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
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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 -
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
to
abide
by
the
Housing
Accountability
Act
(“HAA”)
and
AB
130
when
evaluating
the
proposed
321-unit
housing
development
project
at
3606
El
Camino
Real,
which
includes
38 units
affordable
to
low-income
households.
Under the HAA,
1 a city may not disapprove a qualifying affordable housing project (i.e., a housing
development
project
that
provides
a
certain
percent
of
the
total
units
to
lower-income
households,
as
defined
by
Health
and
Safety
Code
Section
50079.5)
on
the
grounds
it
does
not
comply
with
the
city’s
zoning
and
general
plan
if
the
developer
submitted
either
a
statutorily
defined
"preliminary
application"
or
a
"complete
development
application"
while
the
city's
housing
element
was
not
in
substantial
compliance
with
state
law.
(See
Gov.
Code,
§
65589.5,
subds.
(d)(5),
(h)(5),
(o)(1).
2 )
This
statutory
provision
temporarily
suspends
the
power
of
non-compliant
municipalities
to
enforce
their
zoning
rules
against
qualifying
affordable
housing
projects.
(See,
e.g.,
California
Housing
Defense
Fund
v.
City
of
La
Cañada
Flintridge
,
Case
Number:
23STCP02614
(attached),
for
a
recent
court
decision
affirming
the
plain
language
of
the
statute
in
this
regard.)
The
City’s
Housing
Element
was
not
in
substantial
compliance
with
state
law
when
the
preliminary
application
under
SB
330
was
submitted.
The
City
must
therefore
allow
the
project
to
be
developed
as
proposed.
2 These
code
section
numbers
correspond
to
the
HAA
as
it
existed
when
the
preliminary
application
for
the
project
at
issue
was
submitted
(i.e.
before
AB
1893
went
into
effect).
1 AB 1893, effective January 1, 2025, has amended the “Builder’s Remedy” provisions of the HAA.
However,
the
AB
1893
allows
for
vested
Builder’s
Remedy
applications
to
proceed
under
the
previous
version
of
the
law
or
the
new
version
of
the
law.
2201 Broadway, PH1, Oakland, CA 94612 www.calhdf.org
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
to
approve
this
project
would
risk
de-certification
of
the
City’s
Housing
Element
by
the
California
Department
of
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
of
Appeal
affirms
that
local
governments
err,
and
may
be
sued,
when
they
improperly
refuse
to
grant
a
project
a
CEQA
exemption
or
streamlined
CEQA
review
to
which
it
is
entitled.
(
Hilltop
Group,
Inc.
v.
County
of
San
Dieg
o
(2024)
99 Cal.App.5th
890,
911.)
As you are well aware, California remains in the throes of a statewide crisis-level housing shortage.
New
housing
such
as
this
is
a
public
benefit:
it
will
provide
badly-needed
affordable
housing;
it
will
bring
new
customers
to
local
businesses;
it
will
increase
the
city’s
tax
revenue;
and
it
will
reduce
displacement
of
existing
residents
by
reducing
competition
for
existing
housing.
It
will
also
help
cut
down
on
transportation-related
greenhouse
gas
emissions
by
providing
housing
in
denser,
more
urban
areas,
as
opposed
to
farther-flung
regions
in
the
state
(and
out
of
state).
While
no
one
project
will
solve
the
statewide
housing
crisis,
the
proposed
development
is
a
step
in
the
right
direction.
CalHDF
urges
the
City
to
approve
it,
consistent
with
its
obligations
under
state
law.
CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased
access
to
housing
for
Californians
at
all
income
levels,
including
low-income
households. You may learn more about CalHDF at www.calhdf.org. Sincerely, Dylan Casey CalHDF Executive Director James M. Lloyd CalHDF Director of Planning and Investigations 2 of 2
From:
To: Planning Commission
Cc: Switzer, Steven; Armer, Jennifer
Subject: 3606 ECR agenda item
Date: Wednesday, February 11, 2026 10:48:52 AM
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!
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
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!
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
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!
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
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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
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 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 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 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:
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:
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.
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.
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 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.
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
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 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.
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 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?
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.
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.
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
From: Fei Li
To: Switzer, Steven
Subject: Re: 3606 El Camino Project
Date: Thursday, November 20, 2025 3:22:31 PM
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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]>
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
From: Fei Li
To: Switzer, Steven
Subject: Re: 3606 El Camino Real Project started?
Date: Monday, June 9, 2025 11:44:41 AM
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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
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This is a personal email address.
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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?
Thank you,
Fei
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
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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
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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
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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
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
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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)
CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear Architectural Review Board:
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 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
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?
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,
Penny Brennan, PhD
Ventura Neighborhood