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
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.
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))
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.
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)
• 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)
• 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.
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.
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
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
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:
(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.
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