be responsible for implementing any local regulations. Should the regulation of security personnel proceed, staff will likely recommend an outsourced model for permitting, and staff will need to evaluate options and administer such a program. Police Department staff also observes that if the additional regulations result in a reduction in private security activities, this could increase calls for service to the Police Department.

ATTACHMENTS
None.

Report #: 2604-6201
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CITY COUNCIL
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: City Manager
Meeting Date: April 13, 2026
Report #: 2603-6167
TITLE
Semiannual Update on 2000 Geng Road Recreational Vehicle Safe Parking Expansion and Summary of Financial Needs

RECOMMENDATION
This report is provided for informational purposes only and does not require Council action.

EXECUTIVE SUMMARY
This semiannual update summarizes program activity at the City-owned, County-operated 24- hour safe parking site at 2000 Geng Road for the period July 1–December 31, 2025 (fiscal year 2026 [FY26], quarters 1 and 2 [Q1 and Q2]). The program provides a safe place for households sheltering in vehicles and connects participants to services intended to support transitions to housing. A summary of funding for this program and other Council adopted draws on the same funding sources is included in this report. This is intended to provide context of the existing funding options and needs in advance of the FY 2027 Proposed Budget process and any new proposed draws on these funds.

Similar levels of households served in FY26 Q1 and FY26 Q2 indicate sustained need for safe parking and service connections in Palo Alto.

BACKGROUND
Safe parking programs provide safe, legal locations where households sheltering in vehicles can park and access services. Santa Clara County operates a 24-hour safe parking lot on City-owned land at 2000 Geng Road, which accepts both passenger vehicles and recreational vehicles (RVs).

The site was originally leased to Santa Clara County beginning September 2020.1 The County contracts with Move Mountain View to operate the program. The lease was amended 1 Council Staff Report, September 14, 2020, Item #9,
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September 18, 2023 to extend the term and prioritize Palo Alto–affiliated residents.3 In response to Council direction (June 18, 2024), the lease was further amended in September 2024 to expand capacity from 12 to 224 vehicles to mitigate displacement impacts related to Caltrans’ removal of parking on El Camino Real.5 On March 10, 2025, Council approved a revenue agreement with Santa Clara County through September 2026 for expanded operations.6 The County funds the original spaces; the City funds the additional spaces at approximately $266,162 annually. The prior update to Council was an information item on October 20, 2025.7
8 Program Model
The program is low-barrier9, meaning entry should not require extensive preconditions.

However, participants still must be willing to engage with program expectations and a basic service plan. A practical standard is that participation requires an acknowledgment of the program’s housing-focused intent10 and length-of-stay expectations11. If an individual explicitly states they do not want any housing pathway or do not want to be involved in services at all, staff may treat that as non-alignment with program purpose, which can limit enrollment or continued participation—while still offering alternative resources and referrals.

Participants receive case management and individualized plans addressing housing, employment, and service needs. The site provides showers, kitchen and laundry access, a children’s library and play area, and access to the Santa Clara County coordinated entry system. 3 Council Staff Report, September 18, 2023,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=3115&meetingTemplateType=2 4 Note, while the agreement allows for expansion of up to 22 total RV spaces, site conditions can accommodate 21 RVs and two passenger vehicles.
5 Council Staff Report, August 19, 2024, Item #100,
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=14361 6 Council Staff Report, March 10, 2025,
https://cityofpaloalto.primegov.com/meetings/ItemWithTemplateType?id=6846&meetingTemplateType=2&comp iledMeetingDocumentId=13423
7 Council Staff Report, October 20, 2025,
https://cityofpaloalto.primegov.com/api/compilemeetingattachmenthistory/historyattachment/?historyId=801baf 85-69ba-448c-892a-1fe602a85b13
cmrs/year-archive/2020-2/id-11513.pdf?t=58031.91; lease was included as a supplemental memo, https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-minutes-reports/reports/city-manager-reports- cmrs/year-archive/2020-2/09142020-item-9-at-places-memo.pdf 9 Low-barrier is defined as an emergency housing model that minimizes requirements for entry to facilitate immediate access for individuals experiencing homelessness. The core goal is to remove obstacles—such as sobriety, income, or ID requirements—that often prevent people from seeking shelter, allowing them to enter "as they are".
10The Santa Clara County Office of Supportive Housing (OSH) provides a comprehensive housing goal sheet that case managers and clients work together to fill out and submit via a secure online database known as HMIS (Homeless Management Information System).
11 Length of stay expectations refer to the fact that safe parking is not meant to be a substitution for housing, but a temporary solution while a “positive solution” is found.

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Eligibility includes living in a vehicle as a primary residence; valid vehicle documentation; and agreement to program rules and participation in case management20.

ANALYSIS
Operations continued at the 2000 Geng Road site as a 24-hour safe parking location with ongoing case management and service connections delivered by the County’s contracted operator (Move Mountain View). The site continued to serve both passenger vehicles and RV households and maintained program requirements related to vehicle documentation, adherence to site rules, and participation in case management.

High-Level Data (FY26 Q1–Q2: July 1–December 31, 2025)
Table #1: Participation
Measure FY26 Q1 (Jul 1 – Sep 30, 2025) FY26 Q2 (Oct 1 – Dec 31, 2025) Total households served 3021 2522
Total individuals served 43 44
Palo Alto-affiliated households 24 21
Palo Alto-affiliated individuals 37 36
Table #2: Exits 23 (Palo Alto-Affiliated Households)
Measure FY26 Q1 (Jul 1 – Sep 30, 2025) FY26 Q2 (Oct 1 – Dec 31, 2025) Total exits 5 6
Permanent housing situations 1 (20%) 2 (33%)
Temporary stay with family/friends 3 (60%) 1 (17%)
Place not meant for habitation 1 (20%) 3 (50%)
Table #3: Length of Stay (Palo Alto–Affiliated Households) Measure FY26 Q1 (Jul 1 – Sep 30, 2025) FY26 Q2 (Oct 1 – Dec 31, 2025) Average length of stay (days) 456 438 (currently enrolled) Median length of stay (days) 312 ---
Avg length of stay for exits (days) Included in Q1 summary 279 (exiting households) 20 Once enrolled, case management intensity may vary depending on acuity and participant needs, typically with a consistent minimum standard of engagement and documentation. Examples include use of a housing goal sheet and tracking service transactions.
21 Total number of households above the number of spaces can be explained by clients moving on from the program. One space may be filled by one household for half the quarter and another household might be served for the second quarter.
22 Total household decrease can be explained by higher length of stay and a lack of affordable housing options for clients to move into.
23In Santa Clara County, an exit from homelessness is defined primarily as a move from an unstable, temporary, or unhoused situation into permanent housing.

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Program Utilization28
Prior reporting indicated utilization at or above 100% prior to expansion and 100% utilization achieved by June 2025 following expansion.

Table #4: Geng Rd. Utilization
Date Number of Vehicles Vacancies Occupancy Rate
July 2025 20 3 87%
August 2025 23 0 100%
September 2025 23 0 100%
October 2025 23 0 100%
November 2025 23 0 100%
December 2025 23 0 100%
Table #5: Intakes
Date Applications Approved Waitlist Not Eligible 29
July 2025 11 - 1 9
August 2025 11 2 4 6
September 2025 12 1 4 8
October 2025 8 2 4 4
November 2025 7 - 4 4
December 2025 10 - 6 6
Waitlist
When program capacity is reached, the program maintains an interest list30 (or waitlist) as a holding stage for prospective participants. The interest list functions as a structured “pipeline” to ensure that people who are not immediately able to enroll can still be tracked, contacted, and prepared for rapid entry when space opens. An intake team manages this list and works through it in order of the program’s established prioritization criteria, initiating outreach when a bed/space becomes available and confirming that the person still wants placement and can meet basic entry requirements. As outlined in the table, as of December 31, 2025, there were six households on the waitlist.
28 Utilization refers to the participants use the of program. 29 There are many reasons that a RV may not be eligible, including and not limited to; lack of proper documentation (registration, insurance etc.), size of trailer (Genge does not accept RVs over 30Ft), etc. 30 Geng Rd. interest list is facilitated through direct referral through an online portal.

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Operationally, it’s common for interest lists to shrink naturally over time—some people will “drop off” if they learn the wait will be lengthy, if they self-resolve, or if they choose another option.

Service Connections
Participants are connected to case management, employment and medical resources, Santa Clara County coordinated entry, and VI-SPDAT assessments for housing prioritization.

System Context
Securing affordable housing in Santa Clara County remains challenging due to limited housing inventory, rising rents, strict housing eligibility requirements, and documentation barriers.

These conditions contribute to longer program stays despite participant progress toward housing readiness.

FISCAL/RESOURCE IMPACT
The budget for safe parking was $447,849 (for approximately 1.6 years (19.5 months, February 1, 2025-September 15, 2026)) or an approximate annual cost of $277,000. The following table summarizes amount remitted to the County for operations and costs expended to date, including City-absorbed utilities costs; there remain approximately 10 months in the program.

Operational costs include personnel (caseworkers, program coordinator, lot monitor, etc.), supplies, security services, portable toilets, and sinks. City utilities include electricity, gas, refuse, sewer, and water.

Table #6: City’s Financial Obligation and Costs to Date Total Maximum Financial Obligation Costs Through December 31, 2025 Operational Costs $392,849 $214,282
Utility Charges $55,000 $23,517
TOTAL $447,849 $237,799
Funding for program operations34 is appropriated through the FY 2026 Adopted Budget. Future funding remains subject to Council approval. Both the contract for the expanded operations and the contract that allows the County to lease the site for safe parking are due to expire in September 2026. Staff have identified constraints with ongoing resources for the expanded safe parking specifically and other homelessness initiatives more generally.

The current expanded safe parking is funded through two sources that are restricted to use for specific activities:
34 For reference, the County funds the original spaces and the City funds the expanded spaces, approximately $266,162 annually.

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Permanent Local Housing Allocation (PLHA) funding from the State is restricted to particular named uses. The City must submit a five-year plan describing how it will spend PLHA. Our current five-year plan sets aside a portion of the funds explicitly for “Activity 6” assisting persons who are experiencing or at risk of homelessness, including supportive/case management services. Other efforts that PLHA funds are expended on, besides supportive/case management services for expanded Geng Road operations, are the Homeless Outreach Team and affordable housing.

The PLHA funds vary each year because they are based on the number of real estate transactions occurring in a jurisdiction. Recent years have trended downward.

Additionally, there are new formula requirements for the next PLHA five-year plan which will reduce the amount of the overall award which can go to Activity 6. Business Tax funding which has allocations specifically for “housing affordability”.

Business Tax funds are expended on a variety of efforts, including the San Antonio Road Area Plan, Palo Alto Homekey Operations, the rental registry program, oversized vehicle phased approach, and Geng Road Safe Parking expansion operations. While fund balances can support this current mix of expenses, and even cover some of the anticipated deficits (e.g., due to less PLHA funding), it would leave a very limited amount for any other purposes. This can be seen in the following table.

Table 7 provides a summary of the existing funding of current programs that pull from funds restricted to affordable housing and homelessness (i.e., PLHA and Business Tax) and projects how those programs could be funded going forward. It does not include consideration of proposed new programs and initiatives (e.g., an oversized vehicle pilot program) that could also draw on these funds.

Table 7: Identifying Potential Funding Constraints
FY 2024 FY 2025 FY 2026 FY 2027 FY 2028
PLHA Allocations (Total) $231,496 $359,817 $395,967 $208,383 $159,718 Homeless Outreach Team $138,898 $215,890 $237,580 $125,030 $95,831 Geng Road Safe Parking
Case Management
n/a $71,963 $79,193 $41,677 $31,944
Affordable Housing* $46,299 $71,963 $79,193 $41,677 $31,944 Typical Services Expensesa
Homeless Outreach Team ($164,682) ($185,218) ($226,301) ($236,076) ($243,158) Geng Rd Safe Parking
Exp. Ops - Case
Management
n/a ($31,616) ($75,682) ($77,952) ($80,291)
Difference
Homeless Outreach Team ($25,784) $30,672 $11,279 ($111,046) ($147,327) Item A
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Geng Rd Safe Parking
Exp. Ops - Case
Management
n/a $40,347 $3,511 ($36,276) ($48,347)
TOTAL ($25,784) $71,020 $14,790 ($147,322) ($195,675)
Business Tax Uses (Housing Affordability)
Revenues $1,651,295 $1,981,933 $2,035,983 $2,091,467
Existing Expensesb
San Antonio CAP ($183,907) ($1,216,093) ($700,000) n/a
Homekey Operations n/a n/a n/a ($1,000,000)
Geng Rd Safe Parking Exp. Ops. Thru 9/26c ($71,611) ($191,000) Rental Registry n/a ($60,000) ($63,000) ($66,150)
Oversized Vehicle – admin/implementation n/a ($157,000) ($251,200)d ($167,467) Proposed (if used to fill funding gaps)
Geng Rd Safe Parking Exp. Ops. – Case
Management
($36,276) ($48,347)
Homeless Outreach Team ($111,046) ($147,327)
Geng Rd Safe Parking Exp. Ops. ($196,730) ($202,632)
Difference
TOTAL $1,395,777 $357,840 $677,731 $459,544
a For FY24-26, these are the total expenses the City is incurring. For FY27 onward, should the City continue to support these programs, these are the total projected expenses. b These are the expenses anticipated in the adopted budget through FY26 and projected for the long-range financial forecast in future years.
c The current approved budget and contract end on September 15, 2026. d There was an administrative error when the oversized vehicles administration and implementation was originally costed for the October 20, 2025 Council item. The proposed amounts in FY27 and FY28 correct that error.

These funding constraints and policy choices will be made during the annual budget process in the coming weeks.

STAKEHOLDER ENGAGEMENT
Stakeholder engagement continues to include regular and as-needed meetings between partners (i.e., Santa Clara County Office of Supportive Housing, Move Mountain View).

Additionally, City staff meets monthly with external stakeholders (e.g., the RV Dwellers group consisting of service providers, City staff, a representative of Stanford University, a representative from Palo Alto Unified School District, members of the faith-based community, people from the philanthropic community, and others who meet monthly and as-needed to discuss and share information relation to Palo Altans living in their vehicles) and bimonthly with other cities to review progress and discuss updates related to homelessness in general, as well as safe parking.

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ENVIRONMENTAL REVIEW
This report is for informational purposes only with no action required by the Council and is there not a project subject to CEQA review.

ATTACHMENTS
None.

APPROVED BY:

Ed Shikada, City Manager
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Item No. 8. Page 1 of 2

City Council
Supplemental Report
From: Jonathan Lait, Planning and Development Services Director Meeting Date: April 13, 2026
Item Number: 8
Report #:2604-6226
TITLE
PUBLIC HEARING / QUASI-JUDICIAL. 3606 El Camino Real [24PLN-00162 & 25PLN-00243]:

Request for Approval of Applications for Major Architectural Review and Vesting Tentative Map to Merge Seven Existing Parcels to Create a 113,907-Square-Foot Parcel and to Construct a Seven-Story, Multi-Family Residential Housing Development Project with 321 Units, Thirteen Percent of Which Would be Provided at a Rate Affordable to Low Income. 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 February 15, 2024. CEQA Status:

Exempt Pursuant to Assembly Bill 130 (Public Resources Code Section 21080.66).

RECOMMENDATION
Staff recommends that Council consider the additional information provided in this report, including the revised Draft Record of Land Use Action.

BACKGROUND
This supplemental memo transmits an updated Attachment B: Draft Record of Land Use Action, reflecting revised stormwater-related conditions of approval and ensuring consistency between materials submitted to the City. Following agenda publication, staff coordinated with the applicant to address outstanding drainage issues associated with the Vesting Tentative Map (VTM). Due to the expedited timelines under Assembly Bill 130, there was insufficient time to fully resolve the proposed stormwater infrastructure during project review.

The applicant‘s proposed stormwater improvements caused concerns for staff over increased public maintenance burdens. In February 2026, the applicant coordinated with City staff to resolve several of these concerns. Those updates are reflected in the Architectural Plan set submitted on February 26, 2026, but are not included in the February 3, 2026, VTM plans.

Accordingly, conditions of approval have been incorporated into Section 8 of the Revised Record of Land Use Action to require that the Final Map reflect the revisions shown in the most Item 8
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Item No. 8. Page 2 of 2
recent Architectural Review Plans as well as additional outstanding items related to off-site drainage improvements.

ATTACHMENTS
Supplemental Attachment A: REVISED Attachment B: Draft Record of Land Use Action (4.8.26) APPROVED BY:

Jonathan Lait, Planning and Development Services Director Item 8
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1 DRAFT ACTION NO. 2026-__

RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO LAND USE ACTION FOR 3606 EL CAMINO REAL: MAJOR ARCHITECTURAL REVIEW AND VESTING TENTATIVE MAP [24PLN-00162 & 25PLN-00243]

On _________, 2026, the City Council of the City of Palo Alto (“City Council”) approved a Major Architectural Review application and Vesting Tentative Map for development of 321 residential rental units (“the project”). In approving the application, Council makes the following findings, determinations, and declarations:

SECTION 1. Background.

A. On February 15, 2024, Camino Real Development LLC & Kendall Investors, LLC filed a compliant pre-application in accordance with Senate Bill (SB) 330 and with California Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy).

B. On June 10, 2024, Camino Real Development LLC & Kendall Investors filed an Architectural Review application (24PLN-00162) for construction of a 321 rental unit residential project. In addition, Camino Real Development LLC & Kendall Investors filed an application for a Vesting Tentative Map (25PLN-00243) on September 9, 2025, to merge seven existing lots to create a single resulting 113,907-square-foot parcel (2.62 acres). The project includes 284 base units and 37 density bonus units, for a total of 321 units, as well as the following density bonus waivers and concessions in accordance with State Density Bonus Law, and additional protections as a “builder’s remedy project,” under AB 1893:
 Waiver 1: Build-to-lines (90% of frontage built to setbacks where a maximum 50% along El Camino Real is required)
 Waiver 2: Upper Story Step Back (None proposed where a 10-foot step-back above 55 feet in height is required)
 Waiver 3: Lot Coverage (83% where maximum 80% is allowed)  Waiver 4: Rear setback (11 feet - 15 feet where a minimum 16 feet is required)  Waiver 5: Rear and Side Daylight Plane (None provided where 10 feet at lot line then 45-degree angle is required)
 Waiver 6: Housing typologies (More than two-acre lots are required to provide a minimum of three housing types)

C. The project site is comprised of seven existing lots: APN No. 137-08-088, approximately 10,838 square feet, developed with a commercial use; APN No. 137-08-016, approximately 5,199 square feet, an undeveloped parcel; APN No. 137-08-079, approximately 10,194 square feet, developed with a commercial use; APN No. 137-08-080, approximately 28,350 square feet, an undeveloped parcel; APN No. 137-08-077, approximately 38,058 square feet, developed with a multi-family residential use; APN No. 137-08-070, approximately 5,103 square feet, developed with a multi-family residential use; APN No. 137-08-081, approximately Item 8
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2 16,275 square feet, developed with a commercial and residential use. Adjacent uses include a mix of commercial and low-intensity, one-story and two-story buildings, as well as low density residential uses surrounded by surface parking.

D. Following staff review, the Architectural Review Board held a duly noticed public hearing to review the Major Architectural Review application at hearing on October 16, 2025, to provide feedback on the design.

E. Following staff review, the Planning and Transportation Commission reviewed the Vesting Tentative Map and recommended denial on February 11, 2026, with Council to consider the following:
 Project and cumulative traffic safety analysis;
 Sidewalk easements;
 Relocating ingress/egress to improve pedestrian and bicycle safety and reduce congestion near El Camino Real intersections; and
 Incorporating portions of the site for a bike path.

F. On ___________, 2026 the City Council held a duly noticed public hearing at which evidence was considered, and all persons were afforded an opportunity to be heard in accordance with the City Council’s policies and procedures.

G. The project site includes parcels in the City’s 2023-2031 Housing Element Site Inventory, with a projected capacity of 6 very low income units, 6 low income units, 8 moderate income units, and 17 above-moderate income units. The project will provide 37 low income units and 284 above-moderate income units. Following approval of the project, the remaining sites in the Site Inventory will be insufficient to meet the remaining Regional Housing Needs Assessment (RHNA) for moderate income units.

H. Including the proposed project, the remaining RHNA and remaining capacity at each income level will be approximately:

Lower Moderate Above Moderate
Remaining RHNA 1,957 899 21
RHNA Credits 598 182 515
Remaining Site
Inventory Capacity 1,825 614 1,902
Surplus/Deficit 466 -103 2,396

I. In accordance with Government Code Section 65863, the City shall, within 180 days, identify and make available additional adequate sites to accommodate the remaining RHNA at the moderate income level.

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3 SECTION 2. Environmental Review. The City, as the lead agency for the Project, has determined the project is exempt from California Environmental Quality Act (CEQA) in accordance with AB 130 [Public Resources Code section 21080.66]. Documentation to support the streamlined review is available as part of the public record on file with the Planning and Development Services Division.

Section 3. Architectural Review Findings. In order to make a recommendation of approval, the project must comply with the following Findings for Architectural Review as required in Chapter

18.76.020 of the PAMC.

1. The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan, Zoning Code, coordinated area plans (including compatibility requirements), and any relevant design guides.

A summary of the project’s consistency with the Comprehensive Plan is provided in this table. Because the project is a “builder’s remedy project,” as defined in Gov. Code section 65589.5(h)(11), and in accordance with Gov. Code section 65589.5(f)(6)(A), the project is required to comply only with objective, quantifiable, written development standards, conditions, and policies that would have applied to the project had it been proposed on a site with a general plan designation and zoning classification that allow the density and unit type proposed by the applicant. Moreover, in accordance with Gov.

Code section 65589.5(f)(6)(D)(iii), a project that complies with such objective standards, conditions, and policies “shall be deemed consistent, compliant, and in conformity with an applicable plan, program, policy, ordinance, standard, requirement, redevelopment plan and implementing instruments, or other similar provision for all purposes.”

Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
The Comprehensive Plan land use designations
for the project site are Service Commercial
(CS), Neighborhood Commercial (CN), and
Multiple-Family Residential (MF) which
allow multifamily housing in specific locations.

The project site includes seven parcels with
varying Comprehensive Plan land use
designations, including Service Commercial,
Neighborhood Commercial, and Multiple-
Family Residential designations. Four of the
seven parcels on which the proposed project
would be located are identified as housing
inventory sites. The project adheres to the
Comprehensive Plan by providing housing on
these opportunity sites. The proposed multi-
family use is allowed within this land use
designation.

Housing Element
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4 Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
Policy 4.3 Implement development standards,
objective design standards, and architectural
and green building standards that encourage
new high-quality rental and ownership
housing.

The project complies with the implemented
standards except where requests for waivers or
concessions in accordance with state density
bonus law is provided. The project provides the
necessary upgrades to infrastructure on the
site to provide new high-quality rental
units. The project complies with all required
green building requirements in accordance
with state law and the city’s local reach code.

Land Use and Community Design Element
Goal L-1 A compact and resilient city providing
residents and visitors with attractive
neighborhoods, work places, shopping districts,
public facilities and open spaces.

The project redevelops existing developed
parcels and provides an attractive development
that is generally consistent with the City’s
design criteria.

Policy L-1.3: Infill development in the urban
service area should be compatible with its
surroundings and the overall scale and
character of the city to ensure a compact,
efficient development pattern.

The project is an urban infill development
proposal in the urban service area of the city.

Policy L-1.4: Commit to creating an inventory
of below market rate housing for purchase and
rental.

The proposed residential project includes 321
rental units, and 13 percent of the base 284
units (excluding density bonus units) would be
provided at a rate affordable to low-income
households or below. This would add 37 low
income rental units to the City’s BMR housing
stock.

Goal L-2 An enhanced sense of “community”
with development designed to foster public
life, meet citywide needs and embrace the
principles of sustainability.

The project is designed to comply with
CALGreen Tier 2 requirements that incorporate
sustainable design, construction, and
operational requirements to reduce energy and
water operational costs and in increase indoor
air quality for building owners and occupants.

Policy L-2.2 Enhance connections between
commercial and mixed use centers and the
surrounding residential neighborhoods by
promoting walkable and bikeable connections
and a diverse range of retail and services that
caters to the daily needs of residents.

The project site is located on and adjacent to El
Camino Real, a local serving and regional
serving corridor, defined by a mix of
commercial uses and housing. Caltrans recently
installed Class III and Class IV bike lanes, which
run along the project’s frontage on El Camino
Real. Residents would be able to utilize these
connections to other surrounding areas.

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5 Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
Goal L-6: Well-designed buildings that create
coherent development patterns and enhance
city streets.

The project frontage along El Camino Real
provides a sidewalk and retains the existing
four street trees. Alongside Matadero Avenue,
the project proposes two new street trees,
alongside Kendall Avenue five new street trees,
and four new trees alongside El Camino Real,
for an inviting streetscape. The project includes
high quality materials such as brick, wood, and
stucco that aid in creating a cohesive design.

Policy L-9.2 Encourage development that
creatively integrates parking into the project,
including by locating it behind buildings or
underground wherever possible, or by
providing for shared use of parking areas.

Encourage other alternatives to surface parking
lots that minimize the amount of land devoted
to parking while still maintaining safe streets,
street trees, a vibrant local economy and
sufficient parking to meet demand.

Parking would be screened behind the first
floor amenity spaces alongside El Camino Real
with the parking garage entrance located along
Matadero Avenue and Kendall Avenue. Further,
391 parking spaces would be provided on-site
exceeding the El Camino Real focus area
parking requirements.

Transportation Element
Policy T-3.7 Encourage pedestrian-friendly
design features such as sidewalks, street trees,
on-street parking, gathering spaces, gardens,
outdoor furniture, art and interesting
architectural details.

The project includes direct connections to the
sidewalk that help to activate the frontage
along El Camino Real in addition to new street
trees and plantings along Matadero Avenue,
Kendall Avenue, and El Camino Real.

Policy T-3.9 Support citywide sustainability
efforts by preserving and enhancing the tree
canopy where feasible within the public right-
of-way, consistent with the Urban Forest
Management Plan, as amended.

The project meets the tree canopy replacement
requirements through on-site plantings. The
project includes removal of 31 trees and
replaces with 129 trees, which are proposed to
be located along property lines, in the right of
way, and within open space areas.

The South El Camino Real Design Guidelines are applicable to the project, to the extent that the standards are objective, and the site is located within the Triangle Area Pedestrian Node. The project is consistent with the Guidelines, below is an analysis of the applicable guidelines:

3.1.1 Effective Sidewalk Width:

Create a 12-foot effective sidewalk width
along El Camino Real
The project proposes a 12-foot effective
sidewalk width.

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6 3.1.2 Sidewalk Setback Design:

The design of the sidewalk setback should
create an urban “downtown” character.

The proposed sidewalk setback includes
areas for short-term bicycle parking and
architectural wall lights.

3.1.3 Build to lines:

Buildings should be built up to the sidewalk
to reinforce the definition and importance of
the street.

The project provides 90% built to the
setback while still providing the effective 12-
foot sidewalk width.

3.1.5 Minimum Height:

Buildings should have a minimum height of
25 feet in order to provide presence along El
Camino Real.

The project is 82 feet in height to the
parapets.

3.3.1 Usable Amenities:

Landscape and hardscape features should
not just be visually appealing, but also
function as open space amenities to be used
and enjoyed.

The project includes outdoor seating areas,
dining areas, and one pool.

4.1.8 Expression of Use:

Building forms should be articulated as an
expression of the building use.

The project has been revised to add
additional definition to the two-story
residential entry area at the building’s
corner. The balconies also provide visible
private outdoor space, identifying the
residential uses.

4.2.1 Relationship of Entries to the Street:

Buildings should have entries directly
accessible and visible from El Camino Real.

The building has a lobby facing El Camino
Real. The leasing entrance facing Matadero
Avenue and secondary entrance alongside
Kendall Avenue are visible from El Camino
Real.

4.3.6 Design Consistency on All Facades:

All exposed sides of a building should be
designed with the same level of care and
integrity.

All sides of the building use the same variety
of materials and level of detail. They are also
articulated for visual interest and to reduce
massing.

4.4.1 Amenities:

Building design should offer amenities to
users and the public such as protection from
the elements and places for people to gather
or retreat.

The project provides a number of public and
private gathering areas.

4.5.1 Flat Roofs and Parapets Encouraged.

Flat roofs with parapets are strongly
encouraged.

The proposed building has a flat roof with
parapet design.

4.8.1 Mix of Materials:

Juxtaposition of contrasting materials can
create interest when carefully integrated.

This project includes stucco, cast stone,
marble, brick, glass, and metal in a
composed design.

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7 2. The project has a unified and coherent design, that:
a. creates an internal sense of order and desirable environment for occupants, visitors, and the general community,
b. preserves, respects and integrates existing natural features that contribute positively to the site and the historic character including historic resources of the area when relevant,
c. is consistent with the context-based design criteria of the applicable zone district,
d. provides harmonious transitions in scale, mass and character to adjacent land uses and land use designations,
e. enhances living conditions on the site (if it includes residential uses) and in adjacent residential areas.

The project is consistent with Finding #2 because:

The project is comprised of various residential amenity spaces at the first floor, third floor, and seventh floor and offers short-term bike racks for visitors and well as long-term bike lockers for residents. There is pedestrian access adjacent to El Camino Real located on Matadero Avenue and Kendall Avenue to promote walkability and connectivity. Cars enter the garage on Matadero Avenue and Kendall Avenue as required per the objective standards. The pedestrian walkways are paved with attractive materials and landscaped. The project proposes to construct a building that is generally taller than the immediately surrounding buildings.

The proposed project is consistent with the findings to provide high quality materials and finishes in a neutral color palette. The building will have residential amenity spaces on the first floor with a majority of those spaces utilizing glazing, which helps to engage the sidewalk.

While the project at 82 feet in height exceeds surrounding development, the project complies with the height limits within the El Camino Real Focus Area and deviates from the objective standards in a manner consistent with state law.

3. The design is of high aesthetic quality, using high quality, integrated materials and appropriate construction techniques, and incorporating textures, colors, and other details that are compatible with and enhance the surrounding area.

The project is consistent with Finding #3 because:

The project proposes a contemporary style that is recognizable along the El Camino corridor overall and aligns with the recent residential development to the north of the project site. The project uses materials such as stucco, cast stone, marble, brick, glass, and metal railings on the Item 8
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8 balconies and metal awnings. As conditioned, the stucco surfaces will be a smooth finish texture. The proposed colors are neutral and are compatible with surrounding color schemes.

The project is located within an area subject to the adopted El Camino Design Guidelines and South El Camino Real Guidelines and is consistent with objective standards set forth in these guidelines.

4. The design is functional, allowing for ease and safety of pedestrian and bicycle traffic and providing for elements that support the building’s necessary operations (e.g. convenient vehicle access to property and utilities, appropriate arrangement and amount of open space and integrated signage, if applicable, etc.).

The project is consistent with Finding #4 because:

The design of the new building includes wider sidewalks on El Camino Real, new sidewalks where none currently exist on Matadero and Kendall Avenues, and does not provide any new curb cuts along El Camino Real, which would have otherwise created additional points of conflict with the existing bicycles lanes. The entrances to the parking garage are consistent with both objective standards set forth in the City’s municipal code Ch. 18.24 as well as best practices for roadway engineering design. Introducing or expanding curb cuts directly along an arterial corridor, particularly a state freeway, creates additional turning conflicts, reduces traffic flow efficiency, and increases safety risks for cyclists and motorists, especially given the newly installed bicycle lanes along the project’s El Camino Real frontage. Additionally, there will be 280 bike lockers and, as conditioned, short-term bike rack spaces provided in accordance with California Green Building Standards Code. By providing increased bicycle infrastructure, the project will improve existing conditions. There are both common and private open spaces available, including private decks for a majority of rental units.

5. The landscape design complements and enhances the building design and its surroundings, is appropriate to the site’s functions, and utilizes to the extent practical, regional indigenous drought resistant plant material capable of providing desirable habitat that can be appropriately maintained.

The project is consistent with Finding #5 because:

The project will provide a variety of drought-tolerant planting, including plantings selected from a California native palette. The selected varieties of trees would provide appropriate habitat for wildlife as a part of a bigger neighborhood and community wide system. Additional landscaping is provided on the terraces of the building.

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9 6. The project incorporates design principles that achieve sustainability in areas related to energy efficiency, water conservation, building materials, landscaping, and site planning.

The project is consistent with Finding #6 because:

In accordance with the City’s Green Building Regulations, the project will satisfy the requirements for CALGreen Mandatory + Tier 2. This is demonstrated on the GB sheets in the plan set.

SECTION 4. Vesting Tentative Map Findings. A legislative body of a city shall deny approval of a Subdivision Map, if it makes any of the following findings (California Government Code Section 66474). The City Council cannot make these findings for the following reasons:

1. That the proposed map is not consistent with applicable general and specific plans as specified in Section 65451:

There is no adopted specific plan for this project site. The site is consistent with the Comprehensive Plan as described below.

2. That the design or improvement of the proposed subdivision is not consistent with applicable general and specific plans:

There is no adopted specific plan for this project site. The proposed Vesting Tentative Map and related improvements is consistent with the Comprehensive Plan in that it facilitates housing development on a site designated for multi-family use within the urban services area, consistent with Goal 2 of the Housing Element and Goal L1.2 of the Land Use Element. The project includes 321 Units, 37 of which would be provided at a rate affordable to low income.

The project improves the city’s jobs housing imbalance, consistent with the Transportation Element’s goals and policies. Because the project is a “builder’s remedy project,” as defined in Gov. Code section 65589.5(h)(11), and in accordance with Gov. Code section 65589.5(f)(6)(A), the project is required to comply only with objective, quantifiable, written development standards, conditions, and policies that would have applied to the project had it been proposed on a site with a general plan designation and zoning classification that allow the density and unit type proposed by the applicant. Moreover, in accordance with Gov. Code section 65589.5(f)(6)(D)(iii), a project that complies with such objective standards, conditions, and policies “shall be deemed consistent, compliant, and in conformity with an applicable plan, program, policy, ordinance, standard, requirement, redevelopment plan and implementing instruments, or other similar provision for all purposes.”

3. That the site is not physically suitable for the type of development:

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10 The Project site is suitable for multi-family residential development in that the majority of the parcels are identified as Housing Inventory Sites in the Housing Element. The project is also located within the City’s El Camino Real Focus Area, an area identified for high density housing within the City. The proposed parcel meets the minimum code requirements for the CN, CS, RM-30, and RM-40 zone districts with respect to lot area, width, and depth. The proposed number of apartment units created on the resulting parcel complies with the applicable densities set forth in the land use element and zoning code, consistent with the focus area standards. In addition, as noted above, the project is proposed pursuant to the “builder’s remedy” of the Housing Accountability Act (Government Code section 65589.5) and is consistent with the standards set forth therein.

4. That the site is not physically suitable for the proposed density of development:

The proposed improvements include a total of 321 multi-family residential units and results in 128 dwelling units per acre (DU/AC) across the resulting parcel. Because the site area is comprised of several lots, there are varying zoning designations across these lots, including portions zoned CN, CS, RM-30, and RM-40. In December 2023, the City Council adopted the El Camino Real Focus Area which established a local alternative to State Density Bonus Law along four properties on El Camino Real between Page Mill Road and Matadero Avenue. In accordance with the Housing Element Implementation, several additional sites were added to the El Camino Real Focus Area in July 2025, including the subject property.

While the zoning code does not set a maximum density for projects on El Camino Real, the improvements are consistent with the density, floor area, and height allowances for sites within the Focus Area. Therefore, the project is physically suitable for the parcel. In addition, the project is proposed pursuant to the “builder’s remedy” of the Housing Accountability Act (Government Code section 65589.5) and is consistent with the densities permitted therein.

5. That the design of the subdivision or the proposed improvements are likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat:

The project is located within the built environment that does not contain quality habitat for fish or other wildlife on the site or within the vicinity of the site. The nearest stream is a portion of Matadero Creek approximately 300 feet northwest from the project site. The adopted Palo Alto 2030 Comprehensive Plan includes Map N-1, which identified sensitive animal and plant species within the Palo Alto quadrangle, a large geographic area that includes the urban portions along the bay and within the foothills, based on information in the California natural Diversity Database (CNDDB). Based on this map, and the urban nature of the site, the subject property does not contain any habitat for endangered, rare, or threatened species.

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11 6. That the design of the subdivision or type of improvements is likely to cause serious public health problems:

The record indicates that insufficient information has been provided to fully demonstrate that the project would not create safety risks for bicyclists and pedestrians, including along safe routes to school. Specifically, a traffic analysis has not yet been conducted for the site.

Cumulative impacts from proposed projects in the vicinity, including the project at 3400 El Camino Real across Matadero Avenue, have not been evaluated.

Notwithstanding this inconsistency, the deviation is permitted under applicable State law, which limits the City’s ability to deny based on such impacts. The proposed multi-family use would not include use or storage of hazardous materials and the use is located within the urban environment adjacent to other commercial uses. The site is not located on a hazardous waste site pursuant to government code 65962.5. However, a portion of the site was previously a gasoline service station that had its underground storage tanks removed and issued a Fuel Leak Site Case Closure letter on July 23, 1997. Additional cleanup of the site for residential uses per standard requirements will be included in the conditions of approval for the proposed improvements.

7. That the design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of, property within the proposed subdivision. In this connection, the governing body may approve a map if it finds that alternate easements, for access or for use, will be provided, and that these will be substantially equivalent to ones previously acquired by the public. This subsection shall apply only to easements of record or to easements established by judgment of a court of competent jurisdiction and no authority is hereby granted to a legislative body to determine that the public at large has acquired easements for access through or use of property within the proposed subdivision.

There are no public access easements over the property currently. Therefore, the design of the subdivision will not conflict with any public easements for access through, or use of, the property. New public utility easements will be provided to existing and proposed electrical utilities as part of this subdivision map as required in accordance with City of Palo Alto Utilities standards. New public access easements will be provided to provide the 12-foot effective sidewalk width along El Camino Real, consistent with project plans and City requirements.

SECTION 5. Vesting Tentative Map Approval Granted. Vesting Tentative Map Approval is filed and processed in accordance to PAMC Section 21.13.020 and granted by the City Council under PAMC Sections 21.12 and 21.20 and the California Government Code Section 66474, subject to the conditions of approval in Section 8 of this Record of Land Use Action.

SECTION 6. Final Map. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Vesting Tentative Map prepared by Kier+Wright Item 8
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12 titled “VESTING TENTATIVE MAP” consisting of eleven pages, dated and submitted February 3, 2026, except as modified to incorporate the conditions of approval in Section 8. A copy of the Vesting Tentative Map is on file in the Department of Planning and Development Services, Current Planning Division. Prior to the expiration of the Vesting Tentative Map approval, the subdivider shall cause the subdivision or any part thereof to be surveyed, and a Final Map, as specified in Chapter 21.08, to be prepared in conformance with the Vesting Tentative Map as conditionally approved, and in compliance with the provisions of the Subdivision Map Act and PAMC Title 21 and submitted to the City Engineer (PAMC Section 21.16.010[a]).

SECTION 7. Conditions of Approval Architectural Review.

Planning

1. CONFORMANCE WITH PLANS. Construction and development shall be in substantial conformance with the approved plans entitled, "3606 El Camino Real – Major Architecture Review” uploaded to the Palo Alto Online Permitting Services Citizen Portal on February 2, 2026, as modified by these conditions of approval.

2. BUILDING PERMIT. Apply for a building permit and meet any and all conditions of provided for in this letter. A copy of this cover letter and conditions of approval shall be printed on the second page of the plans submitted for building permit.

3. BELOW MARKET RATE (BMR) HOUSING. This project is proposed as a Builder’s Remedy project, as defined in AB 1893, and is providing thirteen percent of the proposed 284 base units at prices affordable to lower income households. This also represents an alternative means of compliance with the City’s inclusionary housing requirement stated in Palo Alto Municipal Code Chapter 16.65. The applicant shall execute and record a BMR regulatory agreement in a form satisfactory to the City Attorney. The project shall conform to the approved regulatory agreement, which shall be recorded prior to issuance of building permit or final map, whichever occurs first. All BMR units constructed under this condition shall be in conformance with the City’s BMR Program rules and regulations, as modified by the concession granted pursuant to State Density Bonus Law regarding unit distribution.

Failure to comply with the timing of this condition and any adopted BMR Program rules and regulations shall not waive its later enforcement.

4. RENTER PROTECTIONS. The project is subject to the renter protection requirements set forth in PAMC Section 9.68.060 for no fault evictions for rental properties with more than 10 units. This includes either rental fee waiver for the last month or relocation assistance as detailed in the municipal code. Notification requirements in accordance with the code is required. Documentation showing compliance with these code requirements must be provided to the project planner prior to issuance of a demolition/deconstruction permit.

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13 5. PROJECT MODIFICATIONS. All modifications to the approved project shall be submitted for review and approval prior to construction. If during the Building Permit review and construction phase, the project is modified by the applicant, it is the responsibility of the applicant to contact the Planning Division/project planner directly to obtain approval of the project modification.

6. LANDSCAPE PLAN. Plantings shall be installed in accordance with the approved plan set prior to occupancy and shall be permanently maintained and replaced as necessary.

7. STANDARD CONDITION FOR VAPOR INTRUSION. For projects which are known to be subject to risk of vapor intrusion, the applicant shall assess site conditions to determine both the nature and extent of contamination. If contamination at the site exceeds the most current environmental screening levels (ESLs) identified by the Regional Water Quality Control Board (RWQCB) for volatile organic compounds, the applicant shall prepare and submit a Site Management and Contingency Plan (SMCP) to either the Department of Toxic Substances Control (DTSC), RWQCB, or the County of Santa Clara Department of Environmental Health for approval. The SMCP shall include details regarding the pending development and propose remediation and/or mitigation to address any environmental risk identified in the site assessment. The applicant shall agree to and implement all recommendations of the reviewing regulatory agency approving the SMCP in order to reduce the exposure of future occupants to vapor intrusion. A copy of the approved SMCP shall be submitted to the Director of Planning prior to issuance of a building permit. If the reviewing agency requires that a vapor intrusion barrier system be installed, the VIMs shall be document in the building permit plan set prior to issuance of the building permit.

Post construction indoor air monitoring shall be conducted for any VIMS systems and shall comply with the specific recommendations set forth by the regulatory agency approving the SMCP.

8. STANDARD CONDITION NESTING BIRD SURVEY. Vegetation or tree removal shall be prohibited during the general avian nesting season (February 1 – August 31), if feasible. If nesting season avoidance is not feasible, the applicant shall retain a qualified biologist, as approved by the City of Palo Alto, to conduct a preconstruction nesting bird survey to determine the presence/absence, location, and activity status of any active nests on or adjacent to the project site no more than 14 days prior to scheduled vegetation clearance and/or demolition activities. If nesting birds are found to be present, a suitable buffer (typically a minimum buffer of 50 feet for passerines and a minimum buffer of 250 feet for raptors) as determined appropriate by the biologist, shall be established around such active nests and no construction shall be allowed within the buffer areas until a qualified biologist has determined that the nest is no longer active (i.e., the nestlings have fledged and are no Item 8
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14 longer reliant on the nest). A report documenting any data recovered during monitoring shall be prepared by a qualified biologist and submitted to the Director of Planning prior to final planning inspection.

9. CULTURAL SENSITIVITY TRAINING. Prior to issuance of any grading permit, the project applicant shall be required to submit evidence that a Cultural Awareness Training program has been provided to construction personnel. The training shall be facilitated by a qualified archaeologist in collaboration with a Native American representative registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3.

10. SUB-SURFACE MONITORING. Prior to issuance of any tree removal, grading, demolition, and/or building permits or activities, the applicant shall notify the Director of Planning, of grading and construction dates and activities that require a qualified archeologist and Native American monitor to be present on the project site. The City shall then notify the tribe via e-mail correspondence 10 days prior to any grading or construction activities. If the tribe chooses not to send a monitor or does not respond within the 10 days, work shall continue without the monitor.

11. ARCHEOLOGICAL AND CULTURAL MONITORING. A qualified archaeologist and a Native American monitor, registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3, shall be present during earthmoving activities including, trenching, initial or full grading, scraping or blading, lifting of foundation, boring, drilling, or major landscaping. The qualified archaeologist and Native American monitor shall have the authority to halt construction activities within 50 feet of a discovery in the event any cultural materials are encountered during ground-disturbing construction activities. The qualified archeologist and Native American monitor shall keep a daily monitoring log on days that monitoring occurs documenting construction activities that were monitored, location of the monitoring, and any cultural materials identified.

These daily monitoring logs shall be made available to the City upon request.

12. ARCHEOLOGICAL AND CULTURAL TREATMENT PLAN. In the event any significant cultural materials are encountered during construction, construction within a radius of 50 feet of the find would be halted, the Director of Planning shall be notified, and the on-site qualified archaeologist, in collaboration with the Native American Monitor, shall examine the find and make appropriate recommendations regarding the significance of the find and the appropriate treatment of the resource.

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15 The qualified archeologist in collaboration with a Native American monitor, registered with the Native American Heritage Commission for the City of Palo Alto and that is traditionally and culturally affiliated with the geographic area as described in Public Resources Code Section 21080.3, shall prepare and implement a treatment plan that reflects permit-level detail pertaining to depths and locations of excavation activities. The treatment plan shall contain, at a minimum:

a. Identification of the scope of work and range of subsurface effects (including location map and development plan), including requirements for preliminary field investigations.
b. Description of the environmental setting (past and present) and the historic/prehistoric background of the parcel (potential range of what might be found).
c. Monitoring schedules and individuals.
d. Development of research questions and goals to be addressed by the investigation (what is significant vs. what is redundant information). e. Detailed field strategy to record, recover, or avoid the finds and address research goals.
f. Analytical methods.
g. Report structure and outline of document contents.
h. Disposition of the artifacts.
i. Security approaches or protocols for finds.
j. Appendices: all site records, correspondence, and consultation with Native Americans, etc.

The treatment plan shall utilize data recovery methods to reduce impacts on subsurface resources. The treatment plan must be reviewed and approved by the Director of Planning, or the Director’s designee prior to implementation of the plan.

13. ARCHEOLOGICAL AND CULTURAL EVALUATION. The project applicant shall notify the Director of Planning, Native American Monitor, and Archeological Monitor, of any finds during grading or other construction activities. Any historic or prehistoric material identified in the project area during excavation activities shall be evaluated for eligibility for listing in the California Register of Historic Resources as determined by the California Office of Historic Preservation. Data recovery methods may include, but are not limited to, backhoe trenching, shovel test, hand augering, and hand-excavation. The techniques used for data recovery shall follow the protocols identified in the approved treatment plan. Data recovery shall include excavation and exposure of features, field documentation, and recordation. All documentation and recordation shall be submitted to the Northwest Information Center, and the Director of Planning.

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16 14. UNANTICIPATED DISCOVERY OF BURIED ARCHEOLOGICAL AND TRIBAL CULTURAL RESOURCES. If human remains are found, the State of California Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. In the event of an unanticipated discovery of human remains, the County Coroner must be notified immediately. If the human remains are determined to be of Native American origin, the Coroner will notify the Native American Heritage Commission, which will determine and notify a most likely descendant (MLD). The MLD has 48 hours from being granted site access to make recommendations for the disposition of the remains. If the MLD does not make recommendations within 48 hours, the landowner shall reinter the remains in an area of the property secure from subsequent disturbance.

15. In accordance with Mitigation measure Air 2a of the Comprehensive Plan EIR, these BMPs shall be implemented during all demolition, grading, and construction activities to reduce construction-related particulate emissions:
a. Exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day or covered. b. Haul trucks transporting soil, sand, or other loose material off-site shall be covered.
c. Visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
d. Vehicle speeds on unpaved roads shall be limited to 15 miles per hour. e. Roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
f. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Chapter13, Section 2485 of California Code of Regulations [CCR]). Clear signage explaining this rule shall be provided for construction workers at all access points.
g. Construction equipment shall be maintained and properly tuned in accordance with the manufacturer’s specifications. Equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
h. A publicly visible sign shall be posted with the telephone number and name of an individual working for the construction contractor who can be contacted regarding dust complaints. This person shall respond and take corrective action within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

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17 16. NOISE MITIGATION IN CONFORMANCE WITH COMPREHNSIVE PLAN POLICY N6.11.1 AND MITIGATION MEASURE NOISE-8 IN THE COMPREHENSIVE PLAN EIR. Noise control measures would include, but not be limited to, the following BMPs that would further decrease the project’s noise impacts during construction:
 The contractor shall use “new technology” power construction equipment with state-of-the art noise shielding and muffling devices. All internal combustion engines used on the project site shall be equipped with adequate mufflers and shall be in good mechanical condition to minimize noise created by faulty or poorly maintained engines or other components.
 The unnecessary idling of internal combustion engines shall be prohibited.  Staging areas and stationary noise-generating equipment shall be located as far as possible from noise-sensitive receptors such as residential uses (a minimum of 200 feet)
 The surrounding neighborhood shall be notified early and frequently of the construction activities.
 A “noise disturbance coordinator” shall be designated to respond to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaints (e.g., beginning work too early, bad muffler, etc.) and institute reasonable measures warranted to correct the problem. A telephone number for the disturbance coordinator would be conspicuously posted at the construction site.
 Utilize ‘quiet’ models of air compressors and other stationary noise sources where technology exists.
 Equip all internal combustion engine-driven equipment with mufflers, which are in good condition and appropriate for the equipment.
 Construct temporary noise barriers, where feasible, to screen stationary noise- generating equipment when located within 200 feet of adjoining sensitive land uses.

Temporary noise barrier fences would provide a 5dBA noise reduction if the noise barrier interrupts the line of- sight between the noise source and receptor and if the barrier is constructed in a manner that eliminates any cracks or gaps.  If stationary noise-generating equipment must be located near receptors, adequate muffling (with enclosures where feasible and appropriate) shall be used. Any enclosure openings or venting shall face away from sensitive receptors.  Ensure that generators, compressors, and pumps are housed in acoustical enclosures.
 Locate cranes as far from adjoining noise-sensitive receptors as possible.

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18  During final grading, substitute graders for bulldozers, where feasible. Wheeled heavy equipment are quieter than track equipment and should be used where feasible.
 Substitute nail guns for manual hammering, where feasible.  Substitute electrically powered tools for noisier pneumatic tools, where feasible.  Prior to building permit issuance the contractor shall prepare a detailed construction plan identifying the schedule for major noise-generating construction activities. The construction plan shall identify a procedure for coordination with adjacent residential land uses so that construction activities can be scheduled to minimize noise disturbance.

17. NOISE MITIGATION IN CONFORMANCE WITH COMPREHNSIVE POLICY N6.11.1 AND MITIGATION MEASURE NOISE-5a IN THE COMPREHENSIVE PLAN EIR. The project proponent shall implement a construction vibration monitoring plan to document conditions prior to, during, and after vibration generating construction activities for the adjacent residential uses. All plan tasks shall be undertaken under the direction of a licensed Professional Structural Engineer in the State of California and be in accordance with industry-accepted standard methods. The construction vibration monitoring plan shall be submitted to the City prior to issuance of a Grading or Building Permit and shall include, but not be limited to, the following measures:
 The report shall include a description of measurement methods, equipment used, calibration certificates, and graphics as required to clearly identify vibration- monitoring locations.
 A list of all heavy construction equipment to be used for this project and the anticipated time duration of using the equipment that is known to produce high vibration levels (clam shovel drops, vibratory rollers, hoe rams, large bulldozers, caisson drillings, loaded trucks, jackhammers, etc.) shall be submitted to the Director of Planning and Development Services or Director’s designee of the Department of Planning & Development by the contractor. This list shall be used to identify equipment and activities that could exceed the 0.3 PPV threshold at the adjacent residential uses based on the planned equipment, location, and duration of use.

Where project construction activities may be anticipated to exceed the threshold, the applicant shall provide a plan to show how levels would be reduced by phasing activities that are known to cause excessive vibration, utilizing alternative equipment, and/or reducing the time period that the equipment is being used.  Where possible, use of the heavy vibration-generating construction equipment shall be prohibited within 20 feet of the adjacent residential uses. o Smaller equipment (less than 18,000 pounds) must be used near the property lines adjacent to the existing residential uses to minimize vibration levels to 0.3 in/sec PPV or less. For example, a smaller vibratory roller similar to a Caterpillar model CP433E vibratory compactor could be used when Item 8
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19 compacting materials within 20 feet of the adjacent residential buildings. The smaller equipment intended to implement this requirement shall be individually identified among the list of equipment required under the above condition as the subset of equipment allowed for use at the property lines. o Avoid using vibratory rollers and clam shovel drops within 20 feet of the adjacent residential uses.
o Select demolition methods that do not involve large impact tools such as hoe-rams within 20 feet of the eastern property line. Portable jackhammers, saws, or grinders shall be used to minimize impacts to the ground. o Avoid dropping heavy equipment and use alternative methods for breaking up existing pavement, such as a pavement grinder, instead of dropping heavy objects, within 20 feet of the adjacent residential uses. • Develop a vibration monitoring and construction contingency plan to identify structures where monitoring would be conducted, set up a vibration monitoring schedule, define structure-specific vibration limits, and address the need to conduct photo, elevation, and crack surveys to document before and after construction conditions. Construction contingencies shall be identified for when vibration levels approach the limits of 0.3 in/sec PPV at the adjacent residential buildings. • At a minimum, vibration monitoring shall be conducted during demolition and excavation activities.
• Designate a person responsible for registering and investigating claims of excessive vibration. The contact information of such person shall be clearly posted on the construction site.
 Conduct a post-construction survey on structures where either monitoring has indicated high vibration levels or complaints of damage has been made. Make appropriate repairs or compensation where damage has occurred as a result of construction activities.

18. OPEN AIR LOUDSPEAKERS (AMPLIFIED MUSIC). In accordance with PAMC Section 9.12, no amplified music shall be used for producing sound in or upon any open area, to which the public has access, between the hours of 11:00pm and one hour after sunrise. In addition, all rooftop gardens/decks shall comply with the provisions of PAMC 18.42.230.

19. NOISE THRESHOLDS ON RESIDENTIAL PROPERTY. NOISE THRESHOLDS ON RESIDENTIAL PROPERTY. In accordance with PAMC Section 9.10.030, No person shall produce, suffer or allow to be produced by any machine, animal or device, or any combination of same, on residential property, a noise level more than six dB above the local ambient at any point outside of the property plane. At building permit, provide the proposed HVAC specifications. If the proposed decibel level of the HVAC exceeds the decibel level of the HVAC evaluated in the CEQA analysis, a noise analysis of the proposed equipment’s consistency with the municipal code shall be required.

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20 20. NOISE REPORT PRIOR TO INSPECTION. Where the acoustical analysis projected noise levels at or within 5 dB less than the Noise Ordinance limits, the applicant shall demonstrate the installed equipment complies with the anticipated noise levels and the Noise Ordinance prior to final Planning inspection approval.

21. SIGN APPROVAL NEEDED. No signs are approved at this time. All signs shall conform to the requirements of Title 16.20 of the Palo Alto Municipal Code (Sign Code) and shall be subject to approval by the Director of Planning.

22. UNDERGROUND STORAGE TANK. Prior to issuance of a building permit, the Applicant shall provide documentation, to the satisfaction of the City and applicable Cleanup Oversight Agency, demonstrating that the site is suitable for residential use with respect to potential contamination from the former underground storage tanks.

If required, additional investigation or remediation shall be completed in accordance with applicable state regulations, including the State Water Board’s Low-Threat UST Case Closure Policy. Written clearance or a determination of no further action shall be provided prior to building permit issuance.

23. TRASH ROOM. The trash room shall be used solely for the temporary storage of refuse and recycling that is disposed on a regular basis and shall be closed and locked during non- business hours.

24. UTILITY LOCATIONS. In no case shall utilities be placed in a location that requires equipment and/or bollards to encroach into a required parking space. In no case shall a pipeline or water and wastewater services/laterals/meters be placed within 10 feet of a proposed tree and/or tree designated to remain, or within 5 feet where root barrier protection is installed, unless otherwise approved by urban forestry and waste-gas-water.

25. ESTIMATED IMPACT FEE. Development Impact Fees, currently estimated in the amount of $17,698,233.70 shall be paid in accordance with PAMC Chapter 16.64. The final Development Impact Fees shall be calculated before they are due, and payment may be deferred to the date the development is approved for occupancy as set forth in PAMC Section 16.64.030 and as permitted by SB 937.

26. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020 provides that a project applicant who desires to protest the fees, dedications, reservations, or other exactions imposed on a development project must initiate the protest at the time the development project is approved or conditionally approved or within ninety (90) days after the date that fees, dedications, reservations or exactions are imposed on the Project. Additionally, procedural requirements for protesting these development fees, dedications, reservations and exactions are set forth in Government Code Section 66020. IF Item 8
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21 YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD OR FOLLOW THE PROTEST PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION 66020, YOU WILL BE BARRED

FROM CHALLENGING THE VALIDITY OR REASONABLENESS OF THE FEES, DEDICATIONS, RESERVATIONS, AND EXACTIONS. If these requirements constitute fees, taxes, assessments, dedications, reservations, or other exactions as specified in Government Code Sections 66020(a) or 66021, this is to provide notification that, as of the date of this notice, the 90-day period has begun in which you may protest these requirements. This matter is subject to the California Code of Civil Procedures (CCP) Section 1094.5; the time by which judicial review must be sought is governed by CCP Section 1094.6.

27. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice.

28. FINAL INSPECTION. A Planning Division Final inspection will be required to determine substantial compliance with the approved plans prior to the scheduling of a Building Division final. Any revisions during the building process must be approved by Planning. Contact your Project Planner, Steven Switzer at [email protected] to schedule this inspection.

Public Art

29. The project triggers the Public Art in Private Development ordinance, requiring that 1% of the estimated cost of construction be spent either on art on-site, or the payment of the equivalent funds to the Public Art Fund in-lieu of commissioning artwork on site. The applicant has not submitted a public art application at this time. Prior to issuance of a building permit, the applicant shall pay the required in-lieu contribution to the Public Art Fund or, prior to applying for a building permit, shall file a minor architectural review application to evaluate proposed public art, which shall be reviewed and approved by the public art commission. The Public Art Program team will need to verify the Construction Valuation with an outside consultant. Contact the Public Art Program at the time you apply for Building permit to begin this verification process. All information and application materials may be found at paloalto.gov/public art under the Policies and Documents tab. In-lieu fees may be paid at occupancy in accordance with the requirements under PAMC 16.64.030 and as permitted by SB 937.

Building Division

30. A complete construction set shall be submitted to the building department for review. A complete construction shall include, but is not limited to: architectural drawings, structural Item 8
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22 drawings and calculations, mechanical plans, electrical plans, plumbing plans, and Title 24 energy analysis.

31. All sheets shall be stamped and signed by the responsible designer.

32. Refer to this website below for additional building permit submittal requirements. Contact the building department for any questions.
https://www.paloalto.gov/files/assets/public/v/3/development-services/building- division/checklists/simplified/c1-new-comm-shell-checklist-07062023.pdf

Transportation

33. Prior to issuance of a building permit, the applicant shall obtain a transportation analysis (TA) consistent with the City's Local Transportation Impact Analysis Policy and prepared by a consultant reasonably acceptable to the City. The applicant shall implement any mediation measures recommended in the TA that would not render the project infeasible. Potential mediation measures could include but not limited to; flex posts, bike boxes, bike sharrows, and/or speed bumps. At a minimum, the TA shall:
a. Evaluate project ingress and egress operations, including driveway functionality and queuing;
b. Analyze intersection operations and impacts at the Matadero Avenue / El Camino Real and Kendall Avenue / El Camino Real intersections, considering the existing “No Right Turn on Red” restrictions;
c. Evaluate potential impacts to the suggested school route along Matadero Avenue and Kendall Avenue with respect to multimodal access; and d. Identify and recommend improvements as necessary, subject to City approval.

34. OFF SITE IMPROVEMENTS: Off-site improvement plans shall be submitted to the Office of Transportation for review and approval. These improvements shall incorporate all recommendations identified in the transportation analysis prepared for the project. Off- site improvements include, but are not limited to, design modifications that support on site circulation and prevent queuing or other operational deficiencies within the public right of way. Any proposed modifications to the public right of way shall be evaluated to ensure they can be safely accommodated given existing lane geometry.

35. TRANSPORTATION DEMAND MANAGEMENT (TDM): The applicant shall prepare and submit a final TDM Plan consistent with the Comprehensive Plan policies for the El Camino Real corridor and that demonstrates a minimum 30 percent reduction in project generated vehicle trips. The plan shall identify parking and trip reduction measures, include trip targets and a monitoring and enforcement mechanism, and designate the responsible entity for implementation.

All approved TDM measures shall be maintained for the life of the project. Monitoring Item 8
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23 reports shall be submitted two years after occupancy and annually thereafter. If performance targets are not met, the applicant shall implement modifications as required by the Director. Failure to correct deficiencies may result in administrative penalties or other enforcement actions consistent with the Municipal Code.

36. BICYCLE PARKING: In accordance with California Green Building Standards Code (CALGreen), the project shall provide one on-site short term bicycle parking space per 10,000 square feet. Short term bicycle parking spaces shall be located within 200 feet of building entrances and readily visible to passers-by.

37. LOADING ZONES: No project dedicated loading space shall be located within the public right of way. The project shall maintain at minimum one, on-site loading space.

38. CONSISTENCY WITH CALTRANS SR-82 IMPROVEMENTS: All off site improvements shall be consistent with the recently completed Caltrans SR 82 (El Camino Real) improvements, including existing “No Parking” signage along El Camino Real. Any temporary alterations to bike lane enhancements shall be restored to existing conditions upon completion of the project.

39. BUS SHELTER COORDINATION: Potential impacts to the existing VTA bus shelter at the intersection of Matadero Avenue and El Camino Real shall be reviewed and approved through VTA’s development review process. The applicant shall comply with all requirements issued by the transit authority.

40. DRIVEWAY SIGHT LINES: Adequate sight distance shall be preserved at all driveways.

a. Landscaping within driveway vision triangles shall be maintained at a maximum height of three (3) feet.
b. All new and existing trees shall be maintained to provide a minimum vertical clearance of seven (7) feet above grade to ensure unobstructed visibility.

41. QUEUING: Fast opening gates shall be installed and maintained to ensure that vehicle queuing does not extend into or impact the public right of way.

42. TRASH REMOVAL AND OPERATIONS: Trash bin staging and collection operations shall occur entirely on site and shall not encroach into or occur within the public right of way.

Public Works Zero Waste

43. REQUIRED DECONSTRUCTION. In conformance with PAMC 5.24, deconstruction and source separation are required for all residential and commercial projects where structures (other than a garage or ADU) are being completely removed, demolition is no longer allowed.

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24 Deconstruction takes longer than traditional demolition, it is important to plan ahead. For more information, visit www.cityofpaloalto.org/deconstruction.

44. SALVAGE SURVEY FOR REUSE. A Salvage Survey is required for deconstruction permit applications. The survey shall be conducted by a City approved reuse vendor. The survey submittal shall include an itemized list of materials that are salvageable for reuse from the project. The applicant shall source separate and deliver materials for reuse. Certification is required indicating that all materials identified in the survey are properly salvaged. Contact The ReUse People to schedule this FREE survey by phone (888) 588-9490 or e-mail [email protected]. More information can be found at www.TheReusePeople.org.

Please upload a completed copy to the deconstruction permit.

45. SOURCE SEPARATION FOR RECYCLING. The applicant shall source separate deconstruction materials into specific categories for recycling. Additional staging areas for source separated materials will need to be considered. All materials shall be delivered to one of the City approved materials recovery facilities listed in Green Halo, all records shall be uploaded to www.greenhalosystems.com.

For more information, refer to www. paloalto.gov/deconstruction. Trash enclosure can only be used to temporarily store refuse (garbage, recycling, and compost) and not for other storage.

46. On the plans submitted for building permit provide cut-sheets for the color-coded internal and external containers, related color-coded millwork, and its colored signage in the building plans. Trash chutes must have colored doors with colored signage that complies with PAMC 5.20.18 requirements.

47. All indoor and outdoor common spaces are required to comply with the following: As per Palo Alto Municipal Code 5.20.108 the site is required to have color-coded refuse containers, related color-coded millwork, and colored signage. The three refuse containers shall include recycle (blue container), compost (green container), and garbage (black container). Applicant shall present on the plan submitted for building permit the locations and quantity of both (any) internal and external refuse containers, it’s millwork, along with the signage. However, for the copy/ mail area must have either a recycle bin only or all three refuse receptacles (green compost, blue recycle, and black landfill container). Please refer to PAMC 5.20.108 and the Internal Container Guide. Examples of appropriate signage can be found in the Managing Zero Waste at Your Business Guide. Electronic copies of these signage can be found on the Zero Waste Palo Alto’s website, https://www.paloalto.gov/Departments/Public-Works/Zero-Waste/What-Goes- Where/Toolkit#section-2 and hard copies can be requested from the waste hauler, Greenwaste of Palo Alto, (650) 493-4894.

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25 Public Works Engineering

48. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link:
https://www.cityofpaloalto.org/Departments/Public-Works/Engineering- Services/Forms-and-Permits

49. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS: Developer shall familiarize themselves with the guidelines described in the November 2007 revision of the document titled “Overview and Guidelines for the Review of Subdivision Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C). https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file- migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the- review-of-subdivision-projects.pdf

50. PARCEL MAP/FINAL MAP: Approval of this application is subject to, and contingent upon the approval of a tentative map and recordation of a Final Map, as detailed in Section 8.

51. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements.

52. SPECIAL STREET LIGHT: This project is located within an area designated to have special streetlights as shown in the Special Street Light Style Placement Guide. Any new or replaced streetlights shall be installed to the standards adopted by the Public Works Department and Utility Department.
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development- services/current-planning/pw-style-placement-guide-2020.pdf

53. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for improvements within the public right-of-way, any existing improvements to be re-used by the project, which are not to current City standards and are not specifically in these project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to current City standards as required by the Director of Public Works and the Director of Utilities.

54. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any changes or modifications to existing utilities, streets, and public infrastructure within or adjacent to the project site that are attributable to the development. This includes, but is not limited to, the relocation of utility facilities, conduits, or vaults required due to grade changes in the sidewalk area resulting from the development. The Developer’s financial responsibility for utility upgrades exceeding the impacts of the development Item 8
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26 shall be limited to Developer’s fair share contribution, as reasonably determined by the Utilities and/or Public Works Department.

55. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for repairing any damage to existing public improvements fronting or adjacent to the project site caused by construction, to the satisfaction of the Public Works Department.

56. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible for researching all existing utility lines to ensure there are no conflicts with the project.

Any existing utility lines (public or private) or their appurtenances that conflict with the project or do not serve it must be capped, abandoned, removed, relocated, or disposed of to the satisfaction of the City.

57. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines and appurtenances is subject to City review and approval. The Developer’s contractor shall expose the existing storm drain facilities during construction for City inspection or provide video documentation of their condition. Any deficient facilities, as determined by Public Works, must be replaced by the Developer. The Developer’s financial responsibility for storm drain facility upgrades exceeding the impacts of the development shall be limited to Developer’s fair share contribution, as reasonably determined by the Public Works Department.

58. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain tributary pattern. Any deviations require additional analysis and approval by Public Works during plan review. The project shall not negatively impact the drainage pattern for adjacent properties.

59. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter

16.28. The permit application and all applicable documents (see Section H of application) shall be submitted to Public Works Engineering. Add the following note:
“THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE

SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.”

60. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall including the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc.

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27 61. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan.

62. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace and/or add connections to the City maintained storm drain system, then the applicant may be responsible for improvements to the system. These improvements may include, but not limited to, upsizing the storm drain facility, replacing or adding City standard catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR MANHOLES. The extent of required improvements will be at the public works staff discretion and shall be consistent with Storm Drain Master Plan and Public Works Construction Standards. Any work on the city's storm drain systems requires permits and inspection by Public Works inspectors. The Developer’s financial responsibility for storm drain facility upgrades exceeding the impacts of the development shall be limited to Developer’s fair share contribution, as reasonably determined by the Public Works Department.

63. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to provide CCTV inspection of the City’s storm drain facilities to verify that any lines were not broken, cracked or damaged during construction. The video shall be high resolution and done by professional who is familiar with the process and meticulous. A CCTV inspection video is required for new storm drain connection (s) to verify proper connections were made into the City’s system and that no construction material was left behind. Videos of storm drain system may also be required where construction occurred less than 5-ft from the city’s storm drain system. Videos shall be provided from structure to structure, such as manhole to manhole. Contractor may want to conduct their own inspection in advance of construction to verify the existing pipe integrity. If existing damages are located, they shall be reported to Public Works inspectors prior to the start of construction. If not reported, the contractor may be responsible to restore the pipe segment as determined by Public Works prior to final.

64. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS

BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”.

65. SWPPP: This proposed development will disturb more than one acre of land.

Accordingly, the applicant shall apply for coverage under the State Water Resources Control Board’s (SWRCB) NPDES general permit for storm water discharge associated with construction activity. A Notice of Intent (NOI) shall be filed for this project with the Item 8
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28 SWRCB in order to obtain coverage under the permit. The General Permit requires the applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).

The applicant is required to submit two copies of the NOI and the draft SWPPP to the Public Works Department for review and approval prior to issuance of the building permit. The SWPPP should include both permanent, post-development project design features and temporary measures employed during construction.

66. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way.

67. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit.

68. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet.

69. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11. Submit the following:

a. Provide a stamped and signed C.3 data form (April 2024 version) from SCVURPPP. https://scvurppp.org/2024/09/19/provision-c-3-data-form-2024/ b. Final stamped and signed letter confirming which documents were reviewed and that the project complies with Provision C.3 and PAMC 16.11.

70. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final.

71. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the building, the third-party reviewer shall submit to the City Item 8
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29 a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans.

72. PAVEMENT RESTORATION: The applicant shall restore the pavement along the entire project frontage, curb-to-curb, by performing a 3.5” grind and overlay. The exact restoration limits will be determined once the resulting road condition is known following completion of heavy construction activities and utility lateral installations, at minimum the extent will be the project frontage on Matadero and Kendall Avenues. The extent of restoration required on El Camino Real shall be determined by the Public Works Department following completion of heavy construction activities and utility lateral installations.

73. EXISTING EASEMENTS: Provide documentation showing approval from the entities affected by the onsite easements to verify that the work within said easements is permitted.

74. OUTSIDE AGENCY APPROVAL: A portion of the proposed work is within Caltrans right-of- way. Evidence of permit approvals shall be submitted prior to issuance of City permits.

75. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO): The applicant is required to paint “No Dumping/Flows to Matadero Creek” in blue on a white background adjacent to all onsite storm drain inlets. The name of the creek to which the proposed development drains can be obtained from Public Works Engineering.

Stencils of the logo are available from the Public Works Environmental Compliance Division, which may be contacted at (650) 329-2598. Include the instruction to paint the logos on the construction grading and drainage plan.

76. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS): At the conclusion of the project applicant shall provide digital as-built/record drawings of all improvements constructed in the public right-of-way or easements in which the City owns an interest.

77. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT):

An approved indefinite encroachment permit will be required for any private infrastructure constructed in the public right-of-way, easement or on property in which the City holds an interest, but that was not authorized by a building permit.

Urban Forestry

78. Post building permit issuance all protected trees are subject to a 14-day public notice prior to their removal.

79. URBAN FORESTRY GENERAL: The following general tree preservation measures apply to Item 8
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30 all trees to be retained: No storage of material, topsoil, vehicles or equipment shall be permitted within the Tree Protection Zone (TPZ). The ground under and around the tree canopy area shall not be altered. No waste material or construction byproducts are allowed within the TPZ. Trees to be retained shall be irrigated, aerated, and maintained as necessary to ensure survival.

80. TREE DAMAGE: Tree Damage, Injury Mitigation, and Inspections apply to the Contractor.

Reporting, injury mitigation measures, and arborist inspection schedule may apply pursuant to TLTM, Section 5.03.6. Contractor shall be responsible for the repair or replacement of any publicly owned or protected trees that are damaged during the course of construction, pursuant to Title 8 of the Palo Alto Municipal Code, and City of Palo Alto Tree and Landscape Technical Manual, Section 3.02.

81. TPZ EXCAVATION RESTRICTIONS APPLY - TLTM, Sec. 3.03.6 - B5,6: Any approved grading, digging, potholing, or trenching within the TPZ of a protected tree shall be performed using ‘air-spade’ method as a preference, with manual hand shovel as a backup. (TPZ= 10x the tree diameter at 54" above grade) For utility trenching, including sewer line, roots exposed with a diameter of 2 inches and greater shall remain intact and not be damaged. If directional boring method is used to tunnel beneath roots, then CPA Standard Detail #504 shall be printed on the final plans and the buffer distances in TLTM Table 3-4,Trenching and Tunneling Distance, shall be implemented by Contractor.

Contractor must notify the Urban Forestry Section at (650) 496-5953 in advance of conducting any approved excavation within 10-feet of any street trees (or for any protected tree on EVSE projects). Urban Forestry may choose to monitor or review the work for compliance with the City’s Tree Protection Zone (TPZ) excavation standards.

82. TREE PROTECTION COMPLIANCE: The owner and contractor shall implement all protection and inspection schedule measures, design recommendations, and construction scheduling as stated in the Tree Preservation Report and/or T-1 Sheet Set and is subject to code compliance action pursuant to PAMC 8.10.080. The required protective fencing shall remain in place until the final landscaping or Urban Forestry inspection of the project is completed.

83. NO NET LOSS OF CANOPY: In order to comply with the City’s no net loss of canopy policy (PAMC 8.10.055; Urban Forest Master Plan Goals 6.A, 6.B, & 6.C; Comprehensive Plan, Natural Environment Chapter Goal N-2) all trees 4 inches DBH and larger are subject to replacement to avoid a loss of canopy at the neighborhood level. Replacement ratios are determined by table 3-1 in the Tree and Landscape Technical Manual, Section 3.02.

New landscape tree plantings (24 inch box or larger) count towards the replacement total. Screening trees may also count toward the total depending on size and species selected. If unable to plant the required number of trees on site (our preferred solution) there is the option of paying in-lieu fees per each 24 inch box tree into the forestry fund. [Note: A replacement at ratio of 1:1 for trees listed as exempt species under PAMC Item 8
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31 8.10.020 is recommended. Exempt trees may require full replacement on parcels zoned other than R1, RE, R-2, or RMD].

84. PLAN CHANGES: Revisions and/or changes to plans before or during construction shall be reviewed and responded to by the (a) project site arborist, or (b) landscape architect with written letter of acceptance before submitting the revision to Planning and Development Services Department for review by Planning, Public Works, or Urban Forestry.

85. PLAN SET REQUIREMENTS: The final Plans submitted for a building permit shall include the location, DBH, canopy drip-line, and TPZ of all trees 4 inches DBH or greater as well as the following information and notes on relevant plan sheets:
a. T-1 SHEET SET, The building permit plan set will include the City’s full-sized, T-1 Sheet Set (Tree Protection-it's Part of the Plan!), available on the Development Center website. A certified arborist shall complete and sign the Tree Disclosure Statement.
b. TREE PRESERVATION REPORT (TPR), if indicated by Tree Disclosure Statement, All sheets of the Applicant’s TPR approved by the City for full implementation by Contractor, shall be printed on numbered T-1 Sheets (T-3, T-4, etc.) and added to the sheet index.
c. TREE PROTECTION FENCING, The Plan Set (esp. site, demolition, grading & drainage, foundation, irrigation, tree disposition, utility sheets, etc.) must delineate/show the correct configuration of Type I, Type II or Type III fencing around each Protected Tree, using a bold dashed line enclosing the Tree Protection Zone (CPA Standard Detail #605).

Fire

86. Fire sprinkler density of parking garage with EVCE shall be Extra Hazard-II. Install smoke removal sys in parking garage.

87. Overhead utilities on both Kendall Ave and Matadero Ave shall be placed underground along exterior walls of this project.

Watershed Protection
The following comments are provided as a courtesy and these conditions of approval must be complied with before receiving a Demolition Permit for this project:

88. NOTICE OF REGULATION OF PCB MATERIAL – EFFECTIVE JULY 1st, 2019: Please be advised that requirements regarding stormwater control during building demolition for polychlorinated biphenyls (PCBs) became effective starting July 1st, 2019, in accordance with the San Francisco Bay Region Municipal Regional Stormwater NPDES Permit (MRP), Order No. R2-2015-0049. MRP Provision C.12.f. requires that San Francisco Bay Area Item 8
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32 municipalities develop a program to ensure that PCBs from building materials (e.g. caulk, paint, mastic) do not enter the storm drain system during building demolition.

Palo Alto City Council adopted the PCBs regulation in May 2019. For specific questions about your project, please email [email protected], call 650-329-2122 or visit http://www.cityofpaloalto.org/pcbdemoprogram.

89. If the project is submitting a demolition permit application on or after July 1st, 2019, the applicant shall complete and submit the “PCBs Applicant Package,” including any required sampling reports (per the Applicant Package instructions), with the demolition permit application. The PCBs Application Package and other resources are outlined at http://www.cityofpaloalto.org/pcbdemoprogram. The Applicant Package will outline PCBs sampling and reporting requirements that must be met if the project meets ALL of the following conditions:
a. The project is a commercial, public, institutional, or industrial structure constructed or remodeled between January 1, 1950 and December 31, 1980.

Single-family and two-family homes are exempt regardless of age. b. The framing of the building contains material other than wood. Wood-frame structures are exempt.
c. The proposed demolition is a complete demolition of the building. Partial demolitions do not apply to the requirements.

90. If the project triggers polychlorinated biphenyls (PCBs) sampling as identified on the “PCBs Applicant Package,” then the project shall conduct representative sampling of PCBs concentration in accordance with the “Protocol for Evaluating Priority PCBs- Containing Materials before Building Demolition (2018).”  If the representative sample results or records DO NOT indicate PCB concentrations ≥50 ppm in one or more “priority materials,” then the screening assessment is complete. Applicant submits screening form and the supporting sampling documentation with the demolition permit application. No additional action is required.
 If the representative sample results or records DO indicate PCBs concentrations ≥50 ppm in one or more “priority materials,” then the screening assessment is complete, but the Applicant MUST also contact applicable State and Federal Agencies to meet further requirements. Applicant submits screening form and the supporting sampling documentation with the demolition permit application, and also must contact the State and Federal Agencies as indicated on Page 3 of the “PCBs Screening Assessment Form.”

IMPORTANT: ADVANCED APPROVAL FROM THE UNITED STATES ENVIRONMENTAL

PROTECTION AGENCY (USEPA) OR OTHER STATE AGENCIES MAY BE REQUIRED PRIOR TO BUILDING DEMOLITION. IT IS RECOMMENEDED THAT APPLICANTS BEGIN THE PCBs

ASSESSMENT WELL IN ADVANCE OF APPLYING FOR DEMOLITION PERMIT AS THE PROCESS CAN TAKE BETWEEN 1-3 MONTHS.

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33 91. Requirement for oil-water separator in interior parking garage floor drains: If installed, parking garage floor drains on interior levels shall be connected to an oil-water separator prior to discharging to the sanitary sewer system. The oil-water separator shall be cleaned at a frequency of at least once every twelve (12) months or more frequently if recommended by the manufacturer or required by the Director.

Installation, certification, and maintenance records shall be maintained and made available for inspection and copying as described in Section 16.09.155 of this Chapter.

Oil-water separators shall have a minimum capacity of 100 gallons (PAMC

16.09.165(a)(8) and 16.09.170(a)(5)).

92. Exemption for requirements below: This requirement can be exempted if no washing is allowed on-site via rental/lease agreement, any hose bibs are to be fitted with lock-outs or other connection controls, and signage is posted indicating that car washing is not allowed (PAMC 16.09.170(a)(6)).
a. Requirement for an oil-water separator for carwash area: A drain shall be installed to capture all vehicle wash waters and shall be connected to an oil- water separator prior to discharge to the sanitary sewer system. The oil-water separator shall be cleaned at a frequency of at least once every twelve(12)months or more frequently if recommended by the manufacturer or required by the Director. Oil-water separators shall have a minimum capacity of100 gallons.

b. Requirement for bermed area around carwash: The area shall be graded or bermed in such a manner as to prevent the discharge of stormwater to the sanitary sewer system

93. Discharge drains for pools, spas, and fountains shall not be connected directly to the storm drain system or to the sanitary sewer system (PAMC 16.09.165(a)(7) and

16.09.170(a)(4)).

Water-Gas-Wastewater Utilities
The following comments are required to be addressed prior to submittal of any future related permit application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance, Street Work Permit, Encroachment Permit, etc. These comments are provided as a courtesy and are not required to be addressed prior to the Planning entitlement approval:

94. The applicant is to submit flow monitoring data for the sewer connection utility impact study.

PRIOR TO ISSUANCE OF DEMOLITION PERMIT (if required)

95. The applicant shall submit a request to disconnect utility services and remove meters.

The utilities demo is to be processed within 10 working days after receipt of the request.

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34 The demolition permit will be issued by the building inspection division after all utility services and/or meters have been disconnected and removed.

FOR BUILDING PERMIT

96. The Domestic Water meter and service location is to be finalized in the Building Permit.

This includes the Public Utility Easement (P.U.E) for the Water meter. Sizing of meter and service to be determined in the Building Permit. Water meter is to comply with City of Palo Alto Utilities Standard Detail WD-04.

97. The Irrigation Meter location is to be finalized in the Building Permit. Service is to be relocated to connect off the domestic service. Sizing of meter and service to be determined in the Building Permit.

98. Fire Service location is to be finalized in the Building Permit.

99. Sewer Alignments are to be finalized in the Building Permit.

100. The applicant shall submit a completed water-gas-wastewater service connection application - load sheet for the City of Palo Alto Utilities. The applicant must provide all the information requested for utility service demands (water in fixture units/g.p.m., gas in b.t.u.h, and sewer in fixture units/g.p.d.). The applicant shall provide the existing (prior) loads, the new loads, and the combined/total loads (the new loads plus any existing loads to remain).

101. The applicant shall submit improvement plans for utility construction. The plans must show the size and location of all underground utilities within the development and the public right of way including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts, sewer lift stations, and any other required utilities. Plans for new wastewater laterals and mains need to include new wastewater pipe profiles showing existing potentially conflicting utilities especially storm drain pipes, electric and communication duct banks. Existing duct banks need to be daylighted by potholing to the bottom of the duct bank to verify cross section prior to plan approval and starting lateral installation. Plans for new storm drain mains and laterals need to include profiles showing existing potential conflicts with sewer, water, and gas.

102. The applicant must show on the site plan the existence of any auxiliary water supply, (i.e. water well, gray water, recycled water, rain catchment, water storage tank, etc).

103. The applicant shall be responsible for installing and upgrading the existing utility mains and/or services, laterals as necessary to handle anticipated peak loads. This responsibility includes all costs associated with the design and construction for the installation/upgrade of the utility mains and/or services/laterals. The Developer’s Item 8
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35 financial responsibility for utility upgrades exceeding the impacts of the development shall be limited to Developer’s fair share contribution, as reasonably determined by the Utilities Department.

104. An approved reduced pressure principle assembly (RPPA backflow preventer device) is required for all existing and new water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPPA shall be installed on the owner's property and directly behind the water meter within 5 feet of the property line. RPPA's for domestic service shall be lead free. Show the location of the RPPA on the plans.

105. An approved reduced pressure detector assembly (RPDA backflow preventer device, STD. WD-12A or STD. WD-12B) is required for all existing and new fire water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be installed on the owner's property and directly behind the City owned meter, within 5' (feet) of the property line or City Right of Way.

106. All backflow preventer devices shall be approved by the WGW engineering division.

Inspection by the city inspector is required for the supply pipe between the meter and the assembly.

107. The applicant shall pay the capacity fees and connection fees associated with new utility service/s or added demand on existing services. The approved relocation of services, meters, hydrants, or other facilities will be performed at the cost of the person/entity requesting the relocation.

108. If a new water service line installation for fire system usage is required. Show the location of the new water service on the plans. The applicant shall provide to the engineering department a copy of the plans for fire system including all fire department's requirements.

109. Each unit or building shall have its own water meter and gas meter shown on the plans.

Each parcel shall have its own water and gas service and sewer lateral connection shown on the plans.
110. A sewer lateral per lot is required. Show the location of the new sewer lateral on the plans. A profile of the sewer lateral is required showing any possible conflicts with storm, electric/communications ductbanks or other utilities. 111. All existing water, and gas. and wastewater services/laterals that will not be reused shall be abandoned at the main per the latest WGW utilities standards.

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36 112. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot be placed over existing water, gas, or wastewater mains/services. Maintain 1' horizontal clear separation from the vault/cabinet/concrete base to existing utilities as found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall be relocated from the plan location as needed to meet field conditions. Trees may not be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water services/or meters. New water or wastewater services/laterals/meters may not be installed within 10' of existing trees. Maintain 10' between new trees and new water and wastewater services/laterals/meters.

SECTION 8. Conditions of Approval Vesting Tentative Map.

Planning

1. PROJECT PLANS. The Final Map submitted for review and approval by the City Council shall be in substantial conformance with the Vesting Tentative Map titled “VESTING TENTATIVE MAP – 3606 EL CAMINO REAL (25PLN-00243)”, prepared by Kier+Wright and submitted February 3, 2026, except as modified to incorporate the conditions of this approval.

2. FINAL MAP COVER PAGE. At such time as the Final Map is filed, the cover page shall include the name and title of the Director of Planning and Development Services.

3. DEVELOPMENT IMPACT FEES. The Property Owner or their designee shall pay all applicable development impact fees associated with the proposed development and subdivision prior to issuance of the building permit(s) or recordation of the Final Map, as detailed in the Major Architectural Review Approval. Impact fees may be paid prior to occupancy in accordance with the requirements under PAMC 16.64.030 and as permitted by SB 937, with a lien on the property.

4. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020 provides that a project applicant who desires to protest the fees, dedications, reservations, or other exactions imposed on a development project must initiate the protest at the time the development project is approved or conditionally approved or within ninety (90) days after the date that fees, dedications, reservations or exactions are imposed on the Project. Additionally, procedural requirements for protesting these development fees, dedications, reservations and exactions are set forth in Government Code Section 66020. IF YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD

OR FOLLOW THE PROTEST PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION 66020, YOU WILL BE BARRED FROM CHALLENGING THE VALIDITY OR REASONABLENESS OF THE FEES, DEDICATIONS, RESERVATIONS, AND EXACTIONS. If these requirements constitute fees, taxes, assessments, dedications, reservations, or other exactions as Item 8
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37 specified in Government Code Sections 66020(a) or 66021, this is to provide notification that, as of the date of this notice, the 90-day period has begun in which you may protest these requirements. This matter is subject to the California Code of Civil Procedures (CCP) Section 1094.5; the time by which judicial review must be sought is governed by CCP Section 1094.6.

5. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice.

Public Works Engineering

6. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link: https://www. paloalto.gov/Departments/Public-Works/Engineering-Services/Forms-and-Permits

7. OVERVIEW AND GUIDELINES FOR THE REVIEW OF SUBDIVISION PROJECTS: Developer shall familiarize themselves with the guidelines described in the November 2007 revision of the document titled “Overview and Guidelines for the Review of Subdivision Projects”. Particularly Section II (items 5 through 12) and Section V (items A through C). https://www.paloalto.gov/files/assets/public/planning-amp-development-services/file- migration/current-planning/forms-and-guidelines/overview-and-guidelines-for-the- review-of-subdivision-projects.pdf

8. SUBDIVISION IMPROVEMENT AGREEMENT: The applicant shall execute a Subdivision Improvement Agreement and provide improvement securities (Bonds) for all proposed public improvements. THE AGREEMENT SHALL BE EXECUTED PRIOR TO MAP

RECORDATION OR ISSUANCE OF ANY PERMITS FOR CONSTRUCTION, ONSITE AND OFFSITE. ADVISORY -- The applicant shall provide a detailed itemized stamped and signed engineer's estimate for all off-site public improvements which will be reviewed to determine the security amount.

9. PARCEL MAP/FINAL MAP: This project is subject to, and contingent upon the approval of a tentative map and recordation of a Final Map. The submittal, approval and recordation of the Map shall be in accordance with the provisions of the California Subdivision Map Act and Palo Alto Municipal Code Title 21 Subdivision requirements. All existing and proposed property lines, easements, dedications shown on the tentative Item 8
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38 map are subject to City’s technical review and staff approval during the map process prior to issuance of any construction permits.

10. MAP THIRD-PARTY REVIEW: The City contracts with a third-party surveyor that will review and provide approval of the map’s technical correctness as the City Surveyor, as permitted by the Subdivision Map Act. The Public Works Department will forward a Scope & Fee Letter from the third-party surveyor, and the applicant will be responsible for payment of the fee’s indicated therein, which is based on the complexity of the map.

11. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements.

12. SPECIAL STREET LIGHT: This project is located within an area designated to have special streetlights as shown in the Special Street Light Style Placement Guide. Any new or replaced streetlights shall be installed to the standards adopted by the Public Works Department and Utility Department.
https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development- services/current-planning/pw-style-placement-guide-2020.pdf

13. UPGRADE OF EXISTING PUBLIC IMPROVEMENTS: As part of the plan review for improvements within the public right-of-way, any existing improvements to be re-used by the project, which are not to current City standards and are not specifically in these project conditions (such as streetlights, utility covers and lids, etc.), shall be upgraded to current City standards as required by the Director of Public Works and the Director of Utilities.

14. MODIFICATIONS TO EXISTING PUBLIC UTILITIES: The Developer is responsible for any changes or modifications to existing utilities, streets, and public infrastructure within or adjacent to the project site. This includes, but is not limited to, the relocation of utility facilities, conduits, or vaults required due to grade changes in the sidewalk area resulting from the development.

15. DAMAGE TO EXISTING PUBLIC IMPROVEMENTS: The Developer is responsible for repairing any damage to existing public improvements fronting or adjacent to the project site caused by construction, to the satisfaction of the Public Works Department.

16. EXISTING UTILITY ABANDONMENT AND/OR RELOCATION: The Developer is responsible for researching all existing utility lines to ensure there are no conflicts with the project.

17. RE-USE OF EXISTING STORM DRAINS: The re-use of existing City storm drain service lines and appurtenances is subject to City review and approval. The Developer’s contractor Item 8
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39 shall expose the existing storm drain facilities during construction for City inspection or provide video documentation of their condition. Any deficient facilities, as determined by Public Works, must be replaced by the Developer.

18. STORM DRAIN TRIBUTARY PATTERN: This project must follow the existing storm drain tributary pattern. Any deviations require additional analysis and approval by Public Works during plan review. The project shall not negatively impact the drainage pattern for adjacent properties.

19. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter

SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.”

20. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall include the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc.

21. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan.

22. DIRECT CONNECTIONS TO STORM DRAIN SYSTEM: If the project proposes to replace and/or add connections to the City maintained storm drain system, then the applicant may be responsible for improvements to the system. These improvements may include, but not limited to, upsizing the storm drain facility, replacing or adding City standard catch basins, pipes and manholes. THIS MAY INCLUDE REPLACING BRICK AND MORTAR MANHOLES. The extent of required improvements will be at the public works staff discretion and shall be consistent with Storm Drain Master Plan and Public Works Construction Standards. Any work on the city's storm drain systems requires permits and inspection by Public Works inspectors. The Developer’s financial responsibility for storm drain facility upgrades exceeding the impacts of the development shall be limited to Developer’s fair share contribution, as reasonably determined by the Public Works Department.

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40 23. CCTV OF STORM DRAIN SYSTEM: Post construction the applicant may be required to provide CCTV inspection of the City’s storm drain facilities to verify that any lines were not broken, cracked or damaged during construction. The video shall be high resolution and done by professional who is familiar with the process and meticulous. A CCTV inspection video is required for new storm drain connection (s) to verify proper connections were made into the City’s system and that no construction material was left behind. Videos of storm drain system may also be required where construction occurred less than 5-ft from the city’s storm drain system. Videos shall be provided from structure to structure, such as manhole to manhole. Contractor may want to conduct their own inspection in advance of construction to verify the existing pipe integrity. If existing damages are located, they shall be reported to Public Works inspectors prior to the start of construction. If not reported, the contractor may be responsible to restore the pipe segment as determined by Public Works prior to final.

24. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS

BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”.

25. SWPPP: This proposed development will disturb more than one acre of land.

Accordingly, the applicant shall apply for coverage under the State Water Resources Control Board’s (SWRCB) NPDES general permit for storm water discharge associated with construction activity. A Notice of Intent (NOI) shall be filed for this project with the SWRCB in order to obtain coverage under the permit. The General Permit requires the applicant to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP).

26. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way.

27. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit.

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41 28. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet.

29. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11. Submit the following:

30. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final.

31. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the building, the third-party reviewer shall submit to the City a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans.

32. PAVEMENT RESTORATION: The applicant shall restore the pavement along the entire project frontage, curb-to-curb, by performing a 3.5” grind and overlay. The exact restoration limits will be determined once the resulting road condition is known following completion of heavy construction activities and utility lateral installations, at minimum the extent will be the project frontage.

33. EXISTING EASEMENTS: Provide documentation showing approval from the entities affected by the onsite easements to verify that the work within said easements is permitted.

34. OUTSIDE AGENCY APPROVAL: A portion of the proposed work is within Caltrans right-of- way. Be advised that the following storm drain infrastructure is owned by Caltrans and therefore will require their approval prior to City permit issuance. Items owned by Caltrans:
a. 15-inch storm main along El Camino,
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42 b. Catch basins on Matadero/El Camino intersection, and associated proposed improvements.

35. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (STORM DRAIN LOGO): The applicant is required to paint “No Dumping/Flows to Matadero Creek” in blue on a white background adjacent to all onsite storm drain inlets. The name of the creek to which the proposed development drains can be obtained from Public Works Engineering.

36. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (RECORD DRAWINGS): At the conclusion of the project applicant shall provide digital as-built/record drawings of all improvements constructed in the public right-of-way or easements in which the City owns an interest.

37. PRIOR TO PUBLIC WORKS FINAL/ACCEPTANCE (INDEFINITE ENCROACHMENT PERMIT):

38. PLAN SET CONSISTENCY. The Final Map shall incorporate the drainage changes reflected in the Architectural Plan set submitted on February 26, 2026 and shall reflect and be consistent with the requirements and modifications identified in Section 8 of this Record of Land Use Action.

39. STORMWATER MANAGEMENT PLAN REVISIONS. Prior City permit issuance, the applicant shall work with the City to revise the stormwater management approach shown on Sheet C7.1 (Preliminary Stormwater Quality Control Plan). The currently proposed storm drain infrastructure associated with TCM 8 shall be reevaluated, and an alternative solution shall be developed to the satisfaction of the City. This may include, but is not limited to, modifying TCM 8 to utilize infiltration methods and identifying an alternative means of discharging stormwater from TCM 3. Final design details shall be subject to City review and approval prior to Final Map approval.

Water-Gas-Wastewater Utilities

40. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, Water meter shall be relocated so no obstruction is within the 10x10 easement. Refer to conditional comment in C7_3606 El Camino Real_Plans for location.

41. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, remove Item 8
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43 sewer connection shown on El Camino Real. Refer to conditional comment in C7_3606 El Camino Real_Plans for location. If a secondary sewer connection is needed connection shall be on Kendal Ave. or Matadero Ave.

42. On Sheet C4.1 – Preliminary Civil Site Plan, and C6.1 – Preliminary Utility Plan, add Reduced Pressure Principal Assembly (RPPA) to irrigation service per CPAU WGW Standard WD-11C

SECTION 9. Term of Approval.

1. Architectural Review Application. In the event actual construction of the project is not commenced within two years of the Effective Date, the approval shall expire and be of no further force or effect. An extension may be granted in accordance with the allowances set forth in the municipal code and state law.

2. Vesting Tentative Map. All conditions of approval of the Vesting Tentative Map shall be fulfilled prior to approval of a Final Map (PAMC Section 21.16.010[c]). Unless a Final Map is filed, and all conditions of approval are fulfilled within a two-year period from the date of Vesting Tentative Map approval, the Vesting Tentative Map shall expire and all proceedings shall terminate. A request for an extension of time may be granted by the city council after recommendation of the planning commission, after the written extension request of the subdivider is submitted, prior to the expiration of the Vesting Tentative Map approval, or any previous extension granted. Such extension(s) shall be subject to the maximum limitations set forth in the Subdivision Map Act.

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44 INTRODUCED AND PASSED:

AYES:

NOES:

ABSENT:

ABSTENTIONS:

ATTEST: APPROVED:

_________________________ ____________________________ City Clerk Mayor

APPROVED AS TO FORM: APPROVED AS TO CONTENT:

___________________________ ___________________________ Assistant City Attorney City Manager

___________________________
Director of Planning and
Development Services

PLANS AND DRAWINGS REFERENCED:

Those plans titled “C7_3606 El Camino Real_PLANS.pdf” consisting of 77 pages, dated and submitted February 26, 2026.

Those plans prepared by Kier+Wright titled “VESTING TENTATIVE MAP– 3606 EL CAMINO REAL (25PLN-00232)” consisting of twelve pages, dated and submitted February 3, 2026.

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Palo Alto City CouncilApril 13, 2026

Palo Alto City Council
April 13, 2026