The application contains clear errors in right-of-way calculations and setbacks that materially affect the feasibility and legality of the project. The distance to the creek is misstated as 200 feet when it is, in fact, 145 feet. In addition, the plans appear to misapply the roadway centerline as defined in the Palo Alto Road Centerline Data Map, where the center of the median establishes the correct reference point. When the proper 45-foot setback is measured from the true centerline, the encroachment into the property is approximately 23 feet—not the 13 feet represented in the application. This is not a minor discrepancy; it fundamentally undermines the site design, placing required setbacks within the proposed building footprint of Lot 5B. The plans, as submitted, are therefore materially misleading.
The proposal also fails to comply with the 53-foot special setback required along Arastradero Road, a designated scenic corridor. Four of the eight proposed homes are located within this protected setback area. The City’s Bonus Density provisions do not override these requirements under Section 20.08.020.
These protections exist to preserve the character, safety, and environmental integrity of the corridor and have been consistently enforced on neighboring properties. There is no justification for waiving them in this case.
Equally concerning are the public safety implications. Arastradero Road, west of Foothill Expressway, is a critical evacuation route for residents of Palo Alto and Los Altos Hills. Any development that compromises its function raises serious safety concerns. Internally, the project proposes a private roadway that is only 20 feet wide—far below the required 32 feet. This is inadequate for a subdivision of 5+ homes with driveway cuts of 16 feet instead of 20 feet. Safe two-way traffic and maneuvering will be nearly impossible during waste collection times, mail delivery or package drop off. The traf fic study
calculated 70 new trips a day for this development, which means during morning and evening commute times, any blockage along the short private road will cause cars to start backing up not on a side street but on the already congested Arastradero Road.
The biggest safety impact for this development will be the new access point onto Arastradero. Adding a new intersection so close to Old Trace Road will put kids riding their bikes to school in serious danger because it adds more turning movements and unpredictability to an already busy road. It creates an avoidable and unacceptable safety hazard.
While the need for housing is real, State housing laws do not exempt projects from complying with the Subdivision Map Act or from meeting basic health and safety standards. This proposal fails on both counts and is inconsistent with the City’s General Plan. Policy L-1.2 Retain undeveloped land west of Foothill Expressway and Junipero Serra as open space, with allowances made for very low-intensity development consistent with the open space character of the area.
Finally, the proposal to allocate only 4% (approximately 1,900 square feet) of a 44,449-square-foot site to below-market-rate housing is grossly disproportionate to the scale of concessions and waivers requested.
The public benefit does not justify the significant deviations from established standards. Additionally, consistent information throughout the submitted plans would be extremely helpful. As is, it’s impossible to know the exact plans. Perhaps that’s the intent.
For all of these reasons, I urge the City Council to deny this project in its current form. At a minimum, the applicant must be required to correct these errors and fully comply with all applicable regulations before any consideration of approval.
Thank you for your time and attention to this matter.
Sincerely,
Katherine Clancy
4146 Old Trace Road Palo Alto, CA 94306
Jeannie Clancy
4/16/26, 4:34 PM Re: 4103 Old Trace Road - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane6 2/2
goals. I have copied the lead planner for the SCPO update on this email to raise awareness of this apparent inconsistency.
I look forward to your clarification on how the City intends to resolve this contradiction.
Best regards,
Jeff Watt (resident, Esther Clark Park neighborhood)
4/20/26, 6:01 PM CEQA exemption (AB 130) for 4103 Old Trace Road - Kandikuppa, Nishita - Outlook about:blank?windowId=SecondaryReadingPane18 2/2
additional "road", which would allow for some increased density without creating such an anomaly in the neighborhood.
Gaile Gordon
Palo Alto resident on Manuela Ave.
5/1/26, 1:36 PM Mail - Kandikuppa, Nishita - Outlook
https://outlook.office.com/mail/inbox/id/AAQkADVmNWM1NDcyLWQ5YzYtNGI5OS05YmZkLTk0MjdlMmI5OWIwMQAQADl2dddcjzJNvIkGv1bJD%2B… 2/2