August 10, 2026
Thomas G. Agramonte
[email protected]
Jessica Rose Agramonte
[email protected]
Palo Alto City Council
250 Hamilton Avenue
Palo Alto, CA 94301
Via email: [email protected]
Re: 470 Olive Avenue [25PLN-00228]:
Dear Mayor Veenker, Vice Mayor Stone, and City Councilmembers:
On behalf of the Agramonte Family, a four-generation Palo Alto family and landowners of 2951 El Camino Real (ECR) and 470 Olive Avenue, we are writing to respectfully request that the City Council adopt the Planning staff recommendation regarding 470 Olive Avenue to change the Zoning District from NV-R-1 to NV-MXM and the land use designation from NVCAP Low Density Residential to NVCAP Medium Density Mixed, and the site be added to the City’s Housing Element to allow for the appropriate development of high quality housing in Palo Alto.
The City Council’s May 27, 2027 hearing action was “to direct staff to return to Council with a proposal for Rezoning the property behind 2999 [El Camino Real] (470 Olive) from R1 to an appropriate transition for housing.” Consistent with staff’s analysis, we would like to provide additional contextual information supporting staff’s recommendation and address concerns expressed by some of the Planning Commissioners regarding daylight plane and respecting existing single-family homes per the NVCAP, and those expressed by the owner of 471 Pepper Avenue.
Existing Neighborhood & Zoning/LU Context
• 470 Olive is directly across from the 3001-3017 El Camino Real (Mike’s Bikes) 129-unit project which is zoned NV-MXM and designated NVCAP Medium Density and property lines align. See Attachment 1.
• There is an existing single-family home located east of the 3001 ECR project, similar context with the redevelopment of 470 Olive and adjacent ECR parcels. See Attachment 2. • 470 Olive’s approximately 19’ high building walls are located on the property lines abutting 471 Pepper Avenue and 456 Olive Avenue R-1 lots impacting the current daylight onto those single-family properties. See Attachment 3 showing the existing walls. • 456 Olive Avenue is currently under construction with a new 30’ high 2-story home including a 2320 SF house, attached 747 SF ADU, and a 224 SF garage. The owner was disclosed that a rezoning and multifamily development was proposed via the posted signage onsite. • The 471 Pepper Avenue home was completed and sold after the NVCAP process was well underway and the Auto Collision Repair at 2905 ECR was still in operation. • 470 Olive Avenue is located in a mixed-use area with multiple commercial businesses, consistent with the original commercial development of and CS zone designation of the property. • 470 Olive is within ½ mile of the California Avenue CalTrain Station.
SB 79 Transit Oriented Development Combining District Zoning • Since the July 8th Planning Commission hearing, the 470 Olive Avenue property has become eligible to use the City’s SB79 Alternative Transit Oriented Development Combining District Zoning and associated development standards. These standards are more generous (or less restrictive) than those under MXM and require a minimum 5-unit project.
• The 470 Olive Avenue property is 50 feet wide by 119.7 feet deep. Any subsequent development under TOD CD will be required to have a minimum 4-foot setback and adhere to a 45-degree daylight plane starting at 16 feet up along the northern and western sides of the property. Please see Attachment 4 depicting the overlapping impact of the daylight plane and setbacks on the 470 Olive parcel relative to the adjacent 471 Pepper and 456 Olive properties.
In summary, together with staff’s report and the physical and statutory context above, we believe that the proposed recommendation of MXM is the appropriate response to the City Council’s direction on May 27, 2025.
In addition, in response to Planning and Transportation Commission meeting on this rezoning application and certain comments, we would also like to document the timeline and details of the zoning history and our family’s now nine years of working collaboratively with the City of Palo Alto to create housing on this ideal location and support of staff’s recommendation to change the site’s zoning and land use designation.
Zoning History – Summary
This building on 2951 ECR and 470 Olive Avenue is a single building that spans both parcels that was originally zoned and operated as CS, but was rezoned, likely inadvertently, into two different zone designations in 1978 that changed 470 Olive Avenue to R1. A prior owner applied for an Exception from the Non-conforming Use Termination requirement, which was unanimously approved, however, they did not follow up on landscaping required for the approval and sold it as CS zoning without disclosing the zoning issues. It was built as a commercial building and always used as commercial, and office through multiple generations of owners, prior to it being sold to my family in 1993. My father ran his Veterinary practice there. Once we discovered the undisclosed zoning issue, we alerted the City Planning of it and have been working earnestly with the City of Palo Alto since 2017 to accommodate the city’s housing priorities in this ideal location, walking distance from transit. On the prescreening on October 2, 2017, some of the Council members posited that the 1978 rezoning of 470 Olive Avenue from CS to R-1 was likely done mistakenly. Approval of this application for rezoning of 470 Olive Avenue to realign it with 2951 ECR, both corrects this zoning while directly addressing the urgent need of providing viable multifamily housing development on this ideally located site, walking distance to Caltrans and Cal Ave.
470 Olive Avenue Zoning History:
• Based on City of Palo Alto documents, a review of historical aerials and permit history, 470 Olive Avenue is part of a two-parcel, single commercial building in Palo Alto, built and permitted for commercial use in 1968, the building spans both parcels: 2951 El Camino Real (APN# 132-37- 052) and 470 Olive Ave (APN# 132-37-029). 470 Olive Avenue has always been structurally and operationally linked to 2951 El Camino Real, sharing a single building built with a connecting doorway, and a single drive-through parking lot. As described above, the building is zero-lot line along the western and northern property lines with the building connection between the two parcels following the offset lot lines and accommodating parking and circulation.
• 470 Olive Avenue was originally built and zoned CS. The first occupants were Carnes Piano in 1968, where customers walked through the entire building spanning 2951 El Camino and 470 Olive. However, the section of the building located on 470 Olive Avenue was re-zoned in 1978 to R-1, during a City of Palo Alto Comprehensive Plan. As noted by the City Council on October 2, 2017, this splitting of a single building into two different zones may have been done inadvertently, in error. The parcels located directly across from on Olive Avenue and two parcels adjacent to 470 Olive on ECR are zoned CS. We believe that the original CS zone designation of 470 Olive Avenue was appropriate and the subsequent rezoning to R1 was not. The rezoning to R1 created a noncompliant building on 470 Olive; it was designed to meet CS requirements, not R1 requirements. The entire building has always operated as commercial use.
• In 1987, a prior owner applied for an Exception from the Non-conforming Use Termination requirement, which was unanimously approved by the City Council. On July 16, 1992, the City of Palo Alto confirmed in a letter to the owner that this action allowed the existing non-conforming use to continue indefinitely, subject to site improvement. The letter suggested an option of applying for a zone change to change zoning of 470 Olive from R-1, back to CS, Service Commercial’. Unfortunately, the prior owner did not follow up or disclose this when we purchased the building in 1993. We were never notified by the City of Palo Alto regarding this issue. However, since becoming aware of this situation, we immediately brought it to the attention of the city, and we have taken proactive steps to resolve it and to accommodate priorities of the City of Palo Alto.
• In 1993 Superfund ground water quality test wells were installed in the parking lot of 470 Olive Avenue. Access to these wells could be provided within a multifamily residential development, located in the parking garage. The cost to comply with both R1 zone and the Superfund water quality well access, if at all possible, would be financially and space prohibitive.
• On October 2, 2017, the Palo Alto City Council conducted a rezoning prescreening and suggested the Code Amendment Application as a solution. We were advised by the City Council during the prescreening on October 2, 2017 to request an Exception to the Non-conforming Use Amortization Code section 18.70.070 to match Commercial use of the structurally and functionally linked parcel, 2951 El Camino (zoned CS) and the single building that spans both parcels. On October 30, 2019, the Planning and Transportation Commission reviewed the request for a 5-year Exception favorably, and the concept of a Multifamily Residential Development was discussed and initiated. We appreciated the prescreening with City Council in 2020 and 2021.
Development was pursued; however a formal application was not submitted as the project was unfortunately deemed financially infeasible at the time.
Our family’s collaboration with the City of Palo Alto to provide housing on this ideal location:
• Nearly a decade ago, in 2017 we brought this zoning issue to the attention of the City. Through working with staff, they recommended pursuing multifamily development on this location to address the zoning issue, as it presented a “win, win” in terms of providing housing and addressed the zoning. Since then, we have continued to follow the requests and guidance from the City.
• When the City required us to stop renting out 470 Olive Avenue in 2017 until the zoning was resolved and recommended that we pursue multifamily development to resolve both the housing need and the zoning, we agreed and have been consistently working towards this goal since. • We attended the NVCAP working group meetings and listened to the neighborhood priorities. When we requested for our rezoning to be addressed through NVCAP, Jonathan Lait requested that we pursue zoning through a development application instead as the NVCAP was on a short deadline and they didn’t want to risk missing the deadline. For the benefit of the City, we agreed and immediately continued to work toward this goal of multifamily housing on this site. • This brings us to where we are today, nine years later still doing our best, working earnestly and diligently with the City to get much needed housing on this site. We care about this community and the people in it. We feel we have demonstrated this through our interactions with the City. Rezoning this site is a necessary step to get housing on the site that can integrate and benefit the community.
Thank you for taking time to review our application and we request that the 470 Olive Avenue rezoning be approved and added as a Housing Element Site, allowing for the appropriate provision of housing in an ideal location in Palo Alto. Please feel free to contact us: [email protected] and [email protected].
Sincerely,
Thomas G. Agramonte
Jessica Rose Agramonte
Attachments
Cc: Jonathan Lait, City of Palo Alto
Jennifer Armer, City of Palo Alto
Emily Kalla, City of Palo Alto
Attachment 1 – 470 Olive Avenue across from 3001-3017 (Mike’s Bikes) NV-MXM MIKE’S BIKES
470 OLIVE
Attachment 2 – 3001-3017 El Camino Real (Mike’s Bikes)
NV-MXM next to existing single-family home
471 Pepper Avenue 456 Olive Avenue
Attachment 3 – 470 Olive Avenue Building Wall on 471 Pepper and 456 Olive Property Lines Attachment 4 – SB 79 TOD CD Daylight
Plane & Setback Required