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7 Staff Report
From: City Manager
Report Type: CONSENT CALENDAR
Lead Department: Planning and Development Services
Meeting Date: September 28, 2026
Report #: 2607-6561
TITLE
706 Cowper Street [26PLN-00144]. Council Preliminary Review for Comprehensive Plan Land Use Plan Map Amendment to Allow an Approximately 400 Square Foot Commercial Addition to a Category 1 Historic Resource in the Multiple-Family Residential Land Use Designation. CEQA Status: Not a Project.
RECOMMENDATION
Staff recommends Council acknowledge and accept staff response to the Preliminary Review application for a Comprehensive Plan Map Amendment to allow a minor expansion of commercial floor area in a residential land use designation.
EXECUTIVE SUMMARY
The applicant requests a Preliminary Review application to change the Comprehensive Plan land use designation for the site from Multiple-Family Residential to a designation that permits office use. This, in turn, would facilitate an approximately 400 square foot expansion to an existing office use permitted under a 1970s Planned Community (PC) ordinance (Attachment D). The project includes a new two-story addition, seismic and historic rehabilitation of an existing Category 1 historic structure. A project of this minor nature would normally be approved at a staff level pursuant to Palo Alto Municipal Code (PAMC) Section
18.76.020(b)(3)(E). This prescreening is required, however, in accordance with PAMC Section
18.79.030(A), because staff identified the need to amend the City’s Comprehensive Plan.
Due to the minor nature of the subject application, this item is placed on the consent calendar as an efficient approach authorized pursuant to PAMC 18.79.050(a), which gives the City Council broad discretion in the manner in which to conduct the review. Receipt and review of the Preliminary Review application on the consent calendar paves the way for the applicant to file a formal application. If desired, individual Councilmembers could provide feedback under Councilmember comments or when approving the consent calendar. If three or more
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7 Councilmembers are interested in pulling the item from the consent calendar for discussion, staff will be prepared to support that discussion on the same evening.
After this Preliminary Review has been received, the applicant may file a formal application to amend the Comprehensive Plan Land Use Plan Map. Such amendments require Planning and Transportation Commission review and recommendation, followed by Council’s action by ordinance decision as set forth in PAMC Chapter 18.80.
BACKGROUND
Known as the T.B. Downing House, the subject property at 706 Cowper Street is currently listed as a Category 1 (“Exceptional Building”) on Palo Alto’s Historic Inventory. The building is also listed on the California Register of Historical Resources and the National Register of Historic Places under Criterion C3 (Architecture). The three-story-over-basement building was originally constructed in 1894 as a single-family residence and designed in the Queen Anne style by architect and builder W. Matlock Campbell.
Since its construction, the property has undergone a series of alterations over the years, though these modifications have not affected the integrity of the historic structure’s eligibility for any of the registers on which it is listed. In 1901, a detached residential structure was added to the property, followed by a detached garage in 1924. Both structures were later demolished.
Between 1949 and 1975, portions of the original front porch were enclosed, and minor additions were made to the east façade. A 1973 fire heavily damaged the third floor, prompting substantial repairs and interior reconstruction in 1977, along with roof reframing. At that time the property was rezoned to PC-3007 (Attachment D) to allow for the conversion from residential to office use. In 1978, major alterations included additions to the rear, enclosure of the southeast wraparound porch, construction of new upper-story volumes and decks, exterior stairs, basement excavation, and landscaping changes. The building was subsequently reroofed in 1978 and 2001. Other alterations of unknown dates include demolition of a detached rear dwelling, filling of the entrance transom, and installation of skylights.
Project Description
The project includes an approximately 400-square-foot, two-story L-shaped rear and side addition that would provide additional workspace for the existing office use. The addition is located within areas of the rear and side elevations that were substantially altered in 1978, minimizing impacts to the historic street-facing facades. The project also includes interior reconfiguration that would likely trigger required seismic rehabilitation due to structural modifications; two ADA-accessible parking spaces with EV charging infrastructure; an ADA- accessible rear entrance; two ADA-compliant bathrooms; and a publicly accessible front-yard open space featuring a garden with native plant species and interpretive signage. Routine maintenance and repair of historic wood and window components would occur, including paint removal and repainting, sash repair and reglazing, repairs to frames and operating hardware, 1 0
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7 and repair of exterior wood elements such as porch railings, columns, decking, ceilings, siding, cornices, and window and door casings and surrounds.
Surrounding Uses
The property is located on a rectangular parcel at the southeast corner of Cowper Street and Forest Avenue in Palo Alto’s University South neighborhood. Surrounding uses include the two- story boutique hotel Cowper Inn (Category 3 historic resource) to the north, a one-story medical office to the east, a one-story medical office across Downing Lane to the south, and a two-story, 12-unit residential building to the west.
ANALYSIS
Staff will prepare a thorough analysis of the Zoning Code and Comprehensive Plan compliance upon submittal of a formal application, if filed. The preliminary review below summarizes the conceptual plans and identifies key policy considerations.
Comprehensive Plan Compliance
The site has a Comprehensive Plan land use designation of Multiple-Family Residential, which allows residential densities of 8 to 40 units and 8 to 90 persons per acre, with lower densities encouraged adjacent to single-family residential areas. Although the PC zoning specifically allows the existing office land use that has operated since the 1970’s, this use is not consistent with the site’s land use designation. Due to the proposed expansion of the established office use, an amendment to the Comprehensive Plan Land Use Map is also required as part of a formal application. It is anticipated that any future Comprehensive Plan amendment would be narrowly focused on minor expansions of existing commercial uses with planned community ordinance approves thereby limiting the scope of the amendment’s applicability.
Aside from the land use designation, several Comprehensive Plan policies and goals support the project, including:
Policy L-7.1 encourages the public and private upkeep and preservation of resources with historic merit.
Policy L-7.9 specifically allows compatible nonconforming uses to continue for the life of historic buildings, recognizing that continued use can support the long-term preservation and maintenance of historic resources.
Policy L-7.10 supports the preservation of significant historic resources while allowing them to be adapted to contemporary needs consistent with the Secretary of the Interior’s Standards for Rehabilitation.
Policy C-1.7 encourages public access to privately owned open spaces and facilities for community meetings and events.
The project would still retain the existing historic resource while allowing modifications to accommodate the existing use and meet contemporary needs. The proposed seismic and historic rehabilitation would improve the safety of the structure, bring it more into 1 0
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7 conformance with ADA and green building code requirements for accessibility and efficiency, and restore some of the original historic features. The project would also provide a new privately owned public open space, consistent with the Comprehensive Plan’s encouragement for increased public access to open spaces.
While the project is largely consistent with the overall goals and intent of the Comprehensive Plan, a Comprehensive Plan Amendment would be required to formally align the existing land use and allow the expansion of office floor area on the property.
Zoning Compliance
The existing Planned Community (PC-3007) allows professional and general office uses and requires six on-site parking and eight secured bicycle spaces. Further, PC-3007 requires that “the building be restored, maintained, and preserved as much as possible to its original appearance insofar as architectural features are concerned.” Although no changes to the land use is proposed, the following items would need to be addressed as development standards under a new Planned Community.
The existing 11 parking spaces would be reduced to 9 spaces, including two EV spaces. The floor area for the site would increase by approximately 400 square feet. A historic preservation covenant would be requested to ensure future development complies with the Secretary of the Interior’s Standards for Rehabilitation.
PAMC Section 18.76.020 provides for Architectural Review of minor changes to previously approved Planned Community Districts. Based on an initial review of the conceptual plans, it appears the proposed changes are eligible for administrative approval. The conceptual design also appears generally consistent with the Secretary of the Interior’s Standards for Rehabilitation by locating the addition on the secondary rear and side elevations and limiting changes to the building’s primary street facing facades. This approach minimizes the visual impact of the addition and helps preserve the building’s historic character. The formal project would still be required to demonstrate compliance with the Standards as part of the review process.
Under PAMC Section 18.76.020 a “minor” change must be of little visual significance, not materially alter the appearance of previously approved improvements, and not alter the character of the structure.1 Based on the conceptual plans, the proposed addition appears consistent with these criteria, subject to review of the formal project plans. 1 PAMC Section 18.76.020(b)(3)(E): the term "minor" means a change that is of little visual significance, does not materially alter the appearance of previously approved improvements, is not proposed for the use of the land in question, and does not alter the character of the structure involved. If the cumulative effect of multiple minor changes would result in a major change, a new application for Architectural Review approval of a major project, Site and Design approval, Planned Community District approval, or other applicable approval is required. 1 0
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7 Existing Rear Elevation (South): Proposed Rear Elevation (South):
Existing Side Elevation (East):
Proposed Side Elevation (East):
Historic Resource
706 Cowper Street is listed as a Category 1 (“Exceptional Building”) historic resource on the City’s Historic Inventory. Category 1 resources are buildings of preeminent national or state importance, meritorious works by notable architects, or outstanding examples of architectural development, and are subject to historic preservation project review. The property is also listed on the National Register of Historic Places. Despite the property being a listed historic resource,
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7 it is not currently eligible to participate in the Transfer of Development Rights (TDR) program.
The property is located outside the boundaries of the Downtown Commercial (CD) District, and the ordinance establishing the Planned Community (PC) zoning district did not authorize the use of transferable development rights on the site.
The proposed adaptive reuse would involve interior alterations in addition to exterior work.
Although the City’s Historic Preservation Ordinance primarily addresses exterior alterations, both the interior and exterior work would be evaluated under the Secretary of the Interior’s Standards for Rehabilitation to ensure the property’s character-defining features and historic significance are preserved. The 1973 National Register nomination noted that, “The interior was divided into five apartments many years ago, but the original elaborate woodwork and fixtures have remained,” indicating a history of interior alterations. Potential contributing features include the staircase, interior doors and trim, ceiling medallions, interior window frames, and possibly the front ground-floor room arrangements. These features would need to be evaluated as part of the formal application review.
Seismic Rehabilitation
The subject property is not listed on the City’s Seismic List. However, California Building Code Section 503.11 requires, in part, that where work exceeds 50 percent of the building area and involves substantial structural alterations, the lateral load-resisting system of the altered building must satisfy current building code requirements. As a listed historic resource, the property is also subject to the California Historical Building Code (CHBC), which provides alternative approaches to building code requirements associated with the preservation and rehabilitation of qualified historic buildings. The CHBC allows structural and seismic upgrades to be designed based on the actual properties of historic materials and sound engineering principles and professional judgment, rather than prescriptive code requirements. This flexibility can facilitate greater retention of historic fabric while addressing necessary structural improvements.
The applicant has not yet conducted a structural analysis of the building at this preliminary stage. A formal application would provide an opportunity for the required structural and seismic evaluation to be completed.
Public Benefit
Planned Community applications are typically associated with some form of public benefit.
While the proposed work is relatively minor and preservation of the Category 1 historic resource provides an intrinsic benefit to the city, the owner is also interested in creating a publicly accessible open space at the corner of Cowper Street and Homer Avenue. A city walking tour in June included 12 other privately owned public open spaces, termed POPOS by local artist Lisa Van Dusen.3 As part of a formal application, the owner has indicated an interest 3 The Walking Tour of Palo Alto’s Privately Owned Public Open Spaces was supported in part by the ArtLift Grants Program through the City of Palo Alto Public Art Program. More information about this event is available online:
https://www.paloalto.gov/Events-Directory/Community-Services/Walking-Tour-of-Palo-Alto%E2%80%99s- Privately-Owned-Public-Open-Spaces
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7 in memorializing this benefit to include a management and maintenance plan that would address responsibilities related to access, maintenance, litter and other measures associated with the publicly accessible space. Public access to the property in the manner described by the applicant is not currently a planned community benefit associated with the current PC ordinance.
POLICY IMPLICATIONS
Preliminary Review are intended to solicit early feedback on proposed projects and, like all study sessions, cannot result in any formal action. If accepted on the consent calendar, the Council is acknowledging the applicant’s intent to file a Comprehensive Plan amendment to advance the conceptual project. If a formal application is submitted, additional analysis would be required to evaluate the proposed public space and potential impacts to historic resources.
Although the City’s historic preservation regulations primarily address exterior alterations, the proposed interior work is relevant to the property’s National Register listing. If sufficiently extensive, the alterations could affect the property’s ability to convey its historic significance and jeopardize its continued National Register status. The interior alterations would therefore be evaluated for consistency with the Secretary of the Interior’s Standards for Rehabilitation and designed to retain significant historic spaces and features to the greatest extent feasible.
Should the Comprehensive Plan amendment ultimately not be adopted, the project may still proceed with rehabilitation and other improvements. However, the scope would need to change to remove floor area addition.
FISCAL/RESOURCE IMPACT
Processing of this prescreening and any future formal application are funded by applicant fees.
Any formal application would also be subject to impact fees to address impacts of the proposed development on public services and infrastructure. Any work related to a citywide POPOS initiative is currently unfunded and would advance only as available resources allow.
STAKEHOLDER ENGAGEMENT
The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post and postcard mailing occurred on September 18, 2026, which is 10 days in advance of the meeting.
ENVIRONMENTAL REVIEW
The Preliminary Review process is not considered a project in accordance with the California Environmental Quality Act and therefore not subject to environmental review. . A review in accordance with CEQA would be initiated with the formal filing of a development application. 1 0
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7 ATTACHMENTS
Attachment A: Location Map
Attachment B: Applicant’s Description Letter
Attachment C: Project Plans
Attachment D: Planned Community Zoning Ordinance (PC-3007) APPROVED BY:
Jonathan Lait, Planning and Development Services Director