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
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 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 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) • 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) • 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.
I conducted a follow-up inspection on April 1, 2024, at 2:00 PM, confirmed the absence of fire watch coverage, and confirmed the absence of required fire watch logs for the period of March 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 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.
• 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 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.
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