City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: April 20, 2026
Report #:2601-5873
TITLE
Quasi-Judicial: Adoption of a Resolution Documenting the City Council’s Consideration and Decision on an Appeal of the Chief Building Official’s Order to Demolish the Buildings Located at 531 Stanford Avenue.
RECOMMENDATION
Staff recommend that the City Council Adopt a resolution denying the appeal and upholding the Chief Building Official's Order to Demolish the buildings on the subject property based on findings and conditions set forth in Attachment A.
EXECUTIVE SUMMARY
The property located at 531 Stanford Avenue consists of multiple structures that have been determined by the City Chief Building Official to be dangerous and unsafe, constituting public nuisances that pose substantial danger to health, safety, and general welfare. The buildings were originally permitted as R-1 occupancy (hotel) but were being operated as R-2 occupancy (residential apartments) without authorization.
The enforcement history began on March 18, 2024, when City inspectors discovered numerous life-safety violations during an inspection. On March 21, 2024, the City issued a Notice of Violation identifying critical deficiencies including dilapidated fire sprinkler and alarm systems, lack of fire watch services, blocked egress routes, unpermitted construction, structural concerns, hazardous material storage issues, and numerous building code violations.
Following the initial Notice of Violation, the property owner took some remedial actions to respond to the notice of violation. However, the underlying structural, fire safety, and code compliance issues remained unresolved. On April 2, 2024, Chief Building Official issued an Emergency Notice to Repair or Abate, and on April 9, 2024, the building was red tagged as unsafe for occupancy.
After comprehensive assessment and determination that the structures could not be feasibly repaired to meet code requirements, the Chief Building Official issued a Notice and Order to Demolish on October 17, 2025. The Order was based on findings that the structures were fifty
percent or more damaged, decayed, or deteriorated, constituted fire hazards, and could not be repaired to eliminate code violations.
On November 13, 2025, Stanford Orion filed a timely appeal raising four primary contentions:
(1) improper service; (2) failure to meet the demolition threshold; (3) unlawful deconstruction requirement; and (4) unreasonable timeline.
This staff report outlines the actions taken by the Chief Building Official, the legal authority under which those actions were exercised and the substantial evidence supporting the determination that the structures meet the criteria for mandatory demolition. Staff recommends that the City Council deny the appeal and uphold the Order to Demolish.
BACKGROUND
On March 18, 2024, City of Palo Alto code enforcement officials conducted an inspection of the property located at 531 Stanford Avenue (Assessor Parcel Numbers 137-01-121, 137-01-002, and 137-01-003). The property consists of multiple buildings that were originally constructed and permitted for R-1 occupancy (hotel use) but were being operated as R-2 occupancy (residential apartments) without proper authorization or permits.
The March 18, 2024, inspection revealed numerous serious violations. These violations are documented in Attachment J (Declaration of George Hoyt, Chief Building Official) and Attachment L (Declaration of Tamara Jasso, Fire Marshal). On March 21, 2024, the City issued the first Notice of Violation (Attachment B) identifying critical deficiencies requiring immediate remedial action, including:
• Dilapidated Fire Sprinkler & Fire Alarm Systems.
• Unconfirmed Records of Testing for Fire Sprinklers & Fire Alarm Systems. • High Combustible Storage throughout all buildings.
• Improper hazmat storage - Created Corrosive Environments and Conditions. • Severely Corroded electrical and Plumbing systems.
• Combustible Storage in certain areas.
• Plastic film on ceilings in some units and in exit stairways. • Unpermitted remodeling of all units (Includes: Enclosing decks, patios, & roof coverings).
• Unpermitted Construction in Electrical (exposed & unsafe wiring)/ Mechanical/Plumbing/Structural (Unsafe) & Non-Structural. (Gazebo structures) • Potential failure of 2nd Floor exit balcony that appears to be shored for stability. • Dilapidated & Missing emergency exit Signage and emergency lighting. • Expired U&O (permitted for R-1, now being used as R-2) • Inoperable elevators (expired Certifications)
• Blocked Egress - Stanford Side and throughout buildings. • Non-functioning and missing egress exits and components. • Pool with visible mold underfloor/garage level, unhygienic Following issuance of the first Notice of Violation, the property owner took certain corrective actions to address immediate life-safety concerns. Fire watch services were implemented, tenants were evacuated from upper floors, and some hazardous conditions were remediated.
However, the underlying structural deficiencies, extensive unpermitted construction, and code violations remained unresolved. A second Notice of Violation (Attachment C) was issued on March 28, 2024, to set new compliance deadlines for the outstanding violations.
Subsequent Code Enforcement Action
Based on the extensive violations, Chief Building Official George Hoyt, issued an Emergency Notice to Repair or Abate on April 2, 2024 (Attachment D). On April 3, 2024, the City issued a third Notice of Violation (Attachment E) for outstanding code violations and issued two administrative citations for failure to comply with previous Notices of Violation. On April 9, 2024, the buildings were red tagged as unsafe for occupancy (Attachment D) and the City issued a fourth and final Notice of Violation (Attachment F).
PAMC Section 16.40.050(c) permits mandatory demolition when any one of three independent conditions exists. Meeting a single criterion is sufficient to require demolition. The three criteria are: (1) a dangerous building is fifty percent or more damaged, decayed, or deteriorated from replacement value or structure; (2) a building cannot be repaired so that it will no longer exist in violation of Chapter 16.40; or (3) a dangerous building is a fire hazard existing or erected in violation of applicable codes.
The Chief Building Official determined that the buildings met the mandatory demolition criteria established in PAMC Section 16.40.050, specifically finding that the buildings:
were fifty percent or more damaged, decayed, or deteriorated from replacement value or structure;
could not be repaired to eliminate violations of PAMC Chapter 16.40; and constituted fire hazards existing in violation of applicable codes.
While satisfaction of any single criterion would have been sufficient to require demolition, the finding that all three criteria are met provides additional support for the demolition order.
On October 16, 2025, the Chief Building Official issued a formal Notice and Order to Demolish the buildings in accordance with California Health and Safety Code Section 17980.6 and PAMC Chapter 16.40 (Attachment G).
On November 7, 2025, Stanford Orion, the property manager and owner representative sent a letter to the City outlining some concerns with the Notice and Order to Demolish (Attachment H). On November 13, 2025, Stanford Orion filed a written appeal of the Notice and Order to Demolish (Attachment I). The appeal was submitted through Stanford Orion’s attorneys, Patterson & O'Neill, PC, and raises four principal arguments: (1) improper service; (2) failure to meet demolition threshold; (3) unlawful deconstruction requirement; and (4) unreasonable timeline.
Pursuant to PAMC Section 16.40.080(f), the filing of the appeal has stayed enforcement of the Notice and Order during the pendency of the appeal.
Applicable Code Provisions and Required Findings
PAMC Chapter 16.40 establishes comprehensive regulations governing unsafe buildings. PAMC Section 16.40.050 establishes mandatory standards for repair, vacation, and demolition.
Demolition is mandatory when any one of three independent conditions exists: (1) a dangerous building is fifty percent damaged, decayed or deteriorated; (2) a building cannot be repaired to eliminate code violations; or (3) a dangerous building is a fire hazard in violation of applicable codes.
To render a decision on the appeal, the City Council shall consider the evidence presented and shall make written findings of fact, based upon the evidence, to support its decision pursuant to PAMC Section 16.40.080(e).
ANALYSIS
The Chief Building Official possesses clear authority to order demolition of dangerous buildings under California Health and Safety Code Section 17980.6 and PAMC Chapter 16.40. The buildings at 531 Stanford Avenue satisfy all three criteria, though meeting only one would be legally sufficient to require demolition.
The Declarations of Chief Building Official George Hoyt, Code Enforcement Manager Elisa Vargas and Fire Marshal Tamara Jasso (Attachments J, K and L, respectively) provide detailed expert analysis of the extent of damage, decay, and deterioration, explaining why the buildings exceed the fifty percent threshold and cannot be feasibly repaired and why these conditions constitute a fire hazard in violation of the California Fire Code and PAMC Title 15. These declarations are accompanied by photographic evidence that substantiates the dangerous conditions at the property (Attachment M).
City's Response to Objections Raised in Appeal Letter
Stanford Orion's appeal raises four objections: (1) improper service of the Notice and Order; (2) failure to meet the threshold for mandatory demolition; (3) unlawful requirement for deconstruction; and (4) unreasonable timeline for compliance. Staff have reviewed each objection and provides the following analysis demonstrating that the Chief Building Official's order was properly issued, is supported by substantial evidence, and complies with all applicable legal requirements. The appellant’s letter and appeal statement are provided in Attachments H and I.
Objection 1: Alleged Improper Notice
The appellant contends that the Notice and Order was not properly served because the City mailed it to the vacant building at 531 Stanford Avenue.
The Notice and Order was properly served in full compliance with PAMC Section 16.40.060. The City mailed the notice to the property address appearing on county tax records, which is expressly authorized by PAMC Section 16.40.060(d). The code specifies that failure to receive notice does not affect validity and service by certified mail is effective on the date of mailing.
Moreover, the appellant timely filed an appeal, demonstrating actual notice.
In addition to the certified mail service required by code, the City also provided courtesy email notification of the Notice and Order to the property owner and their previous legal counsel.
When Patterson & O'Neill subsequently informed the City that they had not received the email, staff offered a courtesy extension of time to respond to the Notice and Order. This accommodation provided the appellant with additional time beyond the code-required deadlines to review the order and prepare their response.
The Declaration of Code Enforcement Manager Elisa Vargas (Attachment K) supports the City’s position that the notice was issued in accordance with municipal regulations.
Objection 2: Challenge to Determination of Dangerous Conditions The appellant contends that violations do not establish that the building is fifty percent damaged, decayed or deteriorated from replacement value.
The appellant misunderstands the standards. PAMC Section 16.40.050(c) establishes three independent grounds for mandatory demolition, but only one standard must be satisfied to require demolition. The buildings meet all three criteria: (1) fifty percent or more damage based on comprehensive assessment of structural deficiencies, failed systems, and code violations; (2) cannot be repaired so that it will no longer exist in violation of Chapter 16.40; or (3) constitute fire hazards.
The declaration of the Chief Building Official (Attachment J) supports mandatory demolition of the buildings at 531 Stanford Avenue under the first criterion.
Based on a March 2024 inspection, ongoing monitoring, and professional expertise, the Chief Building Official determined that rehabilitation costs exceed fifty percent of replacement value.
This conclusion rests on the cumulative impact of failed and non-functional fire protection systems, systemically corroded electrical and plumbing infrastructure, structural failure requiring emergency shoring, extensive unpermitted construction whose hidden conditions cannot be assessed without demolition, and eighteen months of post-vacancy deterioration that worsened all pre-existing deficiencies. Taken together, the cost of full system replacement, structural reconstruction, unpermitted work remediation, and hazardous materials abatement exceeds the fifty percent threshold, satisfying the first demolition criterion.
The determination that the buildings cannot be repaired so that it will no longer exist in violation of PAMC Chapter 16.40 is supported by the scope and interconnected nature of the violations. Installing new fire protection systems would require demolition throughout the buildings to access concealed spaces for piping and wiring. Reconstructing the structurally failing exit balcony affects the building's egress system and fire-rated assemblies. Replacing corroded electrical and plumbing systems necessitates opening walls, ceilings, and floors throughout multiple buildings. Remediating the extensive unpermitted construction requires demolition to verify structural adequacy and code compliance. Providing code-compliant egress for the unauthorized R-2 occupancy requires reconfiguring building layouts. The scope of work necessary to eliminate all code violations constitutes reconstruction of the buildings rather than repair. The Declarations of Chief Building Official George Hoyt (Attachment J) and Fire Marshal Tami Jasso (Attachment L) explain why repair is not feasible, supported by photographic evidence (Attachment M).
Regarding the third criteria, the buildings constitute fire hazards through multiple code violations that remain unabated, including: dilapidated fire sprinkler and fire alarm systems ; high combustible storage creating excessive fire loads; improper hazardous materials storage; severely corroded and exposed electrical wiring creating ignition sources; blocked egress preventing safe evacuation; non-functioning fire-rated doors and assemblies compromising fire separation; and missing or dilapidated emergency exit signage and lighting preventing safe egress in emergencies. These fire hazards present imminent life-safety concerns and are detailed in the declarations of Chief Building Official George Hoyt (Attachment J) and Fire Marshal Tamara Jasso (Attachment L). The Declaration of Fire Marshal Tamara Jasso (Attachment L) provides expert fire protection engineering analysis of these hazards, supported by photographic evidence and inspection documentation showing the specific violations (Attachment M).
Objection 3: Request for Deconstruction Instead of Demolition The appellant argues that PAMC Section 5.24.080 exempts dangerous structures from deconstruction requirements.
Staff acknowledge the appellant is correct regarding the exemption. The property owner may choose standard demolition methods or voluntarily elect deconstruction but is not required to use deconstruction. Staff recommend that City Council’s findings reflect that deconstruction requirements are voluntary.
This does not provide grounds to reverse the demolition order. The exemption relates to methods of demolition, not the requirement to remove the structures.
Objection 4: Claims Regarding Timing and Other Issues
The appellant contends that the May 18, 2026 compliance deadline is unreasonable for three stated reasons: (1) the deadline requires removal during the wet season which can cause delays, increase costs, and create dangerous conditions; (2) essential public health and safety equipment is located on the building with no plan to address this equipment; and (3) the City has delayed approval of a post-demolition plan and the vacant property will continue to be a magnet for nuisance activities.
Inclement Weather Concerns
As an initial matter, the filing of the appeal on November 13, 2025, has stayed enforcement of the Notice and Order pursuant to PAMC § 16.40.080(f). The compliance deadlines are not currently in effect and will remain stayed until the City Council issues its decision.
If the City Council upholds the demolition order, new compliance deadlines will be established based on the date of the Council's decision. As noted in attached resolution (Attachment A), staff's recommendation includes a six-month timeframe from the Council's decision for complete removal of all structures. Six months is a reasonable timeframe based on standard industry practice for low-rise demolition projects, and includes permitting and regulatory approvals, hazardous material abatement, conventional excavator-based structural demolition, below-grade structure removal, debris hauling, and final site restoration.
The appellant's concern about demolition during wet season does not justify delaying the demolition requirement. The six-month timeframe provides flexibility for the property owner to schedule demolition work during favorable weather conditions within the compliance period.
Public Health and Safety Equipment
The appellant references "essential public health and safety equipment" located on the building, referring to wireless telecommunications equipment on the roof.
This claim does not provide grounds to reverse or delay the demolition order.
The appellant has not provided documentation establishing that the rooftop equipment is "essential" to public health and safety, provides unique coverage not available from other facilities, or that its removal would create a public safety gap. City staff requested such documentation prior to the appeal being filed, but it was not provided.
City staff consulted with emergency response personnel regarding wireless coverage in the area. The feedback did not identify any concerns that could not be mitigated through existing infrastructure or services. Removal of commercial wireless equipment from this building is not anticipated to compromise emergency communications.
Wireless carriers routinely relocate equipment when buildings are demolished. Standard telecommunications site leases contain provisions addressing lease termination and equipment removal. The appellant was asked to provide lease documentation but did not do so. The responsibility to maintain wireless coverage rests with the carriers, not with the property owner or City. Wireless carriers can seek alternative locations for equipment including other rooftop sites, tower facilities, and small cell installations. If equipment needs relocation, carriers can pursue permit applications for alternative sites through normal processes.
Housing Applications and Processing Concerns
The appellant contends that the City has delayed approval of development plans. This contention is not relevant to the validity of the City’s demolition order, which is based on the dangerous condition of the existing structures.
The appellant has expressed an interest in demolishing the buildings when a future housing development is ready to be constructed. Staff recommends against linking these two processes.
As explained above, these buildings constitute a public nuisance and present significant ongoing public safety hazards that cannot wait for uncertain future development approvals. The structures have been red tagged as unsafe since April 2024. They present risks of partial structural collapse (evidenced by the shored exit balcony), fire hazard (due to failed fire protection systems and code violations), potential for unauthorized occupancy in unsafe conditions, and environmental health hazards from mold and vermin. Each day these dangerous structures remain standing increases the cumulative risk to neighboring properties, the surrounding community, and any persons who might access the site. The City cannot subordinate its fundamental public safety obligations to speculative future development timelines.
Moreover, any future development approved for the site will necessarily require demolition of the existing unsafe buildings, the same outcome mandated by the current order. Delaying demolition to await development entitlements would simply prolong the period during which dangerous structures threaten public safety, without changing the ultimate need for their removal. The property owner can continue to pursue development applications while complying with the demolition order; these are not mutually exclusive processes. While the property owner is seeking efficiencies with respect to site preparation activities such as grading, this does not justify delay in abating the present public health and safety concerns.
Findings and Conditions
The attached resolution contains the detailed findings and conditions required for the City Council's decision on the appeal. The resolution includes eight findings supporting the denial of the appeal and upholding the demolition order: (1) the buildings constitute dangerous buildings under PAMC §§ 16.40.010 and 16.40.020; (2) the buildings meet all three independent mandatory demolition criteria under PAMC § 16.40.050(c) – though only one is required; (3) the Notice and Order was properly served and the Chief Building Official acted within his authority; (4) the determination is supported by substantial evidence in the administrative record; (5) the six-month timeline and conditions are reasonable and necessary; (6) the buildings qualify for exemption from mandatory deconstruction requirements under PAMC § 5.24.080(a)(3); (7) the appeal arguments do not provide sufficient grounds to reverse the Notice and Order to Demolish; and (8) complete demolition serves the public interest in protecting health, safety, and general welfare. The resolution also establishes five conditions of approval governing demolition timeline, site remediation, permit requirements, perimeter fencing, and ongoing site maintenance. If the City Council upholds the demolition order, staff recommend adoption of the attached resolution upholding the demolition order.
FISCAL/RESOURCE IMPACT
The recommendation does not result in significant fiscal or budgetary impacts to the City. Staff time is absorbed within existing departmental budgets.
STAKEHOLDER ENGAGEMENT
Pursuant to PAMC § 16.40.080(b), the Planning and Development Services Department provided written notice of the time and place of the City Council hearing to the appellant at least seven days prior to the hearing date. Notice was sent on April 9, 2026, by certified mail to the appellant at the address shown on the appeal.
Additionally, city staff have maintained frequent communication with the property owner representatives and legal counsel throughout the code enforcement process beginning March 21, 2024.
ENVIRONMENTAL REVIEW
The action is exempt from CEQA under two independent exemptions: (1) Emergency Projects Exemption (CEQA Guidelines Section 15269) - demolition is necessary to address imminent public health and safety threats; and (2) Common Sense Exemption (CEQA Guidelines Section 15061(b)(3)) - no possibility of significant environmental effect.
ATTACHMENTS
A. Draft Resolution Upholding Chief Building Official Notice to Demolish B. First Notice of Violation (March 21, 2024)
C. Second Notice of Violation (March 28, 2024)
D. Emergency Notice to Repair or Abate (April 2, 2024)
E. Third Notice of Violation (April 3, 2024)
F. Fourth Notice of Violation (April 9, 2024)
G. Notice and Order to Demolish (October 16, 2025)
H. Letter from Property Owner Representative (November 7, 2025) I. Appeal of Notice to Demolish (November 13, 2025)
J. Declaration of George Hoyt, Chief Building Official
K. Declaration of Elisa Vargas, Code Enforcement Manager L. Declaration of Tamara Jasso, Fire Marshal
M. Photographic Evidence of Code Violations at 531 Stanford Avenue APPROVED BY:
Jonathan Lait, Planning and Development Services Director