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PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
VIA EMAIL
City of Palo Alto
George Hoyt, Chief Building Official
Planning and Development Services Department
250 Hamilton Ave.
Palo Alto, CA 94301
Re: Notice and Order to Demolish/Deconstruct and Remove Buildings 531 Stanford Avenue
Dear Mr. Hoyt:
The City has issued a Notice and Order to Demolish/Deconstruct and Remove Buildings (“Notice”) to my client regarding the existing buildings at 531 Stanford Avenue. The Notice contains multiple factual and legal inaccuracies, and the purpose of this letter to correct the record and address next steps. The Notice seems to suggest that the owners have been dilatory in addressing the City’s concerns regarding the building. Nothing could be farther from the truth. In many respects, the delays in addressing the building have been caused by the City and its ever- shifting demands.
While my client disagrees that the building meets the requirements under PAMC § 16.40.050(c) that would require the building to be demolished, my client nonetheless does not intend to appeal the Notice at this time because my client shares the City’s desire to remove the building.
First, we must note that the City apparently mailed the Notice to the building at 531 Stanford Avenue, which the City knows is vacant, fenced, and inaccessible. The City did not properly serve the Notice pursuant to the requirements of PAMC § 16.40.060. We appreciate that Elisa Vargas, Building Inspector, confirmed in writing that the 15-day period to appeal the Notice would run from October 29, 2025. Again, my client hopes to avoid an appeal, but reserves the right to do so.
Property History
My clients first become involved in the property 531 Stanford Avenue in 2010, when the property was purchased by Fortune Sun, Inc.
(“Fortune”). This entity took over the existing
Stanford Terrace Inn (“STI”), a well-known hotel that had operated for decades prior to Fortune’s ownership. The STI had a long history of hosting many guests for long-term stays, Item 11
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including faculty members who used STI as their residence, as well as short-term transient guests. In 2018, the building was sold to Aurora Rising, Inc. (“Aurora”), who continued to operate the STI in the same manner.
In the Spring of 2020, as a result of COVID, STI rapidly lost its transient customer base, began to operate at a loss, and was forced to lay off most of its staff. The few customers who remained were non-transient residents, specifically Stanford faculty members and students who continued to reside at the property.
On or about June 18, 2021, the City of Palo Alto sent a letter to the ownership of STI, expressing preliminary interest in purchasing the subject property for possible inclusion in the State’s Project HomeKey program to provide housing for unhoused residents. The City sent similar inquiries in 2022 and sent information regarding affordable housing opportunities again to company’s closed registered business email address.
In May of 2023, ownership contacted the City Manager regarding potential redevelopment of the property for housing, including by submitting two different housing proposals. Ownership also requested that the City include the property in its Housing Element rezoning program. The City failed to include the property in its rezoning program and also failed to provide ownership with the necessary application forms to complete the redevelopment plans.
On February 28, 2024, the City sent a “courtesy notice” of the City’s intention to inspect the STI because an enforcement “investigation” had determined the STI property appeared to be used for long term stays that were not permitted under current regulations – even though the STI had long been used for such purposes and the City had certainly been aware of this well-established use for years. The City’s position was that the hotel use had been abandoned, the property was zoned RM-30, and the City made clear that its preference was for the property to be developed for high density housing. Ownership believes that this particular property had been singled out by the City for disparate treatment, as many other hotels in the City also regularly allow long term stays, yet no investigations have been opened against other properties.
Three days after the Planning Department met with the property management’s legal representative on March 18 to discuss redevelopment options, the City issued a formal Notice of Violation citing numerous violations such as lack of fire sprinklers and alarms, high combustible storage, unpermitted electrical and structural work, corroded plumbing, blocked egress routes, and inoperable elevators. The Notice required immediate fire-watch services by March 22, evacuation of upper floors and numerous corrective actions by March 25, 2024, and warned of possible declarations of substandard conditions, fines, or abatement orders if compliance was not achieved.
After years of cooperative engagement with the City regarding potential redevelopment of the STI property, we believe the owners’ decision not to sell the property to the City or repurpose it in accordance with the City’s preferred high-density housing agenda provoked a campaign of retaliation that ultimately led to the Notice of Violation and the building being deemed uninhabitable. These actions have caused my client significant harm, both monetarily and emotionally. The City has now decided that the building – which just less than three years ago Item 11
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the City wanted to purchase – is so dilapidated and dangerous that it must be demolished in a matter of months.
Findings and Violations
The Notice repeats many of the same findings that were issued in the prior Notice of Violation.
A number of the cited “violations” are inaccurate, immaterial, or grossly overstated, creating the false impression that ownership was a negligent operator rather than a reputable and conscientious business that had long operated a three-star hotel and, during extraordinarily difficult pandemic and post-pandemic years, allowed Stanford faculty and students to reside in quality accommodations at a fraction of market value.
Many of these findings and violations have been addressed or are only relevant to issues of habitability. As the City is well aware, the building is not currently occupied or used for habitation purposes. Thus, it is unclear why these largely erroneous findings have been repeated in the current Notice, except to continue to harass my client and create a false impression that ownership has done nothing to address the building.
For much of the last two years, the City’s position has been that the building cannot be demolished without an approved redevelopment plan. In fact, ownership submitted a demolition permit over a year ago and the City refused to accept it. Ownership has taken several remedial steps to address the purported violations, including, but not limited to, addressing the alleged hazardous materials remediation that the City mandated to “close” the property.
Less than two months ago, the City informed ownership that the City had changed its mind and now wants the building demolished regardless of redevelopment plan. The Notice erroneously suggests that ownership has simply ignored the Notice of Violation over the last year, which is simply false. Ownership has diligently addressed all the actions that the City has requested, including as recently as last month when the City demanded vegetation removal. The only reason the building has not yet been demolished is because the City has until two months ago refused to consider demolition until a redevelopment plan is approved, yet continually stonewalled ownership’s efforts at redevelopment.
Required Remedial Action
1. Deconstruction and Hazmat Closure Permits
The Notice demands that the applicant take immediate steps to submit two applications by November 17, 2025 – giving the applicant approximately three weeks to comply after the City sat on the submitted demolition permit for a year. Both of the City’s demands are flawed.
The City demands that the applicant submit a complete deconstruction permit. First, we again note the applicant submitted a demolition application in October 2024. The City had this application for over a year and never identified any deficiencies. This same exact application was submitted again last month.
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Second, the Notice cites to PAMC § 5.24 in support of the City’s demand for deconstruction.
The City’s demand for deconstruction is not authorized by code. Please be advised that PAMC §
5.24.080 clearly states the following:
5.24.080 Exclusions.
The provisions of this chapter shall not apply to the following:
(a) Dangerous Structures. Any building or structure that has been determined to be dangerous, structurally unsafe or otherwise hazardous to human life, and is required to be abated by demolition.
The City has determined that 531 Stanford is a dangerous building that is required to be abated by demolition. The City’s requirement for deconstruction in PAMC § 5.24 clearly does not apply, and we are unaware of any other code basis that would authorize the City to require deconstruction. While ownership will voluntarily recycle and reuse materials as much as possible, deconstruction cannot be legally required.
WE DEMAND THAT YOU CONFIRM DECONSTRUCTION IS NOT REQUIRED BY NOVEMBER 12. If the City fails to confirm by this date, ownership may have no choice but to appeal the Notice on the basis that the City cannot legally require deconstruction of a dangerous building abated by demolition per PAMC § 5.24.080.
Second, we find the City’s demand for a Hazmat Closure Permit puzzling. The applicant has already submitted a Hazmat Closure Permit, which was approved by the City. Much of the remedial action has already been completed. On August 19, 2025, the applicant submitted a permit extension/reactivation request form
to Mike Espeland of the Palo Alto Fire Department. In
short, ownership has already submitted this permit, and it is unclear what further actions the City needs ownership to complete.
1. Building Removal
As noted above, ownership shares the City’s desire to remove the building. However, we believe that the date of May 18, 2026 is unreasonable for several reasons.
First, much of the compliance deadline period (November-May) occurs during the winter months when rain is much more likely. Rain can cause significant delays and can create hazardous conditions during demolition. Ownership would request that the City at least push back the compliance deadline to allow demolition to take place during the dry season.
Second, as the City is aware, currently there is a T-Mobile tower that provides essential 911 communications on the existing building. During our meeting on September 11, 2025 – where the City for the first time stated demolition without redevelopment would be required – City representatives confirmed that they would afford the property owners sufficient time to work with T-Mobile to discuss potential relocation of this equipment. Approximately one month later, Item 11
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the Notice now demands removal with no plan in place and with no regard for this critical safety infrastructure. The City must approve a relocation plan for this equipment prior to demolition.
Third, the owners have already suffered significant financial losses following the pandemic, the liabilities and fines stemming from the City’s enforcement actions, and costs associated with remedial actions. Demolition activities also come with significant costs, and ownership is concerned that a vacant property with no active use will continue to be a magnet for nuisance activities. Ownership submitted an SB 330 application subject to AB 130 on August 19, and the City has failed to carry out its ministerial duties to conduct tribal scoping and process the application. Ownership must be able to put the property to an economically beneficial use following demolition, both to help fund the demolition activities and deter nuisance activities.
Ownership would like to request a meeting with City staff to discuss the timing of demolition, as well as alternatives for the T-mobile tower and post-demolition uses. Potential alternatives include: 1) partial demolition of the building with the equipment being relocated to the remaining portion until the housing development project is approved; 2) a standalone structure for the T- mobile Tower and temporary parking uses until the housing development project is approved; 3) a standalone structure for the T-mobile Tower and temporary storage uses until the housing development project is approved.
Conclusion
The City’s Notice is highly disappointing. After what we thought was a productive meeting on September 11 where the parties agreed to cooperate and communicate on a plan of action, the City unilaterally sends a Notice (to a vacant, fenced building) with an unreasonable timeline, without any attempt to contact the owners or their representatives, and threatening fines and jail time for noncompliance. The City’s surprise Notice is the opposite of a good faith attempt at cooperation.
We hope to avoid an appeal and chart path forward together with the City. However, we need confirmation that the City will provide flexibility and work collaboratively with ownership on the items discussed above. We look forward to resolving the outstanding issues.
V
ery truly yours,
PATTERSON & O’NEILL, PC
_______________________________
Brian O’Neill
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PATTERSON & O’NEILL, PC
235 Montgomery Street, Suite 950
San Francisco, CA 94104
Telephone: (415) 907-9110
Facsimile: (415) 907-7704
www.pattersononeill.com
VIA EMAIL AND U.S. MAIL
Before the city council of the city of Palo Alto
Mahealani Ah Yun, City Clerk
Office of the City Clerk: City Hall, 7th Floor
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Appeal of Notice and Order to Demolish/Deconstruct and Remove Buildings Buildings Located at 531 Stanford Avenue
Dear Ms. Ah Yun:
This appeal is submitted pursuant to PAMC § 16.40.080 on behalf of Stanford Orion, the property manager and owner’s representative, that is subject to the attached Notice and Order.
This appeal protests the following specific orders and actions, for the following reasons:
1) The Notice and Order was not properly served. The City mailed the Notice and Order to the building at 531 Stanford Avenue, which the City knows is vacant, fenced, and inaccessible building. The City did not properly serve the Notice and Order to the building owners, or their known representatives, as required by PAMC § 16.40.060.
2) The buildings at 531 Stanford do not meet the requirements for the City to order demolition. The building has already been vacated. Building can only be ordered demolished if the building is fifty percent damaged, decayed or deteriorated from its replacement value. The Notice and Order cites a number of “violations” that are inaccurate, immaterial, grossly overstated, or which have already been addressed.
Further, these violations are only relevant to issues of habitability and do not establish that the building has been fifty percent damaged, decayed or deteriorated from its replacement value.
3) The Notice and Order requires the submittal of a deconstruction permit and prohibits demolition of the building. The City Code on deconstruction, PAMC § 5.24.080 clearly exempts any building that has been determined to be dangerous, structurally unsafe or otherwise hazardous to human life that is required to be abated by demolition from all Docusign Envelope ID: 4D932618-C4F7-492A-BE9F-3666ECB0E493 Item 11
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deconstruction requirements. Thus, the City’s demand for deconstruction is unlawful, unauthorized, and must be set aside.
4) The Notice and Order requires complete removal by May 18, 2026. This timeframe is unreasonable, including because 1) this requires removal during the wet season, which can cause delays, increases costs, and can create dangerous condition; 2) essential public health and safety equipment is located on the building and there is currently no plan in place to address this equipment; and 3) the City has delayed approval of a post-approval plan and a vacant property with no active use will continue to be a magnet for nuisance activities.
The reasons for this appeal are further elaborated in the attached response to the Notice and Order.
Very truly yours,
PATTERSON & O’NEILL, PC
_______________________________
Brian O’Neill
STANFORD ORION
_______________________________
Sophia Huang
531 Stanford Avenue
Palo Alto, CA 94306
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VERIFICATION
I, Sophia Huang, declare as follows:
I am the appellant in this matter and am authorized to verify as to the truth of the matters stated in the appeal. I have read the foregoing appeal and know its contents. The matters stated in the appeal are true of my own knowledge from having been a representative of the owner’s of 531 Stanford for many years. I declare the foregoing matters are true and correct.
Executed on November 13, 2025 ________________________ Sophia Huang
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CITY OF PALO ALTO
PLANNING & DEVELOPMENT SERVICES
285 Hamilton Avenue, Palo Alto, California 94301
DECLARATION OF GEORGE HOYT
Chief Building Official, City of Palo Alto
Regarding the Conditions and Enforcement Actions
at 531 Stanford Avenue, Palo Alto, California 94306
(APN: 137-01-121, 137-01-002, 137-01-003)
Case No. 24PCE-00203
I. QUALIFICATIONS AND AUTHORITY
I, George Hoyt, CBO, CCEO, am currently employed by the City of Palo Alto as Chief Building Official (CBO) within the Planning & Development Services Department. I hold the Certified Building Official (CBO) designation issued by the International Code Coun cil (ICC) and the Certified Code Enforcement Officer (CCEO) credential issued by the California Association of Code Enforcement Officers , representing the highest professional certifications available in the building and code enforcement disciplines. I hav e served in municipal building and code enforcement roles for more than two decades and have been directly responsible for the enforcement of the California Building Standards Code (C CR Title 24 ), and all applicable provisions of the Palo Alto Municipal Code (PAMC), including without limitation PAMC Chapte r
16. As Chief Building Official, I have statutory authority under California Health and Safety Code (H&SC) Section 17980 et seq. and the Palo Alto Municipal Code (PAMC) to determine when structures constitute dangerous or substandard buildings; to issue Notices and Orders to Repair or Abate; to post “Unsafe to Occupy” placards; to order the vacation of occupants; and —where rehabilitation is not feasible—to order demolition.
I make this declaration based on my personal inspections of the subject property, my review of all building, planning, and enforcement records maintained by the City of Palo Alto, my professional training and experience, and my direct oversight of all enfo rcement proceedings related to this matter.
II. PROPERTY BACKGROUND AND PERMIT HISTORY
The subject property consists of three adjoining parcels located at 531 Stanford Avenue, Palo Alto, California, commonly identified by Assessor's Parcel Numbers 137-01-121, 137-01-002, and 137-01-003. The property is also referenced in various records as 5 20 Oxford Avenue. The buildings at this location consist of a multi -story structure originally constructed and permitted Item 11
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as a hotel under Residential Occupancy Classification R -1 (transient occupancy ). City records indicate that there are approximately 80 lodging rooms.
A thorough search of City building, planning, and permit records conducted in connection with this enforcement matter revealed a near -total absence of required permits and inspections for the subject property. City records confirm no permits or records of inspection for any of the following:
• Use and Occupancy: No valid use and occupancy permit for residential apartment use; the R-1 hotel permit had expired without renewal. Any owner or authorized agent who intends to change the occupancy of a building or structure shall first obtain the required permit. (CBC 111.1.1; PAMC § 16.04.190)
• Address Assignment: The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240) • Building Alterations: No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
• Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC 105.1) • Elevator Operation: Elevator operating certifications had expired with no renewal, in violation of CCR Title 8, Section 3001.
III. INITIAL INSPECTION AND VIOLATION FINDINGS — MARCH 18, 2024 After receiving information that possible code violations existed at the property, the City sent a Request to Inspect issued January 25, 2024. After the responsible parties had failed to cooperate with initial inspection efforts, despite written admissions that the buildings were being occupied for residential purposes, a Final Notice to Inspect was issued on March 11, 2024. On March 18, 2024, I, along with Fire Marshal Tamara Jasso, Code Enforcement Supervisor Elisa Vargas, and other City staff, conducted a comprehensive inspection of the buildings at 531 Stanford Avenue.
The inspection commenced at 10:00 AM and concluded at 12:00 PM, covering the basement, garage, and all accessible levels and units. The March 18, 2024, inspection revealed conditions of extraordinary severity. Based upon my professional training and decades of experience as the Chief Building Official for the City, I determined that the buildings contained numerous violations constituting a substantial danger to the life, health, and safety of all occupants. The following building code violations were identified and documented, organized by building system and location. The following code violations are not intended to be a comprehensive list of all violations present at the property at the time of inspection. The violations listed below are summary of what was observed on this site visit.
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My findings below are based on my direct observations of the property and observations from other City staff present conducting the inspection. Other City staff reported to me the additional findings from spaces I did not enter. Their findings are largely consistent with what I observed.
A. Structural
Violations were documented throughout the buildings. Much of the work described below was performed without permits, inspections, or approvals, in violation of CBC 105.1 or a dangerous or substandard condition existed.
• Basement — Equipment Room: Holes in walls throughout the equipment room. Partial structural deterioration — approximately 50 percent possible erosion of structural material observed in the ceiling of the equipment room. (PAMC § 16.40.020 (a)) • Basement — Storage Room: Old ceiling falling, including attached ceiling light fixtures.
Suspicious growth (mold) and corrosion observed throughout the storage room. (PAMC § 16.40.020 (a), (m))
• Garage — General: Signs of water intrusion on garage ceiling consistent with ongoing moisture infiltration and building envelope failure. (PAMC § 16.40.020 (e)) • Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential structural failure of a required egress path. (PAMC § 16.40.020 (a)(3); CBC 105.1) • B. Mechanical and Plumbing
Violations were documented throughout the buildings. Much of the work described below was performed without permits, inspections, or approvals, in violation of CBC 105.1 or a dangerous or substandard condition existed.
• Basement — Equipment Room: Water heaters installed without permits and without required seismic strapping. An abandoned pool/spa boiler was present. A possible cross- connection to potable water was identified, presenting a public health risk requiring further investigation. (PAMC § 16.40.010 (p) and 16.40.020 (g)) • Basement — Equipment Room — Return Air: Return air vent was severely corroded, compromising the mechanical ventilation system. (PAMC § 16.40.010 (p) and 16.40.020 (h))
• Garage — Equipment Room #2: Corroded drain, waste, and vent (DWV) copper piping in the ceiling. Exhaust fans in deteriorated condition, falling apart. Unpermitted boiler, two unpermitted water heaters, and two unpermitted storage tanks installed without permit or inspection. Appliance exhaust venting was non-compliant. (PAMC § 16.40.010 (p) and
16.40.020 (g), (h))
• Lobby — Unpermitted Plumbing: Unpermitted plumbing piping was installed on a wall in the lobby area to supply the unpermitted commercial kitchen adjacent to Unit 500. (PAMC § 16.40.020 (g))
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C. Electrical
Violations were documented throughout the buildings. Much of the work described below was performed without permits, inspections, or approvals, in violation of CBC 105.1 or a dangerous or substandard condition existed.
• Basement — Equipment Room: Corroded electrical wiring and equipment throughout.
Open junction boxes (j -boxes) with limited or no access cover. Corrosion of electrical components in the closet. Unsafe electrical installations. Unpermitted flood light installed above counter without permit or inspection. No permanent lighting installed; temporary lighting in use that was inappropriate for the application. (PAMC § 16.40.010 (p) and
16.40.020 (f))
• Garage — Hallway: The electrical service in the garage hallway consisted of 800-ampere and 125-ampere services. Unpermitted electrical installations were present throughout.
Dead conduits and open knockouts on electrical enclosures were identified — a condition that leaves energized electrical components exposed and accessible. Exposed non - metallic (NM) cable run on the ceiling at an unpermitted light fixture. Electrical wiring was observed running along and in contact with the fire sprinkler lines, creatin g a condition where a fault in the wiring could occur. Sprint telecommunications electrical equipment requiring removal was present. (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Garage — General: Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions . (PAMC § 16.40.010 (p) and 16.40.020 (f))
• Garage — Restroom: Exposed electrical wiring and exposed ceiling framing in the restroom area adjacent to the garage. (PAMC § 16.40.010 (p) and 16.40.020 (f)) • Level One — Units 109–113 and 500: Unsafe electrical in each unit, including improper use of extension cords and plug strip surge protectors as a substitute for permanent wiring. (PAMC § 16.40.010 (p) and 16.40.020 (f))
• Lobby and Office: Improper use of electrical cords and cord strips throughout the lobby and office area. Unsafe electrical installations outside at the Stanford Avenue lobby entrance. (PAMC § 16.40.020 (f))
D. Egress and Life Safety
Egress violations were documented throughout the buildings. Conditions affecting required means of egress — including fire-rated door assemblies, exit signage, emergency lighting, and exit pathways — were found to be non-compliant at multiple specific locations. • Basement — Stairwell (Basement to Ground Floor): The rated door in the stairwell leading from the basement to the ground floor was missing a hinge and gaskets. The door hardware was not of a listed/approved type. The door did not self -close as required.
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Rated doors in this stairwell were observed propped open, defeating the fire -separation function of the rated assembly. (CBC 716.2)
• Basement — Storage Room: The rated door to the storage room was not properly listed or labeled. Door hardware was incorrect and not of an approved type. The door was not self-closing as required for fire-rated assemblies. (CBC 716.2) • Garage — Equipment Room #2: Minimum head clearance conditions created due to the unpermitted installation of equipment and associated piping. (CBC 1003.2) • Second Stairwell: Door hardware in the second stairwell was non -functional and would not allow the door to close. Only a deadbolt was present as door hardware, which does not satisfy egress latch requirements and cannot be operated from the egress side in an emergency. No exit signs were present in this stairwell. (CBC 1010.2 and 1013.1) • Garage — Restroom: The rated door at the restroom was non-compliant: it was propped open, bore no required labels or ratings tags, and was equipped with the wrong hardware type. No access was available to the adjacent storage closet. (CBC 716.2) • Level One — General: Blocked exits documented on Level One. No emergency lighting was present or functional on Level One. (CBC 1010.2 and 1008.1) • Unapproved Building Materials — Plastic Film: Plastic film was affixed to ceilings in residential units and to the ceiling of the Level One hallway. This is an unapproved building material that poses significant fire propagation risk and produces toxic gases when burned. (PAMC § 16.40.010 (p), 16.40.020 (b) and CBC 803.1) • Open Stairs — Corridor: Exit signage and emergency lighting in the open stairwell corridor were limited and none were found to be working. Unpermitted storage was present in this corridor, creating additional obstructions to egress. (PAMC § 16.40.010 (a) , CBC 1013.1 and 1008.1)
• Garage — No Exit Signage: No exit signage was present in the garage area. (CBC 1013.1) • South Corridor Door: The south corridor door was equipped with a l ockable latch — hardware that does not meet fire egress requirements for a rated assembly. No rated door or frame tags were present. The installation constituted a breach of the required rated assembly. No rated doors were present on the north side of the sam e required opening, creating an unprotected opening in the fire -rated separation. (PAMC §
16.40.010 (a), CBC 1010.2 and 716.2)
• Garage — Blocked Entry: The garage entrance was blocked, preventing required access and egress through this area. (PAMC § 16.40.010 (a), 16.40.020 (j), and CBC 1006.2) • Level One — Storage Closets Locked: Storage closets on Level One were locked, and the locked telecommunication room in the garage was inaccessible to inspectors. Limited access to required spaces prevented full assessment of conditions. • Level One — Units 109–113 and 500: Smoke detectors in occupied units were outdated and did not meet current code requirements. No carbon monoxide (CO) detectors were present in any unit. (CBC 907.2 and 915; California H&S § 13113.7 and 17926) Item 11
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• Inoperable Elevators: Elevators had expired operating certifications and were not in service, in violation of CCR Title 8, Section 3001.
E. Habitability and Sanitation
Habitability violations were documented in multiple areas of the buildings. • Basement — Equipment Room: Suspicious growth on the ceiling , which was visibly - assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.010 (n), and 16.40.020 (i), (m)) • Basement — Storage Room: Suspicious growth and corrosion were observed throughout the storage room, which was visibly-assessed as potentially mold. (PAMC § 16.40.010 (n) and 16.40.020 (i, m))
• Swimming Pool — Garage and Underfloor Level: The swimming pool exhibited visible mold growth at the underfloor a t garage level. (PAMC § 16.40.010 (n) and 16.40.020 (i), (m))
• Buildings Generally — Vermin: Signs of vermin infestation were observed throughout the buildings. (PAMC § 16.40.010(n) and 16.40.020(i)(13).
• Level One — Overcrowding Safety Concerns: Safety concerns were documented related to overcrowded living arrangements observed on Level One, consistent with inappropriate subdivision of hotel rooms for permanent residential occupancy. (PAMC § 16.40.010(l))
F. Change of Occupancy Classification and Unpermitted Construction The buildings were operating with multiple unpermitted uses and an unauthorized occupancy classification.
• Unauthorized Residential Occupancy (R -2): The buildings were originally permitted as R-1 (hotel/transient occupancy) but were being operated as R-2 (non-transient residential occupancy) without permit or approval. R-2 occupancies are subject to substantially more demanding life-safety requirements — including fire sprinkler coverage, egress standards, and occupant load requirements — that these buildings had never been designed, constructed, or inspected to satisfy such an occupancy. (PAMC § 16.40.010(l)) • Level One — Units 109, 110, 111, 112, 113, and 500: All former hotel rooms had been remodeled and converted to residential non transient occupancy use without permits.
Unpermitted construction in each unit included: enclosure of balconies and decks with plastic roof structures; disconnected deck drains; and installation of electric fireplaces without permit or inspection. (CBC 105.1)
• Unpermitted Commercial Kitchen Adjacent to Unit 500: A commercial kitchen was constructed adjacent to Unit 500 without any permits for construction, plumbing, mechanical, or electrical systems. The presence of a commercial kitchen within a residential occupancy building, operating without a permit or health department clearance, constitutes an unauthorized change of use. (CBC 105.1) Item 11
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• Unpermitted Kitchen and Laundry in Garage: Unpermitted kitchen and laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space. (CBC 105.1)
• Unpermitted Office Space in Garage: An office space was constructed in the garage without permits, with unsafe electrical conditions and storage clutter presenting no clear path of travel. (CBC 105.1)
• Lobby and Office Used as Living/Storage Space: The lobby and office areas were being used for storage and as a Wi -Fi area. Warming and cooking appliances were present, indicating use of these common areas beyond their permitted function. (PAMC § 16.40.010(l))
• County Health Department Records — Status Unknown: County Health Department records relevant to the property were noted as requiring further review. The operating status of applicable County Health Department permits could not be confirmed during the inspection. (California H&S § 113700 and 114437)
IV. EMERGENCY NOTICE AND ORDER TO REPAIR OR ABATE — APRIL 2, 2024 Based upon the findings of the March 18, 2024, inspection, my staff issued Notices of Violation to the property owner on March 21, 2024, and March 28, 2024, identifying the unsafe and unlawful conditions observed at the property and directing the responsible parties to take corrective action. The prop erty owner did not take the necessary steps to fully correct the violations or otherwise bring the buildings into compliance.
After determining that the buildings at 531 Stanford Avenue constituted unsafe structures and substandard residential buildings presenting an immediate and substantial danger to the life, health, and safety of the occupants and the surrounding public, I issued an Emergency Notice and Order to Repair or Abate (“N&O”) on April 2, 2024, pursuant to Health and Safety Code Section 17980.6 and PAMC Chapter 16.40.
The Emergency N&O formally documented all violations described above and established the following compliance deadlines. Within five business days (by April 9, 2024), the owners were required to begin remediation of all identified unlawful conditions, incl uding submission of permit applications. The N&O further informed the responsible parties that the City had identified a short -term solution—a FIREWATCH—to allow the existing occupants to remain in residence for a period not to exceed seven calendar days, subject to strict conditions. These conditions included continuous fire watch services, restriction of all occupants to the first floor, cessation of new rentals, draining of the pool, and securing of the second and third floors.
I further formally notified the responsible parties that failure to comply with the N&O would result in the immediate posting of “UNSAFE TO OCCUPY” placards on all buildings, immediate disconnection of all utilities, and criminal misdemeanor prosecution at the rate of $1,000.00 and/or up to six months in jail per day per violation, among other available remedies.
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V. POSTING OF "UNSAFE TO OCCUPY" PLACARD — APRIL 9, 2024 On April 9, 2024, at 5:00 PM, after confirming that the owners had failed to make the required building repairs, obtain the required permits, or otherwise bring the buildings into compliance within the time allowed, and consistent with the direction provid ed in the Emergency N&O, I caused the buildings at 531 Stanford Avenue to be posted with an “UNSAFE — DO NOT ENTER OR OCCUPY” placard pursuant to PAMC Section 16.40.070.
Following issuance of the Emergency N&O, my staff issued additional Notices of Violation to the responsible parties on April 3, 2024, and April 9, 2024, reiterating the unsafe conditions at the property and the requirement to correct those violations. The responsible parties did not take the actions necessary to bring the property into compliance.
From April 9, 2024, forward, the buildings were required to be locked and secured, with access permitted only during City of Palo Alto construction hours and only for the specific purpose of removing loose combustible materials and preparing the buildings for permanent closure.
The posting of the placard constituted my official determination, as Chief Building Official, that the buildings were dangerous and substandard pursuant to PAMC Sections 16.40.010 and
16.40.020, and that continued occupancy would constitute a misdemeanor c riminal violation. I further provided formal notice to the responsible parties that removal of any placard prior to issuance of a Certificate of Occupancy would itself constitute a misdemeanor violation of PAMC Section 16.40.070.
VI. SUBSEQUENT MONITORING AND PERIODIC INSPECTIONS (2024–2025) Following the vacation of the buildings and posting of the placard in April 2024, Code Enforcement and Fire Department personnel conducted periodic inspections pursuant to the requirements set forth in the Fourth Notice of Violation, dated April 9, 2024, to confirm continued non-occupancy and to monitor the security and physical condition of the property.
These inspections confirmed that while tenants had vacated the premises, the underlying structural and code violations remained unaddressed, permits for remediation had not been obtained, and the physical condition of the buildings continued to deteriorate.
Site inspection photographs from subsequent visits —including those taken during fire service inspections (documented under Fire Service Case Numbers 6000014517 and 6000014516) depict the continued deterioration of the property: vegetation overgrowth compromising the building envelope, breaches in the chain-link fencing, debris accumulation at the entryway, and evidence of unauthorized access to the property. A mattress and bedding observed on what appears to be an exterior walkway or balcony are consistent with evidence of unauthorized habitation —a condition I directed to be investigated and addressed.
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City field observations further documented evidence of unauthorized tapping into the property’s irrigation line from the public water meter. This raised concerns regarding unauthorized access to utilities following the required utility disconnection and po tentially indicated the presence of unauthorized occupants.
No remediation, permitting, or rehabilitation work was performed by the responsible parties during the eighteen -month period from April 2024 through October 2025. The hazardous materials closure process also remained incomplete, with Hazmat Closure Permits 24HZM-00040 and 23FDP-00929 remaining open and the responsible parties submitting extension requests as late as August 19, 2025.
VII. ORDER TO DEMOLISH – OCTOBER 17, 2025
On October 17, 2025, I issued a Notice and Order to Demolish/Deconstruct and Remove the Buildings Located at 531 Stanford Avenue (the “Demolition N&O”), pursuant to H&SC Section 17980.6 and PAMC Chapter 16.40. My determination that demolition is required is based on my finding that the buildings meet all three independent mandatory demolition criteria established by PAMC Section 16.40.050(c). Each criterion is addressed in detail below.
A. First Criterion: Buildings Are Fifty Percent or More Damaged, Decayed, or Deteriorated Based upon my comprehensive assessment of the condition of the buildings at 531 Stanford Avenue—informed by my personal inspection on March 18, 2024, eighteen months of post - vacation monitoring, review of all enforcement and permit records, and my professi onal expertise as a Certified Building Official —it is my expert opinion that the buildings are fifty percent or more damaged, decayed, or deteriorated relative to their replacement value.
This determination is based on the cumulative assessment of the following conditions:
• Failed fire protection systems requiring complete replacement: The fire sprinkler and fire alarm systems throughout all buildings are dilapidated, corroded, and non- functional, with no maintenance records. These systems cannot be repaired in place and require complete removal and replacement throughout all buildings. The cost of fire protection system replacement alone is substantial.
• Severely corroded electrical and plumbing systems: Electrical wiring, conduit, panels, plumbing pipes, and fixtures throughout the buildings exhibit severe corrosion, caused in part by exposure to improperly stored hazardous materials. This corrosion is not localized—it is systemic and affects all building s. Complete replacement of the electrical and plumbing systems throughout all buildings is required, as repair of individual corroded components is neither feasible nor code compliant. • Structural deterioration requiring emergency shoring: The second -floor exit balcony required emergency shoring at the time of the March 18, 2024 inspection, indicating a structural failure that was not simply a maintenance issue but a fundamental load-bearing Item 11
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deficiency. Structural rehabilitation of this element requires engineering analysis, permitting, and construction work that cannot be accomplished through surface repair. • Extensive unpermitted construction with unknown compliance status throughout all building systems: Because none of the extensive modifications throughout the buildings were permitted, inspected, or approved, the actual structural, fire, electrical, and plumbing condition cannot be fully determined without physical demolition of finished assemblies. The presence of unknown, uninspected construction means that the apparent condition significantly understates the actual extent of deficiencies. In my professional judgment, the scope of unpermitted work and the inability to fully assess its condition without demolition is itself a significant factor in the fifty -percent determination.
• Eighteen months of documented post -vacation deterioration: From April 2024 through October 2025, the buildings were not maintained, heated, or protected from the elements. Vegetation overgrowth compromised the building envelope; moisture intrusion accelerated deterioration of building systems; the security perimet er was breached; and all pre -existing conditions worsened. Buildings that are red -tagged, unoccupied, and unmaintained deteriorate rapidly, and the eighteen -month deterioration period significantly worsened the already critical conditions documented on March 18, 2024.
Taking into account the cumulative replacement cost of:
(1) complete fire protection system replacement;
(2) complete electrical system replacement;
(3) complete plumbing system replacement;
(4) structural reconstruction of the exit balcony and assessment and remediation of unpermitted structural work;
(5) removal and reconstruction of unpermitted construction throughout all building areas;
(6) egress system reconstruction;
(7) mold remediation; and
(8) hazardous materials remediation
it is my professional determination that the cost of rehabilitation exceeds fifty percent of the replacement value of the structures, satisfying the first demolition criterion under PAMC Section 16.40.050(c).
• B. Second Criterion: Buildings Cannot Be Repaired to Eliminate the Violations It is my professional opinion that the buildings at 531 Stanford Avenue cannot be repaired, in any conventional sense of that term, to eliminate the violations documented herein and bring the Item 11
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buildings into compliance with applicable codes. The scope of work required to achieve compliance constitutes reconstruction rather than repair, for the following reasons:
• Complete replacement of fire protection, electrical, and plumbing systems throughout all buildings
• Structural reconstruction of the second-floor exit balcony • Removal and reconstruction of unpermitted work throughout all building areas • Egress system reconfiguration to meet R-2 occupancy requirements • Compliance with R-2 life-safety standards rather than the originally permitted R-1 occupancy
The cumulative scope of these required activities —complete system replacement, structural reconstruction, interior demolition and rebuilding, egress reconfiguration, and occupancy classification upgrade—is, in my professional judgment, indistinguishable fr om demolition and reconstruction of the buildings. Rehabilitation is therefore not a meaningful option.
C. Third Criterion: Buildings Constitute Fire Hazards in Violation of Applicable Codes It is my professional opinion that the buildings at 531 Stanford Avenue constitute fire hazards in violation of PAMC §§ 16.40.010(p) & 16.40.020(c), and, based on the opinion of Fire Marshall Jasso, PAMC Title 15 and the California Fire Code. These violations include the following conditions:
• Failed fire sprinkler and alarm systems
• Plastic film affixed to ceilings and stairways that rapidly propagates fire • Blocked or non-functional egress routes
• Elevated combustible storage creating excessive fire load • Corroded electrical systems creating ignition risk
• Missing emergency lighting and exit signage
In my more than twenty years of municipal building enforcement experience, the buildings at 531 Stanford Avenue present some of the most extensive and severe code violations I have encountered. The combination of failed fire protection systems, extreme fir e load, unapproved fire-propagating materials in egress paths, and blocked exits creates conditions under which any fire could rapidly become fatal to any person present. These conditions cannot be effectively remediated short of complete removal of the structures.
VIII. CONDITIONS OF DEMOLITION N&O
The Demolition N&O established the following compliance deadlines:
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(1) Submission of a complete deconstruction permit application no later than November 17, 2025; and
(2) Removal of the buildings and securing of the parcel no later than May 18, 2026.
These deadlines were established after careful consideration of the time required to complete necessary pre -construction activities, including hazardous materials closure, utility disconnection, Bay Area Air Quality Management District (BAAQMD) J -number ac quisition, regulated tree surveys, grading and excavation permits, and a pre-construction conference with all required City departments.
I am aware that on November 7, 2025, the property owner’s legal representative transmitted a written response to the Demolition N&O, and that on November 13, 2025, an appeal was filed with the City Clerk pursuant to PAMC Section 16.40.080 on behalf of Stanford Orion, the property manager and owner’s representative. I have reviewed those submissions.
With respect to the argument that deconstruction is not required pursuant to PAMC Section
5.24.080, I directed City staff and the City Attorney’s Office to review the argument in good faith, and I acknowledge that the exemption for dangerous buildings is be applicable. Therefore, any deconstruction efforts will be voluntary.
However, I cannot, and do not, concede the underlying determination that these buildings must be demolished. The evidence of dangerous and unsafe conditions is overwhelming, well documented, and supported by multiple inspections conducted over a period of nearly two years.
IX. PROFESSIONAL OPINION AND CONCLUSION
Based upon my personal inspections of the property, my review of all relevant building and enforcement records, my professional training as a Certified Building Official, and my decades of experience in California municipal building regulation, it is my professional opinion that the buildings located at 531 Stanford Avenue, Palo Alto, California, constitute dangerous, unsafe, and substandard structures within the meaning of H&SC Section 17980 et seq. and PAMC Chapter 16.40.
The scale and severity of the violations documented—encompassing structural deficiencies, life-safety system failures, unauthorized construction affecting all major building systems, unauthorized occupancy classification, sanitation hazards, and the absence of required permits and inspections spanning many years—is among the most extensive I have encountered in my professional career. The buildings meet all three independent mandatory demolition criteria under PAMC Section 16.40.050(c), as set forth in Section VII above. Demolition is not only warranted but required by law.
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I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is based upon my personal knowledge, professional training, and experience.
Executed on: _______________________________
_____________________________________________
George Hoyt, CBO, CCEO
Chief Building Official
Planning & Development Services Department, City of Palo Alto 285 Hamilton Avenue, Palo Alto, California 94301
(650) 329-2605
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CITY OF PALO ALTO
PLANNING & DEVELOPMENT SERVICES — CODE ENFORCEMENT
285 Hamilton Avenue, Palo Alto, California 94301
DECLARATION OF ELISA VARGAS
Code Enforcement Supervisor, City of Palo Alto
Regarding Enforcement History, Compliance Record, and Current Status at 531 Stanford Avenue, Palo Alto, California 94306
(APN: 137-01-121, 137-01-002, 137-01-003)
Case No. 24PCE-00203
I. QUALIFICATIONS AND AUTHORITY
I, Elisa Vargas, am the Code Enforcement Supervisor for the City of Palo Alto Planning & Development Services Department. I have served in municipal code enforcement and building inspection roles for nine years, including extensive service with the City of Palo Alto. I hold the Certified Code Enforcement Officer (CCEO) designation and other professional certifications recognized in the California code enforcement field. In my role as Code Enforcement Supervisor, I am responsible for the management and oversight of all code enforcement cases, including the direction of individual code enforcement officers, coordination with other City departments (including the Building Department and Fire Department), and the administration of all enforcement proceedings from initial complaint through resolution.
I have direct and personal knowledge of the enforcement case involving the property at 531 Stanford Avenue, Case No. 24PCE-00203 (the "Case"). I supervised and personally participated in the enforcement actions described herein from the case's inception through the present.
This declaration is based upon my personal observations during field inspections, my review of all case records (correspondence, inspection reports, administrative citations, and related documents maintained in City enforcement files), and my professional training and experience in California municipal code enforcement.
II. CASE INITIATION AND PRELIMINARY INVESTIGATION
Case No. 24PCE-00203 was opened by the Palo Alto Code Enforcement Division in January 2024, upon receipt of information indicating that the property at 531 Stanford Avenue was being used for residential occupancy without the requisite permits and that numerous modifications to the buildings had been made without building permits. A preliminary review of City building and planning records confirmed that no permits had been issued for any of the reported modifications and that no use and occupancy certification existed for the current use of the buildings.
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A comprehensive review of City permit records confirmed a complete absence of permits for the following uses and activities:
• Use and Occupancy: No valid use and occupancy permit for residential apartment use; the R-1 hotel permit had expired without renewal. Any owner or authorized agent who intends to change the occupancy of a building or structure shall first obtain the required permit. (CBC 111.1.1; PAMC § 16.04.190)
• Address Assignment: The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC §
16.04.240)
• Building Alterations: No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
• Pool Operation: No permits for pool construction, modification, or operation. (CBC 105.1).
On January 25, 2024, Lead Code Enforcement Officer Brian Reynolds issued a formal “Request to Inspect” to Aurora Rising Inc. / Atlas Star, the identified responsible party, via Certified Mail No. 7014 2120 0001 4340 4290. That letter set a deadline of February 5, 2024, for the responsible parties to contact the City to schedule a comprehensive inspection. The letter cited the following code provisions:
• CBC R105.1 — Permits Required: Any owner or authorized agent who intends to construct, enlarge, alter, repair, move, demolish, or change the occupancy of a building or structure, or to install, enlarge, alter, repair, convert, or replace any electrical, gas, mechanical, or plumbing system, shall first obtain the required permit. • CBC § 114.1 — Unlawful Acts: It shall be unlawful for any person, firm, or corporation to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building, structure, or equipment regulated by this code in conflict with or in violation of any of its provisions.
• PAMC § 16.04.225 — Violations: It is unlawful for any person to violate any provision or to fail to comply with any requirement of PAMC Chapter 16.04. Each separate day or portion thereof during which any violation occurs shall constitute a separate offense.
Violators are subject to administrative enforcement pursuant to PAMC Chapters 1.12 and 1.16 and criminal enforcement pursuant to PAMC Chapter 1.08. • PAMC §§ 18.01.030 and 18.01.080 — Compliance with Zoning Regulations Required:
No land shall be used, and no facility, structure, or building shall be erected, constructed, enlarged, altered, moved, or used in any district except in accordance with the regulations established by the zoning title.
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Despite the January 25, 2024, Request to Inspect and the stated deadline of February 5, 2024, the responsible parties did not contact the City to schedule the required inspection. Written communications received from the responsible parties during this period included admissions that the property was being used for residential living purposes, which created both an obligation for the City to conduct a life-safety inspection and an urgent basis for action.
Following this failure to cooperate, I assumed direct supervisory oversight of the case and escalated the enforcement approach.
III. FINAL NOTICE TO INSPECT — MARCH 11, 2024
On March 11, 2024, I issued a “Final Notice to Inspect” (“Final Notice”) under my authority as Code Enforcement Supervisor, transmitted to the responsible parties via Certified Mail No. 7014 2120 0001 4340 4481, with copies to Chief Building Official George Hoyt and Fire Marshal Tamara Jasso. This notice advised the responsible parties that the City had received written admissions confirming residential use of the property and that City Code Enforcement staff required an immediate inspection to verify the absence of immediate life and safety hazards.
The Final Notice stated unambiguously that failure to cooperate could result in the City obtaining a judicial inspection warrant, 24-hour advance notice to tenants, and immediate interruption of utility services.
The Final Notice set a deadline of March 14, 2024, at 5:00 PM. This deadline was not met.
However, arrangements were ultimately made for an inspection to proceed on March 18, 2024.
IV. FIRST NOTICE OF VIOLATION — MARCH 21, 2024
Following the comprehensive inspection conducted on March 18, 2024, by myself, Chief Building Official Hoyt, and Fire Marshal Jasso, I coordinated preparation and issuance of the 1st Notice of Violation, dated March 21, 2024, transmitted via personal service, posting on subject property, and Certified Mail No. 7018 3090 0001 0801 1115, addressed to Aurora Rising Inc./Atlas Star LLC. The 1st Notice of Violation was signed by Chief Building Official Hoyt, with copies to the City Attorney's Office, Fire Marshal Jasso, and Dana Kennedy, attorney for the responsible party.
The 1st Notice of Violation documented the full scope of violations identified during the March 18, 2024, inspection, which are set forth in detail in the Declaration of Chief Building Official Hoyt and the Declaration of Fire Marshal Jasso. In summary, those violations included:
• Dilapidated and missing emergency exit signage and emergency lighting throughout the buildings.
• Dilapidated fire sprinkler and fire alarm systems, with no documentation of required testing, inspection, or maintenance.
• Unconfirmed records of testing for fire sprinklers and fire alarm systems, rendering the systems unreliable for emergency response.
• High combustible storage throughout all buildings; improper hazardous material storage creating corrosive environments; severely corroded electrical and plumbing systems.
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• Plastic film affixed to ceilings in some units and in exit stairways, creating an extreme fire propagation hazard.
• Unpermitted construction — shoring of the 2nd floor exit balcony for stability; potential structural failure of required egress path.
• Unpermitted remodeling of all hotel rooms and throughout the buildings, including unauthorized enclosure of decks, patios, and addition of roof coverings. • Unpermitted construction in electrical systems, mechanical systems, and plumbing throughout all buildings.
• Blocked egress on the Stanford Avenue side and throughout the interior; non- functioning and missing egress exits including missing and inoperable fire-rated doors. • Exposed mold growth in the basement; signs of vermin infestation; swimming pool with visible mold growth, no current Santa Clara County permits or clearances. • Inoperable elevators with expired operating certifications. • Unauthorized change of occupancy from R-1 (hotel) to R-2 (residential) without permit or approval.
The 1st Notice of Violation set the following compliance deadlines:
1. By Friday, March 22, 2024, at 5:00 PM: Fire watch services required to be in place and monitoring the building. The City conducted an inspection at the compliance deadline time to confirm.
2. By Monday, March 25, 2024, at 2:00 PM: (a) All tenants to vacate the 2nd and 3rd floors of all buildings with access restricted; (b) Smoke detectors and carbon monoxide detectors provided to all units and common occupied areas; (c) All deadbolts and paddle lock latches removed from required exit fire-rated doors; (d) All unpermitted barriers removed from exit pathways; (e) Names and addresses of all tenants in all buildings provided to the City.
3. By Tuesday, March 26, 2024, at 5:00 PM: Pool water to be tested for chemical content and a strategy/schedule submitted for draining the pool no later than March 29, 2024.
V. SECOND NOTICE OF VIOLATION — MARCH 28, 2024
A follow-up inspection conducted by City Code Enforcement and the Palo Alto Fire Department at 5:00 PM on March 22, 2024, confirmed that fire watch services were in place. A second follow-up inspection on March 25, 2024, at 2:00 PM confirmed partial compliance with the immediate life-safety corrections required by the 1st Notice of Violation: tenants had vacated upper floors, smoke and carbon monoxide detectors had been installed, deadbolts and barriers had been removed from required exits, and names and contact information for all tenants had been provided.
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Despite this partial progress, I issued the 2nd Notice of Violation on March 28, 2024, cited under PAMC §§ 16.40.010, 16.40.020, Chapter 9.56, and Chapter 1.12, setting a next compliance deadline of Tuesday, April 2, 2024, at 5:00 PM, to confirm the draining of all pool water. The 2nd Notice of Violation also reiterated the full list of outstanding building violations that had not yet been addressed and advised the responsible parties that they remained subject to all potential enforcement consequences.
VI. EMERGENCY NOTICE AND ORDER TO REPAIR OR ABATE — APRIL 2, 2024 Having determined, in coordination with Chief Building Official Hoyt, that the condition of the buildings at 531 Stanford Avenue constituted a continuing immediate danger to occupants and the public, I worked with CBO Hoyt to prepare and serve the Emergency Notice and Order to Repair or Abate ("Emergency N&O"), dated April 2, 2024, signed by CBO Hoyt and delivered via posting, first-class mail, and Certified Mail No. 7018 3090 0001 0801 1146, addressed to Aurora Rising Inc./Atlas Star and citing PAMC §§ 15.04.010, 16.40.010(a)(n)(p), 16.40.020(i)(j)(l)(m); CFC §§ 107.3, 311.2.2, 311.3; CBC § 105.1; CRC § R113.1; and CCR Title 8 § 3001.
The Emergency N&O established a compliance deadline of April 9, 2024, and formally notified the responsible parties, all tenants, and interested parties of: (1) the City's determination that the buildings were dangerous and substandard; (2) the obligation to commence remediation within five business days; (3) the availability of the temporary Firewatch solution to allow continued occupancy for up to seven calendar days; and (4) the right of each tenant to relocation benefits under California Health and Safety Code Section 17975 et seq. and PAMC Chapter 9.68.
On the same date, April 2, 2024, I coordinated the posting and service of the Notice to Tenants required by California Health and Safety Code Section 17975.1(c), which documented the relocation benefits owed to each displaced tenant on a per-unit basis:
• Return of security deposits
• Two months’ fair market rent (ranging from $4,766 for studio units to $8,022 for three- bedroom units under State law)
• Utility security deposit: $50.00
• Local renter relocation assistance under PAMC Chapter 9.68: ranging from $7,971.16 for studio units to $19,358.57 for three or more-bedroom units, with additional assistance available for tenants 60 years of age or older, disabled persons, or households with minors
VII. THIRD NOTICE OF VIOLATION AND ADMINISTRATIVE CITATIONS — APRIL 3, 2024 On April 3, 2024, following the emergency inspection conducted on April 1, 2024, which confirmed that fire watch services had been discontinued without authorization from March 31 through April 1, 2024, I issued the 3rd Notice of Violation under case number 24PCE-00203, cited under PAMC §§ 15.04.010, 15.04.040, 15.04.070, 15.04.130, 16.40.090(a)(b); CFC § 901.7; Item 11
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CBC § 114.1. This notice established a compliance deadline of Friday, April 5, 2024, at 12:00 PM, and documented the issuance of two administrative citations:
4. Administrative Citation No. TJ040324 (issued by Fire Marshal Jasso): $500.00 for the unauthorized discontinuation of fire watch services for the 24-hour period from March 31, 2024, at 5:00 PM through April 1, 2024, at 5:00 PM, in violation of PAMC Sections
15.04.010, 15.04.130, 15.04.140, and 15.04.070, and CFC Section 901.7.
5. Administrative Citation No. BA0040324 (issued by me as Code Enforcement Supervisor): $5,000.00 ($500.00 × 10 days) for failure to provide physical addresses for all identified tenants as required by the March 25, 2024, compliance deadline of the 1st Notice of Violation, in violation of PAMC §§ 16.40.010, 16.40.020, Chapter 9.56, and Chapter 1.12. This citation further advised that the $500.00 daily fine would continue to accrue until a compliant list was submitted.
I also noted in the 3rd Notice of Violation that pool water test results had been submitted by attorney Isaac Weiner on March 31, 2024, and that the results indicated chlorine levels too high for safe discharge to the sanitary system. The responsible parties were directed to retest and provide updated results to the City.
VIII. FOURTH NOTICE OF VIOLATION AND BUILDING POSTING — APRIL 9, 2024 On April 9, 2024, I issued the 4th Notice of Violation, establishing a compliance deadline of Friday, April 12, 2024, at 5:00 PM. That notice cited 2021 IPMC Appendix A (boarding standards) and PAMC § 16.04.010, and confirmed the results of follow-up inspections conducted on April 5 and April 9, 2024:
• All tenants had vacated the 2nd and 3rd floors of all buildings and access was restricted. • All unpermitted installed barriers in exit pathways were continuing to be removed. • Pool water levels were on schedule for 100% water removal by April 12, 2024. • Tenants were no longer residing in the buildings (confirmed April 9, 2024). • Efforts were underway for the removal of personal belongings and loose combustible items.
The 4th Notice of Violation also formalized the agreement reached with the responsible parties and their legal representative at the April 9, 2024 on-site meeting, specifying the conditions under which fire watch services could be discontinued, the required permanent closure steps to be completed by April 17, 2024, the requirement for periodic inspections by Code Enforcement and Fire Department to confirm continued non-occupancy, and the requirement for a Hazardous Materials Closure Permit by April 12, 2024 at 5:00 PM.
Also on April 9, 2024, at 5:00 PM, CBO Hoyt ordered the buildings to be posted with "UNSAFE — DO NOT ENTER OR OCCUPY" placards pursuant to PAMC Section 16.40.070. From that date, Item 11
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the buildings were required to be locked and secured at all times, with access permitted only during construction hours for the specific purpose of completing permanent closure activities.
IX. POST-VACATION MONITORING AND ONGOING ENFORCEMENT (2024–2025) Following the vacation of the buildings in April 2024, Code Enforcement Division maintained periodic oversight of the subject property pursuant to the direction of CBO Hoyt and as documented in the enforcement record. Field observations during this period documented conditions of concern:
• Continued deterioration and vegetation overgrowth on the Stanford Avenue frontage, compromising the building envelope.
• Damage to and unauthorized openings in the perimeter chain link fencing, indicating unauthorized access.
• Debris accumulation in the entry area of the building. • Evidence of an unauthorized tap into the property's irrigation supply line from the public water meter, potentially indicating the presence of unauthorized occupants. • A mattress, pillow, and bedding observed on the floor of what appeared to be an exterior walkway or balcony area, consistent with potential unauthorized occupancy.
These observations were documented and shared with CBO Hoyt and Fire Marshal Jasso.
Throughout 2024 and into 2025, Code Enforcement continued to monitor the required permanent closure activities. No remediation, permitting, or rehabilitation work was performed by the responsible parties. The hazardous materials closure process was the subject of multiple communications between the City, the Fire Department, and the responsible parties, with certain hazmat closure work remaining incomplete as late as August 2025. Hazmat Closure Permits 24HZM-00040 and 23FDP-00929 remained open, with the responsible parties submitting extension requests as late as August 19, 2025.
X. NOTICE AND ORDER TO DEMOLISH AND OWNER RESPONSE (2025) I worked closely with CBO Hoyt in the preparation of the Notice and Order to Demolish/Deconstruct and Remove the Buildings ("Demolition N&O"), dated October 17, 2025, issued pursuant to H&SC § 17980.6 and PAMC Chapter 16.40. I confirmed service of the Demolition N&O and the associated Certified Mail Receipt (USPS Tracking No. 9589 0710 5270 2033 2917 42). I further confirmed in writing to the responsible parties' attorney Brian O’Neill from Patterson & O’Neill, PC, that the 15-day appeal period would run from October 29, 2025.
On November 7, 2025, the firm of Patterson & O'Neill, PC, submitted a written response to the Demolition N&O raising objections including: (1) improper service; (2) the claim that the buildings do not meet the fifty-percent deterioration threshold; (3) the claim that Item 11
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deconstruction requirements do not apply to dangerous buildings; and (4) the claim that the May 18, 2026 removal deadline is unreasonable.
On November 13, 2025, a formal Appeal of the Demolition N&O was filed with the City Clerk by Stanford Orion (property manager and owner's representative), represented by attorney Brian O'Neill of Patterson & O'Neill, PC, and executed by property manager Sophia Huang. The appeal raises the same four issues as the November 7 response letter.
XI. PROFESSIONAL OPINION AND CONCLUSION
Based upon my nine years of municipal code enforcement experience — including direct personal involvement in every significant enforcement action taken at 531 Stanford Avenue from January 2024 through the present — it is my professional opinion that this case represents one of the most significant and complex code enforcement matters I have encountered in my career. The scope of the violations was extraordinary; the habitability and life safety hazards were real, severe, and well-documented; and the displacement of long-term tenants was a serious and adverse consequence compelled by the conditions created by the property owner, not by any punitive intent on the part of the City.
Throughout this enforcement action, City staff endeavored to work collaboratively with the responsible parties — providing multiple opportunities for voluntary compliance, working to identify short-term solutions that would allow tenants to remain in place while remediation was arranged, and communicating clearly at every step about what was required, why it was required, and what the consequences of noncompliance would be. The record of this case — fourteen separate enforcement communications over less than three months in early 2024, followed by nearly eighteen months of ongoing monitoring and coordination — reflects a sustained and good-faith effort by the City to achieve a resolution that protected public safety while giving the responsible parties every reasonable opportunity to comply.
The Notice and Order to Demolish was issued only after eighteen months of post-vacancy monitoring confirmed that no rehabilitation, permitting, or remediation work was undertaken by the responsible parties, and that the buildings continued to deteriorate. The City remains committed to achieving a lawful resolution that results in the safe and complete removal of these dangerous structures and the restoration of this property to a condition that is safe for the surrounding community.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is based upon my personal knowledge, professional training, and experience.
Executed on: _______________________________
_____________________________________________
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Elisa Vargas, CCEO
Code Enforcement Supervisor
Planning & Development Services Department, City of Palo Alto 285 Hamilton Avenue, Palo Alto, California 94301
(650) 885-8565
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CITY OF PALO ALTO
PALO ALTO FIRE DEPARTMENT
250 Hamilton Avenue, Palo Alto, California 94301
DECLARATION OF TAMARA JASSO
Fire Marshal, City of Palo Alto Fire Department
Regarding Fire and Life Safety Conditions and Enforcement Actions at 531 Stanford Avenue, Palo Alto, California 94306
(APN: 137-01-121, 137-01-002, 137-01-003)
Case No. 24PCE-00203 / Fire Service Case Nos. 6000014517 & 6000014516
I. QUALIFICATIONS AND AUTHORITY
I, Tamara Jasso, am the duly appointed Fire Marshal for the City of Palo Alto Fire Department.
In that capacity, I exercise the statutory authority of the fire code official under the California Fire Code (CFC), the Palo Alto Municipal Code (PAMC), including PAMC Chapter 15.04 and related provisions, and applicable National Fire Protection Association (NFPA) standards adopted by reference. My responsibilities encompass fire prevention inspections, enforcement of the California Fire Code and local fire ordinances, hazardous materials regulation, review of fire protection systems including automatic sprinkler systems and fire alarm systems, and the administration of fire watch programs.
I have served as a fire prevention professional in the City of Palo Alto for many years and have conducted hundreds of commercial, residential, and mixed-use occupancy inspections. I hold certifications relevant to fire prevention, inspection, hazardous materials regulation, and fire investigation. This declaration is based upon my personal observations during multiple inspections of the subject property, review of fire department records including Fire Service Case Nos. 6000014517 and 6000014516, my professional training and experience, and my direct involvement in all fire-related enforcement activities at this location.
II. FIRE AND LIFE SAFETY CONDITIONS IDENTIFIED — MARCH 18, 2024 I participated in the joint inspection of the premises at 531 Stanford Avenue conducted on March 18, 2024, commencing at 10:00 AM, together with Chief Building Official George Hoyt, Code Enforcement Supervisor Elisa Vargas, and other City personnel. The fire and life safety conditions I personally observed and documented on that date represent some of the most severe violations of the California Fire Code I have encountered in a multi-occupancy residential setting during my career. My findings are described below by category, with specific locations identified for each violation.
A. Fire Sprinkler and Fire Alarm System Deficiencies
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The buildings at 531 Stanford Avenue are of a size and occupancy type that require both automatic fire sprinkler systems and fire alarm systems under the California Fire Code and applicable NFPA standards. The inspection revealed the following:
• Basement — Equipment Room — Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (CFC § 311.2.2; CFC Appendix I101.2))
• Garage — Hallway — Wiring on Sprinkler Lines: Electrical wiring was observed running along and in physical contact with the fire sprinkler supply lines in the garage hallway.
This condition is dangerous for two reasons: (1) an electrical fault in the wiring could cause physical damage to the sprinkler piping, resulting in a water supply failure at a critical distribution point serving upper floors; and (2) electrical current conducted through metallic sprinkler piping can accelerate corrosion of the system, compromising its long-term reliability. (CFC § 311.2.2; CFC Appendix I101.2) • Level One — Units 109, 110, 111, 112, 113, and 500 — No Sprinkler Coverage: No fire sprinklers were present inside the residential units. These units had been converted from hotel rooms to permanent residential apartments — a higher-risk occupancy classification — without any fire protection system upgrade, permitting, or inspection.
The absence of sprinkler coverage in residential units, combined with the failure of the overall building sprinkler system, leaves occupants with no automatic fire suppression protection whatsoever. (CFC § 311.2.2)
• Buildings Generally — Dilapidated Fire Sprinkler Systems: The fire sprinkler systems throughout all buildings were in a dilapidated condition with clear evidence of corrosion, physical damage, and functional compromise. No documentation of required testing, inspection, or maintenance by a licensed fire protection contractor could be produced by the responsible parties. (CFC § 311.2.2)
• Buildings Generally — Dilapidated Fire Alarm Systems: The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection. (CFC § 901.6.3)
• No Fire Protection System Permits or Records: City records confirmed a complete absence of any permits, inspection records, or certifications for the fire sprinkler or fire alarm systems at this property. The responsible parties could not produce records confirming that these systems had ever been tested, inspected, or certified. Given the combination of dilapidated systems, specific physical evidence of corrosion at documented locations, and the complete absence of testing records, I determined on March 18, 2024 that the fire protection systems at 531 Stanford Avenue could not be Item 11
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relied upon to function in the event of a fire emergency, placing all building occupants at severe and immediate risk of death or injury.
B. Egress, Exit, and Corridor Deficiencies — Location-Specific Findings Deficiencies in the means of egress were documented at multiple specific locations throughout the buildings. Each location is described below. The cumulative effect of these deficiencies is that there was no reliable path of egress available to any building occupant in the event of a fire. (CFC § § 1032.1 - 1032.2)
• Basement — Stairwell (Basement to Ground Floor): The rated door in the stairwell providing egress from the basement to the ground floor was missing a hinge and gaskets. The door hardware was not of a listed or approved type. The door did not self- close as required for fire-rated assemblies. Rated doors in this stairwell were propped open, directly defeating the fire and smoke separation function of the rated assembly. A rated door that is propped open provides no fire or smoke compartmentalization and allows fire and toxic gases to spread from the basement into the rest of the building through the only stairwell egress from that level. (CFC 1026.3; CFC 1010.2.2; CFC § 311.2.2; CRSC Sec 12-10-200 (b) & (c))
• Basement — Storage Room: The rated door to the storage room was not properly listed or labeled — required markings confirming the door assembly's fire rating were absent.
The door hardware was of an incorrect type not approved for rated door assemblies.
The door was not self-closing as required. (CFC 1026.3; CFC 1010.2.2; CRSC § 12-10-200 (b) & (c))
• Second Stairwell: The door hardware in the second stairwell was non-functional: the door would not close properly. The only hardware present was a deadbolt, which does not constitute compliant egress latch hardware and cannot be operated from the egress side in an emergency without a key. The presence of a deadbolt as the sole door hardware on an exit door means that an occupant attempting to escape through this stairwell in a fire could be unable to open the door. No exit signs were present in this stairwell, meaning occupants in a smoke-filled corridor could not locate this exit route. (CFC § 1010.2; CFC § 1010.27; CFC § 1013.1)
• Garage — Restroom — Rated Door: The rated door at the restroom was propped open, bore no required labels or fire rating markings, and was equipped with incorrect hardware that did not satisfy fire-rated door assembly requirements. (CFC § 1026.3; CFC § 1010.2.2)
• South Corridor Door — Breach of Rated Assembly: The south corridor door was equipped with a latchable latch that does not meet fire egress requirements for a rated assembly. No rated door or frame tags were present on this assembly, and the condition of the installation constituted a breach of the required fire-rated wall separation.
Critically, no rated doors were present on the north side of the same required rated opening — meaning the rated wall assembly was completely unprotected at this corridor crossing, allowing fire and smoke to pass freely through what should be a fire barrier. This is among the most serious egress deficiencies observed during the Item 11
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inspection, as it eliminates the compartmentalization that rated assemblies are designed to provide. (CFC § 1020.2; CFC § 1104.17)
• Open Stairs — Corridor: Exit signage and emergency lighting in the open stairwell corridor were limited, and none were working at the time of inspection. Non- functioning emergency lighting and exit signage in a stairwell means that occupants attempting to use this primary egress path in a fire — when smoke and power loss are likely — would be unable to see or navigate the stairs safely. (CFC § 1013.1; CFC § 1032.4; CFC § 1032.10)
• Level One — General: Exits were blocked on Level One. No emergency lighting was present or functional on Level One. (CFC § 1032.2; CFC § 1104.5) • Garage — No Exit Signage: No exit signage was present anywhere in the garage area.
Occupants in the garage — including persons using the unpermitted kitchen, laundry, or office — could not identify exit routes in a fire. (CFC § 1013.1) • Level One — Units 109–113 and 500 — No Rated Unit Doors or Gaskets: The rated doors on individual residential units — which are required to slow the spread of fire between units and the corridor — were non-compliant. No rated door and no door gasket were present on Unit 109, and the same condition was noted in Units 110 through 113 and Unit 500. Gaskets on rated doors serve a critical function: they prevent smoke infiltration under the door, which is a primary cause of death in residential fires.
The absence of both the rated door and gasket means that fire and smoke can enter these residential spaces immediately upon any fire in the corridor (CFC § 1020.2; CBC Table 716.1(2); CFC § 1104.17).
• Buildings Generally — Deadbolts and Latchable Latches on Exit Doors: Throughout the buildings, deadbolts and latchable latches were found on required exit fire-rated doors.
Under California fire code egress requirements, exit doors must be operable from the egress side without a key, special knowledge, or special effort. These conditions directly prevent occupants from escaping a fire and were required to be immediately corrected (CFC § 1010.2; CFC § 1032.7)
C. Combustible Storage and Fire Load Hazards
Combustible materials were stored throughout the buildings in quantities and configurations that created significantly elevated fire load conditions. Elevated fire load accelerates fire spread and dramatically reduces the time available for occupant evacuation. (CFC § 311.3) • Garage — Unpermitted Storage of Flammable Liquids and LP Tanks: Paint thinner, unlabeled fuel containers, and liquid propane (LP) tanks were being stored in the garage and Level One area without permits, proper labeling, or required secondary containment. Flammable liquids and LP tanks stored without proper controls represent acute fire and explosion hazards. In a fire scenario, these materials would dramatically accelerate fire spread and create explosion risk that would be fatal to any building occupants and first responders in the area. (CFC § 3201; CFC § 6109) Item 11
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• Garage — Propane and Oil Tank: A propane tank and an oil tank were present in the garage area without permits or required safety measures. (CFC § 6109) • Garage — Restroom — High Combustible Storage: High combustible storage was present in the unpermitted storage room located in the restroom area of the garage.
High combustible load in an enclosed space with a non-compliant rated door creates conditions under which fire can develop rapidly without any barrier to prevent spread. (CFC § 315.3.4)
• Garage / Level One — Combustible Decorative Items: Combustible plastic pictures and artificial (fake) trees were present in the garage and Level One areas. Plastic decorative items burn rapidly, produce intense heat, and release toxic gases, contributing to both fire spread and smoke toxicity. (CFC § 807.2)
• Level One — Plastic Film on Hallway Ceiling: Plastic film was present on the ceiling of the Level One hallway — a required means of egress. Plastic film is an unapproved building material that burns rapidly, produces toxic gases, and presents extreme fire propagation risk. A fire igniting this material in an exit hallway would immediately contaminate the primary exit path with fire and toxic smoke, trapping occupants who must pass through the hallway to reach an exit. (CFC § 314.3; CFC § 311.3) • Level One — Units — Plastic Film on Unit Ceilings: Plastic film was affixed to the ceilings of residential units (documented in Unit 109 and noted as the same condition in Units 110–113 and 500). The presence of this material throughout occupied residential units means that any fire starting or spreading into a unit would be immediately accelerated by the ceiling material, with no barrier between the burning ceiling and the unit occupants below. (CFC § 311.3; CFC § 807.2)
• Buildings Generally — High Combustible Storage: High combustible storage was documented throughout all buildings, including in the garage restroom, lobby and office area, and open corridor spaces, creating elevated fire load conditions throughout all areas of the buildings. (CFC § 311.3)
D. Hazardous Materials Storage
Hazardous materials were stored at multiple locations throughout the buildings without permits, secondary containment, or compliance with hazardous materials handling requirements, in violation of PAMC Section 17.12.010.
• Basement — Equipment Room — Pool Chemicals: Pool chemicals were present in the equipment room without required secondary containment. Improper storage of pool chemicals creates risk of chemical release, corrosive damage to surrounding building systems, and potential toxic gas generation in a fire or spill event. A possible cross- connection to the potable water supply was also identified and flagged for investigation. (PAMC § 17.12.020 (c); CFC § 5001)
• Garage — Hydraulic Fluid: An empty hydraulic fluid container was present in the garage hallway, indicating prior storage of hydraulic fluid in this location without required permits or controls. (PAMC § 17.12.010; PAMC 17.04.020) Item 11
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• Garage — Flammable/Combustible Liquids and LP Tanks: Paint thinner, unlabeled fuel containers, and LP tanks were stored in the garage and Level One area without permits, proper labeling, or required secondary containment. (PAMC § 17.12.010; PAMC
17.04.020)
• Telecommunications Rooftop Equipment: Hazardous materials associated with telecommunications cell tower infrastructure located on the roofs of the buildings were identified as requiring specialized closure procedures under the City's Hazardous Materials Closure Plan requirements. No Hazardous Materials Business Plan or related permits had been obtained for the storage or handling of any hazardous materials at the property.
III. IMPOSITION AND ADMINISTRATION OF FIRE WATCH REQUIREMENT As a consequence of the dilapidated and unreliable condition of the fire sprinkler and alarm systems, combined with the occupied status of the buildings at the time of the March 18, 2024, inspection, I determined that immediate fire watch services were required pursuant to the California Fire Code and my authority as Fire Marshal. Fire watch services are required under the CFC when fire alarm or sprinkler systems are fully or partially out of service, or when other special hazards exist, because they provide a minimum level of life safety protection when automatic systems cannot be relied upon.
On March 21, 2024, in the 1st Notice of Violation, the responsible parties were given until March 22, 2024, at 5:00 PM to have fire watch services in place and monitoring the building.
My office provided Fire Watch Information documentation to the responsible parties specifying the requirements, including that fire watch personnel conduct continuous patrols at not less than 30-minute intervals, maintain a patrol log, have two means of communication, be knowledgeable about the building floor plan and hazards, and submit daily fire watch logs by email to the Palo Alto Fire Department.
On March 22, 2024, at 5:00 PM, I conducted a follow-up inspection and confirmed that fire watch services were in place and that the fire watch personnel were completing the necessary logs required to be submitted to my department on a weekly basis. I also identified the emergency path of egress and directed it to be made available for inspection on March 25, 2024.
Unauthorized Discontinuation of Fire Watch — April 1, 2024 On April 1, 2024, at approximately 10:45 AM, Code Enforcement conducted an emergency inspection and confirmed that fire watch services were not in place, having been discontinued on March 31, 2024, at 5:00 PM without authorization from the City. The unauthorized discontinuation of fire watch services left an occupied building with no functioning fire protection systems and no continuous monitoring for a period of approximately 24 hours — a condition I determined constituted a life safety emergency.
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31 through April 1. Fire watch services were reinstated with a new service provider on April 1, 2024, at 5:00 PM after the new provider's application and logs were submitted and approved.
In connection with this violation, Administrative Citation No. TJ040324 was issued on April 3, 2024, imposing a $500.00 fine for the unauthorized 24-hour gap in fire watch coverage.
IV. CONDITIONS FOR TERMINATION OF FIRE WATCH — APRIL 9, 2024 At a meeting held at the premises on April 9, 2024, attended by myself, Code Enforcement Supervisor Elisa Vargas, attorney for property manager Sophia Y. Huang, Isaac Weiner, and Property Manager Sophia Y. Huang, I communicated the conditions under which fire watch services could be discontinued without requiring immediate vacation of the building. These conditions included:
1. All residents must have vacated the building, and no person shall sleep or spend extended periods of time in the buildings.
2. Any person working in the building under authorization shall be required to call 911 in the event of an emergency or fire.
3. High fire loads must be removed from the buildings, or documentation that functioning fire sprinklers and alarms have been tested and certified must be provided by April 12, 2024, at 5:00 PM.
4. Updated keys must be provided and placed in the existing Knox Box to allow Fire Department access.
I further communicated that the responsible parties were required to obtain a Hazardous Materials Closure Permit from the Palo Alto Fire Department no later than April 12, 2024, at 5:00 PM, and to work with Fire Department hazardous materials personnel to develop and implement a closure plan, including the removal of hazardous materials associated with the telecommunications cell towers on the rooftops.
V. FIRE DEPARTMENT MONITORING AND ONGOING CONCERNS (2024–2025) Following the vacation of the buildings on or around April 9, 2024, the Palo Alto Fire Department continued to monitor the subject property as part of its ongoing code enforcement obligations. Fire Service Case Nos. 6000014517 and 6000014516 document continued Fire Department involvement in inspection and monitoring activities at the property during the post-vacation period.
During post-vacation monitoring, Fire Department personnel observed conditions consistent with potential unauthorized reoccupation of the premises, including a mattress and bedding positioned on an exterior walkway or balcony area visible during an inspection. Continued vegetative overgrowth, damaged and opened sections of perimeter chain link fencing, and evidence of tapping into the property's irrigation line further suggested the possibility of unauthorized persons entering and utilizing the property. These observations are of particular concern from a fire safety standpoint: vacant buildings with compromised fire protection Item 11
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systems are especially vulnerable to fire when unauthorized occupants are present, as such persons may use open flame for heat, cooking, or lighting.
The hazardous materials associated with the T-Mobile and Sprint/T-Mobile telecommunications equipment on the buildings' rooftops remained a significant concern throughout the post- vacation period. Hazardous materials closure permit 24HZM-00040 and fire department closure permit 23FDP-00929 were the subject of ongoing coordination between the Fire Department and the responsible parties. The responsible parties submitted a permit extension/reactivation request as late as August 19, 2025, indicating that complete closure of the hazardous materials component had not been achieved as of that date.
VI. EXPERT ANALYSIS — FIRE AND LIFE SAFETY BASIS FOR DEMOLITION It is my professional opinion as Fire Marshal, based upon my personal observations, review of fire department records, and professional training and experience, that the fire and life safety conditions at 531 Stanford Avenue provide independent and sufficient grounds for demolition under each of the three criteria of PAMC Section 16.40.050(c).
A. Fire Hazard in Violation of Applicable Codes
The buildings at 531 Stanford Avenue constitute fire hazards in violation of PAMC Title 15 and the California Fire Code through the following conditions, each of which independently violates applicable fire code provisions:
• Failed fire protection systems (PAMC § 15.04.010; CFC §§ 107.3, 311.2.2): The buildings are required to have functional automatic sprinkler and alarm systems. These systems are dilapidated, corroded, and non-functional with no maintenance records. Buildings with non-functional fire protection systems are, by definition, fire hazards under applicable codes.
• Plastic film on ceilings and in exit stairways (CFC § 311.3): The presence of plastic film as a building material in exit stairways is particularly dangerous because: (1) plastic film burns at an extreme rate and cannot be extinguished by building occupants; (2) it produces toxic gases that incapacitate occupants before they can evacuate; and (3) it is located specifically in the exit pathways that occupants must use to escape, meaning that a fire igniting this material in an exit stairway would trap and kill the occupants it was meant to protect.
• Blocked and non-functional egress (CFC 1032.2): Blocked egress routes, missing and non-functional fire-rated doors, and deadbolt locks on fire exits mean that if a fire breaks out in these buildings, occupants cannot escape. This is the fundamental fire safety failure that makes these buildings imminently dangerous — not just code non- compliant.
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• High combustible storage and elevated fire load (CFC 301.1; CCR, Title 19, Division 1, §3.14 (Fire Hazard); CCR, Title 19, Division 1, §3.19 (a)-(g) (Housekeeping)): The accumulated combustible materials throughout the buildings create conditions under which any fire would spread rapidly and overwhelm any response before occupants could evacuate.
• Corroded electrical systems (CFC § 603.2.1): Severely corroded electrical wiring, conduit, and equipment throughout the buildings represents an ongoing ignition risk.
Corroded electrical systems are a leading cause of building fires, particularly in buildings that have been unoccupied and unmaintained.
• Missing emergency lighting and exit signage (CFC 1032.10, CFC 1032.4): In a fire with power loss and smoke, occupants rely on emergency lighting and exit signage to locate and navigate exits. The absence of these systems means that any fire in these buildings would immediately become unsurvivable for occupants who cannot locate an exit.
B. Cannot Be Repaired to Eliminate Fire Violations
It is my expert opinion that the fire and life safety violations at 531 Stanford Avenue cannot be remediated through repair, and that compliance with fire code requirements would require effectively rebuilding the buildings. The basis for this opinion is:
• Complete fire protection system replacement required: The fire sprinkler and alarm systems throughout all buildings are dilapidated and non-functional. These systems cannot be repaired in place; they require complete removal and replacement, including all piping, heads, alarm devices, control panels, and ancillary equipment throughout all buildings. This is a reconstruction-level undertaking, not a repair. • Plastic film requires demolition of finished assemblies to remove: The plastic film is applied to building surfaces and incorporated into the structure. Complete removal requires physical demolition of the surfaces to which it is attached, which is in effect interior demolition of all affected areas — which include exit stairways throughout the buildings.
• Egress system reconstruction: The egress system requires reconstruction, not repair:
fire-rated doors and frames must be replaced or reconstructed; exit pathways must be physically reconfigured to eliminate blockages; and the entire emergency lighting and exit signage system must be replaced throughout all buildings. • Unknown condition of building systems requires demolition to assess: Because extensive unpermitted construction was performed in all building areas, the actual condition of walls, ceilings, and structural assemblies adjacent to fire protection and electrical systems cannot be assessed without physical demolition. The scope of required remediation cannot be determined until the buildings are opened up — at which point the work required will be indistinguishable from rebuilding.
C. Contribution to Fifty Percent Deterioration Finding Item 11
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From a fire protection standpoint, the following conditions contribute materially to the overall fifty percent deterioration determination made by Chief Building Official Hoyt:
• Complete fire protection system replacement cost: The cost of replacing the fire sprinkler and alarm systems throughout all buildings — including system design, permitting, installation, testing, and certification — is substantial and constitutes a significant portion of the total system replacement costs that support the fifty percent determination.
• Eighteen months of deterioration in vacant buildings: Vacant, unmaintained buildings deteriorate rapidly, particularly with respect to fire protection systems, which require regular testing, maintenance, and certification. Systems that were already dilapidated in March 2024 have continued to deteriorate through April 2024–October 2025 without any maintenance, significantly worsening the conditions documented at the initial inspection.
VII. PROFESSIONAL OPINION AND CONCLUSION
It is my professional opinion as Fire Marshal of the City of Palo Alto, based upon my personal observations, my review of fire department records, and my professional training and experience, that the buildings at 531 Stanford Avenue presented, throughout the period of their occupation and continuing through the present, fire and life safety hazards of the most serious nature. The combination of failed sprinkler and alarm systems, blocked egress, combustible storage, corroded electrical systems, non-functioning fire-rated assemblies, missing emergency lighting and signage, and structural deficiencies with the second-floor balcony creates conditions that pose substantial danger of fire, would prevent safe evacuation in the event of a fire and provide an unsafe environment for first responders/firefighters when responding to a fire or other emergency. The combination of dilapidated and unreliable fire protection systems, an extreme combustible fire load, unapproved fire-propagating materials in egress pathways, blocked and non-functional exits, severely corroded electrical systems, and the complete absence of any fire safety permits or inspection records created conditions under which any fire in these buildings could rapidly become fatal to occupants.
The unauthorized discontinuation of fire watch services on March 31, 2024, — leaving an occupied building with no functioning fire protection systems and no monitoring coverage for 24 hours — represents an act of extraordinary recklessness that endangered the lives of all occupants and neighbors. The imposition of the fire watch requirement was not a punitive measure but a minimum necessary life safety protection, and its unauthorized removal is a matter I regard with the utmost seriousness.
The demolition of these buildings is supported by this declaration and is consistent with my professional assessment that the accumulated fire and life safety deficiencies cannot be addressed short of complete removal of the structures. The buildings meet the fire hazard criterion under PAMC Section 16.40.050(c) and independently satisfy the grounds for demolition under that section. In my career as a fire prevention professional, these buildings represent the most serious fire and life safety hazards I have encountered.
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I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is based upon my personal knowledge, professional training, and experience.
Executed on: _______________________________
_____________________________________________
Tamara Jasso
Fire Marshal, City of Palo Alto Fire Department
250 Hamilton Avenue, Palo Alto, California 94301
(650) 329-2184
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Photographic
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Section I - 531
Stanford Avenue
Exterior and
Perimeter
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PAMC Violation: Photo of the mailbox located at 531 Stanford Avenue, Palo Alto, CA 94306.
Indicating where residents could have their packages delivered.
The buildings were being operated under the address "520 Oxford Avenue," which was not formally assigned or authorized by the City of Palo Alto.
No permits on file for an address assignment request for 520 Oxford Avenue. (CBC § 502.0; PAMC § 16.04.240)
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PAMC Violation: Overgrown Vegetation located on Stanford Avenue.
PAMC 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section PAMC § 8.08.010.
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PAMC Violation: Unauthorized installation of safety cage. Knox box not accessible from exterior.
PAMC 16.40.010 Dangerous building defined (l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
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PAMC Violation: Indication that no access to Knox Box was possible by emergency fire personnel in the event of an emergency.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Overgrown vegetation that is also encroaching Public Right of Way PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010.
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PAMC violation: Overgrown vegetation encroaching on sidewalk.
PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010. (8) The existence of any branches or foliage which interfere with visibility on, or free use of, or access to, or obstruct public vehicular or pedestrian travel on any portion of any street improved for vehicular or pedestrian travel so as to be a nuisance under Section 8.04.050(f). (9) The existence of hedges or dense thorny shrubs and plants on any street or part thereof so as to be a nuisance under Section 8.04.050(g). (10) The Item 11
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existence of shrubs and plants more than two feet in height in any street, measured above top of curb grade so as to be a nuisance under Section 8.04.050(h).
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Overgrown Vegetation and unauthorized security cage installed.
PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Overgrown Vegetation
PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010.
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PAMC Violation: Overgrown Vegetation
PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010.
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PAMC Violation: Overgrown Vegetation and unauthorized security cage installed.
PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Overgrown vegetation on public right of way PAMC § 9.56.030(a)(2) Nuisances - The existence of weeds upon the premises, or public sidewalks, or streets, or alleys between said premises and the centerline of any public street or alley, so as to be a nuisance under Section 8.08.010.
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PAMC Vioaltion: Extension cord hanging from roof, landing onto the balcony.
Unathorized basrrier made of wire mesh.
PAMC §16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Vioaltion: Extension cord hanging from roof, landing onto the balcony.
Unathorized basrrier made of wire mesh.
PAMC §16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Unpermitted installation of venting for commercial laundry room in basement, discharging directly onto the sidewalk at 520 Oxford Ave, Palo Alto, CA 94306.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
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PAMC Violation: Unpermitted installation of venting for commercial laundry room in basement, discharging directly onto the sidewalk at 520 Oxford Ave, Palo Alto, CA 94306.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
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PAMC Violation: Unauthorized mailbox indicating 520 Oxford Ave, Palo Alto, CA 94306.
Unpermitted Cage.
The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240)
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PAMC Violation: Unauthorized mailbox indicating 520 Oxford Ave, Palo Alto, CA 94306.
Unpermitted Cage.
The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC 502.0; PAMC § 16.04.240)
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PAMC Violation: Unauthorized Entrance located at Oxford Ave, Palo Alto, CA 94306.
The buildings were being operated under the address "520 Oxford Avenue," which was never formally assigned or authorized by the City of Palo Alto. No permits on file for an address assignment request for 520 Oxford Avenue. (CBC § 502.0; PAMC § 16.04.240)
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Section II: 531
Stanford Avenue
Interior
Floors 1, 2, 3,
& Roof
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PAMC Violation(s): Interior walkway showing the unpermitted shoring of the second level floor above. Mesh atrium was built off the 2nd floor.
PAMC 16.40.010 Dangerous building defined (d) Whenever any portion or member or appurtenance thereof is likely to fall, or to become detached or dislodged, or to collapse and thereby injure persons or damage property.
Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential structural failure of a required egress path. (PAMC § 16.40.020 (a)(3))
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PAMC Violation: Blocking Emergency Egress
PAMC 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Door hardware was not of a listed/approved type. The door did not self-close as required. Rated doors in this stairwell were observed propped open, defeating the fire-separation function of the rated assembly. (CBC 716.2)
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PAMC Violation: Unpermitted installation of screen door. Blocking emergency egress path.
PAMC 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Unpermitted construction of Sunroom.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC 114.1; PAMC § 16.04.225)
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PAMC Violation: Unpermitted installation of egress door.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Unpermitted installation of egress door.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: Unpermitted construction, blocked egress, dangerous conditions.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential structural failure of a required egress path. (PAMC § 16.40.020 (a)(3))
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PAMC Violation: View of Unpermitted Mesh Atrium, corridor, and unpermitted windows.
PAMC § 16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential structural failure of a required egress path. (PAMC §16.40.020 (a)(3))
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PAMC Violation: Exterior View of unpermitted construction of corridor connecting the buildings.
Second-Floor Exit Balcony — Structural Shoring: The second-floor exit balcony exhibited evidence of having been shored for stability, indicating awareness of a structural deficiency requiring emergency intervention. This condition constituted a potential structural failure of a required egress path. (PAMC § 16.40.020 (a)(3))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
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PAMC Violation: Exterior view of removal of unpermitted construction of corridors connecting the buildings. Blocked off door at 2nd Floor. Top view of unpermitted Mesh Atrium.
PAMC §16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
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PAMC Violation: View of the Unpermitted structure that was removed.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
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35 of 163
PAMC Violation: Unpermitted construction; blocking doorways that lead to high falls with no stairs.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
134
Packet Pg. 274 of 489
36 of 163
PAMC Violation: Rooftop view of empty pool.
Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
135
Packet Pg. 275 of 489
37 of 163
PAMC Violation: Rooftop View of unpermitted Gazebo structure.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like gazebos that exceed 120 square ft. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
136
Packet Pg. 276 of 489
38 of 163
PAMC Violation: Unpermitted plastic film installed. Located throughout the buildings; installed in rooms and hallways.
Plastic Film: Plastic film was affixed to ceilings in residential units and to the ceiling of the Level One hallway. This is an unapproved building material that poses significant fire propagation risk and produces toxic gases when burned. (PAMC Section 16.40.020(b) and CBC 803.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
137
Packet Pg. 277 of 489
39 of 163
PAMC Violation: Electrical Panel Not labeled properly.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
138
Packet Pg. 278 of 489
40 of 163
PAMC Violation: Removal of unpermitted Gazebo Structure and ramp.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square ft. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
139
Packet Pg. 279 of 489
41 of 163
PAMC Violation: Removal of unpermitted Gazebo Structure and ramp.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square feet. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
140
Packet Pg. 280 of 489
42 of 163
PAMC Violation: Unpermitted construction of ramp and patio flooring.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square feet. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
141
Packet Pg. 281 of 489
43 of 163
PAMC Violation: Unpermitted Ramp
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. This includes accessory structures like ramps and patio flooring that exceed 120 square feet. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
142
Packet Pg. 282 of 489
44 of 163
PAMC Violation: Unsafe Electrical Panel – No panel cover installed. Panel was live.
Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
143
Packet Pg. 283 of 489
45 of 163
PAMC Violation: Unpermitted construction. Penetration of walls.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
144
Packet Pg. 284 of 489
46 of 163
PAMC Violation: Unpermitted construction. Penetration of wall. Unknown repairs.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
145
Packet Pg. 285 of 489
47 of 163
PAMC Violation: Unpermitted construction. Unfinished open penetration causing fire concerns, and ventilation discharge.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
146
Packet Pg. 286 of 489
48 of 163
PAMC Violation: Storage of combustible materials.
PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
147
Packet Pg. 287 of 489
49 of 163
PAMC Violation: Storage of combustible materials.
PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
148
Packet Pg. 288 of 489
50 of 163
PAMC Violation: Storage of combustible materials
PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause. .
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
149
Packet Pg. 289 of 489
51 of 163
PAMC Violations: Unpermitted construction that created unsafe fire conditions, unknown if it was a repair or a remodel.
Unpermitted venting installed without permit or inspection. Venting was non-compliant. (PAMC §
16.40.020 (g)(h))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
150
Packet Pg. 290 of 489
52 of 163
PAMC Violation: Unpermitted construction that created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished
Unpermitted venting installed without permit or inspection. Venting was non-compliant. (PAMC § 16.40.020 (g)(h))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
151
Packet Pg. 291 of 489
53 of 163
PAMC Violation: Unpermitted construction that created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished.
Unpermitted venting installed without permit or inspection. Venting was non-compliant. (PAMC § 16.40.020 (g)(h))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
152
Packet Pg. 292 of 489
54 of 163
PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished.
Unpermitted venting installed without permit or inspection. Venting was non-compliant. (PAMC § 16.40.020 (g)(h))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
153
Packet Pg. 293 of 489
55 of 163
PAMC Violation: Vacated room that was remodeled from temporary conditions and converted for long term residence.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
154
Packet Pg. 294 of 489
56 of 163
PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
155
Packet Pg. 295 of 489
57 of 163
PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
156
Packet Pg. 296 of 489
58 of 163
PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished
Unpermitted venting installed without permit or inspection. Venting was non-compliant. (PAMC § 16.40.020 (g)(h))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
157
Packet Pg. 297 of 489
59 of 163
PAMC Violation: View of miscellaneous items that were repurposed from when the buildings were used as a hotel.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
158
Packet Pg. 298 of 489
60 of 163
PAMC Violation: View of miscellaneous items that were repurposed from when the buildings were used as a hotel.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
159
Packet Pg. 299 of 489
61 of 163
PAMC Violation: Unpermitted construction of conduit for unknown purpose. Left unfinished.
Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
160
Packet Pg. 300 of 489
62 of 163
PAMC Violation: Unsafe electrical panel. No panel cover installed. Panel confirmed live.
Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
161
Packet Pg. 301 of 489
63 of 163
Unpermitted construction for unknown purpose. Left unfinished.
Unpermitted construction of wall and door.
PAMC Violation: Unpermitted construction of wall and installation of unapproved door.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
162
Packet Pg. 302 of 489
64 of 163
PAMC Violation: Unauthorized removal of drywall for unknown reasons.
Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f)) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
163
Packet Pg. 303 of 489
65 of 163
PAMC Violation: Unpermitted door hardware, adapted to add a lock.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
164
Packet Pg. 304 of 489
66 of 163
PAMC Violation: Unpermitted door hardware, adapted to add a lock.
16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
165
Packet Pg. 305 of 489
67 of 163
PAMC Violation: Improper exit signage.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
166
Packet Pg. 306 of 489
68 of 163
PAMC Violation: Improper exit signage.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
167
Packet Pg. 307 of 489
69 of 163
PAMC Violation: Improper exit signage.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
168
Packet Pg. 308 of 489
70 of 163
PAMC Violation: Unpermitted door hardware, adapted to add a lock.
16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
169
Packet Pg. 309 of 489
71 of 163
PAMC Violation: Miscellaneous items impeding emergency egress.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
170
Packet Pg. 310 of 489
72 of 163
PAMC Violation: Miscellaneous items located in the “former lobby”. Room used as storage.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
171
Packet Pg. 311 of 489
73 of 163
PAMC Violation: Unsafe electrical installation of lightbulb. Fire hazard.
Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
172
Packet Pg. 312 of 489
74 of 163
PAMC Violation: Unpermitted door hardware, adapted to add a lock.
16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
173
Packet Pg. 313 of 489
75 of 163
PAMC Violation: Room used as storage. Represents combustible load. (CFC sec. 311.3)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
174
Packet Pg. 314 of 489
76 of 163
PAMC Violation: Blocked weather head. Unsafe electrical.
Unsafe electrical installations in the garage area generally, including in the unpermitted office space where unsafe electrical conditions. (PAMC § 16.40.020) (f))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
175
Packet Pg. 315 of 489
77 of 163
PAMC Violation: Unpermitted construction, Improper installation of A/C unit. Similar conditions present throughout all converted hotel rooms.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
176
Packet Pg. 316 of 489
78 of 163
Unsafe electrical installations in the garage area generally, including unpermitted conduit runs were installed, unsafe electrical conditions were present. (PAMC § 16.40.020) (f)) PAMC Violation: Unpermitted Construction: Installation of unpermitted conduit that is penetrating the ceiling and wall assembly.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
177
Packet Pg. 317 of 489
79 of 163
PAMC Violation: Expired Fire Extinguisher. Most of the fire extinguishers present throughout the entire buildings were expired.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
178
Packet Pg. 318 of 489
80 of 163
Section III: 531
Stanford Avenue
Basement
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
179
Packet Pg. 319 of 489
81 of 163
PAMC Violation: Unpermitted installation of electric fence in basement. No exit signage is visible in garage.
No exit signage was present in the garage area. (CBC 1013.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
180
Packet Pg. 320 of 489
82 of 163
PAMC Violation: Improper use of signage in basement/garage.
No exit signage was present in the garage area. (CBC 1013.1) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
181
Packet Pg. 321 of 489
83 of 163
PAMC Violation: Unpermitted and unsafe installation of conduit. J box left in an unsafe condition.
Unsafe electrical installations in the garage area generally, including unpermitted conduit runs were installed. J-Box cover missing creating unsafe conditions. (PAMC § 16.40.020) (f)) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
182
Packet Pg. 322 of 489
84 of 163
PAMC Violation: Unpermitted storage areas built, false walls visible. Use of temporary electrical sources. Electrical strips and unsafe runs of electrical cords.
Unsafe electrical installations in the garage area generally, including unpermitted storage areas where unsafe electrical conditions were present. (PAMC § 16.40.020) (f))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
183
Packet Pg. 323 of 489
85 of 163
PAMC Violation: Unpermitted storage areas built, false walls visible. Use of temporary electrical sources. Electrical strips and unsafe runs of electrical cords.
Unsafe electrical installations in the garage area generally, including unpermitted storage areas where unsafe electrical conditions were present. (PAMC § 16.40.020) (f))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
184
Packet Pg. 324 of 489
86 of 163
PAMC Violation: Improper storage blocking access to emergency shut off.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
185
Packet Pg. 325 of 489
87 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
186
Packet Pg. 326 of 489
88 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
187
Packet Pg. 327 of 489
89 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
188
Packet Pg. 328 of 489
90 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
189
Packet Pg. 329 of 489
91 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
190
Packet Pg. 330 of 489
92 of 163
PAMC Violation: Unpermitted installation of water heater/storage tank.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
191
Packet Pg. 331 of 489
93 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
192
Packet Pg. 332 of 489
94 of 163
PAMC Violation: Unpermitted installation of commercial laundry machines. Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
193
Packet Pg. 333 of 489
95 of 163
PAMC Violation: Unsafe use of chemicals associated with the unpermitted installation of commercial laundry machines.
Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
194
Packet Pg. 334 of 489
96 of 163
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
195
Packet Pg. 335 of 489
97 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads.
PAMC § 16.40.020 Substandard Residential Building Defined (h). Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
196
Packet Pg. 336 of 489
98 of 163
PAMC Violation: Unsafe use of chemicals associated with the unpermitted installation of commercial laundry machines.
Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
197
Packet Pg. 337 of 489
99 of 163
PAMC Violation: Unsafe use of chemicals associated with the unpermitted installation of commercial laundry machines.
Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
198
Packet Pg. 338 of 489
100 of 163
PAMC
Violation: Unsafe storage conditions. High combustible loads.
Unpermitted Laundry in Garage: Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space.
PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
199
Packet Pg. 339 of 489
101 of 163
PAMC Violation: Unpermitted installation of laundry machines. This creates unsafe electrical, plumbing, and mechanical venting conditions Unpermitted Laundry in Garage:
Unpermitted laundry facilities were installed and operating in the garage area, constituting an unauthorized change in use of a non-habitable space.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
200
Packet Pg. 340 of 489
102 of 163
PAMC Violation: Unapproved use of indoor bike storage.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
201
Packet Pg. 341 of 489
103 of 163
PAMC Violation: Visible corrosion on piping.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
202
Packet Pg. 342 of 489
104 of 163
PAMC Violation: Improper installation electrical wiring in metallic corrugated raceway.
Unsafe electrical installations in the garage area generally (PAMC § 16.40.020) (f)) No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
203
Packet Pg. 343 of 489
105 of 163
PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Construction left unfinished.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
204
Packet Pg. 344 of 489
106 of 163
PAMC Violation: Unpermitted construction created unsafe fire conditions, unknown if it was a repair or a remodel. Left unfinished.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
205
Packet Pg. 345 of 489
107 of 163
PAMC Violation: Unknown substances stored in closed storage equipment room.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
206
Packet Pg. 346 of 489
108 of 163
PAMC Violation: Improper materials used for firestopping and unpermitted installation of romex wiring.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Unsafe electrical installations. Unpermitted flood light installed without permit or inspection. (PAMC §
16.40.020) (f))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
207
Packet Pg. 347 of 489
109 of 163
PAMC Violation: Untreated penetrations, allowing for airflow.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
208
Packet Pg. 348 of 489
110 of 163
PAMC Violation: Non-operable pull station.
The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
209
Packet Pg. 349 of 489
111 of 163
PAMC Violation: Unpermitted and improperly installed dilapidated lighting fixture.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
210
Packet Pg. 350 of 489
112 of 163
PAMC Violation: Description: Unpermitted construction, unsafe electrical, and structural.
Unsafe storage conditions. High combustible loads.
Code Violation: PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
211
Packet Pg. 351 of 489
113 of 163
PAMC Violation: Unsafe installation of electrical receptable located resting on fire sprinkler.
Unsafe electrical installations. Unpermitted receptacle installed without permit or inspection. (PAMC § 16.40.020) (f))
The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
212
Packet Pg. 352 of 489
114 of 163
PAMC Violation: Unsafe storage conditions. High combustible loads. Blocking emergency egress.
PAMC § 16.40.020 Substandard Residential Building Defined (h) Any building or portion thereof, device, apparatus, equipment, combustible waste, or vegetation which, in the opinion of the fire marshal, is in such a condition as to cause a fire or explosion or provide a ready fuel supply to augment the spread and intensity of fire or explosion arising from any cause.
The garage entrance was blocked, preventing required access and egress through this area. (CBC 1006.2)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
213
Packet Pg. 353 of 489
115 of 163
PAMC Violation: Improper storage of chemicals used for pool.
Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
214
Packet Pg. 354 of 489
116 of 163
PAMC Violation: Improper storage of portable gas container (filled with gas) and paint thinner.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
215
Packet Pg. 355 of 489
117 of 163
PAMC Violation: Unsafe installation of electrical wires in basement. (CBC § 114.1; PAMC §
16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
216
Packet Pg. 356 of 489
118 of 163
PAMC Violation: Unsafe installation of electrical wires in basement. (CBC § 114.1; PAMC §
16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
217
Packet Pg. 357 of 489
119 of 163
PAMC Violation: Unsafe installation of electrical wires draped over accordion door.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
218
Packet Pg. 358 of 489
120 of 163
PAMC Violation: Unsafe installation of electrical wires in basement.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
219
Packet Pg. 359 of 489
121 of 163
PAMC Violation: Sprinkler system corroded. Corrosion visible in ceiling in friable condition.
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
220
Packet Pg. 360 of 489
122 of 163
PAMC Violation: Improper use of emergency egress access. Propping a door for emergency exit is unsafe.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
221
Packet Pg. 361 of 489
123 of 163
PAMC Violation: Removal of Fire Doors, creating unsafe conditions.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
222
Packet Pg. 362 of 489
124 of 163
PAMC Violation: Salt pool system. Corrosion present.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
223
Packet Pg. 363 of 489
125 of 163
PAMC Violation: Unsafe temporary light fixture used instead of permanent light source.
No permanent lighting installed; temporary lighting in use that was inappropriate for the application. (PAMC § 16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
224
Packet Pg. 364 of 489
126 of 163
PAMC Violation: Unpermitted construction and unsafe penetrations created. Unknown if this was part of a remodel, repair, or abandonment of mechanical ducting. Left unfinished.
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
225
Packet Pg. 365 of 489
127 of 163
PAMC Violation: Corrosion of electrical conduit and electrical j-box.
Corroded electrical wiring and equipment throughout. Open junction boxes (j-boxes) with limited or no access cover. Corrosion of electrical components in the closet. Unsafe electrical installations. (PAMC § 16.40.020) (f))
Suspicious growth on the wall, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
226
Packet Pg. 366 of 489
128 of 163
PAMC Violation: Unsafe storage of pool chemicals.
Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
227
Packet Pg. 367 of 489
129 of 163
PAMC Violation: Corrosion on piping for water, electrical conduit, and walls visible in mechanical room associated with pool water conditioning system.
Corroded electrical wiring and equipment throughout. Corrosion of electrical components in the closet. Unsafe electrical installations. (PAMC § 16.40.020) (f)) Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Pool Operation: No permits for pool construction, modification, or operation; pool chemicals found in improper storage conditions. (CBC § 105.1)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
228
Packet Pg. 368 of 489
130 of 163
PAMC Violation: Unsafe penetration in wall.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
229
Packet Pg. 369 of 489
131 of 163
PAMC Violation: Corrosion on piping and walls visible in mechanical room associated with pool water conditioning system. Unsafe installation of electrical cords and terminations.
Corroded electrical wiring and equipment throughout. No permanent lighting installed; temporary lighting in use that was inappropriate for the application. (PAMC § 16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
230
Packet Pg. 370 of 489
132 of 163
PAMC Violation: Corrosion on piping and walls visible in mechanical room associated with pool water conditioning system.
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
231
Packet Pg. 371 of 489
133 of 163
PAMC Violation: Corrosion on piping and walls visible in electrical room. Unsafe.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
232
Packet Pg. 372 of 489
134 of 163
PAMC Violation: Corrosion on piping and walls visible in electrical room. Unsafe.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
233
Packet Pg. 373 of 489
135 of 163
PAMC Violation: Corrosion on piping and walls visible in electrical room. Unsafe.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
234
Packet Pg. 374 of 489
136 of 163
PAMC Violation: Corrosion on walls visible in electrical room. Conduit leading directly into electrical panels. Mold growth on ceiling. Unsafe.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
235
Packet Pg. 375 of 489
137 of 163
PAMC Violation: Dilapidated vent. Vermin/Rodent access. Visible feces.
Vermin: Signs of vermin infestation were observed throughout the buildings. (PAMC §
16.40.010(n) and 16.40.020(i)(13).
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
236
Packet Pg. 376 of 489
138 of 163
PAMC Violation: Evidence of corrosion/causing unknown growth. Unsafe.
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
237
Packet Pg. 377 of 489
139 of 163
PAMC Violation: Deteriorated sprinkler head.
The fire alarm systems were in a dilapidated and unreliable condition, with no verifiable documentation of current testing or inspection, in violation of PAMC Section 15.04.010 and CFC Section 901.6.3.
Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC §
15.04.010; CFC § 311.2.2; CFC Appendix I101.2))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
238
Packet Pg. 378 of 489
140 of 163
PAMC Violation: Unpermitted installation of flood light, left unfinished.
Unsafe electrical installations. Unpermitted flood light installed without permit or inspection. (PAMC § 16.40.020) (f))
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225) Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
239
Packet Pg. 379 of 489
141 of 163
PAMC Violation: Unsafe emergency egress access blocked.
16.40.010 Dangerous building defined
(l) Any building or structure which has been constructed, or which now exists or is maintained in violation of any specific requirement or prohibition, applicable to such building or structure, of the building regulations of this city, as set forth in the building code, or of any provisions of Title 15 of this code relating to the prevention of fire, when so determined and reported by the fire marshal, or of any law or ordinance of this state or city relating to the condition, location or structure of buildings.
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
240
Packet Pg. 380 of 489
142 of 163
PAMC Violation: Visible corrosion is located directly in ceiling, under the pool.
Unsafe electrical runs and terminations.
Unsafe electrical installations. Light installed above without permit or inspection (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020 Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC §
15.04.010; CFC § 311.2.2; CFC Appendix I101.2))
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
241
Packet Pg. 381 of 489
143 of 163
PAMC Violation: Visible corrosion is located directly in ceiling, under the pool.
Unsafe electrical runs and terminations.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
242
Packet Pg. 382 of 489
144 of 163
PAMC Violation: Visible corrosion is located directly in ceiling, under the pool.
Unsafe electrical runs and terminations.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
Item 11
Attachment M -
Photographic Evidence of
Code Violations at 531
Stanford Avenue
Item 11: Staff Report
Pg.
243
Packet Pg. 383 of 489
145 of 163
PAMC Violation: Visible corrosion is located directly in ceiling, under the pool.
Unsafe electrical runs and terminations.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC §
15.04.010; CFC § 311.2.2; CFC Appendix I101.2))
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PAMC Violation: Visible corrosion is located directly in ceiling, under the pool. Unsafe electrical runs and terminations.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
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PAMC Violation: Visible corrosion is located directly in ceiling and on wall, under the pool.
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PAMC Violation: Visible corrosion is located directly in ceiling and on wall, under the pool.
Unsafe electrical runs and terminations. Corroded sprinkler head.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020) Corroded Sprinkler Head: A corroded fire sprinkler head was documented in the basement equipment room. This physical evidence of corrosion at a specific sprinkler head is consistent with systemic corrosion of the entire sprinkler distribution system, and indicates that the sprinkler system in this building has not been maintained, tested, or replaced as required by the CFC. A corroded sprinkler head may fail to activate in a fire, or may rupture prematurely, in either case failing to provide the life-safety protection for which it was installed. (PAMC §
15.04.010; CFC § 311.2.2; CFC Appendix I101.2))
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PAMC Violation: Visible corrosion is located directly in ceiling and wall, under the pool.
Unsafe electrical runs and terminations.
Unsafe electrical installations. Unpermitted electrical run without permit or inspection. (PAMC §
16.40.020) (f)
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
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PAMC Violation: Visible corrosion/deterioration is located directly in ceiling and wall, under the pool.
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PAMC Violation: Visible corrosion/deterioration is located directly in ceiling, under the pool.
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PAMC Violation: Visible corrosion/deterioration is located directly in ceiling, under the pool.
Unsafe electrical conditions caused by corrosion.
Corroded electrical wiring and equipment throughout. Exposed wires with limited or no access.
Corrosion of electrical components. Unsafe electrical due to corrosion conditions. (PAMC §
16.40.020) (f))
Suspicious growth on the ceiling, which was visibly-assessed as potentially mold. This condition is consistent with chronic moisture intrusion and inadequate ventilation. (PAMC § 16.40.020)
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PAMC Violation: Improper storage of hazardous materials.
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PAMC Violation: Unsafe installation of j-box with no cover. Confirmed to be live.
No permits obtained for extensive remodeling work throughout the buildings, including modifications to unit configurations, common areas, mechanical rooms, electrical systems, plumbing systems, and structural elements. It is unlawful for any person to erect, construct, alter, extend, repair, move, remove, demolish, or occupy any building or structure in conflict with or in violation of any provision of this code. (CBC § 114.1; PAMC § 16.04.225)
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PAMC Violation: Unsafe penetrations in walls located in a mechanical room.
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PAMC Violation: Improper materials used for duct venting
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PAMC Violation: Improper materials used for fire penetration caulking.
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PAMC Violation: Broken door assembly. Many instances of similar conditions located throughout the buildings.
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Section IV: 531
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Postings
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Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Stanford Avenue side) All notices were posted in similar manner.
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Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Stanford Avenue side) All notices were posted in similar manner.
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Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Oxford Avenue side) All notices were posted in similar manner.
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Example of how buildings were posted. 4th Notice of Violation Posted on April 9, 2024 (Oxford Avenue side) All notices were posted in similar manner. Use of Evidence tape to confirm that no entry would be made in the future by unauthorized personnel.
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City Council
Staff Report
From: City Clerk
Report Type: ACTION ITEMS
Lead Department: City Clerk
Meeting Date: April 20, 2026
Report #:2604-6232
TITLE
Adoption of Recommendations by the Policy & Services Committee Implementing Changes to Meeting Procedures Related to Teleconferencing, Remote Public Participation, Translation and Interpretation Assistance, and Expanded Public Outreach; CEQA Status – Not a Project.
RECOMMENDATION
The Policy & Services Committee recommends the City Council:
1. Decline the use of expanded alternative teleconferencing for Boards, Commissions, and Committees (BCCs),
2. Receive an update on changes to remote public participation and provide direction on the format for general public comment for City Council and Council Committee meetings,
3. Approve the Two-Way Remote Public Access Disruption Policy (Attachment A),
4. Approve the following practices as reasonable assistance for third party translation and interpretation services, and
a. Arrange a space for interpreters at the meeting location, upon written request to the City Clerk at least 24 hours before the meeting,
b. Provide public speakers using interpretation extra time. Staff recommends providing twice as much time for individuals using interpretation, or an amount of time determined by the presiding officer,
c. Allow the public to use their own devices to access translation or interpretation devices, and
d. Loan city devices to the public to access translation or interpretation services upon written request to the City Clerk at least 24 hours before the meeting.
5. Direct the City Clerk to implement the following outreach practices a. Share information about agenda notification newsletters with community groups and organizations such as neighborhood associations, non-English news media, service organizations,
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webpage, newsletter sign-up page, meeting participation guide, and translation services webpage, and
c. Translate the Meeting Participation Guide 1 into the two most commonly spoken non-English languages as reported by the American Community Survey.
EXECUTIVE SUMMARY
In 2025, the California State Legislature adopted SB 707, which amended the Brown Act to modernize remote participation and expand public access to meetings. This report provides an overview of SB 707 requirements, identifies areas where the City is already compliant, and outlines recommended policy and operational updates where changes are required.
The Policy & Services Committee (P&S) unanimously recommended not authorizing expanded alternative teleconferencing for BCCs, while supporting staff recommendations related to translation, outreach, and related provisions. 2 Because SB 707 requires 3this report is not agendized on consent .
The primary policy considerations before the City Council include whether to authorize expanded alternative teleconferencing for BCCs, how to implement remote public comment requirements, and adoption of policies and practices related to meeting disruptions, translation, and outreach.
BACKGROUND
The enactment of SB 707 brought notable changes to the Brown Act, the law that ensures public access and participation in local legislative body meetings. The bill is intended to modernize public meetings in light of newer technology and expand public participation and engagement.
The updates concern expanded BCC teleconferencing, remote public participation, third-party translation assistance, and public outreach. Certain provisions only affect the City Council’s meetings, while others apply to all Brown Act bodies. Some requirements went into effect on January 1, 2026, but others are not operative until July 1, 2026 to give agencies time to plan implementation.
The table below summarizes SB 707’s key updates and P&S’s implementation recommendations. 1 City of Palo Alto Meeting Participation Guide: https://www.paloalto.gov/files/assets/public/v/1/city-clerk/city- charterprocedures/2025-meeting-participation-guide.pdf
2 Policy & Services Committee, February 10, 2026 Action Minutes:
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Topic Summary
Applicable
Meeting
Bodies
Effective
Date
BCC Expanded
Alternative
Teleconferencing
Council could authorize BCCs to meet fully virtually
for up to six months at a time. The P&S Committee
did not recommend authorizing this form of
teleconferencing.
BCCs 1/1/26
Remote Public
Participation and
Public Comment
SB 707 requires the City Council provide a two-way
audiovisual or telephonic platform. The City’s use
of Zoom for City Council, Council Committees, and
BCCs exceeds this requirement. The City Council
must update its practices to allow for remote
general public comment by 7/1/26. Staff
recommends allowing remote general public
comment for Council Committees to maintain
consistency across meeting bodies. P&S directed
staff to evaluate dividing general public comment
into two sections. In-person comments will be
heard at the beginning of the meeting and remote
comments will be heard at the end of the meeting.
City
Council
7/1/26
Disruption of
Remote Public
Access Policy
The City Council must recess and attempt to
restore remote access if Zoom is disrupted during
a meeting. The City Council must adopt a
disruption policy describing these procedures by
7/1/26. P&S recommended adoption of the policy
(Attachment A).
City
Council
7/1/26
Third-Party
Translation and
Interpretation
Assistance
SB 707 requires the City Council to provide
reasonable assistance to individuals receiving
third-party translation and/or interpretation at
meetings. It does not require the City to provide
translation and/or interpretation services. P&S
recommended arranging space for interpretation
to occur, allotting extra public comment time for
individuals using interpretation, allowing
individuals to use their own devices for
interpretation and loaning City devices for
translation upon advance request.
City
Council
7/1/26
Outreach Efforts SB 707 requires cities to make reasonable efforts to encourage participation from groups that
traditionally do not engage in public meetings.
P&S recommends continuing existing outreach
practices and enhancing transparency and
accessibility by clarifying how community
City
Council
7/1/26
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members may request language assistance and
participate remotely, consistent with SB 707’s
intent to broaden civic engagement.
ANALYSIS
The following section details Brown Act changes brought by SB 707 that will affect the City and staff’s recommended implementations. The City’s current practices already satisfy or surpass some of SB 707’s requirements (detailed in Attachment B), but others will require a change in practice or policy.
Expanded Alternative Teleconferencing for Eligible Subsidiary Bodies (effective January 1, 2026) Following COVID-19, the State Legislature amended the Brown Act to allow members of legislative bodies to participate in meetings remotely under specific circumstances (i.e. “just cause” or “emergency circumstances”) with fewer noticing requirements than traditional Brown Act teleconferencing. This form of teleconferencing, which does not require remote attendance locations to be published on the agenda or accessible to the public, is referred to as alternative teleconferencing. The City Council incorporated SB 707’s changes, detailed in Attachment B, to alternative teleconferencing in its most recent Procedures and Protocol Handbook update.7 SB 707 allows the City Council to authorize an additional form of remote participation, called expanded alternative teleconferencing, for eligible subsidiary bodies, a category that includes the City’s BCCs. Commissioners are permitted to use alternative teleconferencing regardless of the City Council’s decision regarding expanded alternative teleconferencing. Council Committees are not eligible because SB 707 does not permit Councilmembers to use expanded alternative teleconferencing. Expanded alternative teleconferencing would allow BCC members to attend remotely without opening their location to the public and without just cause, subject to the minimum requirements listed below. Unlike alternative teleconferencing, expanded alternative teleconferencing does not require a quorum to attend from a singular physical location and therefore could allow a fully virtual meeting. This provision is optional and requires affirmative Council action to implement.
The City Council may authorize expanded alternative teleconferencing for up to six months and every six months thereafter. To authorize expanded alternative teleconferencing, the City Council must take formal action approving the expanded use of alternative teleconferencing for a period of up to six months, and include findings that Council has:
Considered the circumstances of the subsidiary body,
Determined that teleconferencing would enhance public access, Ensured publication of remote and physical access and comment options, and 7 City Council, February 9, 2025, Agenda Item #12; Staff Report # 2601-5874 https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=85860 Item 12
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Determined that teleconferencing would promote attraction, retention, and diversity of eligible board or commission members.
Meetings held via expanded alternative teleconferencing must meet the requirements below.
The City Council may impose additional requirements but may not remove requirements. The subsidiary body must provide a staffed physical meeting location where the agenda is posted and members of the body or public may attend and participate in-person, Elected officials may not use this section to appear remotely, and Remote members must appear visibly on camera, with limited exceptions.
While expanded alternative teleconferencing may improve flexibility and accessibility for BCC members, staff notes that in-person meetings provide important benefits that support the City’s public engagement goals. Face-to-face meetings facilitate stronger communication between Commissioners, staff, and community members, promote relationship-building, and allow for more dynamic public dialogue.
Further, a significant expansion of alternative teleconferencing presents compliance and administrative challenges. The City has eight BCCs addressing diverse subject areas ranging from stormwater management to arts and culture. These bodies are supported by staff from multiple departments, many of whom support BCC meetings infrequently. The Brown Act’s teleconferencing requirements are complex, and expanded alternative teleconferencing adds additional procedural obligations that increase the risk of inadvertent non-compliance.
The P&S Committee did not recommend authorizing expanded alternative teleconferencing for BCCs. If the City Council wishes to authorize expanded alternative teleconferencing, staff recommends that it be implemented thoughtfully and incrementally, with clear, administrable rules and defined evaluation criteria. Staff suggests beginning with a modest pilot approach. For example, Council could authorize one specific Board or Commission to conduct a limited number of fully virtual meetings within a six-month period, allowing staff and the body to evaluate impacts on public participation, meeting quality, and administrative workload before considering broader implementation. Implementation of expanded teleconferencing may require additional staff training and coordination across departments, particularly for BCCs supported by decentralized staff.
Remote Public Participation and Public Comment (effective July 1, 2026) SB 707 mandates City Council meetings include an option for remote public participation and accept remote public comment via a two-way telephonic or audiovisual platform. Palo Alto already uses Zoom for its City Council, Council Committee and BCC meetings, which surpasses the new requirements. However, the City Council will have to adjust its general public comment practices. The City Council currently accepts general public comment for non-agendized items only in-person and accepts public comment on agendized items in-person and remotely. The City Item 12
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Council must allow remote general public comment beginning on July 1, 2026. This requirement does not apply to BCCs or Council Committees. Although not mandated by SB 707, staff recommends also accepting remote general public comment at Council Committee meetings to maintain consistency across City Council meeting bodies. Staff will communicate the change to the public prior to the effective date and update agenda materials and internal practices to comply with this provision.
P&S directed staff to explore splitting general public comment into an in-person portion at the start of meetings and a remote portion at the end of meetings. The City Council may implement this format for general public comment if it chooses. The City Council splits general public comment into two sections based on whether the speaker is in person or virtual. In-person speakers will be heard at the beginning of the meeting (subject to the existing 30-minute cap, after which remaining speakers will be heard at the end of the meeting) and virtual speakers will be heard along with any additional in-person speakers at the end. Staff is also seeking the City Council’s direction on general public comment for Council Committee meetings. This approach would accommodate an expected increase in general public comment while managing meeting capacity.
Policy on Disruption of Remote Public Access (effective July 1, 2026) SB 707 requires the City Council to take certain actions if remote public access to meetings is disrupted and adopt a policy describing these procedures. This requirement only concerns disruptions to Zoom, not additional services that allow only passive viewing, such as a YouTube livestream or local television broadcast. The disruption requirements do not apply to Council Committees or BCC meetings. The remote public access disruption policy must meet the following requirements, which are also depicted in the flowchart below. If a disruption prevents public participation through Zoom, City Council shall recess open session for at least one hour and attempt in good faith to restore service or adjourn the meeting,
City Council may meet in an agendized closed session during the recess, Open session may not reconvene until at least one hour has passed or service is restored, whichever comes first, and
If service is not restored, City Council may resume after adopting, by roll call vote, a finding that good faith efforts were made to restore service and that the public interest in continuing the meeting outweighs the public interest in remote access.
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Staff from the City Clerk, City Attorney, and IT departments collaborated on the attached draft policy (Attachment A). The draft policy details the good faith efforts staff shall make to restore service, which may include:
Troubleshooting platform or teleconferencing software, Resetting or replacing audiovisual equipment,
Attempting alternative connection methods,
Contacting necessary support staff or service providers, and/or Switching to back-up equipment or platforms, if available.
The Policy & Services Committee recommended the City Council approve the attached disruption policy.
Third-Party Translation and Interpretation Assistance (effective July 1, 2026) As revised, the Brown Act requires the City Council to reasonably assist community members providing or receiving translation and interpretation services from third parties at City Council meetings. These requirements do not apply to Council Committees or BCCs. While SB 707 requires some jurisdictions to translate their agendas, agenda translation is not required in Palo Alto at this time.
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The City must make available to the public a physical posting space where members of the public may post their own translations of the City Council’s agendas. The City will provide notice that these translations are provided by third parties, and that the City cannot verify the content or accuracy of publicly provided agenda translations. Staff recommends authorizing the City Clerk to designate an appropriate posting board for this purpose. Staff currently recommends making the King Plaza posting board available for translated agendas and will post instructions and guidelines for how the public may utilize the space.
Additionally, the City must reasonably assist members of the public wishing to receive translation or interpretation services from a third-party during a City Council meeting, provided the translation does not disrupt the public meeting. This provision does not require the City Council to provide the services. P&S recommends the City adopt the following practices as reasonable assistance:
Arrange a space for interpreters at the meeting location, upon written request to the City Clerk at least 24 hours before the meeting,
Provide public commenters using interpretation extra time. Staff recommends providing twice as much public comment time for individuals using interpreters, or an amount of time determined by the presiding officer,
Allow the public to use their own devices to access translation or interpretation services, and
Loan City devices to the public to access translation or interpretation services upon request. Requests for City devices must be made in writing to the City Clerk at least 24 hours before the meeting. Information on borrowing City devices may be found on the City Clerk’s Translation Services webpage9.
Outreach to Underrepresented Groups (effective July 1, 2026) SB 707 requires the City to make “reasonable efforts,” as determined by the City Council, to invite groups who “do not traditionally participate in public meetings. 10” SB 707 provides examples of such groups, including media organizations, civil rights groups, and neighborhood organizations, including those that serve non-English-speaking communities.
The City prioritizes public engagement in public meetings and already engages in the following practices to promote outreach and access:
Publishes City Council agenda and agenda packet 11 days before meeting, rather than the minimum required 72 hours for regular meetings and 24 hours for special meetings, 9 City of Palo Alto Translation Services: https://www.paloalto.gov/Departments/City-Clerk/City-Meeting- Groups/Translation-Services
10 California Gov. Code Section 54953.4:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV§ionNum=54953.4.
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Provides physical agenda packets for public review at Mitchell Park and Rinconada libraries, in addition to posting agendas in King’s Plaza (accessible 24/7) and in Council Chambers,
Displays prominent link on city homepage to webpage with meeting schedule and agenda materials,
Distributes a weekly newsletter of published agendas and meetings sent to over 1,500 people and prominently displays newsletter sign-up link on agenda website, Maintains a City website explaining the format of public meetings and how the public may participate,
Publishes all City Council and Council Committee agendas, rather than only special meetings, in Palo Alto Weekly and Daily Post,
Enables automatic translation of the City website into Spanish or simplified Chinese, Enables automatic translation of HTML agendas for all meeting bodies into over 200 languages,
Offers free access to Wordly, a real-time audio and text translation service supporting over 50 languages, upon written request to the City Clerk at least 24 hours before the meeting. The public may use own device or borrow a City device to receive verbal and/or written interpretation. Instructions for requesting and using Wordly service are available on the City Clerk’s website, and
Livestreams public meetings on YouTube and broadcasts on local cable television.
Given the priorities of SB 707, staff recommends continuing the above efforts, taking the following additional actions, and continually updating and improving practices based on effectiveness:
Share information about agenda notification newsletters with community groups and organizations such as neighborhood associations, non-English news media, service organizations,
Post informational resources in the King’s Plaza and Council Chambers posting board and other public-facing City facilities with QR codes linking to the Agendas webpage, newsletter sign-up page, meeting participation guide, and translation services webpage, and
Translate the Meeting Participation Guide 13 into the two commonly spoken non-English languages as reported by the American Community Survey.
These efforts are consistent with the City’s broader goals of transparency, accessibility, and inclusive civic engagement.
13 City of Palo Alto Meeting Participation Guide: https://www.paloalto.gov/files/assets/public/v/1/city-clerk/city- charterprocedures/2025-meeting-participation-guide.pdf
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FISCAL/RESOURCE IMPACT
The City Clerk’s Office has sufficient resources in its existing budget to implement the staff recommendations. Additional resources may be required depending on the City Council’s recommendations regarding expanded alternative teleconferencing, translation, and outreach.
STAKEHOLDER ENGAGEMENT
Staff in the City Clerk’s, City Attorney, and IT departments collaborated on the recommended implementation of SB 707. The City Clerk’s Office has also been in touch with BCC members and staff regarding Brown Act changes applicable to their bodies. P&S discussed updates to the Brown Act at its public meeting on February 10, 2026.
ENVIRONMENTAL REVIEW
The proposed City Council action is not a project under the California Environmental Quality Act (CEQA), as it involves organizational and administrative activities (CEQA Guidelines, Section 15378(b)(2).
ATTACHMENTS
Attachment A: Two-Way Remote Public Access Disruption Policy Attachment B: City Practices Already in Alignment with SB 707 APPROVED BY:
Mahealani Ah Yun, City Clerk
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Policy: Disruption of Two-Way Remote Public Access Service
1. Purpose
This policy establishes procedures for responding to a disruption in the telephonic or internet services that provide two-way remote public access to meetings of the City Council of the City of Palo Alto, as required by the Brown Act (Gov. Code § 54953.4). If state law is subsequently amended, the amended terms of state law will apply.
2. Definitions
For purposes of this policy:
“Disruption” means any failure, outage, or other interruption that prevents members of the public from attending or observing the meeting via a two-way telephonic service or two-way audiovisual platform. “Remote access services” means the two-way telephonic service and/or two-way audiovisual platform used to provide real-time remote public attendance and participation in meetings. Services that allow remote observation but not participation of meetings, such as a television broadcast or livestream, are not included.
3. Applicability
This policy applies to all open and public meetings of the City Council of the City of Palo Alto at which remote public participation is offered or required under the Brown Act.
4. Procedures in the Event of a Service Disruption
4.1. Response to Service Disruption
If the Presiding Officer or Clerk becomes aware of a disruption to the agency’s remote access services that prevents members of the public from attending or observing the meeting remotely:
1. The Presiding Officer or Clerk shall immediately announce the disruption to the public.
2. The Presiding Officer may then call for a recess of the open session or convene the legislative body in an agendized closed session. The Presiding Officer will make the following, or a substantially similar, announcement:
“The City is experiencing a disruption of its remote access service that prevents remote public participation. In accordance with the Brown Act, the City Council will recess the meeting for at least one hour or until services are restored, whichever comes sooner. If service is not restored after one hour, the City Council may either vote that the public interest in continuing the public meeting outweighs the public interest in remote access and reconvene or adjourn the meeting.”
3. Staff shall begin efforts to diagnose and restore the disrupted service.
4. The meeting shall remain in recess for at least one hour or until service is restored, whichever is sooner. The recess period may be extended if restoration efforts are ongoing.
4.2. Efforts to Restore Service
The agency shall make good faith efforts to restore remote access services, which may include:
Troubleshooting platform or teleconferencing software
Resetting or replacing audiovisual equipment
Attempting alternative connection methods
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Contacting necessary support staff or service providers Switching to back-up equipment or platforms, if available
5. Reconvening the Open Session
5.1. Timing
The open session may be reconvened after at least one hour has elapsed from the time of disruption or as soon as service is restored, whichever occurs earlier.
5.2. If Service Is Restored
If the remote access service is restored before or at the time the meeting reconvenes, the meeting shall continue as normal.
5.3. If Service Is Not Restored
If service has not been restored after one hour, the City Council of the City of Palo Alto may reconvene and:
1. Adjourn the meeting; or
2. Continue the meeting in open session by adopting, by roll call vote, the following, or a substantially similar, finding:
“The City of Palo Alto has made good faith efforts to restore remote access services in accordance with its adopted policy, and the public interest in continuing the meeting outweighs the public interest in remote public access.”
Upon adoption of the finding, the legislative body may continue the open session.
6. Recordkeeping
The Clerk shall enter a brief statement into the meeting minutes, including the following:
The nature and time of the disruption
That good faith efforts to restore service were made in accordance The time the meeting was reconvened (if applicable)
Any finding adopted pursuant to Section 6.3
7. Review and Updates
This policy may be amended by the City Council of the City of Palo Alto at a noticed public meeting in open session, not on the consent calendar.
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4 City Practices Already in Alignment with SB 707
This attachment describes SB 707 requirements that are satisfied by current City practices and by recent updates and do not need additional implementation.
Alternative Teleconferencing (effective January 1, 2026) Before 2020, the Brown Act only permitted members of Brown Act bodies to attend meetings remotely if the member published their remote address on the agenda, allowed public access at their remote location, and posted the agenda at their remote location, among other requirements. This open location form of remote attendance is referred to as “standard teleconferencing.” SB 707 does not change this form of teleconferencing.
During the Covid-19 state of emergency, the Brown Act permitted members to attend meetings remotely without opening their location to the public if they complied with another set of requirements. After the state of emergency ended, the legislature continued to experiment with narrow reasons (i.e. “just cause” or “emergency circumstances”) that a member could attend remotely without publishing the remote meeting location or making the location open to the public. This is referred to as “alternative teleconferencing” and was established by AB 2449 (2021-2022). Other rules apply to alternative teleconferencing, such as the requirement to participate by video throughout the meeting.
SB 707 extends and revises the alternative teleconferencing provisions of AB 2449. Some notable changes include:
Extends expiration date to 2030,
Removes the procedural differences between attending remotely due to “just cause” or “emergency circumstances,”
Expands “just cause” to include certain military service obligations, Modifies the annual limit on attendance by alternative teleconference based on the body’s frequency of regular meetings, and
Requires meeting minutes to identify specific provision a member relies on to participate remotely.
The City Council adopted the updated provisions as part of its most recent Procedures & Protocols Handbook update.
Brown Act Distribution (effective January 1, 2026)
SB 707 converts a previously optional authority into a mandate. Cities are now required to provide the Brown Act to elected and appointed members of legislative bodies, including City Council and BCCs. The City Clerk’s Office provides the Brown Act as part of the reference materials given to all new 1 February 9, 2026 City Council Action Minutes:
https://recordsportal.paloalto.gov/WebLink/DocView.aspx?id=86544&dbid=0&repo=PaloAlto Item 12
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4 commissioners during their orientation and will incorporate this mandate into new Councilmember onboarding practices.
Remote Member Participation as an Accommodation (effective January 1, 2026) A member of any legislative body may now participate remotely as a reasonable accommodation for a disability. The member’s participation counts as in-person for quorum purposes. Members using this form of teleconference must:
Disclose the presence of anyone over the age of 18 with them and their relationship to that person, and
Use audio and visual technology, unless a physical condition related to their disability results in a need to participate only through audio.
City Clerk staff will coordinate on an as-needed basis with members using this form of teleconference.
Remote Public Attendance
SB 707 requires certain legislative bodies to offer a remote public participation option. In Palo Alto, the City Council is the only legislative body required to provide a remote option. Existing City Clerk practice surpasses this requirement. Palo Alto currently uses Zoom to host meetings and take comments on agendized items at all City Council, Council Committees, and BCC meetings. The City also livestreams meetings to YouTube and broadcasts to local cable television as additional viewing options for the public.
Website Requirements (effective July 1, 2026)
SB 707 requires a city’s homepage to include a prominent link to a public meeting webpage. The webpage must include or link to:
a general explanation of the public meeting process,
an explanation of how to provide in-person or remote verbal or written public comment, a calendar of all public meetings with the times, dates, and locations, and a link to posted agendas.
A link to the City’s Meeting Agendas and Minutes page3 is prominently displayed on Palo Alto’s homepage and complies with these requirements. In addition to the Agendas page, the City Clerk’s Office also maintains a Resources for Meeting Attendance 4 webpage. This page includes information about City Council meeting structure, public comment procedures, FAQs, City Council and BCC meeting frequencies, and resources for remote attendance.
The City Clerk’s Office’s online newsletter meets new requirements regarding electronic meeting agenda distribution. A city must now provide a system to electronically accept and fulfill requests for meeting agendas and display a sign-up link on the City Council’s homepage. The City Clerk’s Office sends a weekly 3 City of Palo Alto Meeting Agendas and Minutes: https://PaloAlto.gov/CouncilAgendas 4 City of Palo Alto Resources for Public Meetings: https://www.paloalto.gov/Departments/City-Clerk/City-Meeting- Groups/Resources-for-Meeting-Attendance
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4 newsletter with information about City Council and Council Committee meetings and events, including direct links to all published agendas and notifications of amended or supplemental materials. The newsletter is currently distributed to over 1,500 individuals, and the public may sign up online via a prominent link on the Meeting Agendas and Minutes page.
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City Council
Staff Report
Report Type: INFORMATION REPORTS
Lead Department: Administrative Services
Meeting Date: April 20, 2026
Report #:2602-6002
TITLE
Monthly Investment Report - March 2026 (Unaudited)
RECOMMENDATION
This is an Information Report. No Council action is required.
EXECUTIVE SUMMARY
The City’s Investment Policy (Policy)1 and California Government Code Section 53607 requires that a report of transactions (investments, reinvestment, sold, and exchanged securities) be made available to the Council on a monthly basis. This reporting requirement is separate and distinct from the quarterly investment report submitted under California Government Code Section 53646 that includes portfolio composition, a detailed list of all securities, performance compared to the Policy, overall compliance with the Policy, and the City’s ability to meet expenditure requirements over the next six months.
ATTACHMENTS
Attachment A: Investment Portfolio Transaction Ledger – March 2026 APPROVED BY:
Lauren Lai, Administrative Services Director
1 Investment Policy Fiscal Year 2025-2026 (Adopted February 2026); https://www.paloalto.gov/files/assets/public/v/1/administrative-services/investment-policies/1-39-asd- investment-policy.pdf
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Buy
Call Redemption
Maturity
CUSIP Security Description Security Type Transaction
Type
Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 91282CQB0 UNITED STATES
TREASURY 3.375
02/29/2028
US GOV Buy 03/20/2026 10,000,000.00 99.227 3.790 -9,922,656.25 18,342.39 -9,940,998.64 91282CGH8 UNITED STATES
TREASURY 3.5 01/31/2028
US GOV Buy 03/13/2026 5,000,000.00 99.547 3.749 -4,977,343.75 19,820.44 -4,997,164.19 912797SM0 UNITED STATES
TREASURY 04/23/2026
T-BILL Buy 03/31/2026 5,000,000.00 99.767 3.704 -4,988,358.17 0.00 -4,988,358.17 912797QN0 UNITED STATES
TREASURY 05/14/2026
T-BILL Buy 03/31/2026 5,000,000.00 99.557 3.693 -4,977,838.06 0.00 -4,977,838.06 91159HJT8 US BANCORP 5.046
02/12/2031
CORP Buy 03/25/2026 2,500,000.00 101.047 4.746 -2,526,175.00 15,067.92 -2,541,242.92 87269AAA8 TMUST 261 A 4.25
10/21/2030
ABS Buy 03/20/2026 1,870,000.00 99.979 4.255 -1,869,603.19 0.00 -1,869,603.19 79466LAR5 SALESFORCE INC 4.65
03/15/2029
CORP Buy 03/20/2026 1,150,000.00 100.007 4.648 -1,150,080.50 1,039.79 -1,151,120.29 47787DAD3 JDOT 2026 A3 3.87
08/15/2030
ABS Buy 03/18/2026 1,755,000.00 99.982 4.489 -1,754,689.01 0.00 -1,754,689.01 3137FKZZ2 FHMS K-088 A2 3.69
01/25/2029
FHLMC Buy 03/31/2026 4,855,000.00 98.434 4.239 -4,778,950.98 14,929.13 -4,793,880.11 24422EYE3 JOHN DEERE CAPITAL
CORP 4.55 06/05/2030
CORP Buy 03/20/2026 2,500,000.00 100.629 4.383 -2,515,725.00 33,177.08 -2,548,902.08 023135DD5 AMAZON.COM INC 4.25
03/13/2031
CORP Buy 03/13/2026 1,535,000.00 99.733 4.310 -1,530,901.55 0.00 -1,530,901.55 023135DD5 AMAZON.COM INC 4.25
03/13/2031
CORP Buy 03/27/2026 1,215,000.00 98.863 4.508 -1,201,185.45 2,008.13 -1,203,193.58 --- --- --- Buy 03/23/2026 42,380,000.00 --- 4.020 -42,193,506.91 104,384.88 -42,297,891.79 CUSIP Security Description Security Type Transaction
Type
Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 6500357D4 NEW YORK ST URBAN
DEV CORP REV 3.07
03/15/2026
MUNI Call
Redemption
03/15/2026 -700,000.00 100.000 2.100 700,000.00 0.00 700,000.00 396916AC2 GreenWay Bank 4.35
04/03/2028
CD Call
Redemption
03/03/2026 -250,000.00 100.000 4.350 250,000.00 0.00 250,000.00 3133ETAF4 FEDERAL FARM CREDIT
BANKS FUNDING CORP
4.9 03/19/2031
AGCY BOND Call
Redemption
03/19/2026 -1,985,000.00 100.000 4.919 1,985,000.00 0.00 1,985,000.00 3133ER5R8 FEDERAL FARM CREDIT
BANKS FUNDING CORP
5.25 03/03/2034
AGCY BOND Call
Redemption
03/03/2026 -1,500,000.00 100.000 5.250 1,500,000.00 0.00 1,500,000.00 --- --- --- Call
Redemption
03/12/2026 -4,435,000.00 100.000 4.554 4,435,000.00 0.00 4,435,000.00 CUSIP Security Description Security Type Transaction
Type
Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 91282CBQ3 UNITED STATES
TREASURY 0.5 02/28/2026
US GOV Maturity 02/28/2026 0.00 100.000 0.831 0.00 0.00 1,500,000.00 912797SZ1 UNITED STATES
TREASURY 03/17/2026
T-BILL Maturity 03/17/2026 -10,000,000.00 100.000 3.672 10,000,000.00 0.00 10,000,000.00 59001PAP4 Meritrust Federal Credit
Union 0.55 03/10/2026
CD Maturity 03/10/2026 -249,000.00 100.000 1.932 249,000.00 0.00 249,000.00 Palo Alto Monthly Transactions
03/01/2026 - 03/31/2026
1 ATTACHMENT A
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Portfolio Transaction
Ledger - March 2026
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Summary
CUSIP Security Description Security Type Transaction
Type
Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount 478160BY9 JOHNSON & JOHNSON
2.45 03/01/2026
CORP Maturity 03/01/2026 -3,000,000.00 100.000 0.823 3,000,000.00 0.00 3,000,000.00 45950VPU4 INTERNATIONAL FINANCE
CORP 0.75 03/23/2026
SUPRANATIONAL Maturity 03/23/2026 -3,500,000.00 100.000 0.839 3,500,000.00 0.00 3,500,000.00 45950VPT7 INTERNATIONAL FINANCE
CORP 2.5 03/15/2026
SUPRANATIONAL Maturity 03/15/2026 -2,000,000.00 100.000 0.820 2,000,000.00 0.00 2,000,000.00 31422XDX7 FEDERAL AGRICULTURAL
MORTGAGE CORP 0.83
03/27/2026
AGCY BOND Maturity 03/27/2026 -4,755,000.00 100.000 0.878 4,755,000.00 0.00 4,755,000.00 3130ALF33 FEDERAL HOME LOAN
BANKS 0.75 03/16/2026
AGCY BOND Maturity 03/16/2026 -1,925,000.00 100.000 0.113 1,925,000.00 0.00 1,925,000.00 20368QAD8 Community Choice Credit
Union 4.0 03/30/2026
CD Maturity 03/30/2026 -249,000.00 100.000 4.000 249,000.00 0.00 249,000.00 --- --- --- Maturity 03/18/2026 -25,678,000.00 100.000 1.933 25,678,000.00 0.00 27,178,000.00 CUSIP Security Description Security Type Transaction
Type
Settlement Date Quantity Price Acq/Disp Yield Amount Purchased/Sold Interest Total Amount --- --- --- --- 03/21/2026 12,267,000.00 --- 3.311 -12,080,506.91 104,384.88 -10,684,891.79 Palo Alto Monthly Transactions
03/01/2026 - 03/31/2026
2 ATTACHMENT A
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Attachment A - Investment
Portfolio Transaction
Ledger - March 2026
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Item No. 6. Page 1 of 2
City Council
Supplemental Report
From: Jonathan Lait, Planning and Development Services Director Meeting Date: April 20, 2026
Item Number: 6
Report #:2604-6260
TITLE
Adopt a Resolution Authorizing the Director of Planning and Development Services to Make Minor Modifications to the 2023-2031 Housing Element Site Inventory. CEQA Status: The City Council adopted a Revised Addendum to the Comprehensive Plan Final Environmental Impact Report on December 18, 2023, that, in conjunction with the Comprehensive Plan Final EIR, fully analyzes the impacts of the 6th Cycle Housing Element, including minor modifications to the site inventory.
RECOMMENDATION
Staff recommends that the City Council adopt a resolution to authorize the Director of Planning and Development Services to make modifications to the 2023-2031 Housing Element site inventory that are consistent with the adopted Housing Element.
BACKGROUND
This transmittal provides additional information on the objective criteria that will be used to identify new Housing Element opportunity sites to replace Regional Housing Needs Allocation (RHNA) capacity. If the City Council adopts the resolution, the Director of Planning and Development Services will apply these criteria to evaluate site suitability. Approving this process for minor modifications to the 2023–2031 Housing Element Site Inventory will help the City maintain compliance with state law and the Housing Element’s Adequate Sites Program.
Evaluation Criteria
Staff will evaluate candidate Housing Element opportunity sites using the same objective criteria used to identify the City’s existing opportunity sites. The California Department of Housing and Community Development (HCD) accepted these criteria as part of the City’s approach to meeting RHNA requirements, and they are described in the Housing Element (pp. 3-25 to 3-33). Examples include:
Improvement to land value ratio
Vacant buildings
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Structure age
Developer interest
Existing use/current zoning
Staff will also consider additional criteria in response to changing circumstances, including implementation of SB 79, and re-evaluate previously studied sites. These tools will be used to screen sites and assess redevelopment potential.
Selection Criteria
Prior to making any determination of whether a site will be added to the Housing Element site inventory, the Director will review candidate sites based on the following selection criteria:
Exclusions:
oR1 zones
oSites immediately adjacent to R1
oEnvironmentally sensitive areas, such as the foothills or Baylands Prioritized locations:
oSites within ½ mile of Caltrain stations
oLocations within commercial or mixed-use corridors, particularly in locations with transit or bike facilities
oLocations within area plans or planning focus areas
The Director will add sites to the inventory as necessary to meet state requirements for RHNA at each income level and to maintain an adequate buffer.
Reporting
The Director will submit a report to the City Council when changes are made to the Housing Element site inventory. In addition, changes will be reported to HCD annually as part of the state-mandated reporting requirements.
APPROVED BY:
Jonathan Lait, Planning and Development Services Director Item 6
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Item No. 10. Page 1 of 1
City Council
Supplemental Report
From: Jonathan Lait, Planning and Development Services Director Meeting Date: April 20, 2026
Item Number: 10
Report #:2604-6256
TITLE
4075 El Camino Way [23PLN-00202]: Recommendation to Decline Adoption on Second Reading of an Ordinance Adopting an Amendment to a Planned Community Ordinance (PC-5116) to Allow for Modifications to an Existing 121-Unit Assisted Living and Memory Care Facility. First Reading Adoption was on March 16, 2026. CEQA Status: Exempt from the Provisions of the California Environmental Quality Act (CEQA) in Accordance with CEQA Guidelines Section 15301 (Modifications to Existing Facilities).
RECOMMENDATION
Staff recommends that the City Council:
1. Decline to adopt the second reading ordinance allowing the application to be withdrawn as requested by the applicant.
BACKGROUND
The published report for the subject item incorrectly stated three votes were required to pull the second reading ordinance from the consent calendar; four votes are required.
This provision is set forth in the City Council Procedures and Protocols Handbook Section 3.8 (f).
ATTACHMENTS
None
APPROVED BY:
Jonathan Lait, Planning and Development Services Director Item 10
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Report
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City Council
Staff Report
From: City Clerk
Report Type: CONSENT CALENDAR
Lead Department: Public Works
Meeting Date: April 20, 2026
Report #:2604-6268
TITLE
Amend the FY 2026 Budget Appropriation for the Capital Improvement Fund to Establish the Embarcadero Road Improvement Project, Phase 1, and Authorize the City Manager or Their Designee to Award a Construction Contract with a Qualified Contractor for the Embarcadero Road Improvement Project, Phase 1; CEQA Status – Exempt under CEQA Guidelines Section 15301(c)
This report will be published as an at-places memo on Monday, April 20, 2026.
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City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Community Services
Meeting Date: April 20, 2026
Report #:2604-6218
TITLE
Informational Update on Stanford Palo Alto Community Playing Fields (Mayfield) PFAS Testing Results
RECOMMENDATION
This is an informational report and no City Council action is required.
BACKGROUND
On June 9, 20251, the City Council approved Construction Contract No. C25193640 with FieldTurf USA, Inc. in the amount of $3,064,185, along with a contingency of $306,419, for the Stanford Palo Alto Community Playing Fields Turf Replacement Project (PG-26000).
At that time, staff issued a supplemental memorandum addressing the question of whether the selected synthetic turf system would be free of per- and polyfluoroalkyl substances (PFAS) and whether testing would be conducted to confirm this. The memorandum stated that “…staff have confirmed that FieldTurf manufactures synthetic turf products without intentionally- added PFAS and this is the product that will be installed at Stanford Palo Alto Playing Fields.
FieldTurf will test the product after installation to verify no intentionally-added PFAS.” Staff have since consulted with the California Department of Toxic Substances Control (DTSC) and coordinated with an independent testing laboratory using a National Environmental Laboratory Accreditation Program (NELAP)-accredited laboratory to conduct testing. The specific testing methodology is known as Total Organic Fluorine (TOF) testing, and measures the total amount of organically bound fluorine in a material by subtracting inorganic fluorine from total fluorine. This includes fluorine from known and unknown PFAS, precursor compounds, and other organofluorine substances. TOF is widely recognized as a conservative 1 City Council, June 9, 2025; Agenda Item #9, SR #2506-4816, https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16135 Item AA2
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and screening approach for evaluating the potential presence of fluorinated compounds associated with PFAS, particularly in complex materials such as synthetic turf.
On April 6, 2026 (Report No. 2604-6212) for the El Camino Park Turf Replacement Project (PG- 24000), the report indicated that the same turf product is proposed for installation at El Camino Park and that additional lot-specific testing will be conducted prior to installation to verify material composition.
ANALYSIS
Samples of the synthetic turf carpet fibers were quarantined from the specific product lots installed at the Mayfield site and shipped to an independent laboratory on December 18, 2025.
The samples were analyzed by Pace Analytical Services, a laboratory accredited by the National Environmental Laboratory Accreditation Program (NELAP), with oversight and data validation performed by Gradient Corporation. The analytical approach included measuring total fluorine using combustion ion chromatography and inorganic fluoride using Method 121, 4500F-BC, with the TOF concentration calculated as the difference between these two values.
The analytical results identified TOF concentrations of 8.7 milligrams per kilogram (ppm) for the primary sample and 11 milligrams per kilogram (ppm) for a duplicate sample. Inorganic fluoride was not detected in either sample, confirming that the measured fluorine was attributable to organic sources. The close agreement between the primary and duplicate samples demonstrates acceptable analytical precision and reliability. The measured TOF concentrations of 8.7 and 11 ppm are significantly below regulatory thresholds established for certain consumer products, including textiles and juvenile products such as crib mattresses and playmats. For example, California Assembly Bill 347 (2024) limits TOF to less than 100 ppm. As there are no PFAS standards specifically applicable to synthetic turf, this provides a meaningful benchmark and support the manufacturer’s disclosure that the product does not contain intentionally added PFAS.
A Level 2 data validation review concluded that there were no technical issues affecting the completeness, accuracy, sensitivity, or precision of the analytical results, providing a high level of confidence in the findings.
It is important to clarify that the laboratory testing did not yield “non-detect” as results for PFAS. Instead, it identified very low concentrations of TOF. The statement that “non-detect is not an established industry standard” reflects the absence of a universally accepted regulatory definition of the term “PFAS-free,” rather than any limitation in the reliability of the testing.
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FISCAL/RESOURCE IMPACT
No additional resources are required based on the actions in this report. All PFAS testing and associated activities, at a total cost of $9,546, were funded within the approved budget for the Stanford Palo Alto Community Playing Fields Turf Replacement Project (PG-26000).
STAKEHOLDER ENGAGEMENT
Information regarding PFAS and synthetic turf has been communicated through public City Council meetings, supplemental reports, and responses to community inquiries. Providing the final testing results as an attachment ensures continued transparency and helps maintain public trust.
ENVIRONMENTAL REVIEW
The Stanford Palo Alto Community Playing Fields Turf Replacement Project was determined to be categorically exempt from the California Environmental Quality Act (CEQA) under Guidelines Sections 15301 and 15302. This informational update does not constitute a project under CEQA and therefore requires no additional environmental review.
ATTACHMENTS
Attachment A: Mayfield Soccer Complex Total Organic Fluorine (TOF) Results APPROVED BY:
Kristen O'Kane, Community Services Director
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Field Turf_Mayfield_m022326m
One
Beacon Street
, 17
th
Floor, Boston, MA
02108
|
617
-
395
-
5000
|
www.gradientcorp.com
Memorandum
To: Sara Marinelli, Josh Robinson (FieldTurf) Date: February 23, 2026 From: Catalina Restrepo, Michael Peterson, and Kim Reid (Gradient)
Subject: Mayfield Soccer Complex Total Organic Fluorine (TOF) Results
Executive Summary
This memorandum summarizes the validated laboratory testing results of FieldTurf's product intended for installation at the Mayfield Soccer Complex in Palo Alto, California. This testing was conducted to verify FieldTurf's claim that their synthetic turf product "FTVTP2-RE3-39-PFF-FS-STND, does not contain any intentionally added per - and poly -fluoroalkyl substances (PFAS) in its formulation or manufacturing process" (see Appendix A). To determine if the product contain s intentionally added per- and polyfluoroalkyl substances (PFAS), laboratory testing was conducted at Pace Labs in Minnesota and Massachusetts. All laboratories involved in this testing are accredited by the National Environmental Laboratory Accreditation Program (NELAP).
Laboratory testing for PFAS compounds in synthetic turf products is difficult due to the complex matrix of the products as well as the wide variety of PFAS compounds that could potentially be present in construction materials. In addition, there are not validated commercially available methods to test for the types of fluoropolymers that historically may have been used in some synthetic turf fibers. Due to these issues, testing for total organic fluorine (TOF) was recommended for this project, as California legislation has suggested that the presence of organic fluorine is an indicator of possible intentionally added PFAS compounds in products. TOF testing has significant limitations in that it can overestimate the presence of PFAS compounds, but it was still deemed the best available method for the purposes of this project.
The TOF results for the two Mayfield Soccer Complex FieldTurf product samples were 8.7 and 11 parts per million (ppm), which are both below regulatory guidelines that have been promulgated for consumer products1 in California and other states (TOF content limit of 100 or 50 ppm ; see, e.g., California bill AB 347 [California, State Assembly, 2024]).
Sample Collection and Analysis
Samples of the FieldTurf product intended for installation at the Mayfield Soccer Complex were collected on 12/18/2025 by FieldTurf staff in accordance with the Sampling and Analysis Plan (SAP), which was developed by Gradient in collaboration with FieldTurf and Pace Labs. See Table 1 for a summary of the sample information. Although there are no validated analytical me thods specifically designed to test synthetic field turf materials, Gradient designed the SAP to include testing of the material in solid form.
1 These regulatory limits are not specifically relevant to synthetic turf, but provide useful guidelines for comparison. In ge neral, the limits are intended to determine whether or not a product might contain intentionally added PFAS compounds.
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Soccer Complex Total
Organic Fluorine (TOF)
Results
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2 Field Turf_Mayfield_m022326m
Determining TOF is a way of determining total PFAS levels in a sample; however, there currently are no validated methods available for testing for TOF in solid media or artificial field turf. Therefore, the samples first underwent cryomilling, followed by total fluorine analysis by combustion ion chromatography (CIC) and inorganic fluoride analysis by Method 121,4500F -BC. Then, we derived the TOF concentration in each sample by subtracting the inorganic fluoride results from the total fluorine results.
Table 1 FieldTurf Sample Information
Sample ID Product Name Product Description Date Collected Laboratory Report # Mayfield-1 Carpet retain Synthetic turf 12/18/2025 10760348 Mayfield-2
(duplicate)
Analytical Result Summary
Pace Labs reported the analysis results in laboratory report number 10760348 (see Appendix B). Duplicate samples were submitted to the laboratory for analysis according to the laboratory's corresponding standard operating procedure for each method.
Both samples Mayfield -1 and Mayfield -2 had detect ed levels of total fluorine (8.7 and 11 mg/kg, respectively) and non -detected levels of inorganic fluoride. Therefore, the calculated TOF is 8.7 and 11 mg/kg for samples Mayfield-1 and Mayfield-2, respectively. Table 2, below, summarizes the results of the analyses.
Data Validation
All the reported analytical data were validated according to the requirements listed in US EPA "Guidance on Environmental Data Verification and Data Validation " (US EPA, 2002) and the professional judgment of the reviewers. The laboratory provided a Level 2 analysis report; thus, raw data were not reviewed during the validation process. Table 2, below, presents a summary of the validated results for the Mayfield Soccer Complex FieldTurf sample analyses. In general, there was good agreement betwe en the primary and duplicate sample analyses performed across both methods, demonstrating that acceptable precision was achieved. Overall, no technical issues affecting the completeness, sensitivity, accuracy, or precision of the sample data were identifi ed during data validation. Appendix C contains the associated data validation report.
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Table 2 Summary of Validated Detected Results for Organic Fluorine Analyses of the Mayfield Soccer Complex FieldTurf Samples
Sample ID
TFa
(mg/kg)
IFb
(mg/kg) TOFc
(mg/kg) Result DV Qualifier RL Result DV Qualifierd RL
Mayfield-1 8.7 – 4 N/A – Result ND U 10 8.7
Mayfield-2 11 – 4 N/A – Result ND U 10 11
Notes:
CIC = Combustion Ion Chromatography; DV = Data Validation; IF = Inorganic Fluoride; N/A = Not Applicable; ND = Not Detected; RL = Reporting Limit; TF = Total Fluorine; TOF = Total Organic Fluorine.
DV Qualifier:
U = Not-detected.
(a) Solid media analysis. Extraction method: cryomilling. Analysis method: TF by CIC. (b) Solid media analysis. Extraction method: cryomilling. Analysis method: Method 121,4500F-BC. (c) Calculated as TF Concentration – IF Concentration. (d) Appendix C contains a full list of the DV qualifiers, including for detected and non-detected values.
Conclusion
PFAS are widespread in the environment and in commercial products. Historically, PFAS have been used as a processing aid during the production of synthetic turf products, which has led to concerns regarding potential exposures. In addition, s ome states have banned the sale of synthetic turf that contains PFAS.
This study provides investigation of the potential occurrence of intentionally added PFAS in product materials.
Because there is currently no analytical method for measuring TOF in solid media, we derived the TOF content of the samples by subtracting the concentration of inorganic fluoride from the concentration of total fluorine. The Mayfield -1 sample and its dupl icate sample (Mayfield-2) had detectable levels of total fluorine (8.7 and 11 mg/kg, respectively), and inorganic fluoride levels were non-detected in both samples.
Therefore, the calculated TOF concentrations are 8.7 and 11 mg/kg (equivalent to 8.7 and 1 1 ppm) for samples Mayfield-1 and Mayfield-2, respectively. These results are below all current regulatory standards for TOF. For example, California Proposition 65 settlements for PFAS generally specify that TOF content in textiles and other products should not exceed 100 ppm (0.01%) (see, e.g., BVCPS [2025]). California bill AB 347 limits TOF in textiles and juvenile products to less than 100 ppm (California, State Assembly, 2024). Vermont restricts TOF to less than 100 ppm in textiles, and will lower this value to 50 ppm in 2027 (Vermont, General Assembly, 2024).
Overall, these results are not indicative of the presence of intentionally added PFAS compounds in the tested FieldTurf product and support FieldTurf's claims (Appendix A).
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References
Bureau Veritas Consumer Products Services, Inc. (BVCPS). 2025. "California Proposition 65 Settlements." 25B-028. 1p., March.
California, State Assembly. 2024. "Assembly Bill No. 347: An act to amend Section 108945 of, to add Chapter 3 (commencing with Section 108075) to Part 3 of Division 104 of, to repeal the heading of Chapter 3 of Part 3 of Division 104 of, and to repeal Arti cle 7 (commencing with Section 108087) of Chapter 3 of Part 3 of Division 104 of, the Health and Safety Code, relating to consumer protection." AB 347. 6p., September 29.
US EPA. 2002. "Guidance on Environmental Data Verification and Data Validation (Final)." Office of Environmental Information. EPA/240/R-02/004, EPA QA/G-8, 95p., November.
Vermont, General Assembly. 2024. "An act relating to regulating consumer products containing perfluoroalkyl and polyfluoroalkyl substances or other chemicals." No. 131. 29p., May 30.
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Appendix A
FieldTurf Confirmation Letter
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FieldTurf
Tel (800) 724-2969
www.fieldturf.com
December 2, 2025
Ben Heistein
Assistant Director - Open Space, Parks, and Golf
Community Services Department
City of Palo Alto
Mayfield Soccer Complex
Subject: Confirmation of No Intentionally added PFAS
Mr. Heistein,
We are writing to confirm that our turf product, FTVTP2-RE3-39-PFF-FS-STND, does not contain any intentionally added per- and poly-fluoroalkyl substances (PFAS) in its formulation or manufacturing process.
At FieldTurf, we are committed to transparency, environmental stewardship, and the safety of the communities we serve. We remain vigilant in our materials selection and testing protocols to ensure our products meet the highest standards for health and environmental responsibility.
If you have any questions or would like to review the supporting documentation, please do not hesitate to contact us.
Sincerely,
Darren Gill
Executive Vice-President
[email protected]
(514) 375-2584
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Appendix B
Laboratory Report
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1(612)607-6351
The test results provided in this final report were generated by each of the following laboratories within the Pace Network:
Enclosed are the analytical results for sample(s) received by the laboratory on December 22, 2025. The results relate only to the samples included in this report. Results reported herein conform to the applicable TNI/NELAC Standards and the laboratory's Quality Manual, where applicable, unless otherwise noted in the body of the report.
Dear Catalina Restrepo:
RE:
Project:
223101 Field Turf (9) Mayfield
Pace Project No.:
10760348
Catalina Restrepo
Gradient Corporation
1 Beacon Street, 17th Floor
Boston, MA 02108
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Enclosures
Michael Peterson, Gradiant Corporation
Kim Reid, Gradient Corporation
cc:
January 14, 2026
Carolynne Trout
[email protected]
Project Manager
1700 Elm Street
Pace Analytical Services, LLC
Minneapolis, MN 55414
(612)607-1700
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC. 1 of 6
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Table of Contents
-2-
Section 1: Sample Summary ............................................................................................................. 3 Section 2: Chain of Custody .............................................................................................................. 4
2.1: Chain of Custody .................................................................................................................... 4 Sections:
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Lab ID
Sample ID
Matrix
Date Collected
Date Received
10760348001
Mayfield-1
Solid
12/18/25 02:02
12/22/25 10:15
10760348002
Mayfield-1
Solid
12/18/25 02:10
12/22/25 10:15
10760348003
Mayfield-2
Solid
12/18/25 02:18
12/22/25 10:15
10760348004
Mayfield-2
Solid
12/18/25 02:25
12/22/25 10:15
SAMPLE SUMMARY
1700 Elm Street
Pace Analytical Services, LLC
Minneapolis, MN 55414
(612)607-1700
Project:
223101 Field Turf (9) Mayfield
Pace Project No.:
10760348
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, LLC.
Date: 01/14/2026 04:30 PM
1 3 of 6
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39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Pace Analytical Services, LLC - East Longmeadow, Ma
January 9, 2026
Carolynne Trout
Pace Analytical Laboratory - MN
1700 Elm Street
Minneapolis, MN 55414
Project Location: 223101 Field Turf (task9)
Client Job Number:
Project Number: 10760348
Laboratory Work Order Number: 26A0197
Enclosed are results of analyses for samples as received by the laboratory on January 8, 2026. If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Rebecca Faust
Project Manager
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Table of Contents
Sample Summary 3
Case Narrative 4
Sample Results 5
26A0197-01 5
26A0197-02 6
Sample Preparation Information 7
QC Data 8
Fluorine by Combustion Ion Chromatography (CIC) 8
B420497 8
Flag/Qualifier Summary 9
Certifications 10
Chain of Custody/Sample Receipt 11
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ANALYTICAL SUMMARY
1/9/2026
Pace Analytical Laboratory - MN
1700 Elm Street
Minneapolis, MN 55414
ATTN: Carolynne Trout
10760348
26A0197
The results of analyses performed on the following samples submitted to Pace Analytical Services, LLC - East Longmeadow, Ma, are found in this report.
PROJECT LOCATION:
PURCHASE ORDER NUMBER:
PROJECT NUMBER:
REPORT DATE:
WORK ORDER NUMBER:
FIELD SAMPLE # LAB ID: MATRIX TESTSAMPLE DESCRIPTION SUB LAB 223101 Field Turf (task9)
10760348
Mayfield-1 26A0197-01 Product/Solid Total Fluorine by CIC Mayfield-2 26A0197-02 Product/Solid Total Fluorine by CIC [TOC_1]Sample Summary[TOC]
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CASE NARRATIVE SUMMARY
All reported results are within defined laboratory quality control objectives unless listed below or otherwise qualified in this report. [TOC_1]Case Narrative[TOC]
The results of analyses reported only relate to samples submitted to Pace Analytical Services, LLC - East Longmeadow, Ma, for testing.
I certify that the analyses listed above, unless specifically listed as subcontracted, if any, were performed under my direction according to the approved methodologies listed in this document, and that based upon my inquiry of those individuals immediately responsible for obtaining the information, the material contained in this report is, to the best of my knowledge and belief, accurate and complete.
Lisa A. Worthington
Technical Representative
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Date Received: 1/8/2026
Work Order: 26A0197Sample Description:Project Location: 223101 Field Turf (task9) Sample ID: 26A0197-01
Field Sample #: Mayfield-1
Sample Matrix: Product/Solid
Sampled: 12/18/2025 02:02
[TOC_2]26A0197-01[TOC]
AnalystAnalyzedDilution Flag/QualRLResultsAnalyte
Date/Time
Units
Date
PreparedMethod
Fluorine by Combustion Ion Chromatography (CIC)
8.7 4.0 1/8/26 20:20 MMHmg/Kg 1/8/26Total Fluorine by CIC1Total Fluorine (TF) [TOC_1]Sample Results[TOC]
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Date Received: 1/8/2026
Work Order: 26A0197Sample Description:Project Location: 223101 Field Turf (task9) Sample ID: 26A0197-02
Field Sample #: Mayfield-2
Sample Matrix: Product/Solid
Sampled: 12/18/2025 02:18
[TOC_2]26A0197-02[TOC]
AnalystAnalyzedDilution Flag/QualRLResultsAnalyte
Date/Time
Units
Date
PreparedMethod
Fluorine by Combustion Ion Chromatography (CIC)
11 4.0 1/8/26 20:41 MMHmg/Kg 1/8/26Total Fluorine by CIC1Total Fluorine (TF) Item AA2
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Sample Extraction Data
Prep Method:EPA 1621 (TF) Analytical Method:Total Fluorine by CIC Lab Number [Field ID] Batch DateInitial [mg] Final [Boat] B420497 01/08/2650.6 1.0026A0197-01 [Mayfield-1]
B420497 01/08/2650.5 1.0026A0197-02 [Mayfield-2]
[TOC_1]Sample Preparation Information[TOC]
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Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Limit Notes Analyte
Fluorine by Combustion Ion Chromatography (CIC) - Quality Control
QUALITY CONTROL
[TOC_2]Fluorine by Combustion Ion Chromatography (CIC)[TOC] Batch B420497 - EPA 1621 (TF)
[TOC_3]B420497[TOC]
Blank (B420497-BLK1) Prepared & Analyzed: 01/08/26
Total Fluorine (TF) mg/Kg4.0ND
LCS (B420497-BS1) Prepared & Analyzed: 01/08/26
Total Fluorine (TF) mg/Kg3.9 36.84 70-13093.134.3
LCS (B420497-BS2) Prepared & Analyzed: 01/08/26
Total Fluorine (TF) mg/Kg3.9 36.55 70-13010337.7
LCS (B420497-BS3) Prepared & Analyzed: 01/08/26
Total Fluorine (TF) mg/Kg3.9 36.62 70-13010337.6
LCS Dup (B420497-BSD1) Prepared & Analyzed: 01/08/26
Total Fluorine (TF) mg/Kg3.9 36.13 70-130101 6.3536.5
[TOC_1]QC Data[TOC]
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FLAG/QUALIFIER SUMMARY
* QC result is outside of established limits.
Wide recovery limits established for difficult compound. Wide RPD limits established for difficult compound.
# Data exceeded client recommended or regulatory level
Percent recoveries and relative percent differences (RPDs) are determined by the software using values in the calculation which have not been rounded.
No results have been blank subtracted unless specified in the case narrative section.
RL Reporting Limit is at the level of quantitation (LOQ) DL Detection Limit is the lower limit of detection determined by the MDL study MCL Maximum Contaminant Level
ND Not Detected
[TOC_1]Flag/Qualifier Summary[TOC]
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CertificationsAnalyte
CERTIFICATIONS
Certified Analyses included in this Report
No certified Analyses included in this Report
[TOC_1]Certifications[TOC]
Pace Analytical Services, LLC - East Longmeadow, Ma, operates under the following certifications and accreditations:
Code Description Number Expires
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L2601022
Pace Analytical Minnesota
10760348
223101 FIELD TURF (TASK 9)
Client:
Project Name:
Project Number:
01/14/26
Eight Walkup Drive, Westborough, MA 01581-1019
Lab Number:
Report Date:
508-898-9220 (Fax) 508-898-9193 800-624-9220 - www.alphalab.com 1700 Elm Street
Minneapolis, MN 55414
Carolynne TroutATTN:
ANALYTICAL REPORT
(612) 607-6351Phone:
The original project report/data package is held by Pace Analytical Services. This report/data package is paginated and should be reproduced only in its entirety. Pace Analytical Services holds no responsibility for results and/or data that are not consistent with the original.
Certifications & Approvals: MA (M-MA086), NH NELAP (2064), CT (PH-0826), IL (200077), IN (C-MA-03), KY (KY98045), ME (MA00086), MD (348), NJ (MA935), NY (11148), NC (25700/666), OR (MA-1316), PA (68-03671), RI (LAO00065), TX (T104704476), VT (VT-0935), VA (460195), USDA (Permit #525-23-122-91930A1).
Serial_No:01142612:02
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L2601022-01
L2601022-02
Lab
Sample ID
MAYFIELD-1
MAYFIELD-2
Client ID
MN
MN
Sample
Location
223101 FIELD TURF (TASK 9)
10760348
Project Name:
Project Number:
Lab Number:
Report Date:
L2601022
01/14/26
12/18/25 14:02
12/18/25 14:18
Collection
Date/TimeMatrix Receive Date
SOLID
SOLID
01/08/26
01/08/26
Serial_No:01142612:02
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Project Name:
Project Number:
Lab Number:
Report Date:
L2601022
01/14/26
Case Narrative
The samples were received in accordance with the Chain of Custody and no significant deviations were encountered during the preparation or analysis unless otherwise noted. Sample Receipt, Container Information, and the Chain of Custody are located at the back of the report.
Results contained within this report relate only to the samples submitted under this Pace Lab Number and meet NELAP requirements for all NELAP accredited parameters unless otherwise noted in the following narrative. The data presented in this report is organized by parameter (i.e. VOC, SVOC, etc.). Sample specific Quality Control data (i.e. Surrogate Spike Recovery) is reported at the end of the target analyte list for each individual sample, followed by the Laboratory Batch Quality Control at the end of each parameter. Tentatively Identified Compounds (TICs), if requested, are reported for compounds identified to be present and are not part of the method/program Target Compound List, even if only a subset of the TCL are being reported. If a sample was re-analyzed or re-extracted due to a required quality control corrective action and if both sets of data are reported, the Laboratory ID of the re-analysis or re-extraction is designated with an "R" or "RE", respectively.
When multiple Batch Quality Control elements are reported (e.g. more than one LCS), the associated samples for each element are noted in the grey shaded header line of each data table. Any Laboratory Batch, Sample Specific % recovery or RPD value that is outside the listed Acceptance Criteria is bolded in the report. In reference to questions H (CAM) or 4 (RCP) when "NO" is checked, the performance criteria for CAM and RCP methods allow for some quality control failures to occur and still be within method compliance. In these instances, the specific failure is not narrated but noted in the associated QC Outlier Summary Report, located directly after the Case Narrative. QC information is also incorporated in the Data Usability Assessment table (Format 11) of our Data Merger tool, where it can be reviewed in conjunction with the sample result, associated regulatory criteria and any associated data usability implications.
Soil/sediments and solids are reported on a dry weight basis unless otherwise noted. Tissues are reported "as received" or on a wet weight basis, unless otherwise noted. Definitions of all data qualifiers and acronyms used in this report are provided in the Glossary located at the back of the report.
HOLD POLICY - For samples submitted on hold, Pace's policy is to hold samples (with the exception of Air canisters) free of charge for 21 calendar days from the date the project is completed. After 21 calendar days, we will dispose of all samples submitted including those put on hold unless you have contacted your Pace Project Manager and made arrangements for Pace to continue to hold the samples. Air canisters will be disposed after 3 business days from the date the project is completed.
Please contact Project Management at 800-624-9220 with any questions.
Serial_No:01142612:02