From: marilynstocker
To: Council, City
Subject: 4103 Old Trace Road
Date: Tuesday, May 12, 2026 9:31:21 AM
Attachments: Denial request for 4103 Old Trace.docx
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Request to disapprove the tentative map for the subdivision at 4103 Old Trace Road The proposal to build 9 houses plus 7 jadus at 4103 Old Trace Road will create a dangerous vehicular “bottleneck” at the intersection of Old Trace Road and Arastradero.
This intersection is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility due to shadows created by shady trees on Arastradero and road curvature, to see cars and e- bikes that travel east at 35 mile an hour or more. The developer claims that the road that bisects the proposed development will give another egress, however that narrow road would be inadequate to accommodate their 32 cars plus the 58 or more from residents of the existing 3 dead end streets (Old Trace Road, Old Trace Court and Mockingbird lane) in an evacuation. The height of the proposed 2 story houses, their fences and plantings that back onto Arastradero will further interfere with visibility.
The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility at the intersection of Old Trace Road and Mockingbird Lane. As it is, the curvature of Old Trace Road south of Mockingbird Lane impedes visibility without additional parked cars.
We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes, and for children to bike safely.
We are not on a bus route that serves Palo Alto, and adjacent towns. This 2 lane section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle Powered by Mimecast
School, and Bowman private school during the week and for 2 synagogues and 2 churches on Saturdays and Sundays.
This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 VMWare employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents of the above mentioned 3 streets, to safely exit or enter Old Trace Road. This campus, now under new ownership is in the process of revitalizing buildings for future increased use.
Marilyn Stocker, 880 Mockingbird Bird Lane
Request to disapprove the tentative map for the subdivision at 4103 Old Trace Road
The proposal to build 9 houses plus 7 jadus at 4103 Old Trace Road will create a dangerous vehicular “bottleneck” at the intersection of Old Trace Road and Arastradero.
This intersection is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility due to shadows created by shady trees on Arastradero and road curvature, to see cars and e- bikes that travel east at 35 mile an hour or more. The developer claims that the road that bisects the proposed development will give another egress, however that narrow road would be inadequate to accommodate their 32 cars plus the 58 or more from residents of the existing 3 dead end streets (Old Trace Road, Old Trace Court and Mockingbird lane) in an evacuation. The height of the proposed 2 story houses, their fences and plantings that back onto Arastradero will further interfere with visibility.
The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility at the intersection of Old Trace Road and Mockingbird Lane. As it is, the curvature of Old Trace Road south of Mockingbird Lane impedes visibility without additional parked cars.
We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes, and for children to bike safely.
We are not on a bus route that serves Palo Alto, and adjacent towns. This 2 lane section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle School, and Bowman private school during the week and for 2 synagogues and 2 churches on Saturdays and Sundays.
This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 VMWare employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents of the above mentioned 3 streets, to safely exit or enter Old Trace Road. This campus, now under new ownership is in the process of revitalizing buildings for future increased use.
Marilyn Stocker, 880 Mockingbird Bird Lane
Request to disapprove the tentative map for the subdivision at 4103 Old Trace Road
The proposal to build 9 houses plus 7 jadus at 4103 Old Trace Road will create a dangerous vehicular “bottleneck” at the intersection of Old Trace Road and Arastradero.
This intersection is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility due to shadows created by shady trees on Arastradero and road curvature, to see cars and e- bikes that travel east at 35 mile an hour or more. The developer claims that the road that bisects the proposed development will give another egress, however that narrow road would be inadequate to accommodate their 32 cars plus the 58 or more from residents of the existing 3 dead end streets (Old Trace Road, Old Trace Court and Mockingbird lane) in an evacuation. The height of the proposed 2 story houses, their fences and plantings that back onto Arastradero will further interfere with visibility.
The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility at the intersection of Old Trace Road and Mockingbird Lane. As it is, the curvature of Old Trace Road south of Mockingbird Lane impedes visibility without additional parked cars.
We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes, and for children to bike safely.
We are not on a bus route that serves Palo Alto, and adjacent towns. This 2 lane section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle School, and Bowman private school during the week and for 2 synagogues and 2 churches on Saturdays and Sundays.
This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 VMWare employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents of the above mentioned 3 streets, to safely exit or enter Old Trace Road. This campus, now under new ownership is in the process of revitalizing buildings for future increased use.
Marilyn Stocker, 880 Mockingbird Bird Lane
The intersection of Old Trace Road and Arastradero, the site of the proposed development, is the only exit for the residents of 3 dead end streets: Old Trace Road, Old Trace Court and Mockingbird Lane. It is a busy intersection with poor visibility of on-coming cars and e-bikes that travel east at 35 mile an hour or more.
The plan for 9-2 story dwellings, plus adus, plus an internal roadway provides inadequate parking. The excess cars will be forced to park on the narrow streets of Old Trace Road and Mockingbird Lane, decreasing visibility even more. Since there are no sidewalks in the neighborhood, we must walk or run on the street for daily exercise, for visiting our neighbors, for walking our dogs.
We know from past experience, that cars parked on Old Trace Road, and Mockingbird Lane made it unsafe for residents to walk, for emergency vehicles to turn into Mockingbird Lane, for disabled residents to be picked up from their homes.
We are not on a bus route that serves Palo Alto, and adjacent towns. It takes 20-30 minutes to walk to El Camino to catch a bus. This section of Arastradero is the main car, bike and walking route for Palo Alto and Los Altos Hills students in the Palo Alto school district, who attend Gunn High School, Fletcher Middle School, and Bowman private school during the week and for 2 synagogues and 2 churches on Saturdays and Sundays.
This proposed development faces the large campus on Stanford Industrial Park land, which prior to the pandemic had 4000 employees, many who used Arastradero linking Foothill Expressway and 280. During peak commuting hours it was difficult for residents to safely exit or enter Old Trace Road.
From: Jeannie Clancy
To: Templeton, Cari; Bryna Chang; [email protected]; To: Comm"r Ji; Allen Akin; To: Chair Akin; To: Comm"r Peterson; Cha, Kelly; Stone, Greer; Stone, Greer; Veenker, Vicki; Veenker, Vicki; Reckdahl, Keith; [email protected]; Armer, Jennifer; Council, City; Lauing, Ed; Lu, George; Burt, Patrick; Lythcott-Haims, Julie; Reckdahl, Keith
Subject: Request to Pull Item [25PLN-00298] (4103 Old Trace Road Tentative Map) from Consent Calendar Date: Friday, May 15, 2026 3:37:26 PM
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Dear Mayor and Members of the Palo Alto City Council,
I am writing to formally request that the Consent Calendar item regarding 4103 Old Trace Road [25PLN-00298] (Tentative Map for a 9-lot subdivision, 9 single-family residences, and 7 JADUs) be pulled and placed on the regular agenda on May 18, 2026 for full public discussion and a separate vote.
Substantial new information and unresolved critical safety issues emerged during the Planning and Transportation Commission (PTC) meeting that demand council scrutiny and public transparency:
1. At the PTC meeting, the City Planner explicitly acknowledged that fire danger was not evaluated beyond the immediate boundaries of the project lot. This lot is located within city and county fire protection management areas. Neighborhood fire mitigation is required annually.
The project site sits at the intersection of Old Trace Road, which dead- ends at a 21-acre park, and Arastradero Road, a critical east-west evacuation route. Multiplying neighborhood density at this specific bottleneck creates an extreme safety hazard.
2. The applicant is seeking a waiver to reduce the required 32-foot- wide private road to just 20 feet. This substandard road will prevent emergency vehicles from turning into the development. To fix this, the PTC recommended painting "no parking" red curbs on Old Trace Road near the development entrance. Eliminating on street parking spaces near the development will force cars to be parked further up Old Trace Road which prevents emergency access to my house and puts more people on a street without pedestrian infrastructure like sidewalks. City Council must deny a waiver preventing emergency access.
3. A mandatory 53-foot special setback applies to 200 feet of the proposed development property line to protect the environmentally sensitive areas around Barron Creek and its tributaries. A similar setback is found on Oakhill Avenue just to the east of this lot. This is not a zoning setback and all the neighboring properties comply with it. This This message needs your attention
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critical environmental protection was never discussed, analyzed, or fully explained to the public.
4. Pursuant to PAMC Chapter 18.10, the RE district allows a baseline maximum of two primary units per parcel, not 7. Applying maximum bonus density multipliers to this base zoning establishes an absolute, legally unyielding limit of three primary units for this parcel. The RE district is explicitly codified to protect and dictate "very low-density" residential use. It is legally distinct from standard single-family residential zones (R-1) or any sub-categories thereof, which are governed by a completely separate chapter of the municipal code.
Because three Councilmembers must agree to pull an item from the Consent Calendar, I urge you to act in the interest of neighborhood safety, environmental protection, and due process by moving this item to the regular agenda.
Thank you for your time and your dedication to the safety of Palo Alto residents.
Sincerely,
Jeannie Clancy
4146 Old Trace Road
--
Jeannie Clancy
970-261-5527
From: James Lloyd
To: Burt, Patrick; Lauing, Ed; Lu, George; Lythcott-Haims, Julie; Reckdahl, Keith; Stone, Greer; Veenker, Vicki; Council, City
Cc: Clerk, City; City Attorney; City Mgr; PlannerOnDuty Subject: public comment re item 12 for the 5/18/26 Council meeting Date: Thursday, May 14, 2026 11:36:21 AM
Attachments: Palo Alto - 4103 Old Trace Road - HAA Letter - CC.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.
Dear Palo Alto City Council,
The California Housing Defense Fund (CalHDF) submits the attached public comment in support of item 12 for the 5/18/26 Council meeting, the proposed 16-unit housing development project at 4103 Old Trace Road, which includes one unit affordable to moderate- income households.
Sincerely,
James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
[email protected]
CalHDF is grant & donation funded
Donate today - https://calhdf.org/donate/
May 14, 2026 City of Palo Alto
250
Hamilton
Avenue
Palo Alto, CA 94301 Re: Proposed Housing Development Project at 4103 Old Trace Road By email: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Cc: [email protected]; [email protected]; [email protected]; [email protected]; Dear Palo Alto City Council, The California Housing Defense Fund (CalHDF) submits this letter to remind the City of its obligation
to
abide
by
all
relevant
state
laws
when
evaluating
the
proposed
16-unit
housing
development
project
at
4103
Old
Trace
Road,
which
includes
one
unit
affordable
to
moderate-income
households.
These
laws
include
the
Housing
Accountability
Act
(HAA),
the
Density
Bonus
Law
(DBL),
and
AB
130.
The HAA provides the project legal protections. It requires approval of zoning and general plan
compliant
housing
development
projects
unless
findings
can
be
made
regarding
specific,
objective,
written
health
and
safety
hazards.
(Gov.
Code,
§
65589.5,
subds.
(d),
(j).)
The
HAA
also
bars
cities
from
imposing
conditions
on
the
approval
of
such
projects
that
would
render
the
project
infeasible
(
id
.
at
subd.
(d))
or
reduce
the
project’s
density
(
id
.
at
subd.
(j))
unless,
again,
such
written
findings
are
made.
As
a
development
with
at
least
two-thirds
of
its
area
devoted
to
residential
uses,
the
project
falls
within
the
HAA’s
ambit,
and
it
complies
with
local
zoning
code
and
the
City’s
general
plan.
Increased
density,
concessions,
and
waivers
that
a
project
is
entitled
to
under
the
DBL
(Gov.
Code,
§
65915)
do
not
render
the
project
noncompliant
with
the
zoning
code
or
general
plan,
for
purposes
of
the
HAA
(Gov.
Code,
§
65589.5,
subd.
(j)(3)).
The
HAA’s
protections
therefore
apply,
and
the
City
may
not
reject
the
project
except
based
on
health
and
safety
standards,
as
outlined
above.
Furthermore,
if
the
City
rejects
the
project
or
impairs
its
feasibility,
it
must
conduct
“a
2201 Broadway, PH1, Oakland, CA 94612 www.calhdf.org
thorough analysis of the economic, social, and environmental effects of the action.” ( Id. at subd.
(b).)
CalHDF also writes to emphasize that the DBL offers the proposed development certain protections.
The
City
must
respect
these
protections.
In
addition
to
granting
the
increase
in
residential
units
allowed
by
the
DBL,
the
City
must
not
deny
the
project
the
proposed
waivers
and
concessions
with
respect
to
lot
size,
setback,
street
width,
and
site
depth.
If
the
City
wishes
to
deny
requested
waivers,
Government
Code
section
65915,
subdivision
(e)(1)
requires
findings
that
the
waivers
would
have
a
specific,
adverse
impact
upon
health
or
safety,
and
for
which
there
is
no
feasible
method
to
satisfactorily
mitigate
or
avoid
the
specific
adverse
impact.
If
the
City
wishes
to
deny
requested
concessions,
Government
Code
section
65915,
subdivision
(d)(1)
requires
findings
that
the
concessions
would
not
result
in
identifiable
and
actual
cost
reductions,
that
the
concessions
would
have
a
specific,
adverse
impact
on
public
health
or
safety,
or
that
the
concessions
are
contrary
to
state
or
federal
law.
The
City,
if
it
makes
any
such
findings,
bears
the
burden
of
proof.
(Gov.
Code,
§
65915,
subd.
(d)(4).)
Of
note,
the
DBL
specifically
allows
for
a
reduction
in
required
accessory
parking
in
addition
to
the
allowable
waivers
and
concessions.
(
Id
.
at
subd.
(p).)
Additionally,
the
California
Court
of
Appeal
has
ruled
that
when
an
applicant
has
requested
one
or
more
waivers
and/or
concessions
pursuant
to
the
DBL,
the
City
“may
not
apply
any
development
standard
that
would
physically
preclude
construction
of
that
project
as
designed,
even
if
the
building
includes
‘amenities’
beyond
the
bare
minimum
of
building
components.”
(
Bankers
Hill
150
v.
City
of
San
Diego
(2022)
74 Cal.App.5th
755,
775.)
Furthermore, the project is eligible for a statutory exemption from environmental review under
AB
130
(Pub.
Res.
Code,
§
21080.66).
Caselaw
from
the
California
Court
of
Appeal
affirms
that
local
governments
err,
and
may
be
sued,
when
they
improperly
refuse
to
grant
a
project
a
CEQA
exemption
or
streamlined
CEQA
review
to
which
it
is
entitled.
(
Hilltop
Group,
Inc.
v.
County
of
San
Dieg
o
(2024)
99 Cal.App.5th
890,
911.)
As you are well aware, California remains in the throes of a statewide crisis-level housing shortage.
New
housing
such
as
this
is
a
public
benefit:
it
will
provide
badly-needed
affordable
housing;
it
will
bring
new
customers
to
local
businesses;
it
will
increase
the
city’s
tax
revenue;
and
it
will
reduce
displacement
of
existing
residents
by
reducing
competition
for
existing
housing.
It
will
also
help
cut
down
on
transportation-related
greenhouse
gas
emissions
by
providing
housing
in
denser,
more
urban
areas,
as
opposed
to
farther-flung
regions
in
the
state
(and
out
of
state).
While
no
one
project
will
solve
the
statewide
housing
crisis,
the
proposed
development
is
a
step
in
the
right
direction.
CalHDF
urges
the
City
to
approve
it,
consistent
with
its
obligations
under
state
law.
CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased
access
to
housing
for
Californians
at
all
income
levels,
including
low-income
households. You may learn more about CalHDF at www.calhdf.org. 2 of 3
Sincerely, Dylan Casey CalHDF Executive Director James M. Lloyd CalHDF Director of Planning and Investigations 3 of 3
From: Heather Clancy
To: Council, City
Cc: Kandikuppa, Nishita
Subject: 4103 Old Trace Rd.
Date: Wednesday, May 13, 2026 6:11:37 PM
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Dear council members,
As a resident of Old Trace Rd. I am concerned about the development plan being proposed.
This is not simply a matter of housing production; it is a matter of maintaining the integrity of adopted planning policies and ensuring fair and lawful treatment of existing residents. The subdivision map 25PLN-00298 is not compliant with California Government Code Section 66474(b)(d)(g). Help me understand why the applicant has not been required to correct their map.
-The City has clearly confirmed that the project site is located within the RE zoning district, which is intentionally designed and maintained as a low-density, large-lot residential area with a base unit density of 2.
-The land use policy for this area policy L1.2 states that undeveloped land west of Foothill Expressway is retained as open space, with allowances made for very low intensity development consistent with the open space character of the area. -The site has a recorded special set back of 53’ along Arastradero. For 50 years this has been enforced by the city.
The proposed subdivision creates parcels that are noncompliant with RE zoning. Approval of such a map would directly conflict with state law, which mandates consistency between subdivision design and local land use regulations. If lot sizes violate RE zoning → map must be denied.
The committee members expressed opinions at the meeting held on March 5 and April 29, 2026, that “This development as proposed is incompatible with this location”.
Yet no substantial modifications have been required to bring the subdivision of this 1 acre lot into alignment with applicable laws and policies. The county and City has both the authority and the obligation to enforce its zoning code and uphold the planning framework that residents rely upon.
Even under California’s pro-housing laws:-The City is not required to approve a project that rewrites its zoning code through a subdivision map.-If a project fails objective standards or legal prerequisites, the City can deny, condition, or require redesign.-State housing laws (SB 330, HAA, Density Bonus, SB 130) all share a core rule: They protect compliant projects—not noncompliant projects.
Please consider denying the application as is. This lot can provide much needed housing without changing the landscape per se. Stuffing This message needs your attention
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this lot will create potentially 44 very frustrated residents in this peaceful neighborhood. The applicant brings 1 small unit for moderate income housing. This parcel can provide 1 unit moderate income housing with a simple legal lot split.
Thank you for your time and consideration of this matter, Heather Clancy
From: E Pirrotta
To: Council, City
Subject: Comments on 4103 Old Trace Road development plan Date: Wednesday, May 13, 2026 10:30:30 AM
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To the Palo Alto City Council
I urge you to approve the tentative map to allow the subdivision of 4103 Old Trace Road. The proposed development is an excellent use of the land and is a good solution for improving affordable housing options.
Please ensure that the plan for these proposed homes maintain deed-restricted household income levels.
Thank you
Elizabeth Pirrotta