HomeMy WebLinkAbout2021-03-29 City Council Agenda PacketCity Council
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Monday, March 29, 2021
Special Meeting
5:00 PM
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Call to Order
Closed Session 5:00-6:30 PM
Public Comments: Members of the public may speak to the Closed Session item(s); three minutes per speaker.
1.CONFERENCE WITH LABOR NEGOTIATORS
City Designated Representatives: City Manager and his designees
Pursuant to Merit System Rules and Regulations (Ed Shikada, Rumi
REVISED
2 March 29, 2021
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Portillo, Molly Stump, Dean Batchelor, Geo Blackshire, Robert Jonsen,
Nick Raisch, Kiely Nose)
Employee Organizations: Utilities Management and Professional
Association of Palo Alto (UMPAPA); Service Employees International
Union (SEIU), Local 521; Service Employees International Union
(SEIU), Local 521, Hourly Unit; Palo Alto Police Officers Association
(PAPOA); Palo Alto Fire Chiefs’ Association (FCA) and Employee
Organization: International Association of Fire Fighters (IAFF), Local
1319; Palo Alto Police Manager’s Association (PAPMA)
Authority: Government Code Section 54957.6(a)
Consent Items 6:30-6:35 PM
Members of the public may speak to any item NOT on the agenda. Council reserves the right to limit the duration
of Oral Communications period to 30 minutes
2.Approval of Council Appointed Officers (CAO)Committee
Recommendation for an Executive Recruitment Process for City Clerk;
Authorize Chair of CAO Committee to Execute a Contract With the
Executive Recruitment Firm Peckham & McKinney as Specified in the
Attached Proposal at an All-inclusive Cost of $27,000; and Authorize
the CAO Committee to Finalize the Job Announcement After Receiving
Council Input
Action Items 6:35-10:00 PM
Include: Reports of Committees/Commissions, Ordinances and Resolutions, Public Hearings, Reports of Officials,
Unfinished Business and Council Matters.
3.CONTINUED PUBLIC HEARING/QUASI JUDICIAL: Castilleja School
Project 1310 Bryant: Conditional Use Permit (CUP) Amendment to
Increase the Student Enrollment cap to 540 Students With Phased
Enrollment and Campus Redevelopment, a Variance to Replace
Campus Gross Floor Area and Architectural Review Approval of the
Campus Redevelopment. Zone District: R-1(10,000). Environmental
Review: Final Environmental Impact Report (EIR) Published July 30,
2020; Draft EIR Published July 15, 2019 (Continued From March
15, 2021)
Adjournment
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MEMO
Public
Comment
Memo
Presentation
Public
Comment
3 March 29, 2021
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City of Palo Alto (ID # 12151)
City Council Staff Report
Report Type: Consent Calendar Meeting Date: 3/29/2021
City of Palo Alto Page 1
Summary Title: Approval of CAO Committee Recommendation for an
Executive Recruitment Process for City Clerk
Title: Approval of Council Appointed Officers (CAO) Committee
Recommendation for an Executive Recruitment Process for City Clerk;
Authorize Chair of CAO Committee to Execute a Contract With the Executive
Recruitment Firm Peckham & McKinney as Specified in the Attached
Proposal at an All -inclusive Cost of $27,000; and Authorize the CAO
Committee to Finalize the Job Announcement After Receiving Council Input
From: City Manager
Lead Department: Human Resources
Recommendation
Staff Recommends that Council:
1. Approve the CAO Committee recommendation for an executive recruitment process
for City Clerk, as described below;
2. Authorize Chair of the CAO Committee to execute a contract with the executive
recruitment firm Peckham & McKinney, as specified in the attached proposal at an
all-inclusive cost of $27k; and
3. Authorize the CAO Committee to finalize the job announcement after receiving
Council input.
Background
City Clerk Beth Minor has notified Council of her intention to retire, with a targeted
retirement at the end of July 2021. Clerk Minor was appointed to her current position in
2015, after serving as Assistant City Clerk for 8 years. Clerk Minor was selected for City
Clerk after competing in an extensive executive recruitment process conducted by the
recruitment firm Peckham & McKinney.
City of Palo Alto Page 2
Following Clerk Minor’s notice of retirement, on March 10 the Council Appointed Officers
(CAO) Committee1 met to make recommendations to Council regarding the pending
vacancy. The CAO committee reviewed the recruitment history for City Clerk, discussed
recent City Clerk recruitments and discussed matters relevant to the recruitment.
Once Council provides authorization to proceed with this recruitment, the selected
executive recruitment firm will begin by conducting 1-1 appointments with each Council
Member to discuss the ideal skills, experience, workstyle, and characteristics desired for
the position. The executive recruitment firm will then incorporate feedback from the 1-1
interviews to develop the job announcement. The CAO Committee will assist the
executive recruiter to finalize the announcement, and the application acceptance period
begins when the job announcement is publicly posted.
Analysis
While researching current market conditions for City Clerk, staff found the nearby cities
of Mountain View and Milpitas recently completed recruitments for City Clerk. Both cities
reported successful recruitments resulting in strong candidate pools. A summary of
recent recruitments are as follows:
• City of Mountain View appointed a new City Clerk in early March 2021, at a salary of
$175k. The selected candidate was previously the City Clerk in the City of Malibu.
The recruitment was conducted by the executive recruitment firm Peckham &
McKinney, which is the same firm that recruited Mountain View’s prior clerk in 2014.
The firm was paid $27k by the City of Mountain View for this recruitment.
• City of Milpitas appointed a new City Clerk in February 2021, at a salary of $182k.
The selected candidate was previously the City Clerk in the City of Campbell. The
recruitment was conducted by the City’s internal Human Resources Department.
Cost and Timeline
Reputable executive recruitment firms are charging fees in the range of $20k-$30k per
recruitment in this region. In addition to paying an executive recruitment fee, the
employer absorbs expenses related to the recruitment, including costs for online ads,
mailings, and any travel, if required, for the recruiter and candidates.
1 CAO Committee reviews personnel matters related to the four posit ions that are appointees of the Council, as
referred by Council. Council Appointed Officers include City Manager, City Attorney, City Clerk, and City Auditor.
City Clerk is established as a Council-Appointed Officer in Municipal Code Article IV, Section 1.
City of Palo Alto Page 3
The typical timeline for an executive recruitment is 3 to 4 months. Given the criticality
of the City Clerk position, it is necessary to begin this recruitment as soon as possible to
avoid a gap before a new City Clerk is appointed. Under ideal conditions, the new City
Clerk will overlap with Clerk Minor for 2-3 weeks before Clerk Minor’s retirement.
Executive Search Process
Under current COVID-19 conditions, the executive recruitment will be conducted
virtually. Major steps in the process include:
1) Retention of an Executive Recruitment Firm: Executive recruitment firms that
have recently conducted a search for a similar position will be advantaged by having
knowledge of the applicant pool and are likely to have potential leads. For this
reason, the CAO Committee recommends that the City retain Peckham & McKinney
to handle the Clerk recruitment, on terms summarized in Attachment A. With
Council’s approval, City staff will prepare a professional services agreeme nt
reflecting the attached terms, for execution by the CAO Committee Chair.
2) Pre-recruitment Interviews with Stakeholders: After the contract is executed
with the executive recruitment firm, the executive recruiter meets with stakeholders
to develop the ideal candidate profile. For City Clerk, the executive recruiter will
interview each member of the Council, City Clerk staff, and selected Department
Directors. Depending on the information obtained in the interviews, the executive
recruiter may reach out to additional stakeholders for further input.
3) Develop Ideal Candidate Profile: Information gathered from the stakeholder
interviews are compiled by the executive recruiter in an “ideal candidate profile.”
The ideal candidate profile is then reflected in the job announcement and
recruitment materials for the position. The CAO Committee recommends that
Council authorize the CAO Committee to review, finalize and issue the job
announcement and recruitment materials.
4) Outreach: Once the job is posted identifying the ideal candidate profile, the
executive recruiter will immerse in a variety of activities to find quality candidates.
Efforts include advertising, marketing on social media, and direct contact with
potential candidates.
5) Candidate Screening: The executive recruitment firm will vet the applicant pool
and recommend a short list of qualified candidates. In closed session, Council will
review the short list and narrow the pool to the top 3-5 candidates to be invited for
formal interviews.
City of Palo Alto Page 4
6) Candidate Interviews: Candidate interviews are conducted in a structured oral
board setting. All Council members will participate as panelists and the oral board is
conducted in closed session. In consultation with the executive recruiter, Council has
the option to select additional stakeholders to participate as panelists. At the
conclusion of the oral board, the executive recruiter will conduct a debrief of the
process and Council will select the finalist. After reference checks and background,
the finalist will advance to negotiations for the employment contract.
7) Proposed Employment Contract Terms: After a finalist is identified, Council will
meet in closed session (labor negotiations) to discuss proposed employment
contract terms and instruct a representative who will negotiate with the finalist.
Council may designate the executive recruitment firm, a member of the CAO
Committee, or staff to negotiate the employment terms with the finalist.
8) City Clerk Appointment: Once the finalist accepts the employment terms, the
appointment and employment contract will proceed to Council as an open session
Action Item at a regular Council meeting for approval.
Recommendations
Given the recent success by the City of Mountain View by the same firm that conducted
Palo Alto’s prior search, the CAO Committee is recommending that Council authorize the
firm of Peckham & McKinney as the executive recruiter. As reflected in the attached
proposal, the firm has proposed the same price as negotiated with Mountain View,
which is $27k for an all-inclusive cost. Under this all-inclusive proposal, the City will not
incur additional expenses for advertising, mailers, travel or other incidentals.
To expedite the completion of the job announcement, it is also recommended that the
CAO Committee Chair coordinate with the executive recruitment firm to proof and
finalize the job announcement. The executive recruiter drafts the job announcement in
a recruitment brochure format, based on interviews with each Council member and
other stakeholder input.
Resource Impact
Authorize the executive recruitment contract for $27k to be funded from budgetary
savings in the City Clerk’s office. The contract amount is all-inclusive and the City will
not be billed for other costs such advertising, mailers, travel or incidentals, as those
costs will be absorbed by the executive recruitment firm.
Policy Implications
There is no immediate policy implication resulting from this report.
Environmental Review
City of Palo Alto Page 5
This proposal to engage Peckham & McKinney and to authorize an executive search for
a new City Clerk is not a project under the California Environmental Quality Act (CEQA).
Attachments:
• Attachment A - Peckham & McKenney Proposal Dated March 15, 2021
Peckham & McKenney, Inc., 300 Harding Boulevard, Suite 203D, Roseville, CA 95678
March 15, 2021
Mayor Tom DuBois
and Members of the City Council
City of Palo Alto
Via Irene Barragan Silipin, Recruitment Manager
Dear Mayor DuBois and Members of the City Council:
Thank you for the opportunity to once again assist you in the selection of your next City Clerk.
Peckham & McKenney brings extensive experience with similar recruitments including the cities of
Beverly Hills, Hayward, Long Beach, Palo Alto (2021, 2017, and 2010), Petaluma, Rancho Santa
Margarita, Redwood City, Rolling Hills, San Mateo, and Walnut Creek. Our most recent placement
was with the City of Mountain View in February 2021.
The recruitment process will include the placement of ads and social media postings, distribution of
the Candidate Profile, and direct outreach by me to potential candidates. My initial focus will be on
qualified candidates within the Bay area, but our outreach will be throughout California.
We will open the recruitment in April, and I would recommend a filing deadline of May 28. I will
conduct my preliminary interviews in early June, will be prepared to provide a recommendation of
the leading candidates to you in mid-June, and City’s interview process will be conducted in late-
June. I have attached the search timeline as well as more detailed information on each of these steps
for your review.
Please feel free to call me toll-free at (866) 912-1919 if you have any questions.
Sincerely,
Bobbi
Bobbi C. Peckham, President
Peckham & McKenney, Inc.
www.peckhamandmckenney.com
bobbi@peckhamandmckenney.com
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THE SEARCH PROCESS
Development of Candidate Profile – This step provides for the development of the Candidate Profile that will
serve as a guide in the identification of potential candidates, outreach and recruitment efforts, screening and
selection of your next City Clerk. The Candidate Profile includes information relating to the City of Palo Alto;
current and future issues and opportunities; expectations, goals, and objectives leading to the success of the new
City Clerk; and the background and experience, leadership style, skills and abilities, and personality traits of the
ideal candidate.
We will request information relating to compensation and benefits, organization charts, and budget data. In
addition, we will request high-resolution photos to be used in an attractive brochure to market the opportunity.
A draft of the Candidate Profile will be provided to the Council Subcommittee for review. We ask that all revisions
and corrections be provided to us in a timely manner in order to maintain the agreed -upon search timeline. Our
marketing and design professional will then prepare an attractive marketing brochure incorporating the Candidate
Profile. This brochure will be distributed to identified industry professionals, and it will also be available on our
firm’s web site. Copies of the brochure will also be made available to the City.
Advertisements will be placed in the appropriate industry publications and websites, and our firm will assume
responsibility for presenting your opportunity in an accurate and professional manner. Social media, including
LinkedIn and other venues, will be used as appropriate. Full information on the position will be posted on the
Peckham & McKenney website and provided to the City for posting as well.
Recruitment –The main focus of our outreach will be direct phone contact with quality potential candidates. Our
recruiting efforts will focus on direct and aggressive recruiting of individuals within the search parameters
established during the Candidate Profile Development.
Throughout this active search process, we will regularly update the City of the recruitment status and share
questions, concerns, and comments received from potential candidates as they consider the opportunity. By doing
so, we will “team” with the City to ensure that all issues and concerns of candidates are discussed and understood
thereby eliminating “surprises” once the resume filing deadline has occurred.
As resumes are received, they will be promptly acknowledged within 48 hours, and we will personally respond to
all inquiries. Once the resume filing deadline has passed, we will update the City on the status of the recruitment,
the number of resumes received, and our intent for preliminary interviews.
Preliminary Interviews – Upon our review of the resumes received, supplemental questionnaires will be sent to
candidates who appear to meet the Candidate Profile. Following a thorough review of the supplemental
questionnaires, we will conduct preliminary interviews with those individuals most closely matching the Candidate
Profile. Internet research will also be conducted so that we may probe the candidate regarding any areas of concern.
Candidates will be advised of the search schedule and updated regularly as to their status.
Recommendation of Candidates/Selection of Finalists – A report will be provided to the Mayor and City Council
prior to our meeting to discuss our recommendation of leading candidates. This report will include a full listing of
all candidates who applied for the position, as well as the cover letters, resumes, and supplemental questionnaires of
the recommended group of candidates for further consideration.
Ms. Peckham will meet with the City Council in a one- to two-hour meeting and will provide an overview of each
recommended candidate as well as share any concerns or negative information. Once a group of finalists has been
selected by the City Council, finalists will be notified and provided with all necessary information to attend finalist
interviews with the City. Peckham & McKenney will notify all candidates of their status.
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If necessary, finalists will make their own travel plans and reservations. It is customary that the City reimburse
finalists for round-trip airfare, car rental, and lodging necessary to attend the interviews with the City. We will
confirm this with the City Council at our meeting to recommend candidates.
Finalist Interview Process – We will provide facilitation during the finalist interview process. An orientation
session will be held at the beginning of the process, and we will facilitate a review and discussion of the finalists at
the end of the day. Interview materials, including suggested interview questions, evaluation and ranking sheets will
be provided. Again, a standard finalist interview process of the leading four to eight candidates is typically
conducted within one day. Should the process desired by the City require more than one day, an additional fee will
be charged.
(Second Round) – Ms. Peckham will provide any necessary facilitation during this second round of interviews with
the leading two to three finalists. Typically, these interviews provide more in-depth, informal conversations that will
ultimately lead to the selection of a finalist candidate.
Qualification – Once the finalist candidate has been selected and a conditional offer has been made by the City
of Palo Alto, a thorough background check will be conducted that is compliant with the Fair Credit Reporting
Act and Investigative Consumer Reporting Agencies Act. Peckham & McKenney utilizes the services of
Sterling Talent Solutions (www.sterlingtalentsolutions.ca), the world’s largest company focused entirely on
conducting background checks. This investigation will verify professional work experience; degree
verification; certifications; and criminal, civil, credit, and motor vehicle records. We encourage our clients to
consider further vetting the candidate through a Department of Justice LiveScan (California clients) in order to
ensure that all known criminal history records (beyond seven years) are investigated.
Ms. Peckham will also contact professional references , and a full report will be provided. This comprehensive
process ensures that only the most thoroughly screened candidate is hired. In addition, negotiation assistance
will be provided as requested by the City of Palo Alto.
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SEARCH SCHEDULE
ACTIVITY
I. Project Organization
• Conference call discussion of recruitment process
• Formalize project schedule
II. Development of Candidate Profile
• Develop Candidate Profile/Marketing Brochure and obtain approval
• Develop advertising and recruiting plan
III.Recruitment
•Advertise, network, and electronically post in appropriate venues
•Distribute candidate profile to identified industry professionals
•Post opportunity on firm’s website
•Focused outreach to individuals within the parameters of the Candidate Profile
•Respond to all inquiries and acknowledge all resumes received within 48 hours
IV .Preliminary Interviews
•Screen resumes and conduct Internet research
•Identify leading candidates and request supplemental questionnaires
•Review supplemental questionnaires
•Conduct preliminary interviews with leading candidates
V. Recommendation of Candidates/Selection of Finalists
• Provide written recommendation of candidates to the City Council
• Meeting to provide overview of recommended candidates
• City Council selects finalist candidates for finalist interview process
• Peckham & McKenney notifies all candidates of status in recruitment process
VI.Finalist Interview Process
•Facilitate finalist interviews with the City Council
•Assist City throughout process and provide recommendations
•City Council selects candidate or leading 2-3 candidates for further consideration
•City Council conducts second interview process.
VII.Qualification
•
•
•
Conduct thorough background and reference checks on leading candidate
Provide negotiation assistance
Exceed expectations and successfully place candidate who “fits.”
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COST OF SERVICES
Cost of Services
Our all-inclusive fee to conduct the search process for your next City Clerk is $27,000. The all-inclusive fee
includes professional fees and expenses (out-of-pocket costs associated with advertising, consultant travel,
administrative support/printing/copying/postage/materials, telephone/technology, partial background checks on
recommended candidates, and full background check on selected finalist only).
Additional Service Costs
The following “menu” details fees for additional requested services. Some fees may be negotiated.
Additional meeting day $500 - 1,000/each + travel expenses
Each additional full background check $300/each
Additional placement within organization* $5,000 (if selected within one year)
*If the City of Palo Alto hires an additional candidate from among those recommended for another position within
one year of the close of the recruitment, a fee of $5,000 will be charged to the City.
Process of Payment
One-third of the all-inclusive fee is due as a retainer upon execution of the agreement. This retainer covers upfront
and necessary expenses incurred by Peckham & McKenney on the City’s behalf for advertising and printing. If the
retainer is not received by Peckham & McKenney within 30 days of execution of the agreement, we will suspend
the recruitment process until payment is received.
The second third of the full payment will be invoiced one month from contract execution, and it is due within 30
days following the invoice date. The final third of the full payment will be invoiced two months from contract
execution, and it is due within 30 days following the invoice date.
If the City requires a different payment schedule, this must be agreed upon within the contract. Peckham &
McKenney expects payment of all invoices in a timely manner.
Insurance
Peckham & McKenney carries Professional Liability Insurance ($1,000,000 limit), Commercial General
Liability Insurance ($2,000,000 General Liability, and $4,000,000 Products) and Automob ile Liability
Insurance ($1,000,000). Our Insurance Broker is Wells Fargo Insuranc e, Inc., Charlotte, NC, and coverage is
provided by Sentinel Insurance Company and Hiscox Insurance Co. Limited. Necessary insurance
documentation will be provided to the City in a timely manner.
Placement Guarantee
Our placement record is particularly strong in that 89% of the candidates we have placed remain in those positions
for over five years. In the unlikely event, however, that a candidate recommended by our firm (external
candidates only) leaves your employment for any reason within the first year (except in the event of budgetary
cutbacks, promotion, position elimination, or illness/death), we agree to provide a one-time replacement at no
additional charge, except expenses.
Reopening the Recruitment
Throughout the recruitment process, all of our efforts are made to ensure a successful placement of a candidate
who fits the Candidate Profile. It is extremely rare that our recruitment process fails to produce a preferred
candidate in the first instance. If the search process, however, does not produce a successful placement, and
there is an understanding that the City of Palo Alto and Peckham & McKenney each take responsibility for
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whatever errors may have been made, we will conduct a second recruitment proces s for the cost of expenses
only (approximately $7,500).
As Albert Einstein said, the definition of insanity is “doing the same thing over and over again and expecting
different results.” Prior to reopening the recruitment again, we will thoroughly review with the City what
adjustments in approach, compensation, or other variables may be necessary to ensure a successful outc ome.
DocuSign Envelope ID: 9F9552A2-9ADB-4810-A3CC-5B9F531FDA2B
TO: HONORABLE COUNCIL MEMBERS
FROM: MOLLY STUMP, CITY ATTORNEY
DATE: MARCH 29, 2021
SUBJECT: AGENDA ITEM NUMBER 3- Castilleja School Continued Discussion
This item is continued from March 8 and March 15, 2021. Please refer to the previously
prepared staff report and accompanying at-places memo from March 8 for background and
staff recommendations.
During the March 15 meeting, staff suggested that public comment would be reopened for a
continued hearing on March 29. Upon further review, staff have determined that any materials
provided to the Council on March 29 will be merely illustrative rather than providing any new
substance for the Council’s deliberations. Specifically, the Council directed staff to provide
examples of text amendments related to the proposed underground garage; these text
amendments will require review by and recommendation from the Planning and Transportation
Commission before they can be presented to the Council for action. Accordingly, public
comment will remain closed on March 29 and the proceedings will be limited to continued
Council deliberations.
Molly Stump Ed Shikada
City Attorney City Manager
1 of 1
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City of Palo Alto (ID # 11180)
City Council Staff Report
Report Type: Action Items Meeting Date: 3/8/2021
City of Palo Alto Page 1
Summary Title: Castilleja
Title: PUBLIC HEARING/QUASI JUDICIAL: 1310 Bryant Street (Castilleja):
Consideration of Certification of an Environmental Impact Report (EIR) and
Applications for a Conditional Use Permit (CUP) Amendment to Increase the
Student Enrollment up to 540 Students; a Variance to Replace Campus Gross
Floor Area; and Architectural Review of Campus Redevelopment. On March 8
the Council Will Receive Presentations and Public Testimony; the Meeting
Will be Continued to March 15 for Council De liberation and Action - No
Public Testimony Will be Heard on March 15. Zone District: R -1(10,000).
Environmental Review: Final Environmental Impact Report (EIR) Published
July 30, 2020; Draft EIR Published July 15, 2019
From: City Manager
Lead Department: Planning and Development Services
Recommendation:
Staff recommends that the City Council consider the subject application over the course of two
public meetings with the following actions:
1. On March 8, 2021
a. receive staff and applicant presentations,
b. receive public testimony, and
c. close the public comment portion of the meeting and continue the hearing to
March 15, 2021.
2. On March 15, 2021
a. Ask clarifying questions of staff, consultants and applicant, as appropriate, and
deliberate on the project. (Note: No additional public testimony is expected to be
received on this date)
b. If the Council agrees with staff analysis and code interpretations applied to the
project (as detailed in this report), take the following actions:
City of Palo Alto Page 2
i. Adopt a resolution certifying the final environmental impact report and
adopting the mitigation monitoring and reporting program (Attachment
A) and,
ii. Approve a Record of Land Use Action (Attachment B) for a Conditional
Use Permit that allows a phased increase in student enrollment; a
Variance to replace (and reduce) existing gross floor area; and,
Architectural Review for the phased demolition/construction and design.
c. Alternatively, if the Council determines one or more elements of staff’s analysis
is inappropriate or if further analysis is required, provide specific direction to
staff to remedy any deficiency and either:
i. Continue the project to a date uncertain, or
ii. Remand the project back to the Planning and Transportation Commission
with specific direction on additional analysis or applications required to
continue processing the requested entitlements.
Executive Summary:
Castilleja private school seeks City approval to redevelop its campus and expand enrollment to
540 students. This action requires Council approval of several discretionary applications,
including certification of the environmental analysis.
The project relies on zoning interpretations that would permit redevelopment but its
application to the project is not supported by some Council-appointed commissioners or many
community members. Beyond the interpretive issue, there are other resident concerns
associated with the increased enrollment and proposed underground parking facility. Many
community members are concerned about anticipated school-related intrusions into the
residential neighborhood, perceived impacts to the residential character and aesthetic
considerations from the loss of protected trees.
The applicant has made significant design changes to respond to resident concerns, including a
scaled down parking facility that allows for the retention of more protected trees and reduces
construction-related disturbances. As conditioned, the project would have a robust
transportation plan that ties student enrollment increases to current trip generation rates (no
net new trips), imposes substantial restrictions on the school’s special event programing, and
incorporates a comprehensive monitoring, enforcement and penalty schedule to help minimize
deleterious impacts to the neighborhood and surrounding community.
The recommendation in this report is for project approval. It is anticipated the current project
design, combined with an extensive list of conditions that establish clear expectations for the
school’s operation will not only mitigate potential impacts but also serve to improve existing
conditions. The City Council, however, has broad discretion over the application and have
City of Palo Alto Page 3
several options to either advance or reject the proposal based on the findings included in this
report or as modified through Council direction.
Background:
Castilleja’s history in Palo Alto dates to 1907. Its educational mission has remained consistent
since its inception and school administrators have sought to expand educational opportunities
over time having received City approval for its current campus size, layout and a student
enrollment.
The subject application was filed on June 30, 2016. Components of the project have been
refined significantly since then, but the overall objective to modernize the campus and expand
student enrollment remains unchanged. The project being considered by the City Council now
is an alternative project studied in the associated environmental impact report (EIR). This
alternative project is preferred by the applicant and attempts to respond to community
concerns regarding impacts to neighborhood character, preservation of existing homes on
Emerson Street and loss of protected trees. The project alternative, referred in the
environmental documents as the Disbursed Circulation/Reduced Garage Alternative #4, is als o
the environmentally superior alternative (that also meets project objectives). The City’s
Architectural Review Board (ARB), Planning and Transportation Commission (PTC) and Historic
Resources Board (HRB) have all reviewed essentially the same project alternative being
presented to the City Council.
Castilleja has an existing Conditional Use Permit (CUP) that allows the private school in the R1
district that was first approved in 1960 and amended over time. The more recent amendments
occurred in 2000,1 and 2006. The CUP limits enrollment to 415 students, regulates special
events, includes requirements for a transportation demand management plan (TDM) and other
operational conditions.
About seven years ago, campus administrators informed the City that it had exceeded its
maximum student cap having enrolled at its peak 448 students. City officials imposed a fee for
violating the CUP and established a compliance schedule to bring Castilleja into conformance
requiring a reduction of four to six students each new academic year until it reached 415
students. Castilleja’s current enrollment is 426 students. Next fall, enrollment is expected to be
no greater than 422 students unless otherwise authorized by the City Council through the
subject applications. The intent behind this enforcement approach was to gradually normalize
operations while giving Castilleja an opportunity to file applications to seek a change in
enrollment. Many in the community have expressed frustration with the City’s approach
toward this enforcement issue and have argued for a timelier resolution to this violation.
1 2000 CUP and prior Use Permit Approval (1999):
https://www.cityofpaloalto.org/civicax/filebank/documents/53961
City of Palo Alto Page 4
Many Castilleja neighbors have also expressed concern regarding the number and intensity of
special events taking place at the campus. Some neighbors and City staff have found the school
was hosting more events than authorized by the CUP. Castilleja disagrees with the City’s
interpretation of the CUP but has reduced the number and intensity of events scheduled. Staff
has not issued a formal enforcement order regarding the special events violation given the
ambiguous language in the CUP, reductions already made and the importance of certain events
for the academic and social experience. Staff instead is looking to an updated CUP to provide
clear direction on the number and size of future events on campus as described later in this
report.
Project Description
Castilleja is located on a 6.17-acre parcel in a residential district surrounded by single family
homes. The project site is generally bounded by Embarcadero Road, Emerson Street, Kellogg
Avenue and Bryant Street. The applicant proposes to demolish five campus buildings, including
the Leonard Ely Fine Arts Center fronting Emerson Street, Classroom and Campus Center
Buildings along Bryant Street and Kellogg Avenue, and the existin g swimming pool. The existing
Fitness and Athletic Center, historic Gunn Administration Building/Elizabeth Hughes Chapel will
remain.
The floor area of all demolished buildings is 84,572 square feet, not including 43,913 square
feet of exempt below grade floor area. The applicant proposes to replace those buildings with a
new academic building containing 81,942 square feet of above grade floor area and 51,069 of
below grade, exempt floor area. Overall the site currently has 116,297 square feet of gross floor
area and a floor area ratio of 0.43:1. This exceeds the 81,379.5 square feet allowed with current
zoning regulations (which enable .45 FAR for the first 5,000 sf and .30 FAR for the remaining
263,765 sf); the site is considered legally non -conforming for floor area.
The applicant proposes a new subterranean parking facility accessed from Bryant Street via a
two-way access ramp and one-way garage exit ramp. The subterranean parking facility would
have 78 non-tandem parking spaces. An additional 26 parking spaces are proposed to be
provided on two surface lots for a total of 104 parking spaces. The proposed project is required
to have 104 parking spaces in accordance with the City’s zoning code. A total of 140 bicycle
parking spaces are provided, in excess of the 108 spaces required by the code. A below grade
pedestrian passage is proposed from the parking facility to new campus building.
Vehicle access is distributed to three drop off/pick up locations around the campus, including a
reconstructed drop off lane at Kellogg Avenue. Service deliveries will occur below grade or
designated locations at surface lots. Refuse enclosures are below grade with a staging area for
service vehicles.
City of Palo Alto Page 5
Other improvements include a new below grade swimming pool with a so und (reduction) wall
relocated near the fitness and athletic center, a reconstructed Circle in the center of campus,
new landscaping and fences.
Two homes adjacent to Emerson Street and owned by Castilleja are not a part of the school’s
redevelopment plans.2
Construction Phasing
The applicant proposes to redevelop the site in four phases. The first phase is the construction
of the subterranean parking facility and some landscaping. Phase two includes the placement of
modular buildings above the parking facility (on Spieker Field). Phase three is demolition of the
Fine Arts Building and construction of the below grade swimming pool and sound wall. Phase
four includes the demolition of the Classroom Building, Campus Center Building, the at -grade
pool, and equipment/maintenance buildings. This phase also includes reconstruction of the
Circle, a new classroom building, access ramp to the below grade service/loading area, removal
of the modular buildings and completion of the landscape plan. Construction is expected to
occur over a three-year period.
To implement the proposed project, the applicant requires several discretionary planning
entitlements, including Architectural Review (AR), a CUP and Variance applications. Each of
these applications have findings that must all be affirmatively answered in order to approve the
project.
ARB Review and AR Recommendation
An AR application is required for the physical buildings (design, colors, materials); landscaping
(hardscape/softscape, including lighting) and irrigation; site planning and, circulation. The
applicant’s request for the three-year phased construction schedule is also subject to City
architectural review.
To approve an AR application, the ARB (or City Council) must conclude that the project meets
six required findings. These findings relate to consistency with the City’s Comprehensive Plan
and zoning code, ensuring the project has a unified and coherent design, includes high quality
materials and construction techniques, a complementary landscape plan, and incorporates
design principles that advance the City’s sustainability interests.
The attached record of land use action (RLUA) documents the ARB’s response to the findings
2 The original project filed with the City included plans to demolish these structures to support a larger
subterranean parking facility. This redesign was in response to public comments and concerns about impa cts to
neighborhood character and the removal of six redwood trees at the western edge of Spieker Field.
City of Palo Alto Page 6
and recommended conditions of approval. In addition to standard conditions of approval, the
ARB also required the applicant to return to the ARB subcommittee for final approval of some
architectural details, including planned work near a protected tree to ensure compliance with
the project arborist’s recommendations for preservation.
The ARB voted 4-1 to recommend approval of the project to the City Council. The dissenting
vote was articulated as an objection to the special condition that required certain project
refinements to be presented to a two-member subcommittee instead of the full Board.
The ARB’s public hearings were held on August 20, October 1, and November 5, 2020. The staff
reports3 are available online as are excerpt minutes,4 presentations5 and videos.6
PTC Review and CUP and Variance Recommendations
A CUP is required for private schools on R1 zoned properties. An amendment to the existing
CUP is required when an applicant seeks changes to a previously approved CUP project.
The CUP is intended to provide for uses that are necessary or desirable for the developm ent of
the community or region but cannot readily be classified as permitted uses in individual districts
due to their uniqueness of size, scope, or possible effect on surrounding uses. Through a CUP a
local jurisdiction can impose conditions that reasonab ly mitigate any anticipated impacts to the
general welfare. Conditional Use Permit conditions typically address topics such as hours of
operation, noise, frequency or intensity of on-site activity, performance measures, operational
controls and restrictions on service vehicles or deliveries.
To approve an CUP application, the PTC must conclude that the project meets two required
findings, specifically:
1. [The use will] Not be detrimental or injurious to property or improvements in the
vicinity, and will not be detrimental to the public health, safety, general welfare, or
convenience;
3 ARB staff report August 20, 2020 https://www.cityofpaloalto.org/civicax/filebank/documents/78025
ARB staff report October 1, 2020 https://www.cityofpaloalto.org/civicax/filebank/documents/78572
ARB staff report November 5, 2020 https://www.cityofpaloalto.org/civicax/filebank/documents/79021
4 ARB August 20th minutes https://www.cityofpaloalto.org/civicax/filebank/documents/78325
ARB October 1st minutes https://www.cityofpaloalto.org/civicax/filebank/documents/78774
ARB November 5th minutes
5 ARB August 20th presentation https://www.cityofpaloalto.org/civicax/filebank/documents/78197
ARB October 1st presentation https://www.cityofpaloalto.org/civicax/filebank/documents/78667
ARB November 5th presentation
6 ARB meeting videos https://midpenmedia.org/category/government/city-of-palo-alto/boards-and-
commissions/architectural-review-board/
City of Palo Alto Page 7
2. [The use will] Be located and conducted in a manner in accord with the Palo Alto
Comprehensive Plan and the purposes of this title (Zoning).
A majority of the PTC was able to support Finding 1 on a 4-2 vote. The dissenting votes were
from Commissioners Summa and Lauing who expressed concern about the enrollment increase,
number of events and potential impacts to the general welfare.
On Finding 2, the PTC was split 3-3. The dissenting commissioners noted a concern about the
project’s compliance with the zoning code, specifically, staff’s interpretation regarding the
permissiveness of the subterranean parking facility, and an inability to find the subterranean
parking facility exempt from gross floor area. One commissioner suggested a text amendment
to the zoning code may be required to facilitate staff’s interpretation. This issue is expanded
upon in the Discussion section of this report.
A second discretionary application considered by the PTC was a Variance application. The
purpose of a Variance is to provide a way for a site with special physical constraints, resulting
from natural or built features, to be used in ways similar to other sites in the same vicinity and
zoning district, and grant relief when strict application of the zoning regulations would subject
development of a site to substantial hardships, constraints, or practical difficulties that do not
normally arise on other sites in the same vicinity and zoning district.
Castilleja’s need for a Variance relates to a request to re -establish (rebuild) gross floor area that
is proposed to be demolish but was legally permitted and is today non-complying with current
codes. More specifically, the existing academic building is proposed to be demolished and
rebuilt in a new design with similar but less gross floor area. However, since the site exceeds
the permitted floor area allowed for R1 properties, any non -complying floor area once removed
cannot be re-established without a Variance. Incidentally, this approach represents a departure
from how the City evaluated a similar request in 2006 when Castilleja received approval for a
CUP to replace the school’s gymnasium. Then, the CUP approval was considered enough to
grant the request. Today, with Council’s direction to strictly apply the zoning code, removal of
non-complying floor area conflicts with PAMC Section 18.70.100 and cannot be remedied
without a Variance application or legislative change to the municipal code.
To approve a Variance application, the PTC must conclude that the project meets four required
findings, specifically:
1. Because of special circumstances applicable to the subject property, including (but not
limited to) size, shape, topography, location, or su rroundings, the strict application of
the requirements and regulations prescribed in this title substantially deprives such
property of privileges enjoyed by other property in the vicinity and in the same zoning
district as the subject property. Special circumstances that are expressly excluded from
City of Palo Alto Page 8
consideration are:
a. The personal circumstances of the property owner, and
b. Any changes in the size or shape of the subject property made by the property
owner or his predecessors in interest while the property was subject to the same
zoning designation.
2. The granting of the application shall not affect substantial compliance with the
regulations or constitute a grant of special privileges inconsistent with the limitations
upon other properties in the vicinity and in the same zoning district as the subject
property,
3. The granting of the application is consistent with the Palo Alto Comprehensive Plan and
the purposes of this title (Zoning), and
4. The granting of the application will not be detrimental or injurious to property or
improvements in the vicinity, will not be detrimental to the public health, safety, general
welfare, or convenience.
A majority of the PTC (4-2) was able to make the required findings as documented in the
attached RLUA. The dissenting Commissioners voted against the Variance because they could
not find that Castilleja was disadvantaged by the size of their parcel, or that the granting of the
variance did not covey a grant a special privilege to the applicant. Moreover, similar to the CUP
findings above, they could not find the project compliant with the City’s zoning code (with
respect to the subterranean parking facility). Accordingly, they found, based on the foregoing
and public testimony included in the administrative record, that the grant ing of the variance
would be detrimental to the general welfare.
The PTC held hearings for this project on August 26, September 9, October 28, November 4,
and November 18, 2020. In addition, the PTC had held a scoping meeting in advance of the EIR
preparation in early 2017. The 2020 staff reports are available online7 as are excerpt minutes8,
presentations9 and videos.10
7 August 26, 2020 PTC report https://www.cityofpaloalto.org/civicax/filebank/documents/78103
September 9, 2020 PTC report https://www.cityofpaloalto.org/civicax/filebank/documents/78347
October 28, November 4, 2020 PTC report https://www.cityofpaloalto.org/civicax/filebank/documents/79015
8 August 26th PTC minutes https://www.cityofpaloalto.org/civicax/filebank/documents/78326
September 9, 2020 PTC minutes https://www.cityofpaloalto.org/civicax/filebank/documents/78760
October 28, 2020 PTC minutes https://www.cityofpaloalto.org/civicax/filebank/documents/79244
November 4, 2020 PTC minutes https://www.cityofpaloalto.org/civicax/filebank/documents/79241
November 18, 2020 PTC minutes https://www.cityofpaloalto.org/civicax/filebank/documents/79557
9 August 26th presentation https://www.cityofpaloalto.org/civicax/filebank/documents/78198
September 9th presentation https://www.cityofpaloalto.org/civicax/filebank/documents/78373
October 28th presentation https://www.cityofpaloalto.org/civicax/filebank/documents/79032
10 PTC meeting videos: https://midpenmedia.org/category/government/city-of-palo-alto/boards-and-
commissions/planning-and-transportation-commission/
City of Palo Alto Page 9
HRB and Historic Review Recommendation
The HRB had conducted a hearing on the Draft EIR in 2019. The HRB reviewed the Final EIR on
September 24, 2020 and provided input on the project and AR approval findings as required by
Code. The HRB requested a condition of approval enabling HRB subcommittee review of a
stairway modification to the historic Gunn Building. This condition is included wit hin the RLUA
(Section 9, Condition 1). Links to the HRB staff report, excerpt minutes, presentation and video
are provided on the project homepage
https://www.cityofpaloalto.org/gov/topics/castilleja_school/default.asp.
Environmental Impact Report Certification
To evaluate the potential environmental impacts of the proposed project, staff hired a
consultant to prepare an EIR. The project studied in the EIR reflects the original project
application. During application processing, the Disbursed Circulation/Reduced Garage
Alternative emerged as the applicant’s preferred project. This alternative, also studied in the
EIR, was the environmentally superior project (while also achieving project objectives) and was
favored by each of the City’s Boards and Commission that reviewed and made
recommendations on the project.
Each Board and Commission had an opportunity to review and comment on the environmental
documents, received public testimony and considered the EIR in their respective deliberations
on the project. Each Board and Commission has forwarded a recommendation for EIR
certification to the City Council.
Additional environmental analysis is provided toward the end of this report.
City Council
The City Council’s appointed Board and Commission members that have a role in land use
decisions reviewed the administrative record and forwarded various recommendations to the
City Council. The City Council is acting in a quasi-judicial capacity and can accept or reject the
draft recommendations. Typically requests for AR, CUP and Variance applications are not
presented to the City Council unless a project has been appealed from a Director’s decision.
However, PAMC Section 18.40.170 provides that Director of Planning and Development
Services may defer a project, when deemed appropriate, to the City Council. Given the
significant public engagement and interest in this project, the matter is being deferred to the
City Council.
Before the City Council are several specific actions and entitlement requests, including:
1. Certification of the Final EIR;
2. Approval of an Architectural Review application for a three-year phased development
that includes demolition of certain buildings, a new below grade swimming pool,
City of Palo Alto Page 10
subterranean garage, a new academic building and other site improvements.
3. Approval of a CUP that:
a. Increases student enrollment, in phases, to 540 students;
b. Establishes a more robust TDM plan;
c. Specifies a maximum number and intensity of campus special events;
d. Authorizes a temporary campus on Castilleja’s Spieker Field;
e. Specifies several operational and program controls on Castilleja; and
4. Approval of a Variance application that allows for the demolition and replacement of
existing academic gross floor area in excess of the R1 maximum floor area ratio.
Staff recommends, given the considerable public interest in this project, that the Council
receive staff, consultant and application presentations and then public testimony before closing
the public comment portion of the meeting and continue the item for Council questions and
deliberation to March 15.
Discussion:
The establishment of Castilleja predates many homes in the area. Its academic mission is
broadly supported and in and of itself has never been a point of contention. In fact, many Palo
Altans are proud to have a prestigious, nationally ranked school in their neighborhood,
consistent with the City’s long tradition and commitment toward outstanding educational
opportunities. At issue for many project opponents is that Castilleja school administrators
allowed student enrollment to exceed its permitted limits, which has resulted in more traffic
congestion, school-related intrusions into the surrounding neighborhood and an exp ansion of
special events that far exceeded the level of activity anticipated in prior City approvals.
Castilleja for its part has acknowledge it has made some mistakes and has worked with City
officials to get back into compliance. Castilleja’s implementat ion of its TDM plan has been very
successful and generates fewer trips now, with more students, than it did two decades ago.
The school has hired an administrator to coordinate all Castilleja special events and has
meaningfully reduced the number of events from its peak. Castilleja and area residents meet
periodically and at different occasions have attempted mediation to help resolve conflicts, but
those efforts did not achieve desired outcomes.
Many in opposition to the project generally accept the notion that the campus should be
allowed to modernize its classrooms and facilities but reject the idea of a subterranean parking
facility, expansion to student enrollment, and would like to see the number of events
substantial curtailed. Some have suggested Castilleja pursue a satellite facility or relocate all
together to accommodate its expansion interests elsewhere in the City. Staff has explored this
concept with the applicant but concluded there are no feasible options to support this idea.
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To address many of these conflicts, it is appropriate to reexamine Castilleja’s existing CUP to
consider if there are opportunities to tighten its operational conditions, provide greater relief to
area residents, establish direct communication channels for dispute r esolution and meaningful
penalties and enforcement. At a minimum, adjustment to the special events condition is
needed, but the community and Castilleja would benefit from a more comprehensive approach.
To the extent an updated CUP can also incorporate Castilleja’s interests to modernize its
campus and expand enrollment with greater protections for residents is a policy consideration
for the City Council.
While staff and the City Council’s appointed Board and Commission members have navigated
through the issues and forward recommendations to achieve a possible balance, there are a
couple of procedural considerations that require exploration before certain operational or
topic-related issues can be addressed. To start, one issue that has been an ongoing conc ern for
many residents from the outset is the subterranean parking facility. While there are design and
operational aspects to this issue, more fundamentally there is a question as to whether it is
permitted by the City’s zoning code.
Subterranean Parking Facility – Code Interpretations
The City Council’s direction on whether the subterranean parking facility is a permitted aspect
of the project design is anticipated to have one of the following outcomes:
• A finding that the proposed parking facility complies with the code would enable
continued consideration of the applicant’s request with likely no major redesign or
procedural changes.
• A finding that the proposed parking facility does not comply with the code would
require either a significant project redesign, an adjustment to the Variance application,
or a text amendment to authorize the structure in an R1 zone for private schools. If the
City Council generally supports the idea of the subterranean parking facility, but finds
procedurally it is not supported by the language in the existing zoning code, it would be
appropriate to state this so the applicant could initiate the process of a text amendment,
which requires review before the PTC. If there is not majority support for a text
amendment or adjustment to the Variance application, a project redesigned would be
required.
The municipal code requires off-street parking for various land uses. To meet code required
parking for the project, the applicant proposes two surface parking lots and a below gr ade
parking facility. The design also serves to mitigate noise associated with student drop off/pick,
focus traffic circulation onsite and provide – through tandem parking or assisted parking –
additional capacity for special events intended to minimize vehicle parking in neighborhoods.
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The use of subterranean parking facilities is supported by the City’s Comprehensive Plan.11 The
ARB in its review considered the parking facility a superior design solution to surface parking
lots. Some area residents object to the below grade parking facility due to the construction
impacts, concern over the loss of mature, protected trees and localized impacts at driveway
ramps.
When evaluating whether the subterranean parking facility is a permitted design solution to
address the off-street parking demand, staff found there were aspects of the code that did not
clearly address the issue and required interpretation. Specifically, three questions needed to be
addressed:
1. Are subterranean parking facilities permitted in the R1 zone for non-residential uses?
2. If permitted, does this floor area count toward the project’s gross floor area?
3. Can a subterranean parking facilities be located under a field without a building above
it?
Each of these questions and staff’s decision path are described below.
1. Are subterranean parking facilities permitted in the R1 zone for non-residential uses?
The Municipal Code generally permits parking to be placed at, above, or below-grade. With
respect to location, the code simply requires that parking to be located on the same site as the
principal use. The City’s basic parking requirements are provided in PAMC Chapters 18.52 and
18.54:
• PAMC 18.52.030(g) (Location) – “All off-street parking facilities required by this chapter
shall be located on the same site as the use for which such facilities are required, except
as authorized pursuant to Section 18.52.050 [Adjustments by the Director].”
• PAMC 18.54.020(a) – “Parking Facility Design. Parking facilities shall be designed in
accordance with the following regulations: (1) Requirements for dimensions of parking
facilities at, above, and below grade are contained in this section and in Figures 1-6 and
Tables 3-6 of Section 18.54.070. [. . .]”
PAMC Chapter 18.12 does provide a specific limitaiton on underground parking for single -family
uses in the R-1 zone:
11 Palo Alto Comprehensive Plan Policy T-5.6: Strongly encourage the use of below-grade or structured
parking and explore mechanized parking instead of surface parking for new developments of all types
while minimizing negative impacts including on groundwater and landscaping where feasible.
City of Palo Alto Page 13
• PAMC 18.12.030(e) – “Underground parking is prohibited for single-family uses, except
pursuant to a variance granted in accordance with the provisions of Chapter 18.76, in
which case the area of the underground garage shall be counted in determining the
floor area ratio for the site.”
While underground parking is prohibited for single-family uses, there is no prohibition for non-
residential uses in R-1 zones. On this point alone, staff does not believe the code allows for any
reasonable debate. The more difficult questions arise in relation to whether and underground
parking for a non-residential use in the R-1 zone should count as gross floor area.
2. Provided subterranean parking facilities are permitted in the R1 zone for non-residential
uses, does this floor area count toward the project’s gross floor area?
Property in the R1 zone is limited to a maximum gross floor area that is calculated using a floor
area ratio. Castilleja exceeds the maximum gross floor area for the site having 116,297 square
feet where only 81,379.5 square feet are allowed. The existing gross floor area was legally
established, but code changes rendered the site non-complying in 1998. The applicant’s
Variance request addresses the removal and replacement of non-complying gross floor area but
does not include any floor area related to the subterranean parking facility.
To determine if underground parking counts toward gross floor area the parking facility itself
needs to be defined. Palo Alto Municipal Code Sections 18.04.030(a)(65)(C) and 18.12.040 state
that “carports” and “garages” shall be included in gross floor area for the R-1 zone. However,
the code defines both “carport” and “garage,” as parking facilities for residential uses.
• PAMC 18.04.030(a)(24.5) “Carport” means a portion of a principal residential building or
an accessory building to a residential use designed to be utilized for the parking or
storage of one or more motor vehicles, which is at least 50% open on two or more sides,
including on the vehicular entry side, and covered with a solid roof.
• PAMC 18.04.030(a)(59) “Garage, private” means a portion of a principal residential
building or an accessory building to a residential use designed to be utilized for the
parking or storage of one or more motor vehicles, which is encl osed on three or more
sides and covered with a solid roof.
Since these definitions relate to residential buildings and uses – they do not apply to the
proposed parking facility for a non-residential use.
Rather, staff concluded, the subterranan parking faciity was more akin to a basement, defined
City of Palo Alto Page 14
as follows in the zoning code:
• PAMC 18.04.030(a)(15) “Basement" means that portion of a building between the
lowest floor and the ceiling above, which is fully below grade or partly below and partly
above grade, but so located that the vertical distance from grade to the floor below is
more than the vertical distance from grade to ceiling.
PAMC sections 18.04.030(a)(65)(D) and 18.12.090(b) provide that basements are exluded from
gross floor area for the R-1 zone. Section 18.12.090(b) provides additional detail:
• PAMC 18.12.090(b) Basements shall not be included in the calculation of gross floor
area, provided that:
1. Basement area is not deemed to be habitable space, such as crawlspace; or
2. Basement area is deemed to be habitable space but the finished level of the
first floor is no more than three feet above the grade around the perimeter
of the building foundation; or
3. Basement area is associated with a historic property as described in
Section 18.04.030(a)(65)(D)(vii).
Accordingly, staff concluded the proposed subterranean parking facility is, by definition, neither
a carport nor a garage and is instead more closely aligned with the definition of a basement,
which is excluded from gross floor area. Staff acknowledges, as discussed further below, that
assigning the basement definition to the subterranean parking facility is not a perfect match,
but arguably offers the best guidance. There is at least one recent project, Congregation Kol
Emeth (2016), that includes a subterranean parking facility in the R-1 zone, which was not
counted as gross floor area. This example does not in itself make this interpretation accurate
but provides some context for how this issue was addressed previously.
Council may draw a different conclusion from staff as to the appropriateness of using the
definition of basement as a guide toward gross floor area. The Council may find that the area
devoted toward parking should count toward gross floor area because it does not fit within any
of the specified exclusions. In this instance, the applicant could seek to revise the proposed
Variance application to include the request for the subterranean parking facility and the
associated gross floor area. Council would then need to evaluate that request to the Variance
findings. A legislative solution amending the code to allow non-residential, subterranean
parking facilites to be exempt from floor area is another possible path forward if Council does
not support staff’s interpretation but supports a subterranean garage structure.
3. Can a subterranean parking facilities be located under a field without a building above
it?
City of Palo Alto Page 15
Staff’s interpretation to link the subterranean parking facility to the basement definition for the
purpose of determing gross floor area requires another interpretation for non -residential uses
in the R1 zone. Although the municipal code does not restrict the location of subterranean
parking facilities for non-residential uses, the R-1 zone, PAMC section 18.12.090(a), does
regulate the location of basements:
• PAMC 18.12.090(a)12 – Basements may not extend beyond the building footprint and
basements are not allowed below any portion of a structure that extends into required
setbacks, except to the extent that the main residence is permitted to extend into the
rear yard setback by other provisions of this code.
Staff has previously interpreted this language to apply only to residential uses, based in part to
the code’s reference to a main residence. If, as staff has interpreted, this section does not apply
to non-residential uses in the R1 zone, then the request for a subterranean parking facility
would be evaluated based on required findings for the CUP and AR applications. This is the
approach that was applied to Congregation Kol Emeth and is similar in concept to the approach
used in 2006 when Castilleja rebuilt its gymnasium.
Notwithstanding staff’s prior interpretations, the City Council may provide alternative direction
on how ambiguities in the code should be resolved going forward, including for the subject
project. Staff has communicated with the applicant team and has been forthright with the
community and PTC that these interpretations require scrutiny and that the City Council
ultimately decides if these interpretations can be supported. The PTC similarly struggled with
these interpretations, which resulted in the split 3-3 vote on the CUP Finding number 2
concerning the project’s compliance with the municipal code.
As stated previously, the above interpretations are gating issues for the project. Based on
Councils findings, the project may require redesign, supplemental discretionary or legislative
applications. The Council may decided, following public testimony, to tackle these issues before
addressing the following operational and other topical aspects of the project.
Enrollment
The applicant proposes a phased enrollment schedule that would immediately increase the
number of students from 415 to 426 upon project approval; extending to 490 students after
completion of the subterranean garage; and, a maximum of 540 students when all construction
is finished. No more than 25 students would be added in any academic year. This schedule was
12 Section 18.12.090(a) is only relevant to the extent the underground parking facility is considered a “basement,”
as staff suggest would be appropriate in these circu mstances. Should the Council disagree that the structure is a
basement, section 18.12.090(a) would have no bearing on its location.
City of Palo Alto Page 16
supported by a majority of the PTC (4-2) and is reflected in the draft RLUA (Section 8, Condition
#4).
Increasing student enrollment is a primary reason for filing the subject applications. Many in
the community are concerned that increasing student enrollment will increase the intensity of
activity at the site bringing more vehicle trips, congestion, and further disruption to what is
describe as an already impacted residential neighborhood. Conditional Use Permit findings are
cited that increasing student enrollment would detrimentally impact the general welfare of the
neighborhood.
A minority perspective on the PTC was to limit the school to 450 students and, after a couple of
years, reward Castilleja with increased enrollment after it demonstrated ongoing compliance
with the CUP, including limits on vehicle trip counts. This approach was seen as an opportunity
for Castilleja to restore some of the trust it lost in the community when it exceeded its
enrollment cap.
The prevailing perspective held that the number of students enrolled at the school was less
important than Castilleja’s ability to meet its trip reduction targets. A robust TDM plan and
other conditions such as a no net new vehicle trip requirement and the ability to freeze or
lower enrollment for not meeting trip reduction goals were cited as appropriate to mitigate
future impacts.
The City Council in its review has broad discretionary to consider the appropriateness of any
increase to the Castilleja’s enrollment. Community input and consideration of the application
findings and draft conditions can help guide the appropriate maximum enrollment, when it can
be achieved, whether phased increases should be allowed and when it would begin.
Special Events
Castilleja holds many events to support its academic mission and campus experience. Typical
events include student performances, admission/orientation meetings, alumni/donor events,
social dances and other celebrations. The applicant proposes to host 90 events13 during the
academic year, with an event being one with more than 50 attendees. Five events are listed as
major events ranging from 300 to 700 attendees, while about one-third of the events have less
than 100 attendees and the balance between 100 and 400 attendees. The PTC in its review of
the project supported a maximum of 74 events and capped major events to 500 attende es.
The draft RLUA defines what an event is and incorporates several restrictions that are fairly
prescriptive with the intent of adding more specificity than exists with the current CUP (Section
8, Condition #6). Some on the PTC considered this approach heavy-handed, but the size,
13 List of Castilleja Events: https://www.cityofpaloalto.org/civicax/filebank/documents/53960
City of Palo Alto Page 17
frequency and intensity of events has been a consistent source of a complaints reported by
some area residents and was an area of disagreement between the City and the applicant. The
draft condition clarifies any ambiguity and provides clear parameters to help facilitate
compliance with this condition.
The applicant has acknowledged it can reduce the number of special events to 74 as
conditioned but cautioned that further reductions would begin to impact their program
interests and social engagement opportunities for students. Special events will be posted in
advance each academic year on the school’s website and will be subject to the proposed TDM
plan. While the proposed reduction in events does not go as far as some resident s would like,
staff and the PTC find the 74 events with all its restrictions an appropriate balance between
Castilleja’s needs with protections for the neighborhood. The City Council, however, has
discretion to change any aspect of this condition imposing more or less restrictions as it deems
appropriate based on the CUP findings.
Transportation Demand Management (TDM) Program and Conditions
There is a strong interest in the community to mitigate impacts associated with the school and
the proposed project. One of the clearest causal relationships between the increase in
enrollment is the concern that it will generate more vehicle trips and more intrusions into the
residential neighborhood. While it is generally accepted that there will be some localized
disruption in proximity to a school during drop off and pick up times and during some events,
the goal is to minimize this disruption to the extent feasible.
One tool the City uses for many projects is a TDM plan but, to be effective, it requires frequent
monitoring and adjustment. Castilleja has an approved TDM and submits periodic reports to the
City, documenting its successful implementation. Since 2000, Castilleja’s AM Peak trip rate per
student when from 1.33 with 385 students to as low as 0.81 in 2018 w ith 434 students. As part
of the application submittal, Castilleja has proposed additional TDM measures that is intended
to achieve more trip reduction results. Conditions 20 through 27, 29 and 32 set forth the
requirements for a TDM plan that including ne w enhanced measures, applicable mitigation
measure from the EIR and other staff proposed adjustments. The TDM plan includes a
comprehensive monitoring and reporting schedule as well as penalties that may result in
enrollment freezes or reductions if the compliance with aggressive trip counts are not achieved.
The draft TDM plan criteria is among the most robust considered in Palo Alto in terms of its trip
reduction goals, monitoring, reporting and penalty assignments. Though, the Council in its
review may determine additional measures are needed to mitigate potential impacts.
The PTC further tethered the connection between student enrollment increases and trip
generation. While staff had proposed a formula-based approach to achieve a certain number of
trips per student measured during the AM Peak and for average daily trips (ADT) as enrollment
increased, the PTC the opted for a ‘no net new trips’ approach based on trip analysis prepared
City of Palo Alto Page 18
in the EIR. According to this model, Castilleja’s enrollment could increase (in accordance with
the schedule provided in Section 8, Condition #4) if it maintained an ADT of 1,198 trips and an
AM Peak of 383 trips, or less. This would represent an AM Peak trip rate of 0.71 per student at
the maximum enrollment of 540 students. Monitoring would occur three times during the
academic year and, during each of those reporting periods, an additional seven consecutive day
monitoring period would be required at a time determined by the Director (Section 8,
Condition 22). A violation occurs if the school fails to meet the established thresholds and
enrollment increases are stayed until Castilleja can document compliance over two consecutive
reporting periods. There are other conditions that authorize the Director to scale back
enrollment for the next incoming class by five students at a time if compliance with trip target is
not achieved.
The applicant expressed concern with the PTC’s no net new trip recommendation and
submitted a letter14 encouraging the Commission at its November 18th meeting to reconsider its
position. The letter argues that there is no substantial evidence to support this
recommendation and that the staff condition effectively achieved the Commission’s intent to
reduce vehicle trip impacts. The Commission was unmoved by the request, and the no net new
trips recommendation has been incorporated into the draft RLUA (Section 8, Condition 22).
With the inclusion of the no net new trips standard, staff removed a condition (Section 8,
Condition 34) requiring the applicant to make a fair share contribution for intersection
improvements at Kingsley Avenue and Alma Street, which was intended to address a (non -
CEQA related) level of service impacts at this intersection. With the no net new trips condition,
the applicant is not worsening service levels at this intersection.
The PTC recommended other adjustments to the TDM conditions to require reconsideration of
the need for continued data collection after 15 years , clarify report schedules and require real
time data15 collection to be shared with the City for trip counters that would be installed on the
property.
Enforcement, Compliance and Reporting
Having an effective monitoring and enforcement program is essential to ensure community
14 Applicant’s Letter dated, November 17, 2020:
https://www.cityofpaloalto.org/civicax/filebank/documents/79234
15 Real time data collection of trip counters has some useful benefits serving as an additional data source to
corroborate applicant monitoring reports and may serve to indicate if there are data collection problems with any
of the counters. This raw data, however, requ ires staff or consultant analysis to calculate ADT and to determine
the two hour AM Peak period. It also requires reviewing the data to authorized special events, which are days
excluded from the ADT calculation. Staff is not sufficiently resourced to acti vely monitor this data and conduct
daily analysis. Rather, staff will likely review the data periodically during the review period and conduct any
analysis concurrent with the established reporting cycle.
City of Palo Alto Page 19
expectations for performance and compliance with conditions of approval are met. The draft
conditions of approval establish objective standards that make it clear when a violation has
occurred. The conditions allow for public meetings before the PTC for any violation of the CUP,
TDM Plan or mitigation measures. The applicant is required to maintain a deposit with the City
for annual performance reviews, TDM monitoring and analysis, proactive and complaint -driven
enforcement.
The conditions of approval and Mitigation Measure (MM) 7a (Attachmen t 1, Exhibit B) provide
additional enforcement authority related to the following:
• Suspending student enrollment increases and authority to reduce enrollment;
• Timelines to cure violations;
• Imposition of financial penalties for violations in accordance with the City’s fee
schedule;
• Funding for the City’s installation of traffic counter devices on City street segments
(Emerson, Bryant, Kellogg), including independent technical review;
Staff’s approach was to be as comprehensive as possible without overly burdening the
applicant or pushing enforcement to area residents. While some residents may observe issues
and file complaints, the intent is that the City’s code enforcement program would conduct
annual reviews and proactively follow up on TDM compliance and other conditions of approval.
Tree Preservation, Planting and Removal
The project plans have evolved significantly since the application was first submitted and there
have been many refinements to the tree preservation and planting plan. The loss of trees has
been an ongoing concern for many in the community and the revised plans have minimized the
number of impacted trees. All trees, included protected trees planned to be removed, comply
with the City’s tree preservation ordinance. Some in the co mmunity have argued the City erred
in its application of the tree preservation rules. Staff have communicated with area residents
and cited PAMC Section 8.10.050(b)(2)16 as the operative code provision that allows for the
removal of protected trees.
Since the PTC and ARB review of the project, staff has made some minor adjustments to the
draft conditions to provide greater specificity and notations regarding tree preservation
treatments (Conditions 70 and 71). The applicant’s tree plan in some areas incorr ectly diagrams
16 PAMC 8.10.050(b)(2): If no building footprint exists, protected trees shall not be removed unless the trunk of
the tree is located in the building area, or the director of planning and development services has determined, on
the basis of a tree report prepared by a certified arborist for the applicant and other relevant information, that the
tree should be removed because it is dead, is hazardous, is a detriment to or crowding an adjacent protected tree,
or constitutes a nuisance under Section 8.04.050(2) of this code. NOTE: the protected trees being removed or
relocated are within the project site’s building area.
City of Palo Alto Page 20
the tree preservation zones but these graphic errors can be addressed during plan review and
do not affect the careful analysis performed by the City’s Urban Forester. A summary of the
tree removal, replacement and relocation schedule is pro vided below:
• 14 trees are to be removed, including 2 Coast Live Oaks
o 43 replacement trees to be planted onsite, including eight Coast Live Oaks
• 28 trees are to be relocated, including 2 Coast Live Oaks
o 47 mitigation trees to be planted to compensate for less vigorous tree growth in
relocated trees, including six Coast Live Oaks
• 4 trees were already removed, including 2 Redwoods
o 9 replacement trees to be planted onsite
All other non-native ornamental trees will be replaced with native tree species (except 1 Blue
Atlas Cedar and 1 Palm). All replacement tree sizes will be installed with adequate root -ball
area in accordance with City standards.
Based on this plan, 18 trees would be removed and 99 new trees would be planted.
Temporary Campus
Castilleja will continue to operate and have in-class instruction while the site is redeveloped.
Two story modular buildings are proposed on Spieker Field for classrooms, dining,
administrative support offices and ancillary purposes. The proposed layout and renderin g of the
modular buildings are available online at
https://www.cityofpaloalto.org/civicax/filebank/documents/78343 and
https://www.cityofpaloalto.org/civicax/filebank/documents/78344 , respectively. It is
anticipated trees to be planted onsite will be placed temporarily in tree boxes around the
modular buildings to further enhance the aesthetic. The draft conditions of approval also
provide for the timely removal of the modular buildings and preclude increases in student
enrollment beyond 490 students until the modular are removed.
Other Operational Conditions
Included in the draft conditions are several restrictions that pertain to the overall operation of a
school in a residential neighborhood. Some of these address noise, including noise from the
below grade swimming pool; lighting; hours of operation; summer school activity; and, use of
the playing field. Some conditions are carried over from prior approvals.
Community Engagement
There are several conditions that set forth the expectation for how the school will engage its
neighbors and respond to complaints. There are requirements post monitoring reports and
other information online, establishing a dedicated contact phone number and continuing a
prior condition for regular community meetings.
City of Palo Alto Page 21
Construction
As with any construction project, localized disruption from truck traffic, construction equip ment
and related activity will be most impactful to residents closest to the project site. The site’s
adjacency to Bryant Bike Boulevard and the added consideration of students accessing a school
that is under construction requires additional precautions. The EIR’s mitigation monitoring and
reporting program includes several requirements to address various issues, including:
• MM 12a requires compliance with and implementation of the geotechnical
recommendations;
• MM HAZ-1 addresses demolition of hazardous materials
• MM BIO-1 and 2 address construction with respect to bird nesting and bat roosts
• MM 4b addresses tree protection related to demolition and construction;
• MM6a and MM6b address historic resource protection during construction and crew
training on cultural resources at each construction phase;
The Mitigation Monitoring and Reporting Program (MMRP) includes timing and performance
evaluation criteria for these measures. A construction logistics plan is required and provides for
coordination between various City departments and consideration for how students will access
the school safely, as well as onsite construction staging and parking.
Policy Implications:
The project is a significant redevelopment of land located in a residential neighborhood. The
size of the parcel, its use as a private school and the associated impacts to those living nearest
to the site requires thoughtful consideration. The attached application findings, conditions and
other supporting documents, such as the EIR and MMRP can he lp guide the Council in its
deliberation on the requested discretionary applications.
This subject application has generated significant interest both from project proponents and
those in opposition. Staff and the Council-appointed Boards and Commission charged with
reviewing the project have attempted to balance competing interests and thoroughly vet the
project in advance of the City Council’s action.
One critical aspect of the project relies on a zoning code interpretation related to the
subterranean parking facility and whether in an R1 zone it is exempt from gross floor area and,
if exempt, can be placed outside the footprint of an above-grade structure. The site is already
over the permitted floor area allowance and the addition of a parking facility that counts
toward the site’s total gross floor area would require approval of a Variance or legislative
amendment to the zoning code. Neither action is before the City Council at this time, but could
be scheduled if directed by Council.
City of Palo Alto Page 22
If there is support for project approval, the City Council could take action on the discretionary
entitlements as recommended in this report and supported by related attachments. This action
could take place even if the Council was unsure of the zoning code interpretation applied to the
project. One remedy could be to direct staff to prepare a text amendment to clarify the zoning
code in alignment with staff’s past interpretations. Another approach is to delay action on the
requested entitlements and ask the applicant t o file a text amendment for Council
consideration, or alternatively, encourage a project redesign if there is not support for a
subterranean parking facility.
Resource Impact:
The are no signifcant budget or fiscal impacts associated with the processing of this application,
which is paid for by the applicant, including associated consultant costs. If approved, the City
would receive limited, discret deposits to fund ongoing enforcement and for the installation of
vehicle trip counters on the public right of way. The City would also collect permit fees to
recover the costs of the building permit and inspection services.
Stakeholder Engagement:
City staff have an extensive contact list through the City’s website that includes a project page
where subscribers have received notifications for hearings and newly posted documents, and
other updates. The project website is:
https://www.cityofpaloalto.org/gov/topics/castilleja_school/default.asp. In addition, staff have
responded to community inquires, participated in meetings with area residents and the
applicant team as needed or requested.
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 the City Council public hearing was published in the Daily Post on
February 26 which is 10 days in advance of the meeting. Notice cards were sent on February 22
which is 14 days in advance of the meeting.
Environmental Review:
As the Lead Agency pursuant to Public Resources Code Section 21067, the City, in compliance
with CEQA, prepared an Environmental Impact Report (EIR) to provide an assessment of the
potential environmental consequences of approving the Project. The “Draft EIR” was circulated
for public review from July 17, 2019, through September 16, 2019. During the Draft EIR public
comment period, two public hearings were held allowing public testimony on the Draft EIR: (1)
the Planning and Transportation Commission (PTC) hearing of August 14, 2019; and (2) the
Historic Resources Board (HRB) hearing of September 12, 2019. The Draft EIR identified
mitigation measures that would reduce each of the Project’s potentially significant effects to a
City of Palo Alto Page 23
less-than significant level; one unmitigated impact (the TIRE impact on Emerson Street) was due
to the Project’s creation of one student drop -off location within a proposed underground
parking facility. The City of Palo Alto considered the comments received during the Draft EIR
public review period and prepared responses to comments.
An alternatives analysis was completed and included in the Final EIR. The alternatives included
these alternatives – and summaries, analysis and feasibility of the alternatives are provided in
Attachment A.
• Six alternatives preliminarily considered but rejected from detailed analysis because
they were incapable of meeting most of the basic project objectives, would not reduce
or avoid any of the project’s significant effects, and/or would require speculation to
evaluate. These include: offsite alternative – relocate full campus, partial offsite
alternative (relocate a portion of the student body and staff to a new second campus),
other offsite options (relocate sports and special events to other locations), surface
parking, modified circulation routes, and minimum enrollment increase.
• Detailed analysis of three project alternatives: the No Project Alternative (as required
by CEQA), the Moderate Enrollment Increase Alternative, and the Moderate Enrollment
Increase with Reduced Parking Alternative.
• In response to comments received on the Draft EIR, the Final EIR evaluated the
Disbursed Circulation/Reduced Garage Alternative, which has replaced the proposed
project.
• The Final EIR also considered the one additional alternative – the No Garage Alternative
– and provided additional discussion of the alternatives that were preliminarily
considered in the Draft EIR but rejected from detailed analysis as described above.
These included consideration of various alternative enrollment caps, creating a split
campus or a second campus, and relocating the school.
In February 2020, the Applicant submitted a Project Alternative, the “Disbursed
Circulation/Reduced Garage Alternative”, intending to address the Emerson TIRE impact and
other community concerns voiced during the Draft EIR comment period. The City considered
the comments received during the Draft EIR public review period and prepared a Final EIR. The
Final EIR also analyzed the Applicant’s Disbursed Circulation/Reduced Garage Project
Alternative (EIR Alternative #4), and further analyzed or discussed other previously identified
alternatives. The Final EIR, which identified Project Alternative #4 as fully mitigated, was
published July 30, 2020. In accordance with the California Environmental Quality Act (CEQA),
the City provided notice of availability of the Final EIR.
Public hearings before the Architectural Review Board, Historic Review Board, and Planning and
Transportation were held to consider the Final EIR and various discretionary applications on
August 20, August 26, September 9, September 24, October 1, October 28, November 4,
City of Palo Alto Page 24
November 5, and November 18, 2020.
The mitigation measures listed in conjunction with each of the project findings, as implemented
through the Mitigation Monitoring Plan (MMP), will eliminate or reduce to a less than
significant level all adverse environmental impacts of the Castilleja School Project – Disbursed
Circulation/Reduced Garage Alternative. Taken together, the Final EIR, the mitigation measures,
and the MMP provide an adequate basis for approval of the Castilleja School Project –
Disbursed Circulation/Reduced Garage Alternative.
In accordance with CEQA Guidelines §15091(a), a specific finding is made for each impact and
its associated mitigation measures. Mitigation measures are in the EIR and the MMRP. The
topic areas where required mitigation measures address the impacts are:
•Land Use and Planning (Impacts 4-1, 4-2, and 4-3)
•Aesthetics (Impact 5-3)
•Cultural Resources (Impact 6-1)
•Transportation (Impacts 7-1, 7-4, 7-5, and 7-7)
•Noise (Impacts 8-1, 8-2, 8-3)
•Air Quality (Impacts 9-1, 9-3)
A comprehensive summary of the environmental impacts associated with the above topics is
included in Attachment A, Exhibit A. For each impact, mitigation measures have been identified
that would reduce the environmental impact to a level of insignificance. Attachment A, Exhibit
B includes the MMRP that details how these impacts will be mitigated.
The proposed project being considered by the City Council is the Disbursed Circulation/Reduced
Garage Alternativeand it is the environmentally superior project that also meets the project
objectives. There are no significant unavoidable impacts associated with the proposed project
alternative.
Each of the City Council appointed Boards and Commission forwarded recommendations to the
City Council for certification of the Final EIR. Prior to taking action to approve the project, the
City Council would need to adopt a resolution certifying the EIR and adopting the MMRP.
Attachments:
Attachment A: Resolution for EIR and MMRP
Exhibit A to Attachment A: Castilleja CEQA Findings 020421
Exhibit B to Attachment A: Casti MMRP
Attachment B: Record of Land Use Action
RESOLUTION NO. ______
Resolution of the Council of the City of Palo Alto Certifying the Adequacy of the
Final Environmental Impact Report (EIR) for the Castilleja School Project, Making
Certain Findings Concerning Significant Environmental Impacts, Mitigation
Measures, and Alternatives, and Adopting a Mitigation Monitoring and Reporting
Program (MMRP)
On _________, the City Council of the City of Palo Alto (“City Council”), in certifying the
Final EIR for the Castilleja School Project and adopting the MMRP, finds, determines, and RESOLVES as
follows:
RECITALS
A. The Castilleja School Foundation (“Applicant”) has proposed the Castilleja School
Project, which includes approval of a Conditional Use Permit, Variance, and
Architectural Review associated with a phased increase in enrollment to 540 students,
demolition and redevelopment of several campus buildings, and construction of an
underground parking garage (the “Project”).
B. Approval of the Project would constitute a project under the provisions of the
California Environmental Quality Act of 1970, together with related state and local
implementation guidelines promulgated thereunder (“CEQA”).
C. The City is the Lead Agency pursuant to Public Resources Code section 21067 as it has
the principal responsibility to approve and regulate the Project.
D. The City, in compliance with CEQA, prepared an Environmental Impact Report (EIR) to
provide an assessment of the potential environmental consequences of approving the
Project.
E. A Draft Environmental Impact Report (“Draft EIR”) was circulated for public review from
July 17, 2019, through September 16, 2019. During the Draft EIR public comment
period, two public hearings were held allowing public testimony on the Draft EIR: (1) the
Planning and Transportation Commission (PTC) hearing of August 14, 2019; and (2) the
Historic Resources Board (HRB) hearing of September 12, 2019.
F. The Draft EIR identified mitigation measures that would reduce each of the Project’s
potentially significant effects to a less-than significant level; one unmitigated impact
(the TIRE impact on Emerson Street) was due to the Project’s creation of one student
drop-off location within a proposed underground parking facility.
G. The City of Palo Alto considered the comments received during the Draft EIR public
review period and prepared responses to comments.
H. In February 2020, the Applicant submitted a Project Alternative, the “Disbursed
Circulation/Reduced Garage Alternative”, intending to address the Emerson TIRE impact
and other community concerns voiced during the Draft EIR comment period;
I. The City considered the comments received during the Draft EIR public review period
and prepared a Final EIR. The Final EIR also analyzed the Applicant’s Disbursed
Circulation/Reduced Garage Project Alternative (EIR Alternative #4), and further
analyzed or discussed other previously identified alternatives. The Final EIR, which
identified Project Alternative #4 as fully mitigated, was published July 30, 2020. In
accordance with the California Environmental Quality Act (CEQA), the City provided
notice of availability of the Final EIR.
J. The City conducted hearings before the Architectural Review Board, Historic Review
Board, and Planning and Transportation to consider the Final EIR and various
discretionary applications on August 20, August 26, September 9, September 24,
October 1, October 28, November 4, and November 5, 2020.
K. The Council is the decision-making body for approval of the proposed Project.
L. CEQA requires that in connection with approval of a project for which an environmental
impact report has been prepared that identifies one or more significant environmental
effects of the project, the decision-making body of a public agency make certain findings
regarding those significant effects on the environment identified in the environmental
impact report.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS
FOLLOWS:
SECTION 1. Certification and Statements of Findings
The City Council, in the exercise of its independent judgment, makes and adopts the following
findings in addition to those contained in Exhibit A, “Castilleja School Project Statement of
Findings,” dated February 2021, which is incorporated by reference as though included in the
body of this Resolution. These findings comply with the requirements of CEQA, including
Sections 15091, 15092, and 15093 of the CEQA Guidelines, and are based upon the entire
record of proceedings for the Project. All statements set forth in this Resolution and its Exhibits
constitute formal findings of the City Council, including the statements set forth in this
paragraph and in the recitals above.
(a) The Final EIR was presented to and reviewed by the City Council on March 8 and
March 15, 2021.
(b) The Final EIR was prepared under the supervision of the City and reflects the
independent judgment of the City. The City Council has reviewed the Final EIR,
and bases the findings stated below on such review and other substantial
evidence in the record.
(c) The City finds that the Final EIR considers a reasonable range of potentially
feasible alternatives, sufficient to foster informed decision making, public
participation and a reasoned choice, in accordance with CEQA and the CEQA
Guidelines.
(d) The City Council hereby certifies the Final EIR as complete, adequate and in full
compliance with CEQA and as providing an adequate basis for considering and
acting upon the Castilleja School Project and makes the following specific
findings with respect thereto. The City Council has considered evidence and
arguments presented during consideration of the Project and the Final EIR. In
determining whether the Project may have a sign ificant impact on the
environment, and in adopting the findings set forth herein, the City Council
certifies that it has complied with Public Resources Code sections 21081,
21081.5, and 21082.2.
(e) The City Council agrees with the characterization of the Final EIR with respect to
all impacts initially identified as “less than significant” and finds that those
impacts have been described accurately and are less than significant as so
described in the Final EIR.
(f) The descriptions of the impacts in these findings are summary statements.
Reference should be made to the Final EIR for a more complete description.
SECTION 2. Mitigation Monitoring and Reporting Program
(a) CEQA requires the lead agency approving a project to adopt a Mitigation
Monitoring and Reporting Program (MMRP) for the changes made to the project
that it has adopted in order to mitigate or avoid significant effects on the
environment. An MMRP has been prepared and is recommended for adoption
by the City Council concurrently with the adoption of these findings to ensure
compliance with standard project requirements incorporated as part of the
project and mitigation measures during Project implementation. As required by
Public Resources Code section 21081.6, the MMRP designates responsibility and
anticipated timing for the implementation of the mitigation measures
recommended in the Final EIR. The MMRP will remain available for public review
during the compliance period.
(b) The City Council hereby adopts the MMRP for the Project attached hereto as
Exhibit B and incorporated by reference, and finds, determines, and declares
that the adoption of the MMRP will ensure enforcement and continued
imposition of the mitigation measures recommended in the Final EIR, and set
forth in the MMRP, in order to mitigate or avoid significant impacts on the
environment.
//
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST: APPROVED:
__________________________ _____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
__________________________ _____________________________
Assistant City Attorney City Manager
_____________________________
Director of Planning and
Development Services
Castilleja School Project
Statement of Findings
SCH # 2017012052
February 2021
Castilleja School Project
Statement of Findings 1 February 2021
TABLE OF CONTENTS
Table of Contents ....................................................................................................................... 1
I. Overview and Introduction .............................................................................................. 1
II. Statutory Requirements for Findings .............................................................................. 2
III. Definitions ...................................................................................................................... 3
IV. Project Background ........................................................................................................ 4
V. Project Objectives and Description ................................................................................. 5
Project Objectives ............................................................................................... 5
Project Description .............................................................................................. 5
VI. Record of Proceedings ................................................................................................... 5
VII. List of Impacts of the Proposed Project Determined to be Less than Significant or No
Impact without Implementation of Mitigation Measures ............................................. 7
Impacts Evaluated in the Draft EIR ..................................................................... 7
Impacts Evaluated in the Initial Study .................................................................. 9
VIII. Findings for Significant and Potentially Significant Impacts Reduced to Less Than
Significant With Implementation of Mitigation Measures ..........................................12
Land Use and Planning ......................................................................................12
Aesthetics ..........................................................................................................14
Cultural Resources ............................................................................................15
Transportation ....................................................................................................15
Noise .................................................................................................................18
Air Quality ..........................................................................................................19
Significant and Unavoidable Impacts .................................................................21
IX. Project Alternatives Findings .........................................................................................21
Reasonable Range of Project Alternatives .........................................................21
Feasibility of Project Alternatives .......................................................................22
Analysis of Project Alternatives ..........................................................................22
X. Growth Inducement Findings .........................................................................................25
XII. Conclusion ....................................................................................................................26
Castilleja School Project
Statement of Findings 1 February 2021
I. OVERVIEW AND INTRODUCTION
This Statement of Findings is made with respect to approval of the Castilleja School Project and states
the findings of the City Council of the City of Palo Alto (City Council) relating to the potentially significant
environmental effects of the project. This Statement of Findings addresses the environmental effects
associated with the proposed Castilleja School Project, located on Assessor’s Parcel Numbers 124-12-
034 (at 1310 Bryant Street), 124-12-031 (1235 Emerson Street), and 124-12-033 (1263 Emerson
Street).
The City Council, in the exercise of its independent judgment, makes and adopts the following findings
to comply with the requirements of the California Environmental Q uality Act (CEQA; Pub. Resources Code,
sections 21000 et seq.), and Sections 15091, 15092, and 15093 of the CEQA Guidelines (14 Cal. Code
Regs., sections 15000 et seq.). All statements set forth in this Resolution constitute formal findings of the
City Council, including the statements set forth in this paragraph.
These findings are made relative to the conclusions of the City of Palo Alto Castilleja School Project Final
Environmental Impact Report (State Clearinghouse No. 2017012052) (Final EIR), which includes the
Draft Environmental Impact Report (Draft EIR). The Final EIR addresses the environmental impacts
associated with implementation of the Castilleja School Project (the Project, as further defined in Sections
IV and V below) and is incorporated herein by reference. The original Project proposal was defined in Draft
EIR Chapter 3, Project Description; but the Project addressed in these Findings is the Dispersed
Circulation/Reduced Garage Alternative, as described in Final EIR Chapter 2, Master Responses, Master
Response 4. The project requests that the City take the following actions:
1. Certify an Environmental Impact Report and adopt the Mitigation Monitoring Plan.
2. Approve a Conditional Use Permit (CUP) Amendment.
3. Approve a Variance to maintain existing above grade FAR.
4. Approve a lot line adjustment or easement to allow for placement of the below-grade parking
structure exit driveway
5. Approve Architectural Review, Grading Permits, Tree Removal Permits, and Building Permits
(phased development approval(s)).
Approval of the requested entitlements constitutes the project for purposes of CEQA and these
determinations of the City Council. These findings are based upon the entire record of proceedings for
the Project. The City Council finds as follows:
1. The record of proceedings in Section VI of these findings are correct and accurate.
2. The Final EIR has been prepared in accordance with all requirements of CEQA, the CEQA
Guidelines, and the City’s Environmental Impact Ordinance, codified in Title 11 of the City’s
Municipal Code.
3. The Draft EIR was presented to and reviewed by the PTC on August 14, 2019.
4. The Final EIR was presented to and reviewed with the project by the ARB (August 20, 2020,
October 1, November 5), HRB (September 24, 2020), and PTC (August 26, September 9, 2020,
October 28/November 4 and 18). The ARB, HRB, and PTC each provided a recommendation to
the City Council that the City Council should certify the Final EIR.
Castilleja School Project
Statement of Findings 2 February 2021
5. The Final EIR was presented to and reviewed by the City Council on March 8 and March 15,
2021.
6. The Final EIR was prepared under the supervision of the City and reflects the independent
judgment of the City. The City Council has reviewed the Final EIR, and bases the findings stated
below on such review and other substantial evidence in the record.
7. The City finds that the Final EIR considers a reasonable range of potentially feasible alternatives,
sufficient to foster informed decision making, public participation and a reasoned choice, in
accordance with CEQA and the CEQA Guidelines.
8. The City Council hereby certifies the Final EIR as complete, adequate and in full compliance with
CEQA and as providing an adequate basis for considering and acting upon the Castilleja School
Project and makes the following specific findings with respect thereto. The City Council has
considered evidence and arguments presented during consideration of the Project and the Final
EIR. In determining whether the Project may have a significant impact on the environment, and in
adopting the findings set forth herein, the City Council certifies that it has complied with Public
Resources Code sections 21081, 21081.5, and 21082.2.
9. The City Council agrees with the characterization of the Final EIR with respect to all impacts
initially identified as “less than significant” and finds that those impacts have been described
accurately and are less than significant as so described in the Final EIR. This finding does not
apply to impacts identified as significant or potentially significant that are reduced to a less than
significant level by mitigation measures included in the Final EIR. The disposition of each of
those impacts and the mitigation measures adopted to reduce them are addressed specifically in
the findings below.
10. All mitigation measures in the Final EIR are adopted and incorporated into the Castilleja School
Project as described in the Mitigation Monitoring Program (MMP), which includes all mitigation
measures adopted with respect to the project and explains how and by whom they will be
implemented and enforced.
11. The mitigation measures and the MMP have been incorporated into the Conditions of Approval
for the amended Conditional Use Permit and have thus become part of and limitations upon the
entitlements conferred by the project approvals.
12. The descriptions of the impacts in these findings are summary statements. Reference should be
made to the Final EIR for a more complete description.
13. The Planning and Community Environment Department is directed to file a Notice of
Determination with the County Clerk within five (5) working days in accordance with CEQA section
21152(a) and CEQA Guidelines section 15094.
II. STATUTORY REQUIREMENTS FOR FINDINGS
Significant effects of the Castilleja School Project were identified in the Draft EIR. CEQA section 21081
and CEQA Guidelines section 15091 require that the Lead Agency prepare written findings for identified
significant impacts, accompanied by a brief explanation of the rationale for each finding. Less than
significant effects (without mitigation) of the project were also identified in the Draft EIR and Initial Study;
Castilleja School Project
Statement of Findings 3 February 2021
these are listed in Section VII below. CEQA does not require that the Lead Agency prepare written findings
for less than significant effects.
CEQA requires that the Lead Agency adopt mitigation measures or alternatives, where feasible, to avoid
or mitigate significant environmental impacts that would otherwise occur with implementation of the
project. Project mitigation or alternatives are not required, however, where substantial evidence in the
record demonstrates that they are infeasible or where the responsibility for modifying the project lies with
another agency. Specifically, CEQA Guidelines section 15091 states:
(a) No public agency shall approve or carry out a project for which an EIR has been certified which
identifies one or more significant environmental effects of the project unless the public agency
makes one or more written findings for each of those significant effects, accompanied by a brief
explanation of the rationale for each finding. The possible findings are:
(1) Changes or alterations have been required in, or incorporated into, the project which avoid or
substantially lessen the significant environmental effect as identified in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public
agency and not the agency making the finding. Such changes have been adopted by such
other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including provision of
employment opportunities for highly trained workers, make infeasible the mitigation
measures or project alternatives identified in the final EIR.
The “changes or alterations” required or incorporated into the project which mitigate or avoid the
significant environmental effects of the project, as stated to in CEQA Guidelines section 15091(a)(1)
above, may include a wide variety of measures or actions as set forth in CEQA Guidelines section 15370,
including avoiding, minimizing, rectifying, or reducing the impact over time, or compensating for the
impact by replacing or providing substitute resources.
III. DEFINITIONS
The following definitions apply where the subject words or acronyms are used in these findings:
“ARB” means the City of Palo Alto Architectural Review Board.
“BAAQMD” means the Bay Area Air Quality Management District.
“City Council” means the City of Palo Alto City Council.
“CEQA” means the California Environmental Quality Act (Pub. Resources Code section 21000 et
seq.).
“City” means the City of Palo Alto.
“Comprehensive Plan” means the City of Palo Alto Comprehensive Plan, as adopted in 2017 with
subsequent amendments.
“Condition” means a Condition of Approval adopted by the City in connection with approval of the
project.
Castilleja School Project
Statement of Findings 4 February 2021
“CUP” means Conditional Use Permit.
“Draft EIR” means the Draft Environmental Impact Report dated July 2019 for the proposed
Castilleja School Project.
“EIR” means environmental impact report.
“Environmental Impact Ordinance” means the City of Palo Alto Environmental Impact Ordinance,
as codified in Title 11 of the City of Palo Alto Municipal Code.
“Final EIR” means the Final EIR as prepared for the project (which includes the NOP and Initial
Study dated January 2017, the Draft EIR dated July 2019, and the Final EIR dated July
2020).
“HRB” means the City of Palo Alto Historic Resources Board.
“MMP” means the Mitigation Monitoring Program for the project.
“Municipal Code” means the City of Palo Alto Municipal Code, including all amendments thereto.
“NOP” means Notice of Preparation of an EIR.
“PTC” means the City of Palo Alto Planning and Transportation Commission.
“PCE” means the City of Palo Alto Planning and Community Environment Department.
“Project” means the proposed Castilleja School Project, Disbursed Circulation/Reduced Garage
Alternative.
“TDM” means Transportation Demand Management.
“TIRE” means the Traffic Infusion in Residential Environments Index.
“Tree Preservation and Management Regulations” means the City of Palo Alto Tree Preservation
and Management Regulations, as defined in Municipal Code Chapter 8.10.
“Zoning Ordinance” means the City of Palo Alto Zoning Ordinance, including all amendments
thereto.
IV. PROJECT BACKGROUND
Castilleja School Foundation (the project applicant) requested approval of an amendment to the school’s
existing Conditional Use Permit (CUP) to increase student enrollment at the campus, architectural review
of a phased campus modification plan (referred to by the applicant as the Master Plan); a Tentative Map
with Exception to merge two small parcels containing dwelling units with the larger parcel; a variance for
below-grade setback encroachments related to the proposed underground parking structure; and a
variance to maintain existing floor-area-ratio to rebuild 84,124 square feet above grade in a different
configuration.
The Draft EIR evaluated the originally proposed project and found that it would result in # significant and
unavoidable impacts. Castilleja School Foundation submitted a project alternative that would avoid those
impacts and better address community concerns, the Disbursed Circulation/Reduced Garage Alternative.
Castilleja School Foundation now proposes to proceed with this alternative.
Castilleja School Project
Statement of Findings 5 February 2021
V. PROJECT OBJECTIVES AND DESCRIPTION
Project Objectives
The Project Objectives of the project applicant are set forth in Draft EIR sections 1.3, 3.3, and 13.2, which
is incorporated herein by reference. In summary, the project objectives include the following concepts:
1. Maintain a single integrated campus for the middle and upper school with new structures that
integrate state-of-the-art technology and teaching practices and retain flexibility.
2. Achieve better architectural and aesthetic compatibility with adjacent neighborhoods through
building design and landscaping.
3. Increase enrollment to 540 students to allow more young women the unique opportunity to
receive an all-girls education.
4. Increase on-site parking and reduce both parking visibility and surface parking spaces.
5. Improve vehicular, pedestrian, and bicycle access for students and staff.
6. Ensure no increase in vehicle trips to and from the campus during AM and PM peak hours;
reduce the number of service deliveries and relocate deliveries within the campus and below
grade, to decrease nuisance effects to neighbors.
7. Improve the campus’s sustainability and energy efficiency.
8. Phase construction to allow continued operation of Castilleja School during construction and to
reduce impacts on the neighborhood.
Project Description
Under the Disbursed Circulation/Reduced Garage Alternative, Castilleja School Foundation has requested
an amendment of their existing CUP to increase the enrollment cap, and approval for building demolition,
new building construction, and construction of a below-grade parking structure. Construction of proposed
physical improvements would occur in four phases. These include constructing a below-grade parking
structure, constructing a temporary campus, relocating the existing pool, relocating service deliveries a
below grade service area, and demolishing the existing Campus Center and classroom buildings and
replacing them with a single Academic building. The project also includes implementation of an
expanded Transportation Demand Management plan and a Sustainability Road Map.
A complete description of the Disbursed Circulation/Reduced Garage Alternative as proposed by the
project applicant is provided in Final EIR Master Response 4. A conceptual site plan of the proposed
campus is shown in Final EIR Figure MR4-1 and the proposed garage plan is shown in Final EIR Figure
MR4-2. Detailed site plans for this alternative are provided in Final EIR Appendix B2.
VI. RECORD OF PROCEEDINGS
In accordance with CEQA section 21167.6(e), the record of proceedings for the City’s decision on the
Castilleja School project includes, without limitation, the following documents:
The NOP and all other public notices issued by the City in conjunction with the project;
Castilleja School Project
Statement of Findings 6 February 2021
All comments submitted by agencies or members of the public during the comment period on
the NOP (provided in Appendix A of the Draft EIR);
The Draft EIR (July 2019) for the project;
All comments submitted by agencies or members of the public during the comment period on
the Draft EIR;
All comments and correspondence submitted to the City with respect to the Project, in addition
to timely comments on the Draft EIR;
The Final EIR (July 2020) for the project, including comments received on the Draft EIR and
responses to those comments;
Documents cited or referenced in the Draft and Final EIRs;
The project MMP;
All findings and resolutions adopted by the City in connection with the project and all
documents cited or referred to therein;
All reports, studies, memoranda, maps, staff reports, or other planning documents relating to
the project prepared by the City, consultants to the City, or responsible or trustee agencies with
respect to the City’s compliance with the requirements of CEQA and with respect to the City’s
action on the project;
All documents submitted to the City (including the HRB, ARB, PTC, and City Council) by other
public agencies or members of the public in connection with the project;
Any minutes and/or verbatim transcripts of all information sessions, public meetings, and
public hearings held by the City in connection with the project;
Any documentary or other evidence submitted to the City at such information sessions, public
meetings and public hearings;
The City of Palo Alto Comprehensive Plan and all environmental documents prepared in
connection with the adoption of the Comprehensive Plan;
The City of Palo Alto Environmental Impact Ordinance and Zoning Ordinance (City of Palo Alto
Municipal Code, Title 11 and Title 18), and all other City Code provisions cited in materials
prepared by or submitted to the City;
Any and all resolutions and/or ordinances adopted by the City regarding the project, and all
staff reports, analyses, and summaries related to the adoption of those resolutions;
Matters of common knowledge to the City, including, but not limited to federal, state, and local
laws and regulations;
Any documents cited in these findings, in addition to those cited above; and
Any other materials required for the record of proceedings by CEQA section 21167.6(e).
The City Council has relied on all of the documents listed above in reaching its decision on the project,
even if not every document was formally presented to the City Council, PTC or City Staff as part of the City
files generated in connection with the project. Without exception, any documents set forth above not
found in the project files fall into one of two categories. Many of them reflect prior planning or legislative
Castilleja School Project
Statement of Findings 7 February 2021
decisions of which the City Council was aware in approving the Castilleja School Project. (See City of
Santa Cruz v. Local Agency Formation Commission (1978) 76 Cal.App.3d 381, 391-392; Dominey v.
Department of Personnel Administration (1988) 205 Cal.App.3d 729, 738, fn. 6.) Other documents
influenced the expert advice provided to City staff or consultants, who then provided advice to the City
Council. For that reason, such documents form part of the underlying factual basis for the City Council’s
decisions relating to approval of the Castilleja School Project. (See Public Resources Code section
21167.6(e)(10); Browning-Ferris Industries c. City Council of City of San Jose (1986) 181 Cal.App.3d 852,
866; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 153, 155.)
The official custodian of the record is the Planning and Community Environment Director, 285 Hamilton
Avenue, Palo Alto, CA 94301.
VII. LIST OF IMPACTS OF THE PROPOSED PROJECT DETERMINED TO BE LESS
THAN SIGNIFICANT OR NO IMPACT WITHOUT IMPLEMENTATION OF MITIGATION
MEASURES
The City Council agrees with the conclusions in the Final EIR with respect to all impacts initially identified
as “no impact” or “less than significant” that do not require implementation of mitigation measures. This
includes consideration of the project’s potential to have a significant contribution to cumulative impacts.
The impacts determined to be less than significant or no impact without implementation of mitigation
measures include:
Impacts Evaluated in the Draft EIR
Land Use and Planning
Impact 4-4 Substantially contribute to cumulative land use impacts.
Aesthetics
Impact 5-1 Substantially degrade the existing visual character or quality of the site and its
surroundings.
Impact 5-2 Substantially shadow public open space (other than public streets and adjacent
sidewalks).
Impact 5-4 Substantially contribute to cumulative impacts to the visual character of the region.
Cultural Resources
Impact 6-2 Disturb any human remains, including those interred outside of dedicated cemeteries.
Impact 6-3 Contribute to a cumulative loss of cultural resources.
Transportation
Impact 7-2 Conflict with an applicable congestion management program, including, but not limited to
level of service standards and travel demand measures, or other standards established by
the County congestion management agency for designated roads or highways.
Castilleja School Project
Statement of Findings 8 February 2021
Impact 7-3 Result a change in air traffic patterns, including either an increase in traffic levels or a
change in location resulting in substantial safety risks.
Impact 7-6 Conflict with adopted policies, plans, or programs supporting alternative transportation or
otherwise decrease the performance or safety of such facilities.
Noise
Impact 8-4 Expose people to noise levels that exceed established noise standards or gene rate a
substantial permanent increase in ambient noise levels in cumulative plus project
conditions.
Air Quality
Impact 9-2 Result in a cumulatively considerable net increase of any criteria pollutant for which the
project region is non-attainment under an applicable federal or state ambient air quality
standard.
Impact 9-4 Result in other emissions (such as those leading to odors) adversely affecting a substantial
number of people.
Greenhouse Gas Emissions
Impact 10-1 Generate greenhouse gas emissions, either directly or indirectly, that may have a
significant impact on the environment.
Impact 10-2 Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing
the emission of greenhouse gases.
Impact 10-3 Make a cumulatively considerable contribution to emissions of greenhouse gases in the
cumulative scenario.
Energy
Impact 11-1 Result in wasteful, inefficient, or unnecessary consumption of energy.
Impact 11-2 Conflict with existing energy standards and regulations.
Geology, Soils, Seismicity and Paleontology
Impact 12-3 Substantial erosion or loss of topsoil.
Impact 12-6 Substantially contribute to cumulative impacts associated with geology, seismicity, soils
and paleontological resources.
Castilleja School Project
Statement of Findings 9 February 2021
Impacts Evaluated in the Initial Study
Agriculture and Forestry Resources
Impact II.a Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non -agricultural use.
Impact II.b Conflict with existing zoning for agricultural use, or a Williamson Act contract.
Impact II.c Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland (as defined by Public Resources Code
section 4526), or timberland zoned Timberland Production (as defined by Government
Code section 51104(g)).
Impact II.d Result in the loss of forest land or conversion of forest land to non-forest use.
Impact II.e Involve other changes in the existing environment which, due to their location or nature,
could result in conversion of Farmland, to non-agricultural use or conversion of forest land
to non-forest use.
Biological Resources
Impact IV.b Have a substantial adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, regulations, or by the California
Department of Fish and Game or U.S. Fish and Wildlife Service.
Impact IV.c Have a substantial adverse effect on federally protected wetlands as defined by Section
404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling, hydrolo gical interruption, or other means.
Impact IV.d Interfere substantially with the movement of any native resident or migratory fish or wildlife
species or with established native resident or migratory wildlife corridors, or impede the
use of native wildlife nursery sites.
Impact IV.f Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan.
Geology and Soils
Impact VI.e Have soils incapable of adequately supporting the use of septic tanks or alternative waste
water disposal systems where sewers are not available for the disposal of waste water
Hazards and Hazardous Materials
Impact VIII.d Be located on a site that is included on a list of hazardous materials sites compiled
pursuant to Government Code Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment.
Castilleja School Project
Statement of Findings 10 February 2021
Impact VIII.e For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project result
in a safety hazard for people residing or working in the project area.
Impact VIII.f For a project within the vicinity of a private airstrip, would the project result in a safety
hazard for people residing or working in the project area.
Impact VIII.h Expose people or structures to a significant risk of loss, injury or death involving wildland
fires, including where wildlands are adjacent to urbanized areas or where residences are
intermixed with wildlands.
Hydrology and Water Quality
Impact IX.a Violate any water quality standards or waste discharge requirements.
Impact IX.b Substantially deplete groundwater supplies or interfere substantially with groundwater
recharge such that there would be a net deficit in aquifer volume or a lowering of the local
groundwater table level (e.g., the production rate of pre-existing nearby wells would drop
to a level which would not support existing land uses or planned uses for which permits
have been granted).
Impact IX.c Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river, in a manner which would result in substantial
erosion or siltation on- or off-site.
Impact IX.d Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river, or substantially increase the rate or amount of
surface runoff in a manner which would result in flooding on- or off-site.
Impact IX.e Create or contribute runoff water which would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted runoff.
Impact IX.f Otherwise substantially degrade water quality.
Impact IX.g Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard
Boundary or Flood Insurance Rate Map or other flood hazard delineation map.
Impact IX.h Place within a 100-year flood hazard area structures which would impede or redirect flood
flows.
Impact IX.i Expose people or structures to a significant risk of loss, injury or death involving flooding,
including flooding as a result of the failure of a levee or dam.
Impact IX.j Inundation by seiche, tsunami, or mudflow.
Land Use and Planning
Impact X.c Conflict with any applicable habitat conservation plan or natural community conservation
plan.
Castilleja School Project
Statement of Findings 11 February 2021
Mineral Resources
Impact XI.a Result in the loss of availability of a known mineral resource that would be of value to the
region and the residents of the state.
Impact XI.b Result in the loss of availability of a locally-important mineral resource recovery site
delineated on a local general plan, specific plan, or other land use plan.
Noise
Impact XII.e For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project expose
people residing or working in the project area to excessive noise levels.
Impact XII.f For a project within the vicinity of a private airstrip, would the project expose people
residing or working in the project area to excessive noise levels.
Population and Housing
Impact XIII.a Induce substantial population growth in an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for example, through extension of roads or other
infrastructure.
Impact XIII.b Displace substantial numbers of existing housing, necessitating the construction of
replacement housing elsewhere.
Impact XIII.c Displace substantial numbers of people, necessitating the construction of replacement
housing elsewhere.
Public Services
Impact XIV.a Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered governmental facilities, need for new or physically
altered governmental facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times, or
other performance objectives for any of the public services: Fire protection; Police
protection; Schools; Parks; Other public facilities.
Recreation
Impact XV.a Would the project increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical deterioration of the facility would occur
or be accelerated.
Impact XV.b Does the project include recreational facilities or require the construction or expansion of
recreational facilities which might have an adverse physical effect on the environment.
Utilities and Service Systems
Impact XVIII.a Exceed wastewater treatment requirements of the applicable Regional Water Quality
Control Board?
Castilleja School Project
Statement of Findings 12 February 2021
Impact XVIII.b Require or result in the construction of new water or wastewater treatment facilities or
expansion of existing facilities, the construction of which could cause significant
environmental effects?
Impact XVIII.c Require or result in the construction of new storm water drainage facilities or expansion of
existing facilities, the construction of which could cause significant environmental effects?
Impact XVIII.d Have sufficient water supplies available to serve the project from existing entitlements and
resources, or are new or expanded entitlements needed?
Impact XVIII.e Result in a determination by the wastewater treatment provider, which serves or may serve
the project that it has adequate capacity to serve the project’s projected demand in
addition to the provider’s existing commitments?
Impact XVIII.f Be served by a landfill with sufficient permitted capacity to accommodate the project’s
solid waste disposal needs?
Impact XVIII.g Comply with federal, state, and local statutes and regulations related to solid waste?
VIII. FINDINGS FOR SIGNIFICANT AND POTENTIALLY SIGNIFICANT IMPACTS
REDUCED TO LESS THAN SIGNIFICANT WITH IMPLEMENTATION OF MITIGATION
MEASURES
The City Council agrees with the characterization in the Final EIR with respect to all impacts initially
identified as “significant” or “potentially significant” that are reduced to less than significant levels with
implementation of the mitigation measures identified in the Final EIR. In accordance with CEQA
Guidelines §15091(a), a specific finding is made for each impact and its associated mitigation measures
in the discussions below. Mitigation measures are summarized below and are presented in full in the EIR
and the MMP, which are incorporated herein by reference. This section includes findings specific to the
project’s potential to result in a significant contribution to cumulative impacts.
Land Use and Planning
Impact 4-1: Conflict with land use plan, policy, or regulation of an agency with jurisdiction over the project
(including, but not limited to the general plan, specific plan, or zoning ordinance) adopted for the
purpose of avoiding or mitigating an environmental effect.
Summary: As discussed in Final EIR Master Response 4, the Disbursed Circulation/Reduced Garage
Alternative would result in similar impacts as the originally proposed project that were
evaluated in Draft EIR Impact 4-1. Specifically, the Disbursed Circulation/Reduced Garage
Alternative could result in conflicts with the City’s land use plans, policies, and regulations by
increasing the intensity of the existing educational use through potential increases in special
events; removing trees and reducing tree canopy in the project vicinity; potential increases in
traffic associated with increased enrollment; and generating noise levels that could exceed
the Municipal Code standards during project construction and during use of the pool.
Castilleja School Project
Statement of Findings 13 February 2021
Finding: Changes in the project to avoid or substantially lessen the significant environmental effect as
identified in the EIR are required. Implementation of Mitigation Measures 4a, 4b, 7a, 7b, 8a,
and 8b will ensure that the potential for the project to result in new land use incompatibilities
or exacerbate existing land use incompatibilities would be reduced to a less-than-significant
level.
Explanation: These mitigation measures will substantially lessen the project’s environmental effects
by establishing requirements for special events (Mitigation Measure 4a, which includes
defining a maximum number of special events, identifying restrictions on event size and
timing, and identifying requirements for parking, ensuring that the level of special event
activity would be slightly less than currently occurs); requiring tree protection and
replacement consistent with the City’s Tree Preservation and Management Regulations
(Mitigation Measure 4b); identifying performance standards that must be attained through
implementation of an enhanced TDM program (Mitigation Measure 7a); requiring vegetation
management to ensure adequate lines of sight are maintained at site driveways (Mitigation
Measure 7b), and establishing noise performance standards that must be met by the
loudspeaker system at the pool and during construction (Mitigation Measures 8a and 8b).
Significance After Mitigation: Less Than Significant.
Impact 4-2: Create land use incompatibility or physically divide an established community
Summary: As discussed in Final EIR Master Response 4, the Disbursed Circulation/Reduced Garage
Alternative would result in similar impacts as the originally proposed project that were
evaluated in Draft EIR Impact 4-2. Specifically, the Disbursed Circulation/Reduced Garage
Alternative would result in a land use compatibility conflict due to the potential to exacerbate
existing land use conflicts between the school and its residential neighborhood. The analysis
identifies potentially significant impacts that would result from any increases in special
events that could increase disturbance to neighbors and generating noise levels that could
exceed the Municipal Code standards during project construction and from use of the pool.
Finding: Changes in the project to avoid or substantially lessen the significant environmental effect as
identified in the EIR are required. Implementation of Mitigation Measures 4a, 8a and 8b will
ensure that the potential for the project to result in new land use incompatibilities or
exacerbate existing land use incompatibilities would be reduced to a less-than-significant
level.
Explanation: These mitigation measures will substantially lessen the project’s environmental effects
by establishing requirements for special events (Mitigation Measure 4a, which includes
defining a maximum number of special events, identifying restrictions on event size and
timing, and identifying requirements for parking, ensuring that the level of special event
activity would be slightly less than currently occurs), and establishing noise performance
standards that must be met by the loudspeaker system at the pool and during construction
(Mitigation Measures 8a and 8b).
Significance After Mitigation: Less Than Significant.
Castilleja School Project
Statement of Findings 14 February 2021
Impact 4-3: Conflict with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance.
Summary: As discussed in Final EIR Master Response 4, the Disbursed Circulation/Reduced Garage
Alternative would result in similar impacts as the originally proposed project that were
evaluated in Draft EIR Impact 4-3. Specifically, the Disbursed Circulation/Reduced Garage
Alternative would result in tree removal and encroachment of construction activities into tree
protection zones.
Finding: Changes in the project to substantially lessen the significant environmental effect as
identified in the EIR are required. Implementation of Mitigation Measure 4b will ensure that
the potential for the project to result in significant tree loss would be reduced to a less-than-
significant level.
Explanation: Mitigation Measure 4b will substantially lessen the project’s environmental effects
associated with tree loss and adverse effects to retained trees by establishing requirements
for tree protection during and after construction and tree replacement, consistent with the
City’s Tree Preservation and Management Regulations and the City’s Tree Technical Manual.
Significance After Mitigation: Less Than Significant.
Aesthetics
Impact 5-3: Would the project create a new source of substantial light or glare which would adversely
affect day or nighttime views in the area?
Summary: As discussed in Master Response 4 and in Draft EIR Impact 5-3, the Disbursed
Circulation/Reduced Garage Alternative would create new sources of light that could
adversely affect day or nighttime views in the area, and tree removal associated with the
project could increase the potential for outdoor lighting to shine on adjacent property. The
Disbursed Circulation/Reduced Garage Alternative project plans provided in Final EIR
Appendix B2 identify that lighting fixtures for the project would include bollards and ground-
level fixtures along walkways and near building entrances, building-mounted lighting around
building perimeters and at entrances, ground-level lighting in bicycle parking areas, and wall
mounted lighting on steps and planter walls. The potential for windows to result in glare
would be minimized with roof overhangs, tree retention and planting, and fencing that would
reduce direct solar exposure on windows and reduce the potential for light reflecting off
windows to create glare for drivers on adjacent streets. The project does not propose use of
highly reflective surfaces, such as mirrored glass, black glass, or metal building materials and
thus would not create potentially significant impacts associated with glare.
Finding: Changes in the project to avoid the significant environmental effect as identified in the EIR
are required. Implementation of Mitigation Measure 5a will ensure that the potential for the
project to create substantial light spillover onto the adjacent public right-of-way or private
property would be reduced to a less-than-significant level.
Castilleja School Project
Statement of Findings 15 February 2021
Explanation: Mitigation Measure 5a requires the project applicant to develop a lighting plan for each
development phase and requires that the lighting plans demonstrate attainment of the
performance standards identified in the Palo Alto Municipal Code, which requires that lighting
be installed such that no light source within the project site generates a light level greater
than 0.5 foot-candle on any off-site residential property.
Significance After Mitigation: Less Than Significant.
Cultural Resources
Impact 6-1: Cause a substantial adverse change in the significance of a historical or archeological
resource.
Summary: No archeological resources were identified through record searches and surveys, however,
there are known archeological resources in the project region and thus there is a potential for
earth-moving activities to disturb previously unknown archeological resources, if any occurred
on site. The project also has the potential to indirectly or accidentally affect the existing
historic resources onsite and adjacent to the site during construction by exposure to dust,
debris, and accidental contact with construction equipment. The analysis in Draft EIR Chapter
8 demonstrates that vibration associated with project construction is not anticipated to
adversely affect any adjacent historic resources.
Finding: Changes in the project to avoid the significant environmental effect as identified in the EIR
are required. Implementation of Mitigation Measures 6a and 6b will ensure that the potential
for the project to adversely affect significant below-grade archeological resources or cause
damage to historic resources onsite and adjacent to the site during construction would be
reduced to a less-than-significant level.
Explanation: Mitigation Measure 6a requires development and approval of a preservation protection
plan for each phase of construction to ensure that historic buildings within and adjacent to
the site are not adversely affected by dust, debris, and/or damage from accidental contact
with construction equipment. Mitigation Measure 6b requires education of construction
workers on archeological resources and the steps to take in the event of the discovery of any
previously unrecorded resource.
Significance After Mitigation: Less Than Significant.
Transportation
Impact 7-1 Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for
the performance of the circulation system, taking into account all modes of transportation
including mass transit and non-motorized travel
Summary: The Disbursed Circulation/Reduced Garage Alternative includes three drop-off/pick-up
locations for Castilleja students. The project applicant proposed assigning a certain
percentage of students to each of the three locations. As discussed in Master Response 4,
Castilleja School Project
Statement of Findings 16 February 2021
the proposed percentage assignments would create an impact under the TIRE Index by
increasing daily traffic volumes on two segments of Bryant Street and could result in vehicle
queues that exceed capacity for the Bryant Street drop off location.
Finding: Changes in the project to avoid or substantially lessen the significant environmental effect as
identified in the EIR are required. Implementation of Mitigation Measure 7a will ensure that
the potential for the project to create a substantial increase in traffic volumes on Bryant
Street or cause vehicle queues that extend into the public right-of-way would be avoided, thus
the impact would be reduced to a less-than-significant level.
Explanation: Mitigation Measure 7a requires adjustments to the percent of students assigned to each
drop-off/pick-up location, consistent with the recommendations of the Transportation Impact
Analysis prepared for this project. It also includes a requirement that the drop-off
assignments be reassessed through routine monitoring to balance traffic flows sufficient to
avoid a significant TIRE Index increase in the project vicinity and maintain appropriate vehicle
queues. Further, Mitigation Measure 7a identifies performance standards that must be
attained by the school’s enhanced TDM program and establishes requirements for
monitoring and reporting on the effectiveness of the TDM program.
Significance After Mitigation: Less Than Significant.
Impact 7-4: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment
Summary: Draft EIR Impact 7-4 evaluates whether the proposed project could introduce new
roadway hazards by creating vehicle queues that extend into the public right-of-way or
providing inadequate sight distance at driveways where vehicles exit the site and enter the
public right-of-way. As discussed in Master Response 4, the Disbursed Circulation/Reduced
Garage Alternative would result in vehicle queues for the Bryant Street drop-off location that
exceed the available storage and would extend into Bryant Street under the proposed
allocations to each of the three drop-off locations. Additionally, sight distance could be
constrained by landscaping and/or on-street parking at the project site driveways. These
conditions would result in significant impacts.
Finding: Changes in the project are required to avoid the significant environmental effect as identified
in the EIR. Implementation of Mitigation Measures 7a and 7b will ensure that the potential
for the project to substantially increase transportation hazards would be reduced to a less-
than-significant level.
Explanation: Mitigation Measure 7a requires adjustments to the percent of students assigned to each
drop-off/pick-up location, consistent with the recommendations of the Transportation Impact
Analysis prepared for this project to ensure that vehicle queues do not extend into the public
right-of-way. It also includes a requirement that the vehicle queue lengths be monitored and
drop-off assignments be reassessed to ensure that appropriate vehicle queues are
maintained. Mitigation Measure 7b stipulates that a minimum of 150 feet of sight distance
Castilleja School Project
Statement of Findings 17 February 2021
must be maintained through vegetation trimming and prohibiting on -street parking adjacent
to each driveway.
Significance After Mitigation: Less Than Significant.
Impact 7-5: Result in inadequate emergency access.
Summary: The project would not create traffic congestion or changes in roadway configurations that
could interfere with emergency response or substantially lengthen response times but could
result in interference with emergency response in the project vicinity if vehicle queues at the
drop-off/pick-up locations extend into the public right-of-way.
Finding: Changes in the project are required to avoid the significant environmental effect as identified
in the EIR. Implementation of Mitigation Measure 7a will ensure that the potential for the
project to cause vehicle queues that extend into the public right-of-way would be avoided,
thus the impact would be reduced to a less-than-significant level.
Explanation: Mitigation Measure 7a requires that the drop-off/pick-up location assignments be
assessed through routine monitoring and adjusted to balance traffic flows sufficient to
maintain appropriate vehicle queues.
Significance After Mitigation: Less Than Significant.
Impact 7-7: Contribute to a cumulative increase in traffic that conflicts with adopted policies and plans.
Summary: The City’s traffic model anticipates that background traffic volumes will continue to
increase over time, but Castilleja traffic is expected to remain constant or decrease because
the school would be required under the TDM plan and Mitigation Measure 7a to maintain a
maximum daily trip rate of 2.4 trips per student. The project’s contribution to cumulative
impacts would be less than significant for all roadways in the study area except the segments
of Bryant Street between Embarcadero Road and Churchill Avenue.
Finding: Changes in the project are required to substantially lessen the significant environmental
effect as identified in the EIR. Implementation of Mitigation Measure 7a will ensure that the
potential for the project to create a substantial increase in traffic volumes on Bryant Street
would be avoided, thus the impact would be reduced to a less-than-significant level.
Explanation: Mitigation Measure 7a requires adjustments to the percent of students assigned to each
drop-off/pick-up location, consistent with the recommendations of the Transportation Impact
Analysis prepared for this project. It also includes a requirement that the drop-off
assignments be reassessed through routine monitoring to balance traffic flows sufficient to
avoid a significant TIRE Index increase in the project vicinity. Further, Mitigation Measure 7a
identifies performance standards that must be attained by the school’s enhanced TDM
program and establishes requirements for monitoring and reporting on the effectiveness of
the TDM program.
Castilleja School Project
Statement of Findings 18 February 2021
Significance After Mitigation: Less Than Significant.
Noise
Impact 8-1: Expose people to or generate noise levels in excess of standards established in the local
general plan or noise ordinance, or applicable standards of other agencies; or create a
substantial permanent increase in ambient noise levels in the project vicinity above levels
existing without the project
Summary: Nighttime outdoor special events and use of amplified sound during pool events has the
potential to expose people to or generate noise levels in excess of the standards established
in the Comprehensive Plan and Municipal Code. The project would not create significant
noise impacts associated with vehicle traffic because it would not result in a doubling of
traffic volumes on any roadway segments. The project would not create significant noise
impacts associated with truck and bus activity because it would relocate delivery and trash
pickup activity to a below-grade loading zone and would relocate bus loading to the interior of
the project site.
Finding: Changes in the project are required to substantially lessen the significant environmental
effect as identified in the EIR. Implementation of Mitigation Measures 4a and 8a will ensure
that the potential for the project to create a substantial increase in noise levels associated
with special events would be avoided, thus the impact would be reduced to a less-than-
significant level.
Explanation: Mitigation Measure 4a, as identified in Draft EIR Chapter 4, Land Use, will ensure that
excessive nighttime noise is not generated by special events by requiring that athletic
competitions end by 8 p.m. Mitigation Measure 8a establishes a performance standard that
must be attained at the time that the loudspeaker system for the pool area is designed,
which must be demonstrated in a noise assessment prepared by a qualified acoustical
consultant.
Significance After Mitigation: Less Than Significant.
Impact 8-2: Create a substantial temporary or periodic increase in ambient noise levels in the project
vicinity above levels existing without the proposed project
Summary: The project could generate substantial periodic increases in noise during nighttime
outdoor special events and use of amplified sound during pool events and project
construction activities could generate substantial temporary increases in noise.
Finding: Changes in the project are required to substantially lessen the significant environmental
effect as identified in the EIR. Implementation of Mitigation Measures 4a, 8a, and 8b will
ensure that the potential for the project to create substantial periodic or temporary increases
in noise levels associated with special events and construction would be avoided, thus the
impact would be reduced to a less-than-significant level.
Castilleja School Project
Statement of Findings 19 February 2021
Explanation: Mitigation Measure 4a, as identified in Draft EIR Chapter 4, Land Use, will ensure that
excessive nighttime noise is not generated by special events by requiring that athletic
competitions end by 8 p.m. Mitigation Measure 8a establishes a performance standard that
must be attained at the time that the loudspeaker system for the pool area is designed,
which must be demonstrated in a noise assessment prepared by a qualified acoustical
consultant. Mitigation Measure 8b will ensure that noise levels during construction remain
below the City’s standards for maximum instantaneous noise levels and for the amount by
which construction noise levels exceed ambient noise conditions by requiring for each
construction phase that Castilleja School submit to the City an inventory and schedule of the
construction equipment proposed to be used during that phase, a technical analysis of the
noise levels that could be generated during construction, and recommended measures to
ensure that noise levels during construction meet the City’s standards.
Significance After Mitigation: Less Than Significant.
Impact 8-3: Expose people to or generate excessive ground borne vibrations or ground borne noise levels
Summary: Construction of the Disbursed Circulation/Reduced Garage Alternative would involve use
of a variety of heavy equipment, which could cause ground borne vibration. None of the
residential structures in the project vicinity would be exposed to vibrations that could cause
vibration damage, but the onsite Administration/Chapel building could be subject to ground
borne vibration damage during demolition of the adjacent academic building. The project
does not include any operational activities that would result in groundborne vibration or noise
that would be perceptible off site.
Finding: Changes in the project are required to avoid the significant environmental effect as identified
in the EIR. Implementation of Mitigation Measure 6a will ensure that the potential for the
project to cause excessive ground borne vibration would be avoided, thus the impact would
be reduced to a less-than-significant level.
Explanation: Mitigation Measure 6a, as presented in Draft EIR Chapter 6, Cultural Resources,
requires that a protection plan be implemented for the Administration/Chapel Theater
building that documents the specific nature of demolition activities that would occur on any
portion of the building that touches or is within 25 feet of the Administration/Chapel Theater
building and provides recommendations for equipment usage and demolition techniques that
will avoid adverse effects to the Administration/Chapel Theater building by ensuring that
continuous vibrations remain below approximately 0.25 in/sec.
Significance After Mitigation: Less Than Significant.
Air Quality
Impact 9-1: 1 Conflict with or obstruct implementation of the applicable air quality plan.
Castilleja School Project
Statement of Findings 20 February 2021
Summary: Construction of the project is not expected to result in average daily emissions of criteria
air pollutants that exceed the BAAQMD thresholds. However, the project could conflict with or
obstruct implementation of the 2017 Clean Air Plan if the BAAQMD basic control measures
for reducing construction emissions of coarse particulate matter are not implemented, as
required by the Comprehensive Plan.
Finding: Changes in the project are required to avoid the significant environmental effect as identified
in the EIR. Implementation of Mitigation Measure 9a will ensure that the potential for the
project to conflict with or obstruct implementation of the 2017 Clean Air Plan would be
avoided, thus the impact would be reduced to a less-than-significant level.
Explanation: Mitigation Measure 9a requires that the City of Palo Alto ensure that site plan notes
include requirements for the construction contractor to implement the BAAQMD Basic
Construction Emission Control Measures and perform visual inspections during construction.
With implementation of Mitigation Measure 9a, project construction would be consistent with
the 2017 Clean Air Plan and the City’s requirements for limiting construction emissions.
Significance After Mitigation: Less Than Significant.
Impact 9-3 Expose sensitive receptors to substantial pollutant concentrations
Summary: As discussed in Final EIR Master Response 4, the Disbursed Circulation/Reduced Garage
Alternative would result in similar impacts as the originally proposed project as discussed in
Impact 9-3. As discussed under Draft EIR Impact 9-3, demolition of structures built prior to
1980 could result in the release of contaminated materials and hazardous substances that
may be present in the buildings, such as lead-based paint or asbestos. Other construction
activities would not expose students, workers, or neighbors to substantial air pollutant
concentrations. Vehicle traffic during operation of the proposed project would not be
expected to create carbon monoxide hotspots that could expose sensitive receptors to
substantial concentrations of hazardous emissions.
Finding: Changes in the project are required to avoid the significant environmental effect as identified
in the EIR. Implementation of Mitigation Measure HAZ-1 will ensure that the potential for the
project to expose sensitive receptors to substantial pollutant concentrations would be
avoided, thus the impact would be reduced to a less-than-significant level.
Explanation: Mitigation Measure HAZ-1, as identified in the Initial Study (Final EIR Appendix A),
requires that prior to issuance of a demolition permit, the project applicant shall retain a
qualified professional to complete a survey of the building proposed for demolition to
determine if lead-containing materials, asbestos containing materials, and/or polychlorinated
biphenyls are present; retaining a contractor trained and qualified to conduct lead- or
asbestos-related construction work to carry out any demolition activities likely to disturb such
materials; and following regulatory protocols for handling and disposal of these materials.
Significance After Mitigation: Less Than Significant.
Castilleja School Project
Statement of Findings 21 February 2021
Significant and Unavoidable Impacts
The City Council agrees with the characterization in the Final EIR that all of the significant and potentially
significant impacts that could result from the Disbursed Circulation/Reduced Garage Alternative would be
reduced to less-than-significant levels and thus the project would not result in any significant and
unavoidable environmental impacts.
IX. PROJECT ALTERNATIVES FINDINGS
Public Resources Code section 21002 provides that “public agencies should not approve projects as
proposed if there are feasible alternatives or feasible mitigation measures available which would
substantially lessen the significant environmental effects of such project[s].” When a lead agency finds,
even after the adoption of all feasible mitigation measures, that a project will still cause one or more
significant environmental effects that cannot be substantially lessened or avoided, it must, prior to
approving the project as mitigated, first determine whether there are any project alternatives that are
feasible and that would substantially lessen or avoid the project’s significant impacts. As stated in Section
VIII above, there are no significant and unavoidable impacts associated with the proposed project.
However, an alternatives analysis was completed and included in the Final EIR.
Reasonable Range of Project Alternatives
CEQA Guidelines §15126.6(f) states that the range of alternatives required in an EIR is governed by a
“rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned
choice. Further, CEQA Guidelines §15126(a) requires that an EIR describe a reasonable range of
alternatives that would “feasibly obtain most of the basic project objectives” but would avoid or
substantially lessen any of the significant environmental effects of the project and evaluate the
comparative merits of the alternatives. Thus, the project objectives presented in the EIR provided the
framework for defining the possible alternatives. Based upon guidance contained in the CEQA Guidelines
and applicable case law as well as the project objectives, the Final EIR provides the following analysis
regarding project alternatives:
• The Draft EIR identified six alternatives that were preliminarily considered but rejected from
detailed analysis because they were incapable of meeting most of the basic project objectives,
would not reduce or avoid any of the project’s significant effects, and/or would require
speculation to evaluate. These include: offsite alternative – relocate full campus, partial offsite
alternative (relocate a portion of the student body and staff to a new second campus), other
offsite options (relocate sports and special events to other locations), surface parking, modified
circulation routes, and minimum enrollment increase.
• The Draft EIR provided detailed analysis of three project alternatives: the No Project Alternative
(as required by CEQA), the Moderate Enrollment Increase Alternative, and the Moderate
Enrollment Increase with Reduced Parking Alternative.
• In response to comments received on the Draft EIR, the Final EIR evaluated the Disbursed
Circulation/Reduced Garage Alternative, which, as discussed in Section III, has replaced the
proposed project.
Castilleja School Project
Statement of Findings 22 February 2021
• The Final EIR also considered the one additional alternative – the No Garage Alternative – and
provided additional discussion of the alternatives that were preliminarily considered in the Draft
EIR but rejected from detailed analysis as described above. These included consideration of
various alternative enrollment caps, creating a split campus or a second campus, and relocating
the school.
The City Council finds that that a good-faith effort was made to evaluate a reasonable range of potentially
feasible alternatives in the EIR that are reasonable alternatives to the project and could feasibly obtain
most of the basic objectives of the project, even when the alternatives might impede the attainment of
the project’s objectives and might be more costly.
Feasibility of Project Alternatives
Although an EIR must evaluate a range of potentially feasible alternatives, an agency decision-making
body may ultimately conclude that a potentially feasible alternative is actually infeasible. (California
Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1001-1002.) CEQA Guidelines
§15126.6(f)(1) provides that among the factors that may be taken into account when addressing the
feasibility of alternatives are “site suitability, economic viability, availability of infrastructure, general plan
consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent
can reasonably acquire, control or otherwise have access to the alternative site.”
Grounds for a conclusion of infeasibility might be the failure of an alternative to fully satisfy project
objectives deemed to be important by decision-makers, or the fact that an alternative fails to promote
policy objectives of concern to such decision-makers. (Id. at pp. 992, 1000-1003.) It is well established
under CEQA that an agency may reject alternatives based on economic infeasibility. (Foundation for San
Francisco’s Architectural Heritage v. City and County of San Francisco (1980) 106 Cal.App.3d 893, 913-
914; San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102
Cal.App.4th 656, 774; Association of Irritated Residents v. County of Madera (2003) 107 Cal.App.4th
1383, 1399-1400; Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490, 1510.) In addition, the
definition of feasibility encompasses “desirability” to the extent that an agency’s determination of
infeasibility represents a reasonable balancing of competing economic, environmental, social, and
technological factors supported by substantial evidence. (City of Del Mar v. City of San Diego (1982) 133
Cal.App.3d 410; 417.) Thus, even if a project alternative will avoid or substantially lessen any of the
significant environmental effects of a proposed project as mitigated, the decision-makers may reject the
alternative for such reasons.
Analysis of Project Alternatives
No Project Alternative
The No Project Alternative assumes that the proposed Castilleja School Project would not be constructed
and that no changes to the existing Conditional Use Permit would be made. Castilleja would be restricted
to a maximum enrollment of 415 students each year. No demolition or construction would occur within
the campus, and no changes would be made to the school’s special event schedule or provisions for
student, staff, and visitor parking. The EIR concluded that this alternative would have reduced impacts
associated with land use, aesthetics, cultural resources, transportation, noise, and air quality; however
the No Project Alternative would not meet any of the proposed project objectives and would not achieve
Castilleja School Project
Statement of Findings 23 February 2021
the project’s aesthetic benefits associated with enhancing the site architecture, landscaping, and fencing
and the project’s noise benefits of reducing neighbors’ exposure to noise associated with use of the pool.
No Project Alternative Findings: The City Council finds that this alternative is infeasible in that it meets
none of the project objectives. Specifically, it does not support the project objectives of increasing
enrollment, increasing the campus’s sustainability and energy efficiency, increasing on-site parking,
and improving architectural compatibility with the surrounding neighborhood. For all of the foregoing
reasons, and for any of them individually, the City Council determines that the No Project Alternative
is infeasible and is hereby rejected.
Moderate Enrollment Increase Alternative
This alternative considered a maximum enrollment of 506 students, which is 34 students fewer than
proposed. The Moderate Enrollment Increase Alternative would include construction of the new academic
building to include 30 classrooms, construction of the below-grade parking structure with 117 parking
spaces (as contemplated in the original Castilleja School Project proposal), demolition of the two
residential structures on Emerson Street (as contemplated in the original Castilleja School Project
proposal), and a reduction in the number of parking spaces in the proposed surface parking lot at
Emerson Street and Kellogg Avenue.
The Moderate Enrollment Increase Alternative was found to slightly reduce potential land use and
transportation impacts compared to the originally proposed project but would increase those impacts
compared to the Disbursed Circulation/Reduced Garage Alternative. This alternative would result in
similar aesthetic impacts as either the originally proposed project or the Disbursed Circulation/Reduced
Garage Alternative because building scale, massing, materials, colors, and details as well as landscaping
and fencing would be generally the same. The Moderate Enrollment Increase Alternative would also
result in similar impacts associated with cultural resources, noise, air quality, greenhouse gas emissions,
energy, and geology and soils as the proposed project because it would involve a similar level of
construction and project site redevelopment.
Moderate Enrollment Increase Alternative Findings: While the alternative may be feasible and capable of
meeting most of the basic project objectives, this alternative does not substantially reduce impacts
compared to the proposed project, and would increase the potential land use and transportation
impacts compared to the Disbursed Circulation/Reduced Garage Alternative. Therefore, under CEQA,
the Moderate Enrollment Increase Alternative is not environmentally superior to the proposed project.
Moderate Enrollment Increase with Reduced Parking Alternative
The Moderate Enrollment Increase with Reduced Parking Alternative would establish a maximum
enrollment of 506 students and would reduce the on-site parking to the minimum required by code by
reducing the size of the below-grade parking structure to 58 spaces and increasing surface parking within
the project site. This alternative would require two fewer classrooms and 46 fewer parking spaces than
the proposed project.
The Moderate Enrollment Increase with Reduced Parking Alternative was found to slightly reduce
potential land use and transportation impacts compared to the originally proposed project but would
increase those impacts compared to the Disbursed Circulation/Reduced Garage Alternative. This
alternative would result in a slight reduction in aesthetic impacts as either the originally proposed project
Castilleja School Project
Statement of Findings 24 February 2021
or the Disbursed Circulation/Reduced Garage Alternative because building scale and massing would be
slightly reduced, while building materials, colors, and details as well as landscaping and fencing would be
generally the same. The Moderate Enrollment Increase with Reduced Parking Alternative would also
result in similar impacts associated with cultural resources, noise, air quality, greenhouse gas emissions,
energy, and geology and soils as the proposed project because it would involve a similar level of
construction and project site redevelopment.
Moderate Enrollment Increase with Reduced Parking Alternative Findings: While the alternative may be
feasible and capable of meeting most of the basic project objectives, this alternative does not
substantially reduce impacts compared to the proposed project, and would increase the potential
land use and transportation impacts compared to the Disbursed Circulation/Reduced Garage
Alternative. Therefore, under CEQA, the Moderate Enrollment Increase with Reduced Parking
Alternative is not environmentally superior to the proposed project.
No Garage Alternative
The No Garage Alternative eliminates the parking garage from the project while accommodating a slightly
reduced level of redevelopment in other areas of the project. A surface parking lot would be created along
Emerson Street, in place of the two existing residential structures. This alternative would use a similar
disbursed circulation plan as the Disbursed Circulation/Reduced Garage Alternative, with drop-off/pick-up
occurring at the Bryant Street loop driveway, the Kellogg Avenue loop driveway, and the Emerson Street
surface parking lot. Based on the space available for the Emerson Street surface parking lot, the No
Garage Alternative also includes a reduction in classroom space and a commensurate reduction in the
enrollment cap. The No Garage Alternative would provide 92 parking spaces, allowing for construction of
a total of 29 classrooms and accommodating an enrollment cap of 489 students.
The No Garage Alternative would result in the following potential changes in the project’s environmental
effects:
• Increased potential for loss of community character by replacing landscaped residential lots
(current condition) or a landscaped passive park setting (proposed project) with a surface parking
lot. Landscaping and fencing could be used to shield public views of the parking lot, keeping this
effect at a less than significant level.
• Increased amount of tree removal in the parking lot location, but this impact would be reduced to
a less-than-significant level with implementation of Mitigation Measure 4b, and thus, impacts
would not be increased in comparison to the Disbursed Circulation/Reduced Garage Alternative.
• Reduced potential transportation impacts due to the reduction in student enrollment, however
the alternative would result in a potential for TIRE Index impacts on Bryant Street and for vehicle
queues to extend into the public right-of-way. These impacts would be reduced to a less-than-
significant level with implementation of Mitigation Measure 7a.
• Potential for increased noise impacts to residences on Emerson Street associated with use of the
surface parking lot for special event parking. During daytime special events, noise effects from
use of the parking lot would be mitigated with an appropriate setback and noise barrier
constructed along the northern boundary of the parking lot. During evening special events, when
the City’s noise standards are lower to reflect the higher noise sensitivity in nighttime hours, it
may be necessary to restrict parking within the northernmost portion of the surface parking lot to
Castilleja School Project
Statement of Findings 25 February 2021
ensure that noise exposure for the adjacent residence remains at acceptable levels. This could
result in additional on-street parking during evening events compared to the proposed project,
however parking demand would not be greater than under existing conditions and thus this does
not indicate that this alternative would result in a new significant impact.
• Similar impacts associated with cultural resources, air quality, greenhouse gas emissions, energy,
and geology and soils as the proposed project because it would involve a similar level of
construction and project site redevelopment.
No Garage Alternative Findings: This alternative would require a substantial reduction in the proposed
enrollment level. Thus, this alternative would impede attainment of one of the primary project
objectives. Additionally, this alternative has the potential to increase some project impacts, although
the impacts would be reduced to less-than-significant levels with implementation of mitigation
measures. Further, this alternative does not substantially reduce impacts compared to the proposed
project. Therefore, under CEQA, the No Garage Alternative is not environmentally superior to the
proposed project.
X. GROWTH INDUCEMENT FINDINGS
Growth can be induced in a number of ways, such as through the elimination of obstacles to growth,
through the stimulation of economic activity within the region, or through the establishment of policies or
other precedents that directly or indirectly encourage additional growth. Induced growth would be
considered a significant impact if it can be demonstrated that the potential growth would directly or
indirectly have a significant effect on the environment.
New employees from commercial or industrial development and new population from residential
development represent direct forms of growth. These direct forms of growth have a secondary effect of
expanding the size of local markets and inducing additional economic activity in the area. A project could
indirectly induce growth by reducing or removing barriers to growth, or by creating a condition that
attracts additional population or new economic activity.
Construction of the Castilleja School Project would create short-term construction jobs. These are
anticipated to be filled by workers who, for the most part, already reside in the surrounding area.
Therefore, project construction is not expected to induce other growth in the City or region.
The proposed increase in student enrollment would require add an additional 10 employees at full p roject
buildout. The existing school currently employs 122 full time employees. These new employees could
indirectly induce a small amount of economic growth in the City to the extent that the employees might
seek housing and would be expected to purchase food and services in the area. However, the potential
for growth inducement due to the increase in employees is not considered substantial because the scale
of the expected increase in employment is insufficient to trigger noticeable changes in the housing
market or demand for local goods and services, as evaluated in Draft EIR Section 14.4.
Finding: The Castilleja School Project would not induce substantial growth in the project area or
region.
Castilleja School Project
Statement of Findings 26 February 2021
Explanation: The potential for growth inducement due to project construction and the increase in
student enrollment is not considered substantial. The increase in employment opportunities
associated with the project (10 new employees) would provide would be insufficient to trigger
noticeable changes in the housing market or demand for local goods and services. In
addition, construction of the proposed project would be temporary and these short-term
construction jobs are anticipated to be filled by workers who, for the most part, reside in the
surrounding area.
XII. CONCLUSION
The mitigation measures listed in conjunction with each of the findings set forth above, as implemented
through the MMP, will eliminate or reduce to a less than significant level all adverse environmental
impacts of the Castilleja School Project – Disbursed Circulation/Reduced Garage Alternative.
Taken together, the Final EIR, the mitigation measures, and the MMP provide an adequate basis for
approval of the Castilleja School Project – Disbursed Circulation/Reduced Garage Alternative.
Castilleja School Project MMRP 10056
October 2020 1
CASTILLEJA SCHOOL PROJECT
MITIGATION MONITORING AND REPORTING PROGRAM
Introduction
Section 15097 of the California Environmental Quality Act (CEQA) Guidelines requires that, whenever
a public agency approves a project based on an Environmental Impact Report (EIR), the public agency
shall establish a mitigation monitoring or reporting program to ensure that all adopted mitigation
measures are implemented.
This Mitigation Monitoring and Reporting Program (MMRP) is intended to satisfy this requirement of
the CEQA Guidelines for the Castilleja School Project, as evaluated in the Castilleja School Project EIR,
State Clearinghouse Number 2017012052. This MMRP will be used by City of Palo Alto (City) staff and
mitigation monitoring personnel to ensure compliance with the mitigation measures included in the
certified EIR (inclusive of those measures identified in the Initial Study provided in EIR Appendix A)
during project implementation and operation.
The intent of the MMRP is to ensure effective implementation and enforcement of all adopted
mitigation measures. The MMRP addresses the requirements for development of detailed plans,
monitoring activities, and reporting regarding construction and operational activities authorized under
the Castilleja School 2020 Conditional Use Permit. The mitigation measure numbering reflects the
numbering used in the Castilleja School Project EIR.
Mitigation Monitoring and Reporting Program Overview
The MMRP includes three tables. Table 1 lists the full text of each mitigation measure and specific
requirements for implementation, monitoring, and timing of each required action, as well as
performance criteria by which the City can verify that each measure has been implemented effectively.
Where a timing requirement is indicated as “in perpetuity,” these requirements shall remain in effect
throughout all operational activities of Castilleja School at its current location at 1310 Bryant Street,
unless modified by future amendments to the Conditional Use Permit.
Tables 2 and 3 are formatted to serve as checklists for the City to verify compliance with measures
that apply only to construction activities (Table 2) and those that apply only to operational activities
(Table 3). They repeat the mitigation measure text and performance criteria and include blank columns
where the City can record actions taken to verify mitigation measure implementation and attainment
of the identified performance criteria. These checklists will be incorporated into the project file
maintained by the City’s Department of Planning and Community Environment and available for public
review.
Castilleja School Project MMRP 10056
October 2020 2
Castilleja School Project MMRP
Table 1
Castilleja School Project MMRP
Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
EIR MITIGATION MEASURES
LAND USE AND PLANNING
Mitigation Measure 4a: The Castilleja School Conditional Use
Permit shall include the following restrictions for onsite special
events:
1. A special event is an event that is separate from the
school’s daily educational programs and includes a
minimum of 50 guests. When a special event is held
during instructional hours and related school programing,
students and staff already onsite are not considered
guests. When a special event is held outside of
instructional hours and related school programming, all
attendees (including students and staff) are considered
guests.
2. There shall be a maximum of 90 special events each year,
which includes 5 Major Events, defined as events that
bring almost all students and parents to the Castilleja
campus.
3. No special events may occur on campus on Sundays.
4. Athletic competitions of any size may occur only on
weekdays and shall be complete by 8 pm.
5. For special events that occur during instructional hours
and related school programming and have between 50
Implementation:
City of Palo Alto to ensure
requirements included in
Conditional Use Permit (CUP)
Castilleja School to ensure special
event schedules, sizes, and
parking plans comply with the
requirements
Monitoring: City of Palo Alto
Timing:
At time of CUP approval –
requirements included in CUP
In perpetuity – adhere to special
events requirements
In perpetuity – parking plans
submitted to City prior to onsite
special events
No more than 90 special events are
held in any calendar year.
No onsite events are held on
Sundays
All athletic competitions occur on
weekdays and end by 8 p.m.
A parking plan is prepared and
submitted to the City prior to each
event. A single parking plan may be
prepared to apply to more than one
event, when those events occur in
similar time periods and have similar
attendance (e.g., a single plan that
applies to multiple events held during
instructional hours and related school
programming with between 50 and
80 guests; a separate single plan that
applies to multiple events held
outside of instructional hours and
related school programing and have
fewer than 160 guests). Such plan(s)
would be submitted for City review
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Table 1
Castilleja School Project MMRP
Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
and 80 guests, Castilleja shall prepare a parking plan
identifying the amount of on-site parking not used by
students and staff (in the below-grade parking garage, on
Spieker Field, and within surface parking lots), the amount
of on-street parking available around the project site’s
frontage on Kellogg Avenue and Emerson Street,
additional on-street parking opportunities in the
neighborhood, and nearby park and ride parking lots that
guests could use to facilitate ride sharing.
6. For events that occur during instructional hours and
related school programing and have more than 80 guests,
Castilleja shall prepare a parking plan identifying the
amount of on-site parking not used by students and staff
as well as use best efforts to park at one or more satellite
parking locations, if available, sufficient to provide at least
one parking space for every 1.3 guests and provide
shuttle service for guests using those locations. Further,
Castilleja shall retain traffic monitors to help direct event
traffic to appropriate parking locations.
7. For events that occur outside of instructional hours and
related school programing and have fewer than 160
guests, all parking shall occur on-site.
8. For events that occur outside of instructional hours and
related school programing and have more than 160
guests, Castilleja shall prepare a parking plan identifying
the amount of on-site parking not used by students and
staff as well as use best efforts to park at one or more
satellite parking locations, if available, sufficient to provide
at least one parking space for every 1.3 guests and
provide shuttle service for guests using those locations.
and approval once annually prior to
the first event intended to be covered
by that plan and thereafter applied to
multiple events (with similar timing
and attendance) without additional
City review and approval. This does
not preclude Castilleja from preparing
additional plans for events with
similar timing and attendance within
the same calendar year.
Castilleja implements approved
parking plan, utilizes traffic monitors,
and provides shuttle service during
events (if required based on the size
and timing of the event)
City or third-party compliance monitor
conducts occasional field inspections
to verify adherence to
conditions/restrictions of the CUP
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
Further, Castilleja shall retain traffic monitors to help direct
event traffic to appropriate parking locations.
Mitigation Measure 4b: Prior to issuance of demolition, grading,
and/or building permits for each construction phase, Castilleja
School shall submit to the City Arborist a Tree Protection and
Preservation Plan meeting the requirements of the Tree Technical
Manual Sections 2.10 and 6.30. This shall include an inventory of
the species, size, and condition of all trees within 50 feet of the
construction area. The Tree Protection, Removal, and Relocation
Plan must identify the regulatory status of each tree based on the
tree size at the time this plan is prepared for each construction
phase. For the regulated trees to be retained in place, the Tree
Protection and Preservation Plan must identify specific tree
protection measures to be in place during construction, consistent
with Section 8.10 of the Palo Alto Municipal Code. Tree protection
measures for unregulated trees must also be identified.
For all trees to be removed, the Tree Protection and Preservation
Plan must identify their species and size and identify specific
locations where new tree planting would occur to replace the
removed trees. For trees that are protected under the Municipal
Code, replacement planting must include trees of the same
species as the protected tree to be removed, and must include
sufficient new trees to replace the tree canopy consistent with the
replanting ratios identified in Tree Technical Manual Table 3-1
based on the size of the tree at the time of removal or relocation.
For trees that are not protected under the Municipal Code,
replacement planting must be sufficient to provide no net loss of
tree canopy after 10 years. If it is not possible to plant all required
replacement trees onsite, the requirements of Section 3.15 of the
Tree Technical Manual shall apply, allowing for tree replacement
using the Tree Value Replacement Standard in Tree Technical
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to issuance of demolition,
grading, and/or building permits for
each construction phase – submit
Tree Protection and Preservation
Plan, implement all pre-
construction tree protection
measures identified in the
approved plan, and submit
Verification of Tree Protection
Report
During construction – Conduct
monthly inspections and submit
Monthly Inspection Report
Five years following completion of
each construction phase – Monitor
all trees (retained, relocated,
newly planted) and submit annual
reports
Additional five years after
subsequent replanting – for
All tree protection, removal, planting,
and monitoring complies with the
Tree Technical Manual
Tree Protection and Preservation
Plan submitted to City for review and
approval for each construction phase
All identified pre-construction tree
protection measures are
implemented, as documented in a
Verification of Tree Protection Report
submitted to City prior to issuance of
a grading permit
Routine inspections and monitoring
are conducted throughout each
construction phase and documented
in Monthly Inspection Reports filed
with the City
All retained, relocated, and planted
trees are monitored for five (5) years
from completion of the construction
phase; annual reports are filed.
Any trees that do not survive the
initial five (5) year monitoring are
replaced and monitored for five (5)
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Mitigation Measure
Implementation Responsibility,
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and Timing Performance Evaluation Criteria
Manual Section 3.25, and for that sum of money to be used in the
following order of preference, as approved by the Director: (1) to
provide additional trees elsewhere on the site; (2) to add or
replace street trees or other public landscaping in the vicinity, or
(3) to add trees or other landscaping to other City property.
For trees to be relocated, the Tree Protection and Preservation
Plan must identify the specific methods for tree removal, storage,
and replanting for each individual tree, including the location
where the tree would be replanted and when that replanting would
occur. Because tree relocation shortens a tree’s lifespan,
replacement planting is required for all relocated trees consistent
with the Tree Technical Manual Table 3-1 (and Section 3.15 if
some replacement trees cannot be planted onsite). The relocated
tree shall be included as one of the required replacement trees.
For example, if the Tree Canopy Replacement Standard would
require planting three trees, the applicant would replant the
relocated tree and two new trees.
Following City approval of the Tree Protection and Preservation
Plan but prior to issuance of demolition, grading, or building
permits, the project applicant shall implement all pre-construction
tree protection measures identified in the approved plan (such as
mulching, pruning, irrigation, and installation of tree protection
fencing). The project arborist shall inspect and review the installed
tree protection measures and submit to the City a Verification of
Tree Protection Report, consistent with Tree Technical Manual
Section 2.15B. Throughout all construction activities, the project
arborist shall conduct routine inspections and monitoring to ensure
all pre-construction tree protection measures are being maintained
and all specific construction methods to minimize tree impacts are
monitoring additional replanting if
needed
years from the date of planting;
annual reports are filed
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
being implemented. The project arborist shall file a Monthly
Inspection Report, as defined in the Tree Technical Manual.
All retained, relocated, and newly planted trees shall be monitored
for a period of five years after planting/replanting to ensure they
have successfully established. Should any trees not survive, they
shall be replaced and monitored for a period of five years.
Mitigation Measures 7a and 7b (see Transportation section below)
Mitigation Measures 8a and 8b (see Noise section below)
AESTHETICS
Mitigation Measure 5a: Prior to issuance of building permits for
each construction phase, Castilleja School shall submit a lighting
plan that identifies the specific light fixtures to be used and their
proposed locations. The lighting plan shall also identify the
expected light levels within the property and at the property
boundaries. The lighting plans must demonstrate compliance with
the criteria identified in Palo Alto Municipal Code Section
18.23.030. This includes requirements such as spillover reduction;
use of high pressure sodium and metal halide as permitted light
sources; lighting limits of 0.5 foot-candle, as measured at the
abutting residential property line; designing interior lighting to
minimize nighttime glow; using low intensity lighting for building
exteriors, parking areas, and pedestrian ways; and directing
pedestrian and security lighting downward.
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to issuance of building
permits for each construction
phase – lighting plan submitted
Prior to issuance of certificate of
occupancy – verification lighting
installed in accordance with
approved plan
Lighting plans comply with Palo Alto
Municipal Code Section 18.23.030
Installed lighting comports with
lighting plans
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Castilleja School Project MMRP
Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
CULTURAL RESOURCES
Mitigation Measure 6a: A protection plan shall be implemented
for the Administration/Chapel Theater building and the residence
at 1215 Emerson Street during proposed new construction and
renovation activities to prevent damage to these structures. A
clear and concise preservation protection plan shall be developed
to provide these details. The protection plan shall be prepared by
a qualified historic preservation specialist and shall be appended
to the final set of construction plans for each construction phase.
At a minimum, the protection plan shall include the following:
Protective fencing shall be installed approximately 15 feet
from the perimeter of the Administration/Chapel Theater
building and from the southern and eastern property lines
of the residence at 1215 Emerson Street, or a lesser
distance if recommended by a qualified historic
preservation specialist. All construction workers shall be
instructed to keep all people, materials, and equipment
outside of the areas surrounded by protective fencing. The
protective fencing shall consist of brightly-colored mesh
fencing at least four feet in height. The mesh shall be
mounted on six-foot tall poles, with at least two feet below
ground, and spaced a maximum of six feet apart.
Material and equipment delivery and stockpile areas shall
be identified on the protection plan, and shall be located
as far as practicable from the Administration/Chapel
Theater building and the residence at 1215 Emerson
Street.
If cranes are used to install buildings or building
components, no materials or structures shall be
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to issuance of grading,
demolition, and/or building permits
for each construction phase –
Protection plan submitted for City
review and approval
During all construction activity –
Protection plan implemented
Protection plan identifies location and
specifications for protective fencing,
equipment delivery and stockpile
areas, crane locations and usage
controls, demolition equipment and
control within 25 feet of the
Administration/Chapel building, and
dust control.
Known historic resources are not
damaged during construction
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
suspended above or within 30 feet measured horizontally
from the exterior walls of the Administration/Chapel
Theater building and the residence at 1215 Emerson
Street.
For demolition of the existing Classroom building, the
protection plan shall document the specific nature of
demolition activities that would occur on any portion of the
building that touches or is within 25 feet of the
Administration/Chapel Theater building and provide
recommendations for equipment usage and demolition
techniques that will avoid adverse effects to the
Administration/Chapel Theater building.
The protection plan shall prescribe measures for
containment of dust during demolition, excavation, and
construction. This may include wetting soils and materials
to prevent wind-blown dust; covering exposed materials,
soil, and unfinished buildings; and use of temporary
barriers to prevent any wind-blown dust from reaching
historic structures.
Mitigation Measure 6b: Prior to initiation of construction for each
construction phase, all construction crew members, consultants,
and other personnel shall receive project-specific Cultural
Resource Awareness training. The training shall be conducted in
coordination with qualified cultural resource specialists and shall
inform project personnel of the potential to encounter sensitive
archaeological material. In the event that archaeological resources
(sites, features, or artifacts) are exposed during construction
activities for the proposed project, all construction work occurring
within 100 feet of the find shall immediately stop until a qualified
archaeologist, meeting the Secretary of the Interior’s Professional
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to commencement of ground
disturbing activities for each
Verification that Cultural Resource
Awareness training was provided to
all construction crew members,
consultants, and other personnel is
provided to the City through submittal
of training materials (videos and/or
handouts) and dated attendance logs
for each training session
If any cultural resources are
encountered, ground disturbance is
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
Qualification Standards, can evaluate the significance of the find
and determine whether additional study is warranted. Prehistoric
archaeological deposits may be indicated by the presence of
discolored or dark soil, fire-affected material, concentrations of
fragmented or whole marine shell, burned or complete bone, non-
local lithic materials, or the characteristic observed to be atypical
of the surrounding area. Common prehistoric artifacts may include
modified or battered lithic materials; lithic or bone tools that
appeared to have been used for chopping, drilling, or grinding;
projectile points; fired clay ceramics or non-functional items; and
other items. Historic-age deposits are often indicated by the
presence of glass bottles and shards, ceramic material, building or
domestic refuse, ferrous metal, or old features such as concrete
foundations or privies. Depending upon the significance of the find
under CEQA (14 CCR 15064.5(f); PRC Section 21082), the
archaeologist may simply record the find and allow work to
continue. If the discovery proves significant under CEQA,
additional work, such as preparation of an archaeological
treatment plan, testing, or data recovery may be warranted and
would be implemented if recommended by the qualified
archeologist.
construction phase – construction
crew training
Throughout all ground disturbing
activities – construction crew halts
work to allow for evaluation of any
discovered cultural resources
halted, the resource is evaluated,
and any treatment recommendations
made by a qualified archeologist are
implemented
TRANSPORTATION
Mitigation Measure 7a: Castilleja School shall implement the
proposed enhanced Transportation Demand Management (TDM)
plan (Appendix B) to reduce the average daily trips and maintain a
maximum peak hour trip volume. The measures currently listed in
the TDM plan are expected to reduce daily traffic by between 12
and 22 percent. Through the ongoing monitoring and reporting
described in this measure, Castilleja School and the City will
identify the effectiveness of the TDM measures and any need to
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
TDM plan is implemented during
construction and in perpetuity
Driveway vehicle count equipment is
installed prior to issuance of
certificates of occupancy
Throughout construction, driveway
counts and monitoring reports
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Mitigation Measure
Implementation Responsibility,
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and Timing Performance Evaluation Criteria
modify their implementation and/or add new TDM measures
sufficient to:
maintain a maximum average daily trip count of 1,296
trips starting two years after construction of the Academic
building is complete and through all subsequent years,
maintain a maximum average daily AM Peak Hour trip
count of 440 trips, and
ensure that vehicle queues for each drop of location are
fully contained within the project site such that no cars are
queuing on or blocking the vehicle lane or the bike lane on
any adjacent public street.
Castilleja School shall conduct routine traffic monitoring and
submit monitoring reports to the City three times per year until the
school has reached its maximum enrollment for two consecutive
years and has attained the average peak hour and average daily
trip standards. After that time, only two monitoring reports per year
shall be required. As part of the monitoring, Castilleja shall install
traffic counting devices at each project site driveway and submit
the raw data along with a data summary and analysis in the
monitoring reports. The analysis shall also include reporting of
drop-off lane discharge rates, and the average and maximum
lengths of ingress and egress queues in the four 15-minute
increments prior to the first bell for each grade level (start of the
first class session of the day) and the 15-minute increment
following the first bell for the grade level(s) with the latest start
time each day.
Student enrollment at Castilleja School shall increase by no more
than 27 students in any academic year. In the period between
commencement of construction and attainment of the maximum
During construction – install
driveway vehicle count
equipment
In perpetuity beginning
during construction –
implement TDM plan,
conduct monitoring and
reporting, conduct active
traffic management
demonstrate that average AM peak
hour traffic volumes are 440 trips or
less, not including days on which
special events are held
Throughout construction and for two
years following completion of the
Academic building, three monitoring
reports are submitted to the City in
each academic year (generally every
3 months, beginning approximately 3
months after the first day of school
for that year)
Once full enrollment is reached for
two consecutive years and the
average peak hour and average daily
trip standards are achieved, two
monitoring reports are submitted to
the City in each academic year
(generally every 4.5 months,
beginning approximately 4.5 months
after the first day of school for that
year)
Beginning at the start of the third
academic year after completing the
Academic building, driveway counts
and monitoring reports demonstrate
that average AM peak hour traffic
volumes are 440 trips or less and
average daily traffic volumes are
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
enrollment level, if the peak hour standard is not achieved
additional TDM measures shall be implemented as follows:
1st report showing an average daily AM peak hour trip
count above 440 - add an additional TDM measure
2nd consecutive report showing an average daily AM
peak hour trip count above 440 – add a more intensive
TDM measure
3rd consecutive report showing an average daily AM peak
hour trip count above 440 - reduce enrollment by at least
5 students, or more as determined necessary by the City
to ensure attainment of the average daily AM peak hour
standard, in next admission cycle.
In the period between commencement of construction and two
years following completion of the Academic building, daily trip
counts shall be monitored and reported for informational
purposes.
Beginning two years following completion of the Academic
building, if the peak hour and daily trip standards are not
achieved, additional TDM measures shall be implemented as
follows:
1st report showing an average daily AM peak hour trip
count above 440 and/or average daily trip count above
1,296 - add an additional TDM measure
2nd consecutive report showing an average daily AM
peak hour trip count above 440 and/or average daily trip
count above 1,296 – add a more intensive TDM measure
1,296 trips or less, not including days
on which special events are held
If a monitoring report demonstrates
that the average AM peak hour and
average daily trip (when applicable)
standards were exceeded during that
monitoring/reporting period,
additional TDM measures are
implemented in the subsequent
monitoring/reporting period
If applicable standards are exceeded
in all three (or two, where applicable)
monitoring/reporting periods,
enrollment is reduced for the
following academic year
Active traffic management is
implemented as identified in the
Garage Circulation Plan, or
subsequent plans approved by the
City, during all drop-off and pick-up
periods and during special events
with more than 75 guests.
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Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
3rd consecutive report showing an average daily AM peak
hour trip count above 440 and/or average daily trip count
above 1,296 - reduce enrollment by at least 5 students, or
more as determined necessary by the City to ensure
attainment of the average daily AM peak hour and
average daily trip count standards, in next admission
cycle.
1st and/or 2nd reports in the subsequent year showing an
average daily AM peak hour trip count above 440 and/or
average daily trip count above 1,296 – implement more
intensive TDM measures
3rd report in the subsequent year showing an average
daily AM peak hour trip count above 440 and/or average
daily trip count above 1,296 – reduce enrollment in the
next admission cycle by at least 10% or more as
determined necessary by the City to ensure attainment of
the average daily AM peak hour and average daily trip
count standards.
Castilleja School shall conduct active traffic management as
identified in the Garage Circulation Plan (Figure 3-12), or
subsequent plans approved by the City, during all drop-off and
pick-up periods and during special events with more than 75
guests. This includes having 7 school staff members stationed
along the drop-off/pick-up queues to direct vehicle and pedestrian
movements into, within, and exiting the garage. Traffic entering or
exiting the project site driveways on Bryant Street shall be
restricted to right-turns; traffic exiting the parking garage onto
Emerson Street shall also be restricted to right-turns. Traffic
management staff shall direct vehicles to loop around the school if
they are approaching a project site driveway where there is a
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Implementation Responsibility,
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and Timing Performance Evaluation Criteria
queue that would not permit the vehicle to completely exit the
public right-of-way. As part of the traffic monitoring and reporting,
Castilleja shall instruct the traffic management staff to report any
excessive vehicle queues, safety concerns, or other concerns or
recommendations to improve safety and circulation to the
administration. These staff reports and Castilleja’s response to
each shall be summarized in the traffic monitoring reports.
As described in the TDM plan (Appendix B), Castilleja School
shall implement some or all of the following measures sufficient to
attain the average peak hour and average daily trip standards:
1. late afternoon shuttle departures
2. off-site drop-off/pick-up area
3. expanded carpool/trip planning program
4. additional off-site parking
5. parking/carpool incentives program for employees
6. alternative transportation information
7. bike tune-up day and on-site repair stations
8. Guaranteed Ride Home program
9. on-site car or bike sharing program
10. provide transit passes
11. mandatory ridesharing
12. other TDM measures developed by Castilleja in
coordination with the City of Palo Alto (City), including the
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Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
monitoring and enforcement provisions identified in
Appendix B.
In addition, Castilleja School shall modify the proposed enhanced
TDM plan to include the following
13. Educate staff, students, and families regarding the
importance of an efficient and safe student drop-off
operation to prevent excessive queuing in the garage.
14. Provide staff, students, and families with required drop-
off/pick-up and parking procedures to include that drop-off
and pick-up must occur in the garage unless there are
extenuating circumstances, daily parking for parents or
other community members attending meetings or other
activities onsite shall occur within the garage or on-site
surface parking lots, outside of special events.
15. Conduct ongoing monitoring of drop-off lane discharge
rates and ingress and egress queues.
16. If vehicle queues are causing spillover into the public right
of way on Bryant Street, modify the drop-off procedures
and TDM program to include greater staggering of bell
schedules or other strategies that would decrease vehicle
trips or otherwise spread out the number of peak hour
vehicle trips accessing the underground garage.
17. Provide bicycle safety education for students, parents,
and staff to encourage students and staff to ride bicycles
to and from school.
18. Host school-wide bicycle encouragement events (such as
competitions, incentives, and other fun events) to support
biking, walking, carpooling, and transit use so that the
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
school community understands that active transportation
is a community-held value.
Mitigation Measure 7b: Castilleja School shall maintain
vegetation within 40 feet of the school’s driveways onto public
streets such that vegetation is trimmed down to a height of less
than three feet and trees trimmed up so that nothing hangs below
a height of seven feet from the surface of the roadway. Vegetation
shall be trimmed no less once per month. Castilleja School shall
provide the City with evidence of a landscaping management plan
or active landscape maintenance contract annually. Castilleja
School and the City shall provide curb markings to prohibit on-
street parking within 35 feet of each driveway.
Implementation:
City of Palo Alto provide curb
markings
Castilleja School maintain
vegetation
Monitoring: City of Palo Alto
Timing: In perpetuity beginning
during construction
No vegetation within 40 feet of
school’s driveways onto public
streets is present between three feet
and seven feet from the surface of
the roadway
Evidence of landscaping
management plan or active
landscape maintenance contract is
submitted to the City annually
Curb markings are maintained at all
times
NOISE
Mitigation Measure 4a (see Land Use and Planning section above)
Mitigation Measure 8a: Prior to issuance of a building permit for
the outdoor pool, Castilleja School shall submit to the City a
technical analysis documenting the specific loudspeaker
equipment proposed for use at the pool, the locations and
positioning of speakers, and the likely noise levels for each of the
receptor locations evaluated in the Environmental Noise Study for
the proposed Castilleja School Conditional Use Permit
Amendment and Master Plan. The technical analysis shall
demonstrate that use of the loudspeaker would not generate noise
levels that are more than 6 dB greater than existing noise levels
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing: Prior to issuance of building
permit for pool
Technical analysis submitted to City
identifying specific loudspeaker
equipment and locations and
positions of speakers
Use of the loudspeaker does not
generate noise levels that are more
than 6 dB greater than existing noise
levels
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
Mitigation Measure 8b: Prior to issuance of demolition, grading
and/or building permits for each construction phase, Castilleja
School shall submit to the City a technical analysis of the noise
levels that could be generated during construction and
recommended measures to ensure that noise levels during
construction meet the City’s standards. This analysis must include
and be based on a list of the construction equipment proposed to
be used (including horsepower), a schedule for the use of each
piece of equipment during that phase, and the general location
where each piece of equipment would operate. Noise reduction
measures may include modifying the equipment list, restrictions
on the number of individual pieces of equipment that may be used
at one time, modifying the location of individual pieces of
equipment, providing shielding for individual pieces of equipment,
use of temporary noise attenuation barriers, and/or other
measures that are demonstrated to be sufficient to ensure that the
maximum noise level at the property boundary would remain at or
below 110 dB and increases in hourly noise levels at the property
boundary would not exceed 10 dBA above the ambient noise level
for two or more hours per day, more than five days per week, for a
period of 12 months or more.
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to issuance of demolition,
grading, and/or building permits for
each phase of construction –
construction noise analysis
submitted
Ongoing during construction –
noise control measures
implemented
Technical analysis of construction
noise levels and recommended noise
control measures submitted
Recommended measures
implemented sufficient to ensure that
the maximum noise level at the
property boundary would remain at or
below 110 dB and increases in hourly
noise levels at the property boundary
would not exceed 10 dBA above the
ambient noise level for two or more
hours per day, more than five days
per week, for a period of 12 months
or more
AIR QUALITY
Mitigation Measure 9a: Prior to issuance of demolition permits,
grading permits, or building permits for the proposed project, the
City of Palo Alto shall ensure that site plan notes include
requirements for the construction contractor to implement the
following Basic Construction Emission Control Measures. Visual
site inspections shall be conducted throughout construction to
ensure these measures are implemented appropriately:
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Notes on site plans for each
construction phase include
requirements for construction
contractor to implement Basic
Construction Emission Control
Measures
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Implementation Responsibility,
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and Timing Performance Evaluation Criteria
1. All exposed surfaces shall be watered two times daily.
Exposed surfaces include, but are not limited to parking
and staging areas, soil piles, graded areas, and unpaved
access roads.
2. Haul trucks transporting soil, sand, or other loose material
off-site shall be covered.
3. Wet power vacuum street sweepers shall be used to
remove any visible trackout of mud or dirt onto adjacent
public roads at least once a day. Use of dry power
sweeping is prohibited.
4. Vehicle speeds on unpaved roads to shall be limited to a
maximum of 15 miles per hour.
5. All roadways, driveways, sidewalks, and parking lots to be
paved shall be completed as soon as possible. In
addition, building pads shall be laid as soon as possible
after grading unless seeding or soil binders are used.
6. Materials stockpiles shall be covered on days when they
are not accessed, including any day on which construction
does not occur.
7. Idling times shall be minimized either by shutting
equipment off when not in use or reducing the maximum
idling time to 5 minutes (as required by the California
airborne toxics control measure Title 13, Section 2485 of
California Code of Regulations [CCR]). Clear signage
shall be provided for construction workers at all access
points.
8. All construction equipment shall be maintained and
properly tuned in accordance with manufacturer’s
Prior to issuance of demolition,
grading, or building permits – site
plans contain appropriate emission
control notes
Throughout construction – site
inspections
Emission control measures are
implemented throughout all
construction
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
specifications. All equipment shall be checked by a
certified mechanic and determined to be running in proper
condition prior to operation.
9. The construction contractor shall post a publicly visible
sign with the telephone number and person to contact at
the City of Palo Alto regarding dust complaints. This
person shall respond and take corrective action within 48
hours. The BAAQMD phone number shall also be visible.
Mitigation Measure HAZ-1 (see Hazards and Hazardous Materials section below)
GEOLOGY, SOILS, AND SEISMICITY
Mitigation Measure 12a: Project design and construction shall
show compliance with and implement all of the recommendations
contained in the geotechnical investigation (January 2107) and
supplemental recommendations memorandum (March 2017)
prepared by Silicon Valley Soil Engineering or provide an
acceptable equivalent to these measures to the satisfaction of the
Director of Public Works Engineering in order to reduce hazards
related to expansive soils and the stability of soil and landforms.
These include but are not limited to:
1. the basement foundation system should use a
concrete mat slab with a minimum thickness of 12
inches and underlain by 6 inches of ¾-inch clean
crushed rock and waterproofed;
2. basement retaining walls shall be designed using a
pseudo-static force value of 2.71kips per lineal foot of
wall length acting at a distance of 0.6H from the
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to issuance of demolition,
grading, or building permits – site
plans reflect geotechnical
investigation and supplemental
memorandum recommendations
Prior to issuance of certificate of
occupancy – site inspections to
verify as built conditions
All recommendations contained in
the geotechnical investigation
(January 2107) and supplemental
recommendations memorandum
(March 2017) prepared by Silicon
Valley Soil Engineering, or
acceptable equivalents, are
implemented during construction
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Mitigation Measure
Implementation Responsibility,
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and Timing Performance Evaluation Criteria
bottom of the wall, which shall be added to the lateral
active force for seismic loading condition,
3. basement retaining walls shall be waterproofed
consistent with the recommendations of the
geotechnical investigation and a waterproofing
consultant;
4. shoring shall be provided for trenches and excavation
in excess of five feet in depth;
5. a geotechnical engineer shall be retained to observe
and inspect all earthwork and grading;
6. within construction areas, organic materials shall be
stripped from the soil and the soil shall be scarified by
machine to a depth of 12 inches and thoroughly
cleaned of vegetation and other deleterious matter;
7. subgrade shall be compacted to not less than 90%
relative maximum density per ASTM D1557-12 at a
moisture content greater than 3% above the optimum
moisture provided that the subgrade meets
compaction and is determined to be stable under
construction equipment loading; and
8. a contingency dewatering plan shall be prepared that
provides for collection of any surface runoff water and
perched groundwater and use of the water as
approved by the City and consistent with the City’s
dewatering requirements, such as for on-site dust
suppression, street-sweeping, and other City
programs.
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
Mitigation Measure 12b: A discovery of a paleontological
specimen during any phase of the project shall result in a work
stoppage in the vicinity of the find until it can be evaluated by a
professional paleontologist. Any paleontological resource
discovered on site should be either preserved at its location or
adequately documented as a condition of removal. Should loss or
damage be detected, additional protective measures or further
action (e.g., resource removal), as determined by a professional
paleontologist, shall be implemented to ensure that the
information potential represented by the resource is retained.
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing: Throughout construction
Work is stopped within 100 feet of
any paleontological specimen
discovered during construction
Any discovered specimens are
evaluated by a professional
paleontologist
Recommended protective measures
or further action, as determined by
the paleontologist, are implemented
prior to resuming construction
INITIAL STUDY MITIGATION MEASURES
BIOLOGICAL RESOURCES
Mitigation Measure BIO-1: If feasible, vegetation on the project
site shall be removed outside of the bird-nesting season. If the
start of site clearing, tree removal, or building demolition occurs
between February 1 and August 31, a pre-construction survey for
nesting birds protected under the Migratory Bird Treaty Act shall
be conducted by a qualified biologist to identify the location of
nests in active use that were established prior to the start of
project implementation activities. The pre-construction survey
shall take place no more than 7 days prior to initiation of
construction. All trees and shrubs on the site and on adjacent
properties shall be surveyed, with particular attention to any trees
or shrubs that would be removed or directly disturbed. If an active
nest of a protected bird is found on site, the biologist shall, in
consultation with the California Department of Fish and Wildlife
(CDFW), determine whether construction work would affect the
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing: Prior to issuance of
demolition, tree removal, and/or
grading permits for each
construction phase
Pre-construction surveys are
completed and submitted to the City
within 7 days of commencement of
construction activity if construction
begins between February 1 and
August 31
No construction occurs within 300
feet of active raptor nests.
Consultation with CDFW occurs prior
to construction if an active nest of a
protected bird is identified within the
project site
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
active nest or disrupt reproductive behavior. Criteria used for this
evaluation shall include presence of visual screening between the
nest and construction activities, and behavior of adult birds in
response to the surveyors or other ambient human activity. If
construction could affect the nest or disrupt reproductive behavior,
the biologist shall, in consultation with CDFW, determine an
appropriate construction-free buffer zone around the nest to
remain in place until the young have fledged or other appropriate
protective measures are taken to ensure no take of protected
species occurs.
If it is determined that construction will affect an active raptor nest
or disrupt reproductive behavior, then avoidance is the only
mitigation available. Construction shall not be permitted within 300
feet of such a nest until a qualified biologist determines that the
subject nests are no longer active.
Prior to issuance of a demolition permit or tree removal permit, the
City of Palo Alto (City) shall verify that pre-construction surveys
have been conducted within 10 days of the proposed start of
demolition. If active bird nests are present, the City shall verify that
CDFW has been consulted and either determined that
construction will not affect an active bird nest or that appropriate
construction-free buffer zones have been established or other
appropriate protective measures have been taken.
Mitigation Measure BIO-2: No earlier than 30 days prior to
initiation of demolition activities, a pre-construction survey shall be
conducted by a qualified biologist (i.e., a biologist holding a
California Department of Fish and Wildlife (CDFW) collection
permit and a Memorandum of Understanding with CDFW allowing
the biologist to handle bats) to determine if active bat roosts or
Implementation: Castilleja School
Monitoring: City of Palo Alto
Pre-construction surveys completed
and reports submitted to the City no
more than 30 days prior to demolition
If active roosts are found within 300
feet of the demolition activities,
CDFW is consulted and no
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Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
maternal colonies are present on or within 300 feet of the
demolition area.
Should an active maternity roost be identified, the roost shall not
be disturbed and demolition and construction within 300 feet of the
maternity roost shall be postponed or halted until the juveniles
have fledged and the roost is vacated, as determined by a
qualified biologist. Consultation with CDFW shall also be initiated.
Under no circumstance shall an active roost be directly disturbed.
If nonbreeding bat hibernacula are found on the project site, the
individuals shall be safely evicted under the direction of a qualified
bat biologist and with consultation with CDFW. These actions shall
allow bats to leave during nighttime hours, thus increasing their
chance of finding new roosts with a minimum of potential
predation during daylight.
If it is determined that demolition or construction will not affect
roosting behavior or disrupt a maternal colony, demolition or
construction may proceed without any restriction or mitigation
measure.
If it is determined that demolition or construction will affect an
active bat roost or disrupt reproductive behavior, then avoidance
is the only mitigation available. Under no circumstance shall an
active roost be directly disturbed. Demolition or construction within
300 feet shall be postponed or halted until the roost is naturally
vacated as determined by a qualified biologist.
Prior to issuance of a demolition permit, the City of Palo Alto (City)
shall verify that pre-construction surveys have been conducted
within 30 days of the proposed start of demolition. If bats are
present, the City shall verify that CDFW has been consulted and
either determined that construction will not affect an active bat
Timing: Prior to issuance of
demolition permits for each
construction phase
demolition occurs within 300 feet of
active roosts
Individuals within any nonbreeding
bat hibernacula are evicted in
compliance with recommendations
from a qualified biologist and in
consultation with CDFW
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Castilleja School Project MMRP
Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
roost or disrupt a maternal colony, or that individuals in a
nonbreeding bat hibernacula have been safely evicted.
Due to regulations from the California Health Department, direct
contact by construction workers with any bat is not allowed.
HAZARDS AND HAZARDOUS MATERIALS
Mitigation Measure HAZ-1: Prior to building demolition, the
project applicant shall demonstrate to the satisfaction of the City of
Palo Alto that a survey of the existing buildings has been
conducted by a qualified environmental specialist who meets the
requirements of the current U.S. Environmental Protection Agency
regulations for suspected lead-containing materials (LCMs),
including lead-based paint/coatings; asbestos containing materials
(ACMs); and the presence of polychlorinated biphenyls (PCBs).
Any demolition activities likely to disturb LCMs or ACMs shall be
carried out by a contractor trained and qualified to conduct lead-
or asbestos-related construction work. If found, LCMs and ACMs
shall be disposed of properly. If PCBs are found, these materials
shall be managed in accordance with the Metallic Discards Act of
1991 (California Public Resources Code, Sections 42160–42185)
and other state and federal guidelines and regulations. Demolition
plans and contract specifications shall incorporate any necessary
abatement measures in compliance with the Metallic Discards Act,
particularly Section 42175, Materials Requiring Special Handling,
for the removal of mercury switches, PCB-containing ballasts, and
refrigerants.
Implementation: Castilleja School
Monitoring: City of Palo Alto
Timing:
Prior to issuance of demolition
permits for each construction
phase – complete hazardous
materials building survey and
retain qualified contractor for
demolition and disposal if needed
During construction – ensure any
hazardous building materials are
handled and disposed of in
accordance with state and federal
regulations
Hazardous materials building survey
conducted by a qualified
environmental specialist
If LCMs and/or ACMs are identified,
demolition activities shall be
conducted by a trained and qualified
contractor and LCMs and ACMs are
disposed of properly
Any PCBs are managed in
accordance with the Metallic
Discards Act of 1991 (California
Public Resources Code, Sections
42160–42185) and other state and
federal guidelines and regulations
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Table 1
Castilleja School Project MMRP
Mitigation Measure
Implementation Responsibility,
Monitoring Responsibility,
and Timing Performance Evaluation Criteria
TOPICS FOR WHICH NO MITIGATION MEASURES ARE REQUIRED:
Agriculture and Forestry Resources
Greenhouse Gas Emissions
Energy
Hydrology and Water Quality
Mineral Resources
Population/Housing
Public Services
Recreation
Utilities/Service Systems
Castilleja School Project MMRP 10056
October 2020 25
Castilleja School Project Construction MMRP Checklist
Table 2
Castilleja School Project Construction MMRP Checklist
Mitigation Measure Action City Verification Actions/Dates
ACTIONS REQUIRED BY CASTILLEJA PRIOR TO ISSUANCE OF CONSTRUCTION PERMITS
Mitigation Measure 4b Submit Tree Protection and Preservation Plan, implement all pre-
construction tree protection measures identified in the approved
plan, and submit Verification of Tree Protection Report for each
construction phase
Mitigation Measure 5a Submit lighting plan for each construction phase
Mitigation Measure 6a Submit historic resources protection plan for each construction
phase
Mitigation Measure 8a Submit technical analysis identifying specific loudspeaker
equipment, locations and positions of speakers, and anticipate noise
levels for nearby sensitive receptors
Mitigation Measure 8b Submit construction noise analysis and construction plans
demonstrating implementation of recommended noise control
measures for each construction phase
Mitigation Measure 9a Include notes on site plans requiring implementation of Basic
Construction Emission Control Measures for each construction
phase
Mitigation Measure 12a Submit site plans demonstrating compliance with all geotechnical
investigation and supplemental memorandum recommendations for
each construction phase
Mitigation Measure BIO-1 Complete pre-construction nesting bird surveys and submit to the
City within 7 days of commencement of construction activity if
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Table 2
Castilleja School Project Construction MMRP Checklist
Mitigation Measure Action City Verification Actions/Dates
construction begins between February 1 and August 31 for each
construction phase
Consult with CDFW if an active nest of a protected bird is located for
each construction phase
Mitigation Measure BIO-2 Complete pre-construction roosting bat surveys City no more than
30 days prior to demolition for each construction phase
Consult with CDFW if active roosts are found within 300 feet of
demolition activities for each construction phase
Evict any individual bats within any nonbreeding bat hibernacula in
compliance with recommendations from a qualified biologist and in
consultation with CDFW
Mitigation Measure HAZ-1 Complete hazardous building material survey and retain qualified
contractors for demolition and disposal if hazardous building
materials are identified
ACTIONS REQUIRED BY CASTILLEJA DURING CONSTRUCTION
Mitigation Measure 4b Conduct monthly tree inspections and submit Monthly Inspection
Report
Mitigation Measure 5a Install lighting in accordance with approved plan
Mitigation Measure 6a Implement historic resources protection plan
Mitigation Measure 6b Provide cultural resources awareness training to all construction
crew prior to beginning any ground disturbing activities
Ensure that construction crew halts work if cultural resource are
discovered until resources are evaluated by qualified archeologist
and any treatment measures are implemented
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Table 2
Castilleja School Project Construction MMRP Checklist
Mitigation Measure Action City Verification Actions/Dates
Mitigation Measure 7a Install driveway vehicle count equipment
Mitigation Measure 7b Maintain vegetation within 40 feet of school’s driveways onto public
streets so that the area between three and seven feet (elevation)
from the roadway surface is clear
Mitigation Measure 8a Install loudspeaker in accordance with technical report
specifications; retain noise consultant to measure noise levels after
installation and submit report to City
Mitigation Measure 8b Implement construction noise control measures
Mitigation Measure 9a Implement air pollution emission control measures
Mitigation Measure 12a Implement all geotechnical investigation and supplemental
memorandum recommendations
Mitigation Measure 12b Stop work within 100 feet of any paleontological specimen
discovered during construction until they are evaluated by a
professional paleontologist and recommended protective measures
are implemented
Mitigation Measure BIO-1 Prohibit construction within 300 feet of any active raptor nests
Mitigation Measure HAZ-1 Ensure any hazardous building materials are handled and disposed
of in accordance with state and federal regulations
ACTIONS REQUIRED BY CITY PRIOR TO ISSUANCE OF CERTIFICATE OF OCCUPANCY
Mitigation Measure 4b Verify implementation of Tree Protection and Preservation Plan
Mitigation Measure 5a Verify that lighting comports with Municipal Code
Mitigation Measure 6a Verify that historic resources were not damaged, or require repairs if
damage occurred
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Castilleja School Project Construction MMRP Checklist
Mitigation Measure Action City Verification Actions/Dates
Mitigation Measure 7a Verify that driveway vehicle count equipment was installed and is
operational and calibrated
Mitigation Measure 7b Paint curbs to prohibit on-street parking within 35 feet of project site
driveways
Mitigation Measure 8a Verify pool loudspeaker noise levels
Mitigation Measure 12a Complete site inspections to verify as built conditions comport with
all geotechnical investigation and supplemental memorandum
recommendations
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October 2020 29
Castilleja School Project Operation MMRP Annual Checklist
Table 3
Castilleja School Project Operation MMRP Annual Checklist
Mitigation Measure Castilleja Action Timing City Verification Actions/Dates
ACTIONS REQUIRED FOR SPECIFIC DURATION
Mitigation Measure 4b Monitor all trees (retained,
relocated, newly planted) and
submit annual reports
Beginning at end of each
construction phase and
continuing for five years
Plant additional trees to replace
any that do not survive initial five-
year monitoring and monitoring
such trees for five years from the
date of planting
Beginning at the time that any
tree subject to monitoring is
shown to have died and
continuing for five years from the
date of planting
ACTIONS REQUIRED IN PERPETUITY
Mitigation Measure 4a Publish special events calendar At the beginning of each
academic year, with updates
each trimester
Submit parking plans to City Prior to onsite special events
Mitigation Measure 7a Implement TDM plan During all operation, including
during construction when school
is still operating
Submit monitoring reports Three times per year until full
enrollment reached and peak
hour and daily trip standards
achieved – generally every 3
months, beginning approximately
3 months after the first day of
school for that year
Thereafter two times per year -
generally every 4.5 months,
Castilleja School Project MMRP 10056
October 2020 30
beginning approximately 4.5
months after the first day of
school for that year
Mitigation Measure 7a
(continued)
If standards are not achieved as
defined in Mitigation Measure 7a,
implement additional TDM
measures and reduce enrollment
Need for action to be determined
at end of each
monitoring/reporting period.
When additional TDM measures
are required, they shall be
implemented as soon as possible.
If enrollment reductions are
needed, they shall occur in the
next admission cycle.
Implement active traffic
management as identified in the
Garage Circulation Plan, or
subsequent plans approved by
the City
during all drop-off and pick-up
periods and during special events
with more than 75 guests
Mitigation Measure 7b Submit evidence of landscaping
management plan or active
landscape maintenance contract
Annually
Inspect no-parking curb markings
within 35 feet of site driveways
and report any need for repainting
to the City
Annually
Mitigation Measure 8a Maintain pool loudspeaker
equipment in accordance with
noise technical report
specifications and submit
evidence of inspection and any
repairs to City
Annually
DRAFT
ACTION NO. 2021-0X
RECORD OF THE COUNCIL OF THE CITY OF PALO ALTO LAND USE ACTION
1310 BRYANT STREET (CASTILLEJA)
ARCHITECTURAL REVIEW 19PLN-00116
CONDITIONAL USE PERMIT AND VARIANCE 16PLN-00238
On March 15, 2021, the Council _____ the _______making the following findings, determination and
declarations:
SECTION 1. Background. The City Council of the City of Palo Alto (“City Council”) finds,
determines, and declares as follows:
A. On March 8 and 15, 2021, City Council held public hearings of the Architectural Review,
Conditional Use Permit and Variance applications, and considered the Final Environmental Impact Report (EIR)
and Mitigation Monitoring and Reporting Program (MMRP) prior to certifying the adequacy of the EIR, as
reflected in the Resolution (2021-OX), and
B. The Planning and Transportation Commission reviewed the DEIR and Final EIR and on
September 9, 2020, recommended Council certify the EIR. The Final EIR, published July 29 and 30, 2020,
responded to public review comments on the Draft Environmental Impact Report (DEIR) published July 17, 2019.
The analyses included Project alternatives. The Commission’s five meetings included August 20, September 9,
October 28, November 4, and November 18, 2020. On November 18, 2020, the Commission supported the four
Variance findings to support the Gross Floor Area replacement, and the first of two CUP findings, with a s plit
vote on the second CUP finding, to forward the CUP with modified approval conditions.
C. The ARB reviewed the Castilleja School Project during three hearings (August 20, October 1,
2020, and November 5, 2020), including the Final EIR, Architectural Review Findings and Approval Conditions,
and recommended approval of the Architectural Review application for phased redevelopment at 1310 Bryant
Street on November 5, 2020, in support of the updated Alternative Project Plans.
SECTION 2. Environmental Review. The City, as the lead agency prepared a Draft Environmental
Impact Report subject to the provisions of the California Environmental Quality Act (CEQA). The public notice
period for the DEIR began on July 17, 2020 and concluded following a 60-day public review and comment
period. Responses to comments received prior to the end of the public comment period were prepared and
included with responses and evaluation of an additional project alternative in a Final EIR published July 30, 2020,
for Council certification.
1. The environmental effects of the Project and Project Alternative have been analyzed in an
Environmental Impact Report prepared in accordance with the requirements of the California
Environmental Quality Act of 1970 (CEQA).
2. The Draft EIR identified one or more potentially significant effects of the Project and Project Alternative
on the environment as well as mitigation measures that would, for the Project Alternative #4, reduce the
significant effects to a less than significant level. The Project applicant, before public release of the Final
EIR, submitted the ‘Disbursed Circulation/Reduced Garage Alternative’ (Project Alternative #4) which
modifies the Project to mitigate the effects to a less than significant level and address many community
concerns, as demonstrated through the Council certification of the Final EIR by Resolution, and adoption
of the related Mitigation Monitoring and Reporting Program (MMRP).
3. The Director independently reviewed and considered the DEIR, together with public comments received
during the public review process and other information in the record, prior to forwarding the
recommendations from the HRB, ARB and PTC on the Final EIR to the City Council.
4. The EIR reflects and represents the independent judgment and analysis of the City of Palo Alto as lead
agency.
5. Based on the whole record of proceedings, the City Council adopted by Resolution (###) findings that
there is no substantial evidence the Project Alternative will have a significant effect on the environment,
with implementation of the Mitigation Measures.
6. The Director of Planning and Development Services at the Director’s Office at 250 Hamilton Avenue, Palo
Alto, California 94301 is the custodian of records and documents of proceedings on which this decision is
based.
SECTION 3. Architectural Review Findings. The design and architecture of the proposed project, as
conditioned, complies with the Findings for Architectural Review as required in PAMC Chapter 18.76. The
design and architecture of the proposed public parking garage complies with the Six Findings for Archi tectural
Review set forth in Palo Alto Municipal Code Chapter 18.76 Section 18.76.020 effective as of January 12, 2017.
Finding #1: The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan and
Zoning Code.
The Project Alternative conforms to the following Comprehensive Plan Goals and Policies.
Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan
The Comprehensive Plan land use designation for the
site is Single Family Residential
Castilleja School has existed at this site since 1910 and has co -existed since
1960 via CUP with the surrounding Single-Family Residential uses
Land Use and Community Design Element
Policy L-1.1: Maintain and prioritize Palo Alto’s varied
residential neighborhoods while sustaining the
vitality of its commercial areas and public facilities.
The school’s functionality will be enhanced for increased safety, sustainability,
and programmatic space to better serve its student population. Project
features are intended to minimize existing school-related disruptions on the
surrounding neighborhood: below grade pool with sound -wall, and all but 26
parking spaces are hidden below grade, the distributed drop off to avoid TIRE
impact on Emerson; preservation of mature trees that are of value to the
community.
Policy L-1.5: Regulate land uses in Palo Alto according
to the land use definition in this Element and Map L-
6.
Schools are conditionally permitted uses in areas designated as Single-Family
Residential. This is not a ‘grandfathered use’. No change to the land use
designation is proposed.
Policy L-1.6: Encourage land uses that address the
needs of the community and manage change and
development to benefit the community.
Existing school land use is single-gender, non-sectarian school. Schools are an
important community need. Project expands enrollment gradually with as
facilities are redeveloped for increased safety, sustainability, and
programmatic space with enhanced TDM.
Policy L-1.11: Hold new development to the highest
development standards to maintain Palo Alto’s
livability and achieve the highest quality
development with the least impacts.
New building design utilizes high quality materials, results in net reduction of
campus gross floor area (and thus, FAR). Total gross floor area reduced by
988 sf). Increased are below grade. Building replaces over-height limit
buildings with building meeting height limit. Temporary changes in campus-
wide visual character will occur, via demolition, construction and associated
tree removal. Overall, project would improve the site’s visual character its
compatibility with the surrounding residential neighborhood compared to
existing conditions by reducing the perceived building scale and massing.
Policy L-2.11: Encourage new development and
redevelopment to incorporate greenery and natural
The site plan includes greater open space area (3,766 sf). This new open space
was reduced from 6,904 sf additional open space for Project Alternative noted
features such as green rooftops, pocket parks, plazas
and rain gardens.
in EIR (Existing open space at 140,390 sf; 147,294 sf in Alternative #4). New
porch at 3,513 sf reduces the increase in open space to 164 sf; however, the
porch has 1,954 sf green roof. Circle to be smaller but retained. Project
incorporates new planter areas, preserves most trees around the site’s
perimeter, provides additional landscaping with trees, shrubs, grasses, vines,
and groundcover, gardens adjacent to buildings, bioretention areas, and a
green roof above subterranean parking facility.
Policy L-2.8: When considering infill redevelopment,
work to minimize displacement of existing residents.
The houses on Emerson Street are retained under Project Alternative #4. One
house is used as a rental housing unit. Both of these R-1 properties are
developable with second dwelling units to increase housing supply.
Policy L-3.1: Ensure that new or remodeled
structures are compatible with the neighborhood and
adjacent structures.
The new academic building complies with the R-1 height limit and the revised
Kellogg elevation shows the roofline/mass at second floor level broken to help
the proposed building’s scale and massing to be more compatible with
neighboring residences. Buildings would be slightly smaller in scale and mass
than the existing buildings. Building design incorporates articulation and
variety in material and colors to further break up the massing. Architectural
features, fences and walls similar to those found in residential, rather than
institutional, neighborhoods; examples: large roof overhangs with exposed
wood beams, trellised patios, outdoor covered areas, use of exterior materials
that are predominant in the neighborhood.
Program L4.9.1: While preserving adequate parking
to meet demand, identify strategies to reuse surface
parking lots.
The existing surface parking lot next to the gym is to be reused as below -
grade pool location; the size of the parking lot at Emerson/Kellogg is reduced
and tandem spaces eliminated.
Goal L-6: Well-designed Buildings that Create
Coherent Development Patterns and Enhance City
Streets and Public Spaces.
Policy L-6.1: Promote high-quality design and site
planning that is compatible with surrounding
development and public spaces.
Policy L-6.7: Where possible, avoid abrupt changes in
scale and density between residential and non-
residential areas and between residential areas of
different densities. To promote compatibility and
gradual transitions between land uses, place zoning
district boundaries at midblock locations rather than
along streets wherever possible.
Project replaces five institutional buildings with two new buildings with
slightly less gross floor area; Kellogg façade undulates; roofline and mass are
broken up partway; porch entrance on Bryant connects the new buildings;
updated materials are compatible with the existing residences surrounding
the site. Removing outdated buildings of substantially lower quality than
buildings built to current standards promotes high quality design and site
planning. The new building design is more consistent with the surrounding
neighborhood; the required ARB review process ensures building will meet the
City’s architectural review approval findings.
The below-grade parking facility would relocate many circulating and parked
vehicles from the neighborhood streets with a new pick-up and drop-off
location. On-street parking in the neighborhood will be reduced with
adequate on-site parking space supply. School parking will become more
compatible with residential neighbor parking. The bus drop -off and pick-up
area relocated internal to the site, and loading, delivery, and trash functions
moved off City streets and onto school property to reduce neighborhood
congestion and noise.
New building façades scaled to the size of neighboring residences, to avoi d
abrupt changes in scale between residential and nonresidential uses. The
project increases the amount of undeveloped open space on the project site
and retaining the Emerson homes improves transitions between uses.
Policy L-5: Maintain the scale and character of the
City. Avoid land uses that are overwhelming and
unacceptable due their size and scale.
The proposed changes to the site with this project are consistent with the site
and neighborhood character, which is primarily a two-story residential
neighborhood. Project Alternative #4 maintains scale on site and maintains
the Emerson Street character by retaining the two residential structures at
1235 and 1263 Emerson.
Policy L-9.2: Encourage development that creatively
integrates parking into the project, including by
locating it behind buildings or Consistent.
Analysis underground wherever possible, or by
providing shared use of parking areas. Encourage
other alternatives to surface parking lots that
minimize the amount of land devoted to parking
while still maintaining safe streets, street trees, a
vibrant local economy, and sufficient parking to meet
The project would reduce the amount of surface parking on the site from 82
spaces to 26 spaces and construct an underground parking facility for 117
spaces (10 of which are the interior space of a tandem pa ir and are not
counted towards attainment of the City’s minimum parking requirements).
With many drop-off and pick-up traffic routed through the underground
parking garage, and the availability of on -site parking, the parking garage
would relocate vehicle circulation and parking away from the neighborhood
streets such that the school use can be more compatible with its residential
neighbors.
demand.
Policy L-9.3: Treat residential streets as both public
ways and neighborhood amenities. Provide and
maintain continuous sidewalks, healthy street trees,
benches, and other amenities that promote walking
and “active” transportation.
The project would include bicycle parking for students consistent with the
Municipal Code. The project would be consistent with all aboveground
setback and landscaping requirements which would ensure a high-quality and
comfortable pedestrian experience on adjacent residential streets
Policy T-1.1: Take a comprehensive approach to
reducing single-occupant vehicle trips by involving
those who live, work and shop in Palo Alto in
developing strategies that make it easier and more
convenient not to drive
As part of the proposed Sustainability Plan, Castilleja School will implement
additional Transportation Demand Management strategies to reduce pea k
hour vehicle trips. This includes encouraging bicycling, walking, and
carpooling and providing shuttle and bus service.
Policy T-1.2: Collaborate with Palo Alto employers
and business owners to develop, implement and
expand comprehensive programs like the TMA to
reduce single-occupant vehicle commute trips,
including through incentives
As part of the proposed Sustainability Plan, Castilleja School will implement
additional Transportation Demand Management strategies to reduce peak
hour vehicle trips (Appendix B). This includes encouraging bicycling, walking,
and carpooling and providing shuttle and bus service.
Policy T-1.6: Encourage innovation and expanded
transit access to regional destinations, multi-modal
transit stations, employment centers and commercial
centers, including those within Palo Alto through the
use of efficient public and/or private transit options
such as rideshare services, on-demand local shuttles
and other first/last mile connections.
As part of the proposed Sustainability Plan, Castilleja School will expand the
school’s Transportation Demand Management program to meet the
performance standards identified in Mitigation Measure 7a, which may
include expanding shuttle and bus service.
Policy T-1.16 Promote personal transportation
vehicles as an alternative to cars (e.g. bicycles,
skateboards, roller blades) to get to work, school,
shopping, recreational facilities and transit stops.
Policy T-1.19 Provide facilities that encourage and
support bicycling and walking.
Program T5.12.1 Work with employers, merchants,
schools and community service providers, to identify
ways to provide more bicycle parking, including e-
bike parking with charging stations, near existing
shops, services and places of employment.
As part of the proposed Sustainability Plan, Castilleja School will implement
additional Transportation Demand Management strategies to reduce peak
hour vehicle trips and the daily trip rate per student as required in Mitigation
Measure 7a. This includes encouraging bicycling, walking, and carpooling and
providing shuttle and bus service.
The project will add new bicycle facilities on- consistent with the goals of the
2012 Palo Alto Bicycle + Pedestrian Transportation Plan; it will improve the
bicycle parking capacity of the site and incentivize the use of bicycles as a
mode of transportation to the site.
• 140 bike spaces (94 long term spaces and 46 rack spaces) provided in
three bike parking areas; 46 rack spaces at grade along the front of the
proposed library; 52 long term spaces between the proposed pool and
the parking garage exit ramp; 42 long term spaces near athletic building.
• Castilleja increasing TDM efforts to meet a “no new AM or PM peak
hour trips” standard (2016 TDM Plan and 2016 TDM Plan Supplement,
EIR Appendix B).
• Additional requirements and performance standards for the TDM
plan are identified in Mitigation Measure 7a.
• The building and site design will enhance the pedestrian and
bicycling environment and access to the site overall. The parking lot
adjacent to Bryant Street would be reconfigured, providing 13 parking
spaces for visitors. Emerson and Kellogg parking lot to be repurposed as
a staff parking lot with 13 parking spaces.
Policy T-4.6: Require project proponents to employ
the TIRE methodology to measure potential street
impacts from proposed new development of all types
in residential neighborhoods
EIR Chapter 7, Transportation and Circulation, includes analysis of the
project’s effects using the TIRE methodology. Mitigation measure 7a
recommends specific percentage distribution of drop offs to avoid TIRE
impacts.
Policy T-5.1: All new development projects should
manage parking demand generated by the project,
without the use of on street parking, consistent with
the established parking regulations. As demonstrated
parking demand decreases over time, parking
requirements for new construction should decrease.
Policy T-5.6: Strongly encourage the use of below-
grade or structured parking and explore mechanized
Most parking will be in a below-grade parking garage within the project site.
Currently, the campus does not provide sufficient vehicle parking to meet the
Municipal Code requirements. The original project’s on-site parking facilities
would exceed the Municipal Code requirements; Project Alternative #4’s
parking facilities would meet the Municipal Code requirements. Further, the
facilities would improve the ratio of parking spaces to students, which would
reduce the amount of on-street parking in the neighborhood.
The development of below-grade parking would reduce the use of on-street
parking instead of surface parking for new
developments of all types while minimizing negative
impacts including on groundwater and landscaping
where feasible.
Policy T-5.11: Work to protect residential areas from
parking impacts of nearby businesses and uses,
recognizing that fully addressing some existing
intrusions may take time.
parking by students and parents and would therefore reduce the intrusion of
campus vehicles on street parking in the residential neighborhood
Policy T-5.12: To promote bicycle use, increase the
number of safe, attractive and well-designed bicycle
parking spaces available in the city, including spots
for diverse types of bicycle and associated
equipment, including bicycle trailers, prioritizing
heavily travelled areas such as commercial and retail
centers, employment districts, recreational/cultural
facilities, multi-modal transit facilities and ride share
stops for bicycle parking infrastructure.
The project includes provision of onsite bicycle parking and a bicycle repair
station for students and staff. As part of the Transportation Demand
Management Plan, the project would also provide for bicycle “fix-it” days to
encourage bike riding.
Policy N-2.1: Recognize the importance of the urban
forest as a vital part of the city’s natural and green
infrastructure network that contributes to public
health, resiliency, habitat values, appreciation of
natural systems and an attractive visual character
which must be protected and enhanced.
Adverse effects to the existing trees within and adjacent to the project site
were studied; the proposed landscaping plan includes planting new trees
throughout the campus. Project Alternative #4 would preserve 114 trees,
remove 14 trees, including 2 protected trees and 4 street trees, and relocate
28 trees, including 2 protected trees. Project Alternative #4 retains the row of
six redwoods next to Spieker Field. The Tree Removal Management Program
is intended to ensure the protection of existing trees and the survival of new
and replanted trees. Replanting established trees causes significant impact
which will require long term care plus mitigation for reduction of health and
longevity. Mitigation Measure 4b requires replacement of protected trees,
replacement of street trees, and additional tree planting to replace the tree
canopy from trees that are not specifically protected.
Policy N-2.4: Protect soils in both urban and natural
areas as the foundation of a healthy urban forest.
Recognize that healthy soils are necessary to filter air
and water, sustain plants and animals and support
buildings and infrastructure.
The evaluation considered effects due to encroachment into the soil area
necessary to support healthy trees. Specifically, the Arborist Report and
September 2020 landscape architect’s letter contains recommendations
regarding provision and/or protection of adequate soil area to supp ort
healthy tree growth.
Policy N-2.6: Improve the overall distribution of
citywide canopy cover, so that neighborhoods in all
areas of Palo Alto enjoy the benefits of a healthy
urban canopy.
Mitigation Measure 4b requires Castilleja School to plant trees in landscape
planters along public streets in the project vicinity. This will improve the
canopy cover in the neighborhood.
Policy N-2.8: Require new commercial, multi-unit and
single-family housing projects to provide street trees
and related irrigation systems.
The project would retain most of the existing street trees around the project
site perimeter and would plant additional street trees in the vicinity as
required by Mitigation Measure 4b.
Policy N-2.9: Minimize removal of, and damage to,
trees due to construction-related activities such as
trenching, excavation, soil compacting and release of
toxins.
Impact 4-3 evaluates the project’s potential to result in adverse effects to the
existing trees within and adjacent to the project site, including consideration
of effects due to encroachment into the soil area necessary to support healthy
trees. The project alternative #4 would retain 114 trees, remove 14 trees and
relocate 28 trees. Mitigation Measure 4b requires that the project applicant
prepare and implement a Tree Protection, Removal, and Relocation
Preservation Plan for each construction phase, subject to review and approval
by the City’s Urban Forester. Further, this plan must include specific measures
for the protection of retained trees from 4 – LAND USE AND PLANNING
Castilleja School Project Draft EIR 10056 July 2019, as revised July 2020 4-19
Table 4-1 Comprehensive Plan Policy Consistency Analysis Policy Analysis
adverse effects associated with construction activities
Policy N-2.10: Preserve and protect Regulated Trees,
such as native oaks and other significant trees, on
public and private property, including landscape trees
approved as part of a development review process
and consider strategies for expanding tree protection
Impact 4-3 evaluates the project’s consistency with the City’s Tree
Preservation and Management Regulations. Project Alternative #4 would
remove 14 trees, including 2 protected and 4 street trees, and relocate 28
trees, including 2 protected trees. The Tree Protection and Preservation Plan
required under Mitigation Measure 4b, which is subject to review and
in Palo Alto. approval by the City’s Urban Forester, must include specific measures for the
protection of retained trees from adverse effects associated with construction
activities.
Policy N-6.7: While a proposed project is in the
development review process, the noise impact of the
project on existing residential land uses, public open
spaces and public conservation land should be
evaluated in terms of the increase in existing noise
levels for the potential for adverse community
impact, regardless of existing background noise
levels. If an area is below the applicable maximum
noise guideline, an increase in noise up to the
maximum should not necessarily be allowed.
EIR Chapter 8, Noise, provides a detailed analysis of the potential noise
impacts associated with the project. The proposed project could create a
substantial increase in ambient noise levels for some neighbors during
construction and associated with the use of amplified sound equipment at the
proposed pool. However, implementation of Mitigation Measures 8a and 8b
which require use of noise management measures during construction and
modeling that demonstrates the sound system at the pool would be designed
and installed such that noise levels remain in compliance with the City’s
standards, would ensure that the proposed project would be compliant with
Policy N-6.7.
Policy N-6.8: The City may require measures to
reduce noise impacts of new development on
adjacent properties through appropriate means
including, but not limited to, the following:
• Orient buildings to shield noise sensitive outdoor
spaces from sources of noise.
• Construct noise walls when other methods to
reduce noise are not practical and when these walls
will not shift similar noise impacts to another
adjacent property.
• Screen and control noise sources such as parking
lots, outdoor activities and mechanical equipment,
including HVAC equipment.
• Increase setbacks to serve as a buffer between
noise sources and adjacent dwellings.
• Whenever possible, retain fences, walls or
landscaping that serve as noise buffers while
considering design, safety and other impacts.
• Use soundproofing materials, noise reduction
construction techniques, and/or acoustically rated
windows/doors.
• Include auxiliary power sources at loading docks to
minimize truck engine idling.
• Control hours of operation, including deliveries and
trash pickup, to minimize noise impacts
EIR Chapter 8, Noise, identifies the anticipated noise levels associated with
special events and truck activity and finds that impacts would remain less
than significant. The proposed project would relocate truck activity to a
below-grade loading and trash enclosure area. A Sound Wall is proposed
adjacent to the new, below grade pool to be set 15 feet below grade.
Policy N-6.11: Continue to prioritize construction
noise limits around sensitive receptors, including
through limiting construction hours and individual
and cumulative noise from construction equipment.
EIR Chapter 8, Noise, identifies the general noise levels associated with
construction and includes Mitigation Measure 8b requiring Castilleja School to
submit detailed construction equipment and noise management plans for
each construction phase
Policy N-7.4: Maximize the conservation and efficient
use of energy in new and existing residences and
other buildings in Palo Alto.
As part of the proposed Sustainability Plan, Castilleja School will work
towards achieving “zero net energy” use by using renewable energy
generated onsite to meet the majority of energy demand. This may include
photovoltaics, solar water heating, and/or wastewater heat recovery.
Policy N-7.5: Encourage energy efficient lighting that
protects dark skies and promotes energy
conservation by minimizing light and glare from
development while ensuring public health and safety.
As part of the proposed Sustainability Plan, Castilleja School will work
towards achieving “zero net energy” use by using renewable energy
generated onsite to meet the majority of energy demand. This may include
photovoltaics, solar water heating, and/or wastewater heat recovery.
Policy N-7.6: Support the maximum economic use of
solar electric (photovoltaic) and solar thermal energy,
both as renewable supply resources for the Electric
Utility Portfolio and as alternative forms of local
power generation.
As part of the proposed Sustainability Plan, Castilleja School will work
towards achieving “zero net energy” use by using renewable energy
generated onsite to meet the majority of energy demand. This may include
photovoltaics, solar water heating, and/or wastewater heat recovery.
Castilleja’s Sustainability Road Map is to improve energy and water efficiency,
reduce vehicle travel, prioritize use of environmentally sensitive materials,
and reduce light pollution.
Policy N-8.1: Take action to achieve target reductions
in greenhouse gas emission levels from City
operations and the community activity of 80 percent
The project would replace four buildings with new construction that is more
energy efficient and water efficient than the existing structures which would
help reduce greenhouse gas emissions. The project also includes
below 1990 levels by 2030. implementation of a Sustainability Plan that would further reduce Castilleja
School’s contribution to greenhouse gas emissions
Policy S-2.5: Minimize exposure of people and
structures to geologic hazards, including slope
stability, subsidence and expansive soils, and to
seismic hazards including ground shaking, fault
rupture, liquefaction and landslides.
The geotechnical report for the proposed project demonstrates that the
geologic and soil conditions at the site are suitable to support the proposed
improvements.
The Project Alternative design complies with the City’s Zoning regulations; it will not increase the development
area of the site regarding height (which will be reduced to meet the R-1 Zone height limit), gross floor area/floor
area ratio (net loss of GFA, FAR (above grade floor area), and setbacks. A Variance is requested to replaced non-
complying gross floor area that exceeds the maximum floor area ratio, established in 1998 for the R-1 district
properties. On-site parking spaces will be increased to address the increased student enrollment; the parking
facilities will be Zoning Code compliant with the required parking ratio based on the number of classrooms, but
not ‘overparked’. The project will increase the number of bike parking spaces on the site to meet/exceed bike
parking requirements. The applicant requests approval of a phased Architectural Review project, under Palo
Alto Municipal Code Chapter 18.76.020 (g), for construction to take place over a three-year period, with
associated enrollment increases at a rate not to exceed 27 students per year.
Finding #2: The project has a unified and coherent design, that:
a. creates an internal sense of order and desirable environment for occupants, visitors, and the general
community,
b. preserves, respects and integrates existing natural features that contribute positively to the site and
the historic character including historic resources of the area when relevant,
c. is consistent with the context-based design criteria of the applicable zone district,
d. provides harmonious transitions in scale, mass and character to adjacent land uses and land use
designations,
e. enhances living conditions on the site (if it includes residential uses) and in adj acent residential areas.
Responses:
(a) The project’s new buildings and site improvements will enhance the pedestrian environment within and
surrounding Castilleja School. The L-shaped Academic building will provide a desirable environment with a
library and fine arts space located in the wing facing Bryant Street and the majority of the teaching stations,
the cafeteria, offices and common areas in the wing facing Kellogg Avenue. The Academic Building design
will be unified and coherent, an aesthetic improvement from the existing buildings to be replaced.
(b-1) The project retains and improves the existing Historic Resource Category 3 resource, the Gunn
Administration Building, in a way that demonstrates compliance with the Secretary of the Interior Standards for
Rehabilitation, by:
• Separating it from the Rhoades building to be demolished;
• Refinishing the exterior wall on the eastern façade with differentiated stucco on the first floor and wood
shingles on the second floor, consistent with the existing building materials and finishes, and matching
the existing exterior finishes in material, color and dimension; the refinishing plans would not alter the
building dimensions;
• Adding new doors on the first and second floors and constructing new exterior stairs (with Condition for
modifications to Option 1 retaining door proposal but capturing some of Option 2’s railing features –
with review of final details for egress stairway to be reviewed by HRB subcommittee) to provide access
to the second floor (with wood trim to match existing window trim);
• Maintaining and preserving distinctive finishes and character-defining features, including its stucco- and
shingle-clad exterior walls, wood shingle roofing, and Craftsman style features;
• Enabling, upon project implementation, the Administration Center to continue to convey its distinctive
features, finishes, construction techniques, and examples of fine craftsmanship.
(b-2) The Project Alternative #4 would preserve, respect and integrate existing natural features (tree s) that
contribute positively to the site, including the row of six Redwoods (trees #115-120) next to Spieker Field, by:
(i) retaining in place 114 trees (including 34 ‘protected’ trees, 35 street trees, and 45 ‘un-regulated’ trees),
(ii) relocating 28 trees (2 ‘regulated’ and 26 ‘un-regulated’ trees) elsewhere on site with appropriate
conditions of approval to ensure survivability, and with the provision of additional trees to mitigate
the potential for less robust tree growth in the relocated trees,
(iii) removing 14 trees (6 ‘regulated’ trees including 2 oaks (#140, 155) and 4 street trees (#23, 53, 66, 67))
and 8 ‘un-regulated/not protected trees.
(c) Not applicable (no context-based design criteria in the R1 zones)
(d) With Project Alternative #4’s retention of Castilleja’s two single-family houses on Emerson Street, the
existing character of Emerson Street between Melville Avenue and Embarcadero Road will be retained.
Character and quality are represented in the proposed harmonious fencing and landscaping. These will add to
the residential and school character, to improve the transitions between uses; the character of the Bryant and
Kellogg frontages will be improved with the new Academic Building . Temporarily, due to the proposed
temporary campus, the character of Embarcadero Road frontage will be dramatically changed, but the proposed
vegetation is intended to interrupt views of the proposed two-story portables.
(e) There are no living units on the Castilleja School campus. There are measures in the EIR that address
protection of the adjacent historic resource at 1215 Emerson Street, under separate ownership, from damage
during construction. Construction and the installation of the proposed temporary campus will be a nuisance to
residents adjacent to the project for a certain period of time, after which construction will cease and the
temporary campus would be removed.
The proposed below-grade pool’s stepped bleachers would face northwest (towards the interior of the campus);
pool equipment would be in an area below grade under a portion of the bleachers and adjacent to the driveway
ramp; a six foot tall noise attenuation wall would be constructed at the setback from Emerson Street with a two
foot kicker placed at the top, slanted inwards towards the pool, extending 3 feet towards the interior of the
project site. These noise-reduction measures are supplemented by mitigation measures related to loudspeaker
use.
Finding #3: The design is of high aesthetic quality, using high quality, integrated materials, and appropriate
construction techniques, and incorporating textures, colors, and other details that are compatible with and
enhance the surrounding area.
The project includes materials which are durable and have high-quality finishes. The new Academic Building will
be finished with cedar wood shingles and vertical cedar siding wall system in a board and batten pattern.
Window, storefront and curtain wall glazed assemblies are proposed. Exterior metals include painted steel, steel
plate and picket railings, anodized aluminum window and opening framing, zinc and anodized aluminum
paneling. The design is intended to enhance the character of the site and update the existing conditions, with:
board form finishing from foundation to roof, timber or composite metal decking topped in concrete, with an
SBS flat roof system with overhangs and trellises to shade and reduce conditioned space, and with extensive
photovoltaic panels.
The lighting plans were reviewed in the EIR and subject to mitigation measure implementation; ARB review to
ensure lighting limits of 0.5 foot -candle, as measured at the abutting residential property line; with interior
lighting to minimize nighttime glow; low intensity lighting for building exte riors, parking areas, and pedestrian
ways; and directing pedestrian and security lighting downward.
Finding #4: The design is functional, allowing for ease and safety of pedestrian and bicycle traffic and
providing for elements that support the building’s necessary operations (e.g. convenient vehicle access to
property and utilities, appropriate arrangement and amount of open space and integrated signage, if
applicable, etc.).
Bicycle parking: The project will improve circulation for vehicle, bicycle, and pedestrian traffic and access to the
project site.
• Bike parking increases from 102 surface level spaces to approximately 140 spaces, consistent with the
proposed Sustainability Plan. These spaces would be provided in several bicycle parking areas.
(1) At grade along the front of the proposed library within the new Academic building, at site access
driveway on Bryant Road (46 rack spaces).
(2) Surface-level bike area between the proposed pool and the parking garage exit ramp (52 rack
spaces).
(3) Additional 42 bicycle parking spaces near the athletic building.
(4) Long-term bicycle parking would be located along the northern wall of the pool area and
gymnasium and include four bicycle lockers as well as bicycle racks.
Bicycle circulation and repairs: The project includes a Bryant Street repair station for students to use for routine
bicycle maintenance and minor repairs. Bicyclists would be directed to access the campus either from Emerson
Street or the corner of Bryant Street and Kellogg Avenue. Bicyclists using Bryant Street would park in the short-
term parking or walk their bicycles across the front of the Academic and Administration buildings and then along
the Chapel Theater to the long-term parking area. Pedestrian access to the site would be provided from Bryant
Street at the exit driveway for the Bryant Street loop and from the sidewalk along Emerson Street.
Service delivery facilities: These would be relocated below grade and away from the perimeter of the campus,
accessed via a 26-foot wide paved vehicle ramp from Emerson Street into the basement area of the proposed
Academic building, which would host a trash enclosure and service/loading area.
Temporary campus on Spieker Field: The temporary campus would contain 40 classrooms, restrooms, a kitchen
and dining facilities, a library, a student -cubbies building, a storage building, several storage sheds, and a
maintenance building. These would be placed on Spieker Field following construction of the garage. In the final
construction phase, the temporary campus would be removed, and Spieker Field would be restored.
Pedestrian tunnel: The approximately 36-foot long underground pedestrian tunnel would provide access from
the garage to the central part of the campus, between the athletic center and chapel. With a standard section of
12 feet by 11 feet (which would provide an inside dimension of 10 feet by 7.5 feet), the tunnel at both ends
would include appropriate provisions for access required under the Americans with Disabilities Act. This tunnel
is proposed as a permanent encroachment within the 25-foot PUE located along the old alignment of Melville
Avenue through the campus; the PUE would shift 15 feet to the southeast to accommodate construction of the
proposed below-grade garage. The garage walls would be placed a minimum of five feet from the existing sewer
line (so the sewer line would not be affected).
The Circle: An open-space organizing feature of the campus to be reconstructed in a slightly smaller
configuration and shifted easterly (with the Circle’s edge approximately 40 feet further from Bryant Street than
the current Circle). A driveway would continue to provide access to the Circle from Emerson Street and continue
around the perimeter of the Circle for on-site circulation of buses and other vehicles, as needed. The Circle
would be surfaced with artificial turf requiring no irrigation.
Finding #5: The landscape design complements and enhances the building design and its surroundings, is
appropriate to the site’s functions, and utilizes to the extent practical, regional indigenous drought-resistant
plant material capable of providing desirable habitat that can be appropriately maintained.
Many of the existing trees will be preserved as noted in Finding 2, and there will be no net loss of t ree canopy.
All but one tree species (Queen Palm) will be native trees. The plant species will provide suitable habitats; and
include flowering plants/trees suitable for wildlife. The different planting areas are appropriate to the functions
and locations – perimeter plantings, interior garden, and bioretention swales. California natives, drought
tolerant and habitat creating species are selected, with an appropriate variety of perennials, shrubs, grasses and
trees that will complement the building design and site.
Finding #6: The project incorporates design principles that achieve sustainability in areas related to energy
efficiency, water conservation, building materials, landscaping, and site planning.
As part of the proposed Sustainability Plan, Castilleja School will work towards achieving “zero net energy” use
by using renewable energy generated onsite to meet the majority of energy demand. This will include
photovoltaics, solar water heating, and/or wastewater heat recovery. Castilleja’s Sustainabil ity Road Map is to
improve energy and water efficiency, reduce vehicle travel, prioritize use of environmentally sensitive materials,
and reduce light pollution.
The project will comply with green building energy code requirements. The landscaping will include a significant
amount of native or low to moderate water usage plants along with on -site water treatment (C3) that will
reduce storm water runoff and allow water to enter the local aquifer.
When removal of an entire structure is proposed, it must be accomplished through a process of deconstruction
rather than demolition, requiring careful disassembly of building components to maximize reuse and recycling.
This approach is consistent with Castilleja School’s proposed Sustainability Road Map and their goal of attaining
a LEED platinum
The mechanical systems are primarily radiant heating and cooling distributed in a concrete topping slab over
decks; this uses a center water cooled heat pump in the lower level of the new building. The system includes
pumps, expansion tanks, air separators, chemical feed and VFDs. This will replace the existing on -site cooling
tower that will then serve other buildings on site.
____________________________________
SECTION 4. Architectural Review Approval Granted. Architectural Review Approval is hereby
granted for the Project by the City Council pursuant to Chapter 18.77 of the Palo Alto Municipal Code. Section 9
of this Record of Land Use Action contains Conditions of Architectural Review Approval assoc iated with the
Project (i.e. Project Alternative #4.)
SECTION 5. Plan Approval. The plans for the Castilleja School, Project Alternative (Disbursed
Circulation/Reduced Garage Alternative) submitted for Building Permit shall be in substantial conformance with
those plans prepared by WRNS and Archirender, entitled ‘ARB Resubmission #4’ consisting of 111 pages, and
dated October 22, 2020 (with Supplementary Information dated 02.02.2021), except as modified to incorporate
the conditions of approval in Section 9. A copy of these plans is on file in the Department of Planning and
Development Services.
SECTION 6. Conditional Use Permit (CUP) Findings.
The following findings for a Conditional Use Permit are made pursuant to PAMC Section 18.76.010 and subject
to Conditions of Approval in this Record of Land Use Action:
1. The proposed use at the proposed location will not be detrimental or injurious to property or
improvements in the vicinity, and will not be detrimental to the public health, safety, general
welfare or convenience:
A. Castilleja is a private school, in existence in its current location since 1910, prior to the City’s
requirement for CUP approvals for private schools in R-1 zones. Campus modifications and
operations have been subject to CUPs issued since the 1960s, as follows:
• 1960 CUP and Variance for 41’ tall, three-story dormitory exceeding R1 height limit; classrooms,
administrative offices, auditorium, library, dorm kitchen, dining room, social room, gymnasium,
pool, tennis courts, caretaker quarters, shop, and garage.
• 1970’s CUPs traffic condition, chapel addition requiring 52 parking spaces, designated student
pick-up and delivery areas, and compliance with prior CUP
• 1990’s CUPs sixth grade class added back, Melville Avenue abandonment, use of the abandoned
area, creation of 28-space parking lot, multi-use field; TDM required; conversion of a dormitory
into a library, classrooms and offices for a maximum of 385 students (154 middle school and 231
high school by the year 2000), requiring an amendment to exceed 385 students
• 2000’s CUPs increased the allowable enrollment to 415 students, implemented TDM program,
added basement below the physical arts building (ARB)
B. Over eight years of fall and spring TDM program monitoring, Castilleja has demonstrated the
school is capable of reducing peak hour trips and maintaining these reductions. Since the
monitoring began in 2012, Castilleja has achieved a reduction of 28% of the trips in the morning
peak hour.
C. In 2013 and 2017, the City began enforcement actions for violations of the 2000 CUP related to
enrollment and events, respectively. Castilleja School has worked cooperatively with the City to
gradually reduce enrollment and lessen the impact of events on the surrounding neighborhood.
D. Project Alternative #4:
a. Does not change the campus parcel size,
b. Does not increase the degree of nonconformity with respect to maximum lot size within the R-
1(10,000) zone;
c. Proposes a replacement academic building to meet the R-1 Zone height limit of 30 feet, whereas
the existing 34’8” tall building to be demolished in this location does not meet the R -1 Zone
height limit;
d. Expands usable (habitable) basement area within the Academic Building, and replaces and
slightly reduces existing above ground Gross Floor Area (GFA);
e. Demolishes non-historic buildings and proposes site improvements and buildings that would be
more compatible than the existing buildings with the residential character of the area, given
materials and landscaping relevant to the residential context; i.e., materials, colors, and details
would be compatible with the remaining, existing structures on the site such that the overall
campus would have a unified and coherent design.
f. Further improves the visual character of the site and its compatibility with the surrounding
residential neighborhood compared to the existing conditions by:
i. reducing the amount of at-grade parking, both on-street and off-street,
ii. relocating bus loading and unloading to the Circle.
g. Includes pedestrian scale fencing and gates to provide several paths of ingress and egress for
students, staff and visitors, including convenient bicycle parking.
h. Incorporates elements that meet the City’s sustainability goals, such as rooftop photovoltaics,
energy efficiency, and water-use efficiency, in addition to meeting current building and seismic
codes;
i. Improves compliance with the City’s parking requirements, whereas the existing campus’ on-site
automobile parking facilities do not meet the code requirements for on-site parking for private
school facilities. The proposed parking facilities will meet the required number of spaces: 104
non-tandem spaces - located in two surface lots (at 13 spaces each) and in one underground
parking facility (78 spaces, non-tandem);
j. Improves bicycle parking spaces (an increase from 102 spaces to 140 spaces);
k. Does not increase the number of peak hour trips with implementation of the Enhanced TDM
program and mitigation measures. Traffic to the proposed school will be conducted in an orderly
and safe manner, with consequences for noncompliance (including enrollment reductions and
CUP revocation);
l. Increases the number of daily trips to 114 net new daily trips (after implementation of Mitigation
Measure 7a), which does not represent a significant, adverse environmental impact.
E. The conditions of approval, mitigation measures and monitoring and reporting program are
designed so that:
• Development and approval of a preservation protection plan is ensured for each phase of
construction so as not to adversely affect nearby eligible cultural resources;
• Tree removals/relocations will be limited as per arborist recommendations in 2016 and 2020
reports, and protection measures to ensure survival of trees to remain in place, replacemen t
trees, and relocated trees;
• The project will meet sustainability requirements and goals (including EV charging stations
spaces provided and LEED standard green building);
• The enhanced TDM program will be monitored and enforcement measures will ensure le ss
than significant impacts to traffic, vehicle circulation, queuing due to student drop offs,
school activities and events, and parking requirements met on site with the Project
Alternative #4 will address parking spill-over issues, all of which have greatly concerned
neighbors in the vicinity of Castilleja School.
• The noise from construction and pool activity will be mitigated.
• The conditions of approval for the project are intended to address these issues by placing
limitations on school hours, the number, frequency, and type of events, and enforcing
ongoing performance standards and the TDM program.
• Performance standards include the requirement to have a designated point of contact for all
complaints, provision of events and construction information, traffic data and reports on the
School website, and provision of funds to enable the City to retain a 3rd party to assist the
City evaluate, monitor, and enforce compliance with conditions and mitigation measures.
• Enforcement of the TDM program and events will be assured, including coordination of
the School to troubleshoot issues and handle complaints in a timely manner.
Therefore, with implementation of the EIR mitigation measures as outlined in the MMRP and the
conditions of project approval, the proposed CUP amendment will not be detrimental or injurious to
property or improvements in the vicinity, and will not be detrimental to the public health, safety,
general welfare, or convenience.
2. The proposed use will be located and conducted in a manner in accord with the Palo Alto
Comprehensive Plan and the purposes of the Zoning Ordinance, in that:
The School Use is an existing, Conditionally Permitted use within Palo Alto’s R-1 Zone, consistent with
the underlying R-1 (10,000) zoning designation (PAMC Section 18.12, Table 1, Private Educational
Facilities are listed as a use allowed with a CUP) and Comprehensive Plan designation of Single Family
Residential. The project is consistent with the applicable develop ment of PAMC Chapter 18.12 and
parking standards of PAMC Chapter 18.52.
Table 4-1: Zoning Ordinance Policy Consistency Analysis
Development Standard R-1(10,000) Zoning Existing Property Project Alternative #4
Lot Size 10,000 – 19,999 sf 268,783 sf existing campus 268,783 sf (no change)
Maximum Floor Area Ratio 0.45 first 5,000 sf of lot size; 0.30
square footage in excess of
5,000 sf
1310 Bryant existing 0.43 Proposed: 0.42
Maximum Building Height 30 feet standard; 33 feet for
buildings with a roof pitch of
12:12 or greater
34 feet 6 inches 30 feet
Minimum Setbacks
Emerson 20 feet 20 feet 20 feet
Kellogg 20 feet 27 feet 9 inches 20 feet
Bryant 20 feet 22 feet 20 feet
Embarcadero 24 feet 108 feet 6 inches Above grade: 108 feet 6 inches
(no change above grade); Below
grade meets special setback
Maximum site coverage, multiple-
story development
35% (100,374 sf) 24.3% (65,273 sf) 25.3% (68,071 sf)
Vehicle Parking 2 spaces per middle grade
teaching station, 4 spaces per
upper grade teaching station
74 104
Bicycle Parking 1 space for every 5 students 95 140
The project conforms to relevant Comprehensive Plan policies cited in the project EIR. The EIR Mitigation
Measures are intended to improve upon the existing TDM measures with performance monitoring and
enforcement and impose clear special event restrictions; conditions of approval related to the CUP provide
additional clarity for operations in a manner that is consistent with the intent and provisions of the
Comprehensive Plan and the purposes of the Zoning Ordinance. The underground parking facility is in accord
with the Zoning Ordinance because PAMC 18.52.030(g) requires parking to be located on the same site as the
use being supported, unless an exception is granted and the project does not propose a residential use and
PAMC 18.12.060(e) and 18.12.090(a) do not apply to non-residential uses. The underground parking facility is
also supported by Comprehensive Plan Policy 7-5.6 that strongly encourages the use of below-grade or
structured parking and explore mechanized parking instead of surface parking for new developments of all types
while minimizing negative impacts including on groundwater and landscaping where feasible. The FAR for the
project is in accord with the Zoning Ordinance by approval of the Variance pursuant to PAMC Section 18.76.030
and 18.77.060 granted in this Record of Land Use Action.
SECTION 7. Variance Findings
The following findings for a Variance allowing replacement of existing, above grade gross floor
area are made pursuant to PAMC Section 18.76.030 and are subject to the Co nditions of
Approval in this Record of Land Use Action.
1. Because of special circumstances applicable to the subject property, including (but not limited
to) size, shape, topography, location, or surroundings, the strict application of the requirements and
regulations prescribed in this title substantially deprives such property of privileges enjoyed by other
property in the vicinity and in the same zoning district as the subject property.
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The Castilleja School campus is found to have special circumstances, in that:
• FAR limitations and maximum lot size (19,999 sf) would not support the physical space
requirements of a private school and were not created with conditionally permitted private
school uses in mind;
• The size of the campus (at 268,765 sf) is substantially greater than any other lot in the R-
1(10,000) zone (where most surrounding lots are 8,000 to 12,000 sf) resulting in a
maximum floor area ratio that disproportionately constrains the campus compared to
neighboring properties;
• The extreme disparity in lot sizes is detrimental to Castilleja School; the formula calculates
FAR at .45 for the first 5,000 sf and 0.30 for the remaining sf so as properties increase in
size, the maximum permitted FAR decreases. While this has a reasonable impact for a lot
up to 19,999 sf lot, it significantly constrains development potential on a lot the size of
Castilleja School’s. Therefore, strict application of the R1(10,000) development regulations
would deprive Castilleja School of privileges enjoyed by other property owners in the
R1(10,000) zone and deprived the School of its longstanding historic and permitted use of
its property.
• There currently exists on the parcel 116,297 square feet of legal, countable, building
square footage (gross floor area).
2. The granting of the application shall not affect substantial compliance with the regulations or
constitute a grant of special privileges inconsistent with the limitations upon other properties in the
vicinity and in the same zoning district as the subject property.
Except for the requested Floor Area Ratio standard, the Project Alternative #4 complies with all
other R-1(10,000) development standards including building height, setbacks, site coverage, open
space, and parking requirements.
• Whereas the allowable lot coverage for the campus parcel is 110,374 sf (35% of the
campus) a total of 72,240 sf of coverage (27% of the campus parcel) is proposed.
• Whereas the existing gross floor area on the campus parcel is 116,297 sf (FAR of 0.43:1), a
total of 113,667 sf is proposed on the campus (FAR of 0.42:1) which is the new Academic
Building at 81,942 sf plus the buildings to be retained, at 31,725 sf.
The request is not to increase the gross floor area on campus, but to retain and slightly decrease
the existing of above-grade gross floor area, which is most visually impactful on neighboring
properties. The School facilities will be modified to provide appropriate programmatic space for
learning environments, and for seismic safety. The removal of outdated buildings and
reconstruction of gross floor area does not constitute a special privilege.
The project would improve the campus open space characteristics, create code-compliant and
sustainable buildings with deep roof overhangs and solar shading screens, renewable energy solar
panels, high efficiency and noise mitigation glazing, natural lighting via skylights for teaching
stations, durable and sustainable siding materials, locally sourced interior finishes, water efficient
plumbing fixtures, graywater irrigation, and extensive landscaping.
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3. The granting of the application is consistent with the Palo Alto Comprehensive Plan and the
purposes of the Zoning Ordinance.
a. As noted in the CUP findings above, EIR Table 4 -1 provides an exhaustive list of the
Comprehensive Plan policies relevant to the project review and analysis. As noted in CUP
Finding #2: The School Uuse is an existing, Conditionally Permitted use within Palo Alto’s R-
1 Zone, consistent with the underlying R-1 (10,000) zoning designation (PAMC Section
18.12, Table 1, Private Educational Facilities are listed as a use allowed with a CUP) and
Comprehensive Plan designation of Single Family Residential. The project is consistent with
the applicable development of PAMC Chapter 18.12 and parking standards of PAMC
Chapter 18.52. The project conforms to relevant Comprehensive Plan policies cited in the
project EIR on Table 4-2 of the final EIR related to Project Alternative #4. The EIR Mitigation
Measures are intended to improve upon the existing TDM measures with performance
monitoring and enforcement and impose clear special event restrictions; conditions of
approval related to the CUP provide additional clarity for operations in a manner that is
consistent with the intent and provisions of the Comprehensive Plan and the purposes of
the Zoning Ordinance. The underground parking facility is in accord with the Zoning
Ordinance because PAMC 18.52.030(g) requires parking to be located on the same site as
the use being supported, unless an exception is granted and the project does not propose a
residential use and PAMC 18.12.060(e) and 18.12.090(a) do not apply to non-residential
uses. The underground parking facility is also supported by Comprehensive Plan Policy 7-5.6
that strongly encourages the use of below-grade or structured parking…instead of surface
parking for new developments of all types while minimizing negative impacts including on
groundwater and landscaping where feasible. The FAR for the project is in accord with the
Zoning Ordinance by approval of the Variance pursuant to PAMC Section 18.76.030 and
18.77.060 granted in this Record of Land Use Action.
b. Below-grade non-residential parking facilities are not included in Gross Floor Area (GFA)
because, of the defined inclusions and exclusions from GFA in the R-1 zone (PAMC
18.04.030(a)(65)(C) and (D)), they most closely align with the definition of “basement.”
i. PAMC 18.04.030 Definitions (15) "Basement" means that portion of a building
between the lowest floor and the ceiling above, which is fully below grade or partly
below and partly above grade, but so located that the vertical distance from grade
to the floor below is more than the vertical distance from grade to ceiling.
ii. PAMC 18.04.030(a)(65)(D) and 18.12.090(b) provide that basements shall not be
included in the calculation of gross floor area.
iii. Although Carports and Garages are included in GFA for the R -1 zone, PAMC
18.04.030(a)(24.5) and (59) define carports and garages to be parking facilities
accessory to a residential use.
4. The granting of the application will not be detrimental or injurious to property or
improvements in the vicinity will not be detrimental to the public health, safety, general welfare,
or convenience.
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The replacement floor area variance would enable construction of a seismically safe building, with
a lower GFA and FAR than the existing buildings being removed, designed to be visually compatible
with the neighborhood character, with increased open space and provision of all required parking
spaces provided on site, and sustainability measures. The variance is associated with a slight
reduction in above-grade floor area and modernization of facilities, improving on existing
conditions. The location of the Academic Building would allow bus drop-off and pick-ups to move
internal to the site, and enable loading, delivery and trash functions to move off City streets and
onto the school property below grade, to reduce neighborhood congestion and noise while
enhancing neighborhood safety. Mature tree preservation and canopy retention and replacement
is prioritized, and site landscaping and fencing is carefully designed for neighborhood compatibility.
SECTION 8. Conditions of CUP Approval.
Conditions of approval for the Conditional Use Permit for the Disbursed Circulation/Reduced Garage
Project Alternative (‘Project Alternative’ #4 in the Environmental Impact Report (EIR)). Alternative
#4 includes the reduced and reconfigured below grade parking facility, retains the two residential
structures on Emerson Street and the stand of Redwoods next to Spieker Field, utilizes three drop-off
/pick-up locations to disburse traffic around the campus.
CUP APPROVAL:
1. This conditional use permit incorporates all relevant conditions of approval from prior
conditional use permits (00-CUP-23 and 06-PLN-15) and replaces those prior approvals.
Upon the effective date of this entitlement, Castilleja School (‘School’) will be governed by
this conditional use permit and other related City actions associated with the subject
application.
2. The School shall operate in accordance with Project Alternative #4 documented in the
project environmental impact report (EIR Alternative #4), as detailed in the administrative
record and as modified by these conditions.
3. Any future request by the School to change or modify the CUP conditions of approval shall
require a noticed public hearing before the Planning and Transportation Commission and
Council action in accordance with PAMC Section 18.77.060 (e) Hearing and
Recommendation by the Planning and Transportation Commission.
ENROLLMENT:
4. The School may enroll a maximum of 540 students in accordance with the following
schedule:
a. Student enrollment for the 2020-21 academic year and subsequent years, except as
modified below, shall not exceed the current enrollment of 426 students.
b. Upon completion (issuance of a certificate of occupancy) of the non-residential
underground parking facility (Phase I), and starting with the next academic year,
enrollment may begin to increase up to a maximum of 490 students.
c. Upon completion of all project construction (issuan ce of a final certificate of
occupancy for all new buildings and facilities) and removal of all portable/temporary
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modular buildings, enrollment may begin to increase to a maximum 540 students.
d. Student enrollment shall not increase by more than 25 students per academic year
based on the lesser of the School’s actual or permitted enrollment as documented
by the School’s independent auditor.
e. No enrollment increase may occur unless the School has achieved the performance
standards of Condition #22 for the preceding three reporting periods. For example,
the ability to increase enrollment for the 2023-2024 academic year will require
review, in early 2023, of one reporting period from the 2022 -2023 academic year
and two reporting periods from the 2021-2022 academic year.
5. Prior to March 1st each year, the School shall provide the Director of Planning and
Development Services a letter from an independent auditor attesting to the number of
students enrolled at the School, at the time of the audit, for that academ ic year.
EVENTS:
6. The School may schedule up to a maximum of 74 special events each academic year. A
special event is defined as one that includes more than 50 attendees as defined in
Mitigation Measure 4a included in the Mitigation Monitoring Reporting Program (MMRP).
A special event includes, but is not limited to student performances, showcase or social
events; parent group meetings; admission, orientation, alumni and donor events; athletic
competitions; celebrations, or other activity that brings parents of enrolled students or non-
enrolled students to the campus. A special event does not include individual parent
meetings or activity associated with the School’s daily educational programing. Special
events are subject to the following additional restrictions:
a. Thirty-seven (37) of the maximum allowed special events may exceed 100
attendees, including five (5) major special events that may exceed 500 attendees.
b. Inclusive of all special events, the maximum number of weekday evening special
events, after 6pm, shall not exceed 32 events.
c. Inclusive of all special events, the maximum number of Saturday special events,
after 6pm, shall not exceed 5 events.
d. No special events are permitted on Sunday.
e. No special event during the weekday shall begin prior to 8am, or 9am on Saturday.
f. Those special events that extend past 6pm must end by 8pm, except for student
performances, dances and major events, which shall end no later than 10pm.
g. The School shall minimize the number of special events occurring on consecutive
days and, for larger events, occurring on consecutive weekends.
h. All special events are subject to the requirements of Mitigation Measure 4a
included in the MMRP.
i. A list of all special events for the upcoming academic year shall be provided to the
Director of Planning and Development Services before school begins and posted on
the School’s website for the duration of the academic year. The number of event
attendees and applicable parking plan required in Mitigation Measure 4a shall be
similarly posted. The purpose of this condition is to provide a reasonable
18
expectation when such events are anticipated and ensure the maximum number of
events is not exceeded or occur during restricted hours. Occasional adjustments to
the event schedule or minor exceedances to the ending time of an event during the
academic year shall not constitute a violation of this condition of approval provided
other applicable restrictions are met.
j. All special events shall comply with the approved transportation demand
management.
7. The Director of Planning and Development Services may approve a request to use the
School’s campus by the Palo Alto Unified School District, up to five times per academic year,
without the need for a Temporary Use Permit or counting as special event as defined i n
Condition #6. The School shall provide traffic management for any such events. This
condition is intended to support and encourage continued collaboration between PAUSD
and Castilleja in a manner that is minimally intrusive to the Castilleja neighborhood and
may allow some of the School’s larger events to occur off campus. The Director may impose
conditions deemed necessary to address impacts of PAUSD events on Castilleja campus.
Nothing in this condition is intended to preclude the School from applying for a Temporary
Use Permit in accordance with Palo Alto Municipal Code section 18.42.050.
OPERATIONS-RELATED:
8. Standard School hours are Mondays through Fridays 7am to 6pm. Co-curricular
programming involving fewer than 50 students and confined to indoor spaces may occur
outside of these hours.
9. Summer school programs shall be subject to all conditions and restrictions that apply to
school year programs, except that summer use of the playing fields or the pool shall not
occur before 9:00am. The School shall provide a minimum one-week student break
between the school year and the summer program(s). The School is prohibited from renting
or loaning the campus to another summer school program, organization or group provider.
The summer enrollment shall be the same level of enrollment as the academic year ending
just prior to commencement of the summer school program.
10. Following construction of the Academic Building, all deliveries and bus pickups and drop
offs shall be accomplished within the below grade parking garage or designated
pickup/drop off areas on campus accessed from the driveway from Kellogg Avenue.
11. Removal of the temporary campus on Spieker Field shall commence within six months of
the City’s issuance of a final occupancy permit for the Academic Building.
12. At all times the School shall comply with the City’s Noise Ordinance. Except for swimming
pool-related activity, which is subject to Mitigation Measure 8b, and emergencies, including
drills, no outdoor amplified sound equipment shall be used on the campus without
19
approval of a noise exception permit from the City. For the purposes of this permit,
“amplified sound equipment” includes bull horns, air horns, loudspeakers, or similar noise-
generating equipment. Amplified outdoor sound associated with the swimming pool shall
be prohibited between 8pm and 7am. The School shall take reasonable efforts to mitigate
School-related noise complaints from nearby residents. If noise complaints are not
satisfactorily resolved, the Director of Planning and Development Services may require the
placement of noise monitors to collect data and determine compliance with this condition.
Any consultant costs, installation, monitoring or remedial action and staff time required to
address noise-related complaints shall be paid for by the School.
The School is also subject to requirements of Mitigation Measure 8a and 8b related to
construction and pool use. If noise levels exceed these standards, the activity causing the
noise shall be abated until appropriate noise reduction measures have been installed and
compliance verified by the City.
13. The School’s adjacent Emerson Street residential properties shall not be used for any School
related purpose, including but not limited to, additional parking, storage or staging of
materials or equipment, deliveries or student pick-up or drop-off. These parcels do not
have City approval for use or activity supporting the School and are limited to residential
and accessory uses customarily incidental to single family residential uses.
14. Outdoor athletic practices and games shall be limited to daylight hours only. No field
lighting shall be installed. This does not preclude lighting for safety, landscaping and
pathways approved by the City.
15. The following restrictions apply to the School’s gym operations in accordance with prior City
approvals:
a. Activities are not permitted in the lower basement level of the Physical Arts Building
that would cause the number of occupants to exceed 500.
b. Ventilation equipment for the gym is not to be operational from 9 pm to 6 am.
However, the ventilation equipment may be operational until 10 pm when the gym
is used for evening events as listed on the School’s event calendar.
COMMUNITY ENGAGEMENT:
16. The School is required to provide the following information on its website to serve as a
resource to nearby residents and provide access to certain documents and information.
This information shall be posted on the school website prior to the start of the 2021 -2022
academic year and updated annually prior to the start of each academic year to include the
following:
a. A signed copy of the Record of Land Use Action authorizing the School’s use and
expansion project along with the mitigation monitoring and reporting program and
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transportation demand management plan.
b. A list of all planned special events in accordance with Condition #6.
c. Information on the maximum number of students authorized by this conditional use
permit and the actual student enrollment figures for each academic year as soon as
they are available, but no later than November 1 each year. Prior to March 1st each
year, the School shall post the findings of an independent auditor attesting to the
number of enrolled students for that academic year as required by Condition #5.
d. All monitoring and reporting documents required by these conditions of approval,
including but not limited to transportation demand management program
monitoring reports and the annual landscape maintenance contract (Mitigation
Measure 7b).
e. The School shall provide regular construction updates to inform nearby residents of
the status, schedule and upcoming construction activity, information on lane
closures, when heavy truck traffic is expected or use or particularly noisy equipment
or vibration causing equipment. The website shall include an opportunity for the
public to opt-in to receive twice monthly construction news updates by email.
17. Commencing prior to the 2021-2022 academic year, the School shall establish and maintain
a dedicated phone number to be answered by someone affiliated with the School who will
immediately respond to complaints regarding noise, special events, academic competitions,
traffic and parking or other neighborhood disturbances. Prior to the start of each academic
year, the School shall send notice to all property owners and tenants within 600 feet of the
School’s property boundaries informing occupants of this dedicated phone number and a
link to find these conditions of approval on the School’s website.
18. The School shall host regular neighborhood meetings to report on school operations,
receive feedback, and attempt to problem solve any identified issues. A minimum of two
meetings shall be scheduled each academic year, one in the fall semester and another in
the spring semester. The School shall provide a summary of the topics discussed and any
follow up action to Director of Planning and Development Services staff within 30 days of
the meeting.
19. The School shall communicate with the parents of enrolled students the r ules and
expectations of the School and these conditions of approval. The School shall distribute a
transportation and parking handbook that institutionalizes and encourages good neighbor
parking and driving behavior detailed in Condition 25.
TRANSPORTATION DEMAND MANAGEMENT:
20. Sixty (60) days following the effective date of the Council’s action on this application, the
School shall prepare a complete transportation demand management (TDM) plan that
compiles all applicable transportation-related requirements of this Record of Land Use
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Action into a cohesive, well-organized and indexed document. The TDM plan shall be
submitted to the Director of Planning and Development Services for approval. The intent of
the TDM plan is to reduce vehicle trips to, and parking demand at, the school for the
purpose of minimizing School-related disruptions and intrusions into the nearby residential
neighborhoods. The TDM plan shall also serve as a publicly available resource to inform
interested residents of the School’s transportation-related expectations and requirements
and, therefore, may include performance standards or operational conditions of approval
not typically associated with a TDM plan. As required below, the TDM plan shall incorporate
requirements from several source documents. The TDM plan required by this condition
does not need to be a verbatim restatement of the transportation management
requirements but shall include specific performance measures and criteria where
appropriate and generally document the implementation strategies to effectuate the intent
of these provisions. Where a dispute between the City and School is unresolved regarding
implementation of this condition, the Director shall schedule a hearing before the Planning
and Transportation Commission for a recommended resolution to the City Council. The
TDM plan shall apply to the 2021-2022 academic school year and every year thereafter.
21. The TDM plan shall incorporate all transportation -related provisions from the following
source documents:
a. All components of the School’s current transportation demand management plan
(on file with the City of Palo Alto), including but not limited to: implementation of
an incentive program for faculty, staff and students for carpooling and using
alternative means of transportation; annually posting and reporting on special
events; and, bi-annual communications with parents reminding them of the
importance/purpose of the School’s TDM strategies.
b. All applicable Mitigation Measures from the Certified Final EIR and particularly
Mitigation Measures 4a and 7a (on file with the City of Palo Alto and attached to
this document).
c. All applicable conditions included in this Record of Land Use Action.
d. Reference to applicable sections of the Palo Alto Municipal Code regarding TDM
programs, monitoring, reporting and penalties.
e. The TDM supplement submitted by the applicant and prepared by the
transportation firm Nelson Nygaard, dated June 17, 2019, which includes updated
monitoring report requirements and introduces new TDM strategies (on file with
the City of Palo Alto and temporarily available online:
https://www.cityofpaloalto.org/civicax/filebank/documents/77808 ).
22. The following additional performance measures and requirements shall be incorporated
into the TDM Plan:
a. Average Daily Trips (ADT) Standard: The School’s Average Daily Trips (ADT) shall not
exceed 1198 trips.
b. Data from permanent driveway counters placed at all entrance and exit driveways
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will be used to calculate ADT. Refer to condition 24 regarding the monitoring report
for the ways ADT shall be calculated. A violation of the ADT target occurs when one
of the ADT measures using driveway counts exceeds the trip target.
c. AM Peak Trips Standard: The School’s AM Peak trips shall not exceed 383 trips.
d. Data from permanent driveway counters placed at all entrance and exit driveways
will be used to calculate AM Peak Trips. Refer to condition 24 regarding the
monitoring report for the ways ADT shall be calculated. A violation of the AM Peak
Trips target occurs when one of the AM Peak Trips measures using driveway counts
exceeds the trip target.
e. The School shall install permanent vehicle counter devices at the entrance/exit of all
drop off locations on campus, surface parking lots, and the subterranean garage to
count the number of vehicle trips arriving to the campus and exiting each day. The
data collected by these devices shall be provided to the City at the end of each
month showing the unmodified counts for every 15-minute interval from each
location. The School will preserve count data electronically for a period not less
than three years. The vehicle counting devices shall be kept in working order.
Malfunctioning devices shall be promptly fixed. A device that is out of order or
provides inaccurate data for more than 10 consecutive days shall be considered a
violation of this condition. It is the intent of this condition to also record vehicle
trips during the construction phase of the project.
f. The School shall provide real time driveway counter data to the City, as directed by
the Director or the Office of Transportation.
g. The School, in consultation with the Director of Planning and Development Services,
shall install temporary vehicle counter devices in the public right of way at locations
determined by the Director for each TDM monitoring report required by these
conditions of approval. Data shall be collected for no less than seven (7) consecutive
days, determined by the Director, for each reporting period. The data collected by
the counters shall be included in the TDM monitoring reports and used for ongoing
monitoring and not to determine a violation of this conditional use permit.
However, the data collected may inform future action regarding possible
adjustments to the TDM plan to further minimize neighborhood traffic impacts.
h. The School shall provide roundtrip shuttle service to appropriate Caltrain stations
that coincide with the School’s arrival and dismissal schedule and available to
students, faculty and staff. The School shall determine the appropriate frequency of
roundtrip shuttle service to maximize this incentive, but no less than two roundtrips
for each schedule shall be provided.
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i. The School’s TDM plan shall apply to special events. In addition, the School shall
provide roundtrip shuttle service for all special events to encourage participants to
use transit or a park and ride service. The shuttle pickup/drop off location(s) and
schedule shall be included with other event information shared with potential
attendees and shall also include a parking plan for each special event.
j. The School shall routinely monitor and reassess drop-off/pick-up assignments to
balance traffic flows in accordance with the expectations set forth in the Mitigation
Monitoring and Reporting Plan. The actual and target distribution percentages shall
be included in TDM monitoring reports.
23. Notwithstanding Palo Alto Municipal Code Section 18.52.050 (d) (1), TDM monitorin g
reports shall be prepared by the School and submitted to the Director of Planning and
Development Services three times per academic year until the school has reached, or
approximately reached, maximum enrollment for two consecutive years and has
consistently met the peak hour and daily trip rate standards required by these conditions.
At that time, only two monitoring reports per year shall be required. After 15 years of
monitoring, the Planning and Transportation Commission shall review whether this
condition is still necessary. Monitoring reports shall be provided to the City in accordance
with the following schedule:
a. Reporting Three Times / Year
i. Report due by January 15 and covers the academic period from August
through November.
ii. Report due by May 15 and covers the academic period from December
through March.
iii. Report due by September 15 and covers the academic period from April
through July.
b. Reporting Twice / Year
iv. Report due by February 15 and covers the period from July through
December.
v. Report due by August 1 and covers the academic period from January
through June.
24. Required TDM monitoring reports shall include the following components:
a. Describe in full the requirements of the recurring Monitoring Report, including TDM
Plan goals and performance measure targets and data collected.
b. Include the following data and metrics:
i. driveway volume counts by 15-minute increments (raw counter data);
ii. the total average weekday AM peak trips and average weekday daily trips
for the monitoring period, excluding special event dates;
iii. the total average daily weekday trips and AM weekday peak trips during the
weeks the campus frontage street segments are evaluated by the City;
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iv. the average daily weekday traffic volumes on the campus frontage City
street segments (except Embarcadero) per these conditions – raw data to
provided by the City according to the reporting schedule;
v. the dates and number of times the average weekday daily trips and/or AM
weekday peak trips exceeded AM weekday peak and/or ADT exceedance
threshold, including any special, limited circumstances such as trips during
construction;
vi. rates of use of alternative transportation (% of mode split between bicycle,
pedestrian, shuttles, etc.);
vii. parking conditions (number of spaces within the garage used, number of
spaces within surface lots used, extent (counts) of on-street parking
adjacent to the school and in the expanded parking study area);
viii. bicycle parking counts (supply and demand) and dates, times, & attendance
of bicycle repair clinics.
ix. student drop-off/pick-up location counts and percentages by driveway.
x. an electronically transmitted appendix to the report containing the raw data
from the driveway counting devices for the monitoring period.
c. Describe how and where counts were conducted. Describe any off-site data
collected by an independent traffic engineering company.
d. Driveway Counting Device: Describe installation, calibration methods, function and
proposed maintenance of permanent traffic counting devices. Describe how records
of traffic counts are to be preserved electronically and frequency of posting of this
data to the School’s website for accessibility to City officials and the public.
e. Include a detailed explanation of the pick-up and drop-off process as well as target
pick-up/drop-off distribution percentages.
f. Include the number of daily (while school is in session) onsite traffic attendants.
g. Describe the use of traffic safety warning devices.
h. Provide a map of each parking study area, and description of methodology
employed to capture off-campus parking.
i. Describe on and off campus Parking Management Strategies, Traffic Circulation
Management Strategies and Event Traffic Procedures.
j. Identify scope and breadth of TDM measures utilized (i.e. programs that encourages
walking/biking/transit, Auto trip reduction strategies, etc.).
k. Describe other programs provided by the school in detail (i.e. organized vans,
shuttles, transit subsidies) and how the mode split data was collected (survey,
website, etc.).
l. Provide the number of enrolled students for the period covered by the report.
m. List the dates of special events that occurred in the period covered by the report,
including times, attendance, and parking/traffic management efforts and results.
n. Provide copies of mailings to families regarding the parking/traffic/pick-up/drop-off
policy, including traffic management for special events.
o. Include a list of disciplinary consequences for students and parents who do not
cooperate with the parking requirements
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p. Provide the TDM Monitoring Report in a simplified, easy to read compliance review
matrix format.
q. In addition to the TDM Monitoring Report, the School shall provide real time
driveway counter data to the City, as directed by the Director or the Office of
Transportation.
25. The School shall update its transportation and parking handbook and distribute it annually
to the parents of enrolled students in advance of the upcoming academic year. The
handbook shall be incorporated into the Castilleja School long range planning efforts and
made part of the Board Policies and Procedures Manual. The handbook shall include the
following policies and any applicable provisions from these conditions of approval:
a. At the beginning of each school year an updated parking/traffic/pick-up/drop-off
policy shall be communicated to parents to remind them of the importance of the
Parking and Traffic policy. Regular newsletters to parents will include a TDM section
with any relevant updates:
i. Parents shall be instructed not to double-park on street nor drop-off or pick-
up students in undesignated areas.
ii. Traffic monitors will direct cars to maintain a constant flow of traffic to
avoid queueing on public streets.
iii. Parents shall be instructed not to make left turns in or out of driveways at
peak times. Signs shall be posted to indicate these turning rules.
iv. Castilleja School shall continue to provide traffic monitors during peak drop-
off, pick-up and for special events. The traffic monitors shall educate
students and parents and enforce the circulation related conditions of
approval to keep surrounding streets clear of congestion. Traffic monitors
will be identified by wearing a highly visible safety vest.
v. Once per day, School personnel shall monitor parking onsite and on
surrounding public streets. The School shall notify any violators that they
must move their car(s).
vi. Castilleja students, faculty, staff, and parents shall be instructed to park
exclusively either on campus, at designated off-site lots made available for
School use, or on the School side of adjacent streets where parking is
permitted. Daily monitoring of parking shall be conducted, and offenders
shall be instructed where to park.
vii. The School shall develop clear disciplinary consequences for students and
parents who do not cooperate with the parking requirements.
viii. Oversight for the Transportation Demand Management Plan shall be the
responsibility of the Head of School. Other staff may be assigned
responsibilities regarding the daily operation and enforcement of the plan.
As the designated person or persons could change each year as job
responsibilities are redefined, at the beginning of each year Castilleja shall
provide neighbors and the City of Palo Alto with a list of individual contacts
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with emails and phone numbers. Head of School shall ensure all personnel
fully understand and are trained to complete their responsibilities: A log
shall be kept of all communication (i.e. email, telephone calls) and the
expressed concerns which are received. School staff shall review the log for
trends and respond to remedy any problems. If any neighbor feels their
concern was not properly responded to, they should contact the number
the School publishes for complaints (condition #19).
ix. At the beginning of every school year Castilleja shall set aside scheduled
time for all faculty and staff to register their cars, receive an I.D. tag and
review the traffic and parking policies.
x. At the beginning of each semester Castilleja shall register all student cars,
distribute I.D. tags, and review the traffic and parking policies with student
drivers.
xi. For special events, Castilleja School shall utilize the area on Spieker Field for
overflow parking, as needed.
xii. Castilleja shall continue its major transportation campaign with families to
emphasize carpools and use of Castilleja buses and shuttles, Caltrain and
other alternative means of transportation. Every Castilleja family shall
receive information promoting carpooling and providing information to
facilitate car/vanpooling in their immediate geographic area.
xiii. Castilleja shall experiment with a plan for an assigned parking program with
designated areas for certain types of parking (i.e. student, employee,
visitor).
xiv. Castilleja shall designate a Visitor Parking Zone in the area of the
Administration Building. Visitors shall register in the Administration Building.
At that time, they shall be asked where they are parked and redirected to
the visitor's zones if necessary.
xv. Castilleja will continue to review its event calendaring process and develop
procedures to more strategically plan school functions and their placement
on the calendar so that functions with more than 100 attendees coming to
campus do not become bunched on consecutive nights or weekends.
xvi. Castilleja has five major events each year (a start of year ceremony, back to
school night, a community building event, Founder's Day Luncheon, and
Baccalaureate/Graduation) that will bring almost all students and parents to
the Castilleja Campus. For these occasions Castilleja shall provide traffic
monitors to make sure that all vehicles park legally and safely on all street
parking. Castilleja shall maximize all on-site parking and use tandem parking
whenever feasible. Shuttles to Caltrain shall operate so that guests may
attend without bringing a car to the campus area, and the shuttle schedule
shall be published along with the parking plan for these events. A complete
list of these events including date, time of event and number of expected
attendees shall be published annually and distributed to neighbors and the
City of Palo Alto.
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xvii. The School shall review the parking/traffic requirements of each event and
develop appropriate parking and shuttle service to Caltrain. Parking
instructions and Caltrain shuttle schedules shall be included in event
notifications. Castilleja shall provide traffic monitors for these events and
shall direct as much traffic as possible onto the school site, using assisted
tandem parking, allowing students to use all lots after hours, using the day-
time loading zones for parking, and utilizing all resources to minimize impact
to street parking. For certain events as needed, Castilleja shall make every
effort to arrange off-site parking with nearby parking lots and provide
shuttle service to the parking locations using school vehicles to transport
people to and from the school. The availability of these lots is dependent on
events and cooperation from lot owners.
xviii. For School committee meetings which bring volunteers to the campus,
Castilleja shall coordinate a parking plan and shuttle schedule that will be
communicated to all committee members. At the beginning of meetings, a
reminder of parking policies shall be announced to all attendees. Anyone
not following the policy shall be requested to move their car. When meeting
notices are sent to committee members, a parking reminder and shuttle
schedule shall be included.
xix. Castilleja shall give all summer camp families Castilleja written instructions
for a drop-off/pick-up procedure at the beginning of each camp session.
Drop- off and pick-up shall be conducted on-site. Castilleja personnel shall
facilitate getting campers into vehicles and ensure all policies are followed.
It shall be the responsibility of the Director of Summer Camp to enforce the
policies with parents.
xx. Parents shall be instructed to move out of the driveway if their daughter is
not at the pick-up location and others are waiting.
xxi. Castilleja School shall develop a comprehensive incentive program for
faculty, staff, and students for carpooling and using alternative means of
transportation
26. After implementation of the TDM Plan, the Director of Planning and Development Services
may, based on empirical data or other information that would reasonably impact the
effective of the TDM plan, determine that one or more of the above TDM strategies has
become infeasible or ineffective. Upon such determination, the School shall propose an
alternative measure(s) in consultation with the Director to achieve the intended
performance of the replaced strategy or strategies.
27. From time to time, the City may require supplemental traffic counts or studies to be funded
by the School to assess and possibly redistribute student drop-off/pickup to further limit
impacts on surrounding streets.
ENFORCEMENT, COMPLIANCE AND REPORTING
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28. These Conditions of Approval (COAs) incorporate the Mitigation Monitoring and Reporting
Program (MMRP), attached hereto, based on the 2019-2020 Environmental Impact Report
(EIR) analysis prepared for the Castilleja School project. These COAs and the MMRP are in
compliance with Section 15097 of the California Environmental Quality Act (CEQA)
Guidelines, which requires that the Lead Agency “adopt a program for monitoring or
reporting on the revisions which it has required in the project and the measures it has
imposed to mitigate or avoid significant environmental effects.” These COAs and the MMRP
list mitigation measures recommended in the project Final EIR dated July 30, 2020 and
identify mitigation monitoring requirements. In addition, the City’s Standard Conditions of
Approval were identified in the Draft EIR as measures that would minimize potential
adverse effects that could result from implementation of the project. This Record of Land
Use Action ensures the approval conditions are clear to enable City staff oversight,
monitoring and enforcement. All mitigation measures and Conditions of Approval identified
in the 2020 CEQA Analysis are included herein. To the extent that there is any inconsistency
between the COA and Mitigation Measures, the more restrictive conditions shall govern; to
the extent any mitigation measures and/or COA identified in the 2020 CEQA document
were inadvertently omitted, they are automatically incorporated herein by reference.
29. Upon written notice from the City of Palo Alto, increases to student enrollment may be
suspended and/or reduction required when the School is found to be in violation of any
conditions of approval, including but not limited to the approved transportation demand
management plan, anticipated student drop off distribution, or environmental mitigation
measures, subject to the following criteria:
a. Following initial notice of a violation, the School shall be given 45 days to take
corrective action and demonstrate compliance to avoid a suspension in enrollment.
b. Any determination to reduce or suspend increases in enrollment from the Director
of Planning and Development Services shall be made within 60 days of the initial
notice. This determination may be appealed in writing within 14 days, in accordance
with PAMC Chapter 18.78 and subject to applicable fees.
c. A final determination to suspend increases to or reduce enrollment made after the
start of the academic year and prior to March 1 shall apply to the next academic
year. Final determinations made on or after March 1 but before the start of the
next academic year shall apply to the following academic year regardless of whether
the School has remedied any violation(s) that were the cause of the suspended
enrollment. The term final determination used in this context includes the time to
process an appeal, if filed.
d. Violations of Average Daily Trips (ADT) and AM Peak trips performance standards
may also be enforced pursuant to Mitigation Measure 7a and Conditions of
Approval #4 and #35.
30. Violation of any term, condition or Mitigation Measure relating to the approvals is unlawful,
prohibited, and a violation of the Palo Alto Municipal Code pursuant to PAMC Section
18.01.080. The City of Palo Alto reserves the right to initiate civil an d/or criminal
29
enforcement and/or abatement proceedings, or after notice and public hearing, to revoke
the Approvals or alter these conditions/mitigation measures if it is found that there is
violation of any of the conditions/ mitigation measures or the provisions of the Municipal
Code, or the project operates as or causes a public nuisance. This provision is not intended
to, nor does it, limit in any manner whatsoever the ability of the City to take appropriate
enforcement actions, including but not limited to the imposition of administrative financial
penalties. The project applicant shall be responsible for paying fees in accordance with the
City’s Municipal Fee Schedule for inspections conducted by the City or a City-designated
third-party to investigate alleged violations of the conditions of approval.
31. The School shall deposit $15,000 with the City of Palo Alto to cover all City costs associated
with periodic review of the school’s compliance with these conditions of approval, the cost
of the City’s consultant review of School-generated technical reports required by these
conditions (including reports analyzing raw traffic data in accordance with these
conditions), and handling of community complaints of alleged violations. The deposit
amount shall be replenished within 30 days after receiving notice from the City that deposit
balance is $5,000 or less.
32. Before the start of each academic year, the School shall fund the City’s installation of
temporary vehicle traffic counter devices, for each TDM plan monitoring report required by
these conditions for the corresponding academic year. The counting devices shall be placed
on street segments identified in MM7a (Emerson, Bryant, and Kellogg). After 15 years of
monitoring, the Planning and Transportation Commission shall review whether this
condition is still necessary.
33. Prior to issuance of a building permit, the School shall deposit funds with the City of Palo
Alto in the amount provided on the City’s municipal fee schedule to cover the full costs of
independent technical review, monitoring and inspection to ensure compl iance with the
Mitigation Monitoring and Reporting Program.
34. Reserved.
35. In addition to the enforcement measures contained in Mitigation Measure 7a and
conditions #28-30, the School shall be subject to the following for violation of conditions
#21-24:
a. During the construction period, violation of the AM Peak or ADT thresholds
provided in Condition #22 shall be subject to the following schedule:
i. For each of the first two consecutive reporting periods where the AM Peak
or ADT thresholds are exceeded, additional TDM measures shall be
required;
ii. If there are three consecutive reporting periods (and for each consecutive
violation thereafter) during which AM Peak or ADT thresholds are exceeded,
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the Director shall scale back the student enrollment level until the TDM
program is operating in compliance with the targets; in the event the
Director reduces the enrollment level, the enrollment level cannot be
increased until the School is successful in meeting the targets for two
consecutive reporting periods.
iii. Construction trips shall be excluded from the trip counts for AM Peak and
ADT.
b. Violation of TDM program requirements or transportation conditions other than AM
Peak and ADT thresholds may result in penalties as provided in Conditions #28 -30.
INDEMNIFICATION/SEVERABILITY:
36. To the extent permitted by law, the School shall indemnify and hold harmless the City, its
City Council, its officers, employees and agents (the “indemnified parties”) from and against
any claim, action, or proceeding brought by a third party against the indemnified parties
and the applicant to attack, set aside or void, any permit or approval authorized hereby for
the project, including (without limitation) reimbursing the City for its actual attorneys’ fees
and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to
defend any such action with attorneys of its own choice.
37. Approval of the project would not have been granted but for the applicability and validity of
each and every one of the specified conditions and/or mitigations, and if one or more of
such conditions and/or mitigations is found to be invalid by a court of competent
jurisdiction this approval would not have been granted without requiring other valid
conditions and/or mitigations consistent with achieving the same purpose and intent of
such approval.
SECTION 9. Conditions of AR Approval.
PLANNING AND DEVELOPMENT SERVICES ARCHITECTURAL REVIEW APPROVAL CONDITIONS
1. ARCHITECTURAL REVIEW: Any exterior modifications to the building or property shall require
submittal of an application for Architectural Review, including for any new signs. The following
items are subject to Subcommittee Review prior to submittal of Building Permit applications:
a. An HRB Subcommittee shall review final designs for the exit stair on the Gunn Building.
b. An ARB Subcommittee shall review the final design for placement of rooftop equipment.
c. The ARB Subcommittee, comprised of two ARB members, shall review these details:
i. Green tile patterning detail – including the tile size and how tile pattern will be
implemented;
ii. Detail of the cap on the Kellogg shingled wall – to show how this will be finished;
iii. A larger scale cut sheet of landscape lights on Kellogg Avenue;
iv. Consideration for adding transparent sound barrier (panel) at Kellogg balcony per
acoustician’s recommendation to achieve a 5 dB reduction, describing projected
sound mediation;
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v. A small level of additional study of the basement lighting using walkable light
wells/skylight;
vi. Full scale interior courtyard façade elevations – scale @ 1/18” on reduced size
paper. Include in drawings shingle/band covering over sheer wall shown at hearing;
vii. Detail of work near Tree #89 to reconfigure staircase as per the proposed arborist
recommendation.
2.TREE PROTECTION, REMOVAL AND RELOCATION: All but three of the existing street trees shall
be protected during construction (street trees 53, 66, and 57 are proposed for removal). Two
protected trees (trees 6 and 13) are to be relocated. The tree protection measures must be
approved by the City of Palo Alto Urban Forester and shall be in place prior to any demolition or
construction. The School shall comply with Mitigation Measure 4b, which requires that, prior to the
issuance of demolition, grading, and/or building permits for each construction phase, the School
submit to the City’s Urban Forester a Tree Protection and Preservation Plan meeting the
requirements of the Tree Technical Manual Sections 2.10 and 6.30 and the specific requirements
of Mitigation Measure 4b.
• Protected trees 140 and 155 identified in the tree list as updated in 2020
https://www.cityofpaloalto.org/civicax/filebank/documents/78617 and located within the
parcel’s building area as defined in PAMC Chapter 8.10, may be removed as part of this
approval pursuant to PAMC 8.10.050(b)(2). Protected tree 102 shall protected to the
maximum extent feasible and its removal, if required, shall be subject to the provisions of
these conditions.
• The School shall provide justification to the Urban Forester with any request to remove
protected trees. If the Urban Forester determines any tree is unlikely to survive the
construction process, and therefore meets allowances of Palo Alto Municipal Code, Section
8.10.050 (b), a tree removal permit may be issued to the School, with the associated
mitigations previously identified in Mitigation measure 4b.
• The School shall follow the recommendations related to the most recent tree protection
plan dated August 28, 2020
https://www.cityofpaloalto.org/civicax/filebank/documents/78616 . This plan includes
specific measures for irrigation for all trees to be preserved, for excavation for utilities, for
reporting damage to trees, for root buffer in locations where work is done inside the tree
protection zone, for installation of fencing warning signs, for tree pruning, and to ensure:
a. the scheduling of demolition inside any tree protection zone shall occur well in
advance so that the project arborist can be present. Demolition within the tree
protection zone as required by these conditions shall not occur without the project
arborist being present on site.
b. the project arborist shall remain on site during the excavation of the first five feet of
soil for the new Garage near Trees # 115-120 to confirm any cut roots two inches in
diameter or larger are sealed and the stub ends are cut cleanly and sealed to prevent
desiccation.
c. use of a “Soil Nail Wall” for the wall nearest Trees # 115-120; as such, an over cut
would not be required.
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d. the face of the soil cut meets the following minimum distances:
i. protect Redwoods #115-120 with a 12-foot excavation setback from trunk bark,
ii. protect Coast Live Oak #113 with an 18-foot excavation setback from trunk bark,
iii. protect tree #126 with a 15-foot excavation setback from trunk bark,
iv. protect trees #123, #124 with an 11-foot excavation setback from the trunk bark,
v. protect tree #157 with a 12-foot excavation setback from the trunk bark,
vi. protect tree #122 with a 15-foot excavation setback from the trunk bark,
vii. protect tree #137 with a 4-foot excavation setback from the trunk bark.
e. protection of tree #89 during demolition of pavement, during which time the
project arborist shall remain on site; further, the School shall adhere to
recommendations for tree #89 in the September 4, 2020 project landscape architect
memo https://www.cityofpaloalto.org/civicax/filebank/documents/78331 including:
i. reconfiguring the stairwell down to the pool with a switch back, to minimize
excavation within 20’ of the trunk,
ii. providing irrigation over the entire root zone during construction,
iii. constructing the transformer pad and DG paving on top of existing grades with
minimal subgrade compaction, and
iv. placing utility line boring under roots at a minimal depth of 48” to protect the root
zone or “Air Spading” the utility line at the proposed location.
OFFICE OF TRANSPORTATION ARCHITECTURAL REVIEW CONDITION
3. Compliance with the following shall be verified prior to the issuance of a building permit:
a. Include a product specification for the long and short-term bicycle parking fixtures. Ensure
proposed products meet performance criteria listed in Chapter 18.54.
b. An eight-foot wide, shared-use path for bicycles and pedestrians shall be provided
alongside the gym, chapel, administration building, and Bryant drop off driveway The School
shall provide signs and pavement markings on the shared-use path to guide the bicyclists as
they enter and exit the shared-use path. Proper signage and monitoring shall be provided to
keep bicyclists and pedestrians separated from the vehicle circulation path.
c. School employees shall constantly monitor the parking garage operations during peak
hours. The School shall add traffic control and safety signs to guide visitors
and to enable smooth and safe site circulation. Traffic control and safety signs shall
include, but not be limited to, Stop or Yield sign, pavement marking, shared-use path sign,
and marking, speed limit sign, traffic direction sign, drop-off/pick-up area markings.
PUBLIC WORKS ENGINEERING CONDITIONS OF APPROVAL
The following comments are required to be addressed prior to any future related permit
application and are not required to be addressed prior to the Planning entitlement approval:
4. STORM WATER TREATMENT: This project shall comply with the storm water regulations
contained in provision C.3 of the NPDES municipal storm water discharge permit issued by the San
Francisco Bay Regional Water Quality Control Board (and incorporated into Palo Alto Municipal
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Code Chapter 16.11). In order to address the potential permanent impacts of the project on storm
water quality, the School shall implement the proposed set of permanent site design measures,
source controls, and treatment controls that serve to protect storm water quality, subject to final
approval of the Public Works Department. The School shall include with the Building Permit
application the C3 data form signed and stamped by the third party (which prepared this form
previously for the Planning Entitlement). The School shall include in Building Permit Plans, the size,
design and incorporate permanent storm water pollution prevention measures (landscape-based
treatment controls such as bioswales, filter strips, and permeable pavement) to treat the runoff
from a “water quality storm” specified in PAMC Chapter 16.11 prior to discharge to the municipal
storm drain system.
5. Reserved.
6. LOGISTICS PLAN: The School’s contractor shall submit a logistics plan to the Public Works
Department prior to building permit demolition. In addition, the School shall provide a proposed
schedule to accompany all logistics plans at each phase on construction prior to th e start of
construction. The logistics plan requires review by PDS director and Chief Transportation Official as
well as PW director. The Plan shall include consideration of the Bryant Bike Boulevard and student
circulation on the campus during construction. Special consideration is needed to ensure
construction traffic does not interfere / interact with students arriving / leaving the site. The City
has the authority to amend / modify logistics plans as needed to address neighborhood impacts or
address public safety concerns. All construction staging is taking place on site. The logistics plans
must address all impacts to the City’s right-of-way, including, but not limited to: pedestrian control,
traffic control, truck routes, material deliveries, contract or’s parking, concrete pours, crane lifts,
work hours, noise control, dust control, storm water pollution prevention, contractor’s contact,
noticing of affected businesses, and schedule of work. Plans shall include the following, but not
limited to, construction fence, construction entrance and exit, stockpile areas, equipment and
material storage area, workers parking area, construction office trailer, temporary bathroom,
measures for dewatering if needed, crane location, working hours, contractor’s contact
information, truck traffic route, setbacks from environmentally sensitive areas, erosion and
sediment control measures to be implemented during construction.
7. EROSION CONTROL PLANS: The School shall submit multiple erosion control plans to adequately
demonstrate erosion control for each construction phase. Each phase shall require separate C.3
certification if permits are not issued concurrently.
8. STORM WATER HYDRAULICS AND HYDROLOGY: The School shall provide an analysis that
compares the existing and proposed site runoff from the project site. Runoff shall be based on City
of Palo Alto Drainage Design Standards for 10-year storm event with HGL’s 0.5 foot below inlet
grates elevations and 100-year storm with HGL not exceeding the street right -of-way. Please
provide the tabulated calculations directly on the conceptual grading and drainage plan. This
project may be required to replace and upsize the existing storm drain system to handle the added
flows and/or depending on the current pipe condition. The IDF tables and Precipitation Map for
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Palo Alto is available County of Santa Clara County Drainage Manual dated October 2007. The
proposed project shall not increase runoff to the public storm drain system.
9.STORM WATER TREATMENT: At the time the School installs the required storm water treatment
measures, and prior to the issuance of any occupancy permit, a third -party reviewer shall also
submit to the City a certification for approval that the project’s permanent measures were
constructed and installed in accordance to the approved permit drawings.
10. STORM WATER POLLUTION PREVENTION: The School shall include the City's full-sized
"Pollution Prevention - It's Part of the Plan" sheet in the Building Permit plan set. The sheet is
available here: http://www.cityofpaloalto.org/civicax/filebank/documents/2732
11. SWPPP: The proposed development will disturb more than one acre of land. Accordingly, the
School will be required to comply with the State of California’s General Permit for Storm Water
Discharges Associated with Construction Activity. This entails filing a Notice of Intent to Comply
(NOI), paying a filing fee, and preparing and implementing a site -specific storm water pollution
prevention plan (SWPPP) that addresses both construction-stage and post-construction BMP’s for
storm water quality protection. Provide the WDID # directly on the Grading and Drainage Plan.
12. STORMWATER MAINTENANCE AGREEMENT: The School shall designate a party to maintain
the control measures for the life of the improvements and must enter into a maintenance
agreement with the City to guarantee the ongoing maintenance of the permanent C.3 storm water
discharge compliance measures. The maintenance agreement shall be executed prior to the
Grading or Building permit issuance. The City will inspect the treatment measures yearly and
charge an inspection fee.
13. CONNECTION INTO THE CITY STORM SYSTEM. The School is proposing a direct connection into
the City storm system, and therefore will be required to provide a video of that storm lateral and
main to demonstrate that the storm line is in good condition. Any repairs or replacements required
shall be completed by this project applicant.
14. DEMOLITION PLAN: The School shall place the following note adjacent to any affected tree on
the Site Plan and Demolition Plan: “Excavation activities associated with the proposed scope of
work shall occur no closer than 10-feet from the existing street tree, or as approved by the Urban
Forestry Division contact 650-496-5953. Any changes shall be approved by the same”.
15. SIDEWALK, CURB & GUTTER: As part of this project, the School must replace all existing
sidewalk, curbs, gutters and driveway approaches in the public right-of-way along the frontages of
the property. The site plan submitted with the building permit plan set must show the extent of the
replacement work (at a minimum all curb and gutter and sidewalk along the project frontage). The
plan must note that any work in the right-of-way must be done per Public Works’ standards by a
licensed contractor who must first obtain a Street Work Permit from Public Works at the
Development Center.
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16. STREET TREES: The School may be required to replace existing and/or add new street trees in
the public right-of-way along the property’s frontage(s). Call the Public Works’ arborist at 650-496-
5953 to arrange a site visit so he can determine what street tree work, if any, will be required for
this project. The site plan submitted with the building permit plan set must show the street tree
work that the arborist has determined, including the tree species, size, location, staking and
irrigation requirements, or include a note that Public Works’ arborist has determined no street tree
work is required. The plan must note that in order to do street tree work, the School must first
obtain a Permit for Street Tree Work in the Public Right-of-Way from Public Works’ arborist (650-
496-5953).
17. GRADING PERMIT: The School shall provide a site plan that includes an earthworks table
showing cut and fill volumes. An application and plans for a grading permit are submitted to Public
Works separately from the building permit plan set. The application and guidelines are available at
the Development Center and on our website.
18. GRADING & DRAINAGE PLAN: The School shall provide a separate Grading and Drainage Plan
prepared by a qualified licensed engineer, surveyor or architect. Plan shall be wet -stamped and
signed by the same. The Plan shall include the following: existing and proposed spot elevations,
earthwork volumes (cut and fill in CY), pad, finished floor, garage elevation, base flood elevation (if
applicable) grades along the project conforms, property lines, or back of walk. See PAMC Section
16.28.110 for additional items. Projects that front directly into the public sidewalk, shall include
grades at the doors or building entrances. Provide drainage flow arrows to demonstrate positive
drainage away from building foundations at minimum of 2% or 5% for 10-feet per 2013 CBC Section
1804.3. Label the downspouts, splash-blocks (2-feet long min) and any site drainage features such
as swales, area drains, bubble-up locations. Include grate elevations, low points and grade breaks.
Provide dimensions between the bubblers and property lines. In no case shall drainage across
property lines exceed that which existed prior to grading per 2013 CBC Section J109.4. In particular,
runoff from the new garage shall not drain into neighboring property. For additional grading and
drainage detail design, see Grading and Drainage Plan Guidelines for Residential Development.
http://www.cityofpaloalto.org/civicax/filebank/documents/2717
19. GROUNDWATER: Due to high groundwater throughout much of the City and Public Works
prohibiting the pumping and discharging of groundwater, perforated pipe drainage systems at the
exterior of the basement walls or under the slab are not allowed for this site. The School shall
provide a drainage system for all exterior basement-level spaces, such as lightwells, patios or
stairwells. This system shall consist of a sump, a sump pump, a backflow preventer, and a closed
pipe from the pump to a dissipation device onsite at least 10 feet from the property line, such as a
bubbler box in a landscaped area, so that water can percolate into the soil and/or sheet flow across
the site. The device must not allow stagnant water that could become mosquito habitat.
Additionally, the plans must show that exterior basement-level spaces are at least 7-3/4” below any
adjacent windowsills or doorsills to minimize the potential for flooding the basement. Public Works
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recommends a waterproofing consultant be retained to design and inspect the vapor barrier and
waterproofing systems for the basement.
20. BASEMENT SHORING: Shoring for the basement excavation, including tiebacks, must not
extend onto adjacent private property or into the City right-of-way.
21. DEWATERING: Proposed underground garage excavation may require dewatering during
construction. Public Works only allows groundwater drawdown well dewatering. Open pit
groundwater dewatering is disallowed. Dewatering is only allowed from April 1 through October
31 due to inadequate capacity in our storm drain system. The geotechnical report for this site must
list the highest anticipated groundwater level; if the proposed project will encounter groundwater,
the School must provide all required dewatering submittals for Public Works review and approval
prior to grading permit issuance. Public Works has dewatering submittal requirements and
guidelines available at the Development Center and on our website:
http://www.cityofpaloalto.org/gov/depts/pwd/forms_and_permits.asp
22. UTILITIES AND BIO-RETENTION AREAS: Due to maintenance and inspection requirements
associated with the bioretention areas, utilities that are not associated with the bio-retention
design, shall not be installed within the bio-retention areas. It’s not clear if there are any existing or
proposed utilities within the bio-retention areas. Plot and label any existing lines and proposed
lines in the Building Permit set to determine if these lines should be relocated or relocate the
treatment areas if necessary.
23. WORK IN THE RIGHT-OF-WAY: The Building Permit plans shall clearly indicate any work that is
proposed in the public right-of-way, such as sidewalk replacement, driveway approach, or utility
laterals. The plans must include notes that the work must be done per City standards and that the
contractor performing this work must first obtain a Street Work Permit from Public Works at the
Development Center. If a new driveway is in a different location than the existing driveway, then
the sidewalk associated with the new driveway must be replaced with a thickened (6” thick instead
of the standard 4” thick) section. Additionally, curb cuts and driveway approaches for abandoned
driveways must be replaced with new curb, gutter and planter strip.
24. IMPERVIOUS SURFACE AREA: The project will be creating or replacing 500 square feet or more
of impervious surface. Accordingly, the School shall provide calculations of the existing and
proposed impervious surface areas with the building permit application. The Impervious Area
Worksheet for Land Developments form and instructions are available at the Development Center
or on our website.
25. PROPOSED POOL DRAINAGE: The proposed new pool shall drain to sanitary sewer.
26. PAVEMENT: The School shall be required to resurface (grind and overlay) the full street width
(curb to curb) on all four project frontages (Embarcadero, Bryant, Emerson, Kellogg).
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27. ROUGH GRADING PLAN. The School shall provide a Rough Grading Plan for the work proposed
as part of the Grading and Excavation Permit application. The Rough Grading Plans shall include the
following: pad elevation, basement elevation, elevator pit elevation, ground monitoring wells,
shoring for the proposed basement, limits of over excavation, stockpile area of material, overall
earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for the
basement access, crane locations (if any), etc. Plans submitted for the Grading and Excavation
Permit, shall be stand-alone, and therefore the plans shall include any conditions from other
divisions that pertain to items encountered durin g rough grading for example if contaminated
groundwater is encountered and dewatering is expected, provide notes on the plans based on
Water Quality’s conditions of approval. Provide a note on the plans to direct the contractor to the
approve City of Palo Alto Truck Route Map, which is available on the City’s website.
28. EASEMENT BENEFICIARY APPROVALS. The School shall obtain approval from all easements
beneficiaries for any gates blocking access to any existing or proposed easements and provide that
approval to the City before grading permit or building permit issuance.
29. ENCROACHMENT PERMIT. The School shall obtain an encroachment permit for private utilities
within a Public Utility Easement prior to issuance of Grading or Building Permits.
PUBLIC WORKS URBAN FORESTRY CONDITIONS OF APPROVAL
The School shall address the following conditions prior to any future related permit application
such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance, Street Work
Permit, Encroachment Permit, as further described below. In the event the mitigation measure 4b
or planning architectural review condition of approval #2 are more stringent than below conditions,
the more restrictive condition or measure applies.
30. TREE TRANSPLANTING. Tree transplanting is not equivalent to retention, therefore must be
carefully considered. Destinations for transplanted trees must have adequate soil volume and site
conditions to match the needs of the individual tree. Soil volume should be at least four times the
size of the root ball and not less than 400 cubic feet for a species that is small stature at maturity,
800 cubic feet for a medium stature, and 1,200 cubic feet for a large stature. Newly planted trees
must be compatible species and have adequate soil volume to mature to full stature.
31. TREE PROTECTION ZONE. Tree protection zones, appraised values, and viability for protection
or transplanting must be calculated using current field measurements, observations, and
assessments (not older than one year).
32. CONSTRUCTION ACTIVITY. Construction activity (including demolition and temporary uses
during phases of construction) is not allowed inside a tree protection zone (TPZ) unless approved
by the Urban Forester and reasonable treatments are pro posed to offset potential impacts.
Excavation for the building or garage which extends beyond the building footprint (for shoring or
other purposes) must be considered as an impact. Design alterations may be considered to
prevent impacts to trees. Impacts must not be significant such as those defined as “removal” in
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Palo Alto Municipal Code, Chapter 8.10.020. The tree protection report must be updated to
include specific treatment recommendations for all trees where construction activity will occur
within the TPZ. Treatments should be considered such as enhancing soil conditions beyond the TPZ
and outside the limits of construction so that root density and health improves. Tree protection
fencing alignments should be considered to include treatment are as (beyond the TPZ), protect
groups of trees where possible, and align on limits of construction (instead of idealized circles).
Treatments should be scheduled before, during, and/or after construction as appropriate. The
updated tree protection report should be included in the plan set as sheets T.2, T.3, T.4, etc. The
project arborist must closely supervise construction activities within a TPZ, and treatments applied
to offset those impacts.
33. REPLACEMENT TREES. Replacement trees must be 24” box size unless a larger (alternative) box
size is justified for the site. Utilize the size of the tree protection zone for conical trees (such as
Redwoods #115-120) to calculate the canopy size for replacement (and not the actual canopy
width). The number of replacement trees on Sheet T.2.0. must match those proposed to be
planted on Sheet L.2.0. In order to comply with the policy of no net loss of canopy cover (Urban
Forest Master Plan, policy 6.C., pg. 150), replacement trees that cannot be planted on the project
site may be replaced in lieu by paying into the Forestry Fund in the amount of $650 per tree (for
each 24” box size). Include a table or add columns to show the square feet or canopy removed,
transplanted, and replaced (on-site and in-lieu). The planting plan, Sheet L.2.0., should show a total
quantity of small, medium, and large stature trees and designate where each is proposed to be
located. Species may be shown on the current plan set but must be provided prior to issuance of a
building permit.
34. TREE APPRAISAL & SECURITY DEPOSIT AGREEMENT. (Reference: CPA Tree Technical Manual,
Section 6.25). Prior to the issuance of a grading or building permit, the School shall prepare and
secure a tree appraisal and security deposit agreement stipulating the duration and monitoring
program. The appraisal of the condition and replacement value of all trees to remain shall
recognize the location of each tree in the proposed development. Listed separately, the appraisal
may be part of the Tree Survey Report. For the purposes of a security deposit agreement, the
monetary market or replacement value shall be determined using the most recent version of the
“Guide for Plan Appraisal”, in conjunction with the Species and Classification Guide for Northern
California. The appraisal shall be performed at the School’s expense, and the appraiser shall be
subject to the Director’s approval.
a. SECURITY DEPOSIT AGREEMENT. Prior to grading or building permit issuance the applicant
shall identify by number and appraised value all trees that will be transplanted or where ANY
construction activity is anticipated within a tree protection zone of a retained tree, subject to
approval by the City’s Urban Forester. The applicant shall post a security deposit for 150% of
the appraised replacement value for each tree on that list. The security may be a cash deposit,
letter of credit, or surety bond and shall be filed with the Revenue Collections/Finance
Department or in a form satisfactory to the City Attorney.
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b. SECURITY DEPOSIT & MONITORING PROGRAM. The School shall provide to the City of Palo
Alto an annual tree evaluation report prepared by the project arborist or other qualified
certified arborist, assessing the condition and recommendations to correct potential tree
decline for trees retained, relocated, and trees planted. The monitoring program shall end five
years from date of final occupancy, unless extended due to tree mortality and replacement, in
which case a new five-year monitoring program and annual evaluation report for the
replacement tree shall begin. Prior to occupancy, a final report and assessment shall be
submitted for City review and approval. The final report shall summarize the status of all trees
on the project, documenting tree or site changes to the approved plans, update status of tree
health and recommend specific tree care maintenance practices for the property owner(s). The
School shall call for a final inspection by the Planning and Development Services staff and
Urban Forester.
c. SECURITY DEPOSIT DURATION. The security deposit duration period shall be five years
from the date of final occupancy. Return of the security guarantee shall be subject to City
approval of the final monitoring report. A tree shall be considered dead when the main leader
has died back, 25% of the crown is dead or if major trunk or root damage is evident. A new tree
of equal or greater appraised value shall be planted in the same area by the property owner.
Landscape area and irrigation shall be adapted to provide optimum growing conditions for the
replacement tree. The replacement tree that is planted shall be subject to a new five -year
establishment and monitoring program. The School shall provide an annual tree evaluation
report as originally required.
d. FOREFEIT OF DEPOSIT. The City may determine that trees which die (as defined above) or
are not replaced will constitute a forfeit of the portion of the deposit equal to the appr aised
value. Any forfeit will be deposited into the Forestry Fund to plant new trees elsewhere. Issues
causing forfeit of any portion of the deposit may also be subject to remedies described in Palo
Alto Municipal Code.
35. TREE PROTECTION COMPLIANCE. The School and contractor shall implement all protection and
inspection schedule measures, design recommendations and construction scheduling as stated in
the TPR & Sheet T-1 and is subject to code compliance action pursuant to PAMC 8.10.080. The
required protective fencing shall remain in place until final landscaping and inspection of the
project. Project arborist approval must be obtained and documented in the monthly activity report
sent to the City. The mandatory Contractor and Arborist Monthly Tree Activity Report shall be sent
monthly to the City (pwps@cityofpaloalto.org) beginning with the initial verification approval, using
the template in the Tree Technical Manual, Addendum 11.
a. TREE PROTECTION VERIFICATION. Prior to any site work verification fro m the contractor
that the required protective fencing is in place shall be submitted to the Urban Forestry
Section. The fencing shall contain required warning sign and remain in place until final
inspection of the project.
36. PLAN CHANGES. The School shall submit revisions and/or changes to plans before or during
40
construction for review; these changes shall be responded to by the (a) project site arborist, or (b)
landscape architect, with written letter of acceptance before submitting the revision to the Building
Department for review by Planning, PW or Urban Forestry.
37. TREE DAMAGE. Tree Damage, Injury Mitigation and Inspections apply to Contractor. Reporting,
injury mitigation measures and arborist inspection schedule (1-5) apply pursuant to TTM, Section
2.20-2.30. Contractor shall be responsible for the repair or replacement of any publicly owned or
protected trees that are damaged during the course of construction, pursuant to Title 8 of the Palo
Alto Municipal Code, and city Tree Technical Manual, Section 2.25.
38. GENERAL. The following general tree preservation measures apply to all trees to be retained:
No storage of material, topsoil, vehicles or equipment shall be permitted within the tree enclosure
area. The ground under and around the tree canopy area shall not be altered. Trees to be retained
shall be irrigated, aerated and maintained as necessary to ensure survival.
39. EXCAVATION RESTRICTIONS APPLY (TTM, Sec. 2.20 C & D). Any approved grading, digging or
trenching beneath a tree canopy shall be performed using ‘air-spade’ method as a preference, with
manual hand shovel as a backup. For utility trenching, including sewer line, roots exposed with
diameter of 1.5 inches and greater shall remain intact and not be damaged. If directional borin g
method is used to tunnel beneath roots, then Table 2-1, Trenching and Tunneling Distance, shall be
printed on the final plans to be implemented by Contractor.
40. PROTECTIVE TREE FENCING. Plans to show protective tree fencing. The Plan Set (esp. site,
demolition, grading & drainage, foundation, irrigation, tree disposition, utility sheets, etc.) must
delineate/show the correct configuration of Type I, Type II or Type III fencing around each
Regulated Tree, using a bold dashed line enclosing the Tree Protection Zone (Standard Dwg. #605,
Sheet T-1; City Tree Technical Manual, Section 6.35-Site Plans); or by using the Project Arborist’s
unique diagram for each Tree Protection Zone enclosure.
PUBLIC WORKS RECYCLING CONDITIONS OF APPROVAL
The following conditions are required to be addressed prior to any future related permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance,
Street Work Permit, Encroachment Permit, etc. as further described below.
41. WASTE CONTAINER LOCATIONS. The School shall present on the plan the locations and
quantity for the internal and external three container waste stations. The three waste containers
shall include recycle (blue container), compost (green container), and garbage (black container).
Please refer to PAMC 5.20.108.
42. INTERNAL WASTE STATIONS (PAMC 5.20.108).
a. Internal waste stations are required for common areas such as lunchrooms, conference
rooms, cafeterias, and coffee stations. The waste station shall be comprised of three-color
coded containers. Black for landfill waste, blue for recycling, and green for compostables. The
41
green compostable container, if bags are used, shall be green compostable bags. The waste
station containers shall also contain color coded signs. All dining area waste stations must have
3-sort color-coded labeled containers for garbage (black), recycling (blue) and compost (green).
Any kitchen area must have the appropriate number of 3 -sort color-coded labeled waste
stations for garbage, recycling and compost.
b. Restrooms that uses paper towels for hand drying must have color-coded labeled compost
container for paper towels and it is recommended to have a labeled landfill container for the
diaper changing stations.
c. Signs can be obtained from GreenWaste of Palo Alto
pacustomerservice@greenwwaste.com or call (650) 493-4894 to request signs.
43. EXTERNAL WASTE STATION (PAMC 5.20.108).
a. If the School chooses to have refuse containers outside, they will need to be installed at
convenient and appropriately selected locations. The waste station shall be comprised of three-
color coded containers. Black for landfill waste, blue for recycling, and green for compostables.
The green compostable container, if bags are used, shall use gr een compostable bags. The
waste station containers shall also contain color coded signs. Signs can be obtained from
GreenWaste of Palo Alto pacustomerservice@greenwwaste.com or call (650) 493-4894 to
request signs.
44. COVERED DUMPSTERS, RECYCLING AND TALLOW BIN AREAS (PAMC 16.09.075(q)(2))
a. Buildings that house FSEs shall include a covered area for all receptacles, dumpsters, bins,
barrels, carts or containers used for the collection of trash, recycling, food scraps and waste
cooking FOG or tallow. The areas shall be designed to prevent water run-on to the area and
runoff from the area. Drains that are installed within waste storage areas are optional. Any
drain installed shall be connected to a GCD. If tallow receptacle(s) are to be stored outside then
an adequately sized, segregated space for tallow receptacle(s) shall be included in the covered
waste storage area. These requirements shall apply to remodeled or converted facilities to the
extent that the portion of the facility being remodeled or converted is related to the subject of
the requirement.
45. DUMPSTERS FOR NEW AND REMODELED FACILITIES (PAMC 16.09.180(b)(10))
a. New buildings and residential developments providing centralized solid waste collection,
except for single-family and duplex residences, shall provide a covered area for a bin/dumpster.
The area shall be adequately sized for all waste streams (garbage, recycling, and yard
waste/compostables) and designed with grading or a berm system to prevent water run-on and
runoff from the area.
b. A recycling, compost, and garbage enclosure shall be required for the project.
46. REFUSE DISPOSAL AREA REQUIREMENTS (PAMC 18.23.020)
a. The design of any new, substantially remodeled, or expanded building or other facility shall
provide for proper storage, handling, and accessibility which will accommodate the solid waste
and recyclable materials loading anticipated and which will allow fo r the efficient and safe
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collection.
i. All solid waste bins (dumpsters) must be located in a trash enclosure.
ii. A trash enclosure must be included in the plans.
47. GENERAL COMMENTS
a. Refuse enclosure must be covered.
b. Collection vehicle access (vertical clearance, street width and turnaround space) and
street parking are common issues pertaining to new developments. Adequate space must
be provided for vehicle access.
c. Weight limit for all drivable areas to be accessed by the solid waste vehicles (roads,
driveways, pads) must be rated to 60,000 lbs. This includes areas where permeable pavement is
used.
d. Carts and bins must be able to roll without obstacles or curbs to reach service areas "no
jumping curbs"
e. Containers must be within 25 feet of service area or charges will apply.
f. All service areas must have a clearance height of 20’ for bin service.
g. New enclosures should consider rubber bumpers to reduce wear-and-tear on walls.
h. Service must be provided for garbage, recycling, and compost
i. Project plans must show the placement of all three refuse containers, for example, within
the details of the solid waste enclosures. Enclosure and access should be designed for equal
access to all three waste streams – garbage, recycling, and compostables.
The following comments and/or standard Municipal Code requirements are provided for
supplemental guidance, recommendation and/or best practices:
a. Recommended Refuse Container Number and Sizes (for each refuse enclosure).
b. For any service-related questions, contact Greenwaste of Palo Alto at 650-493-4894.
PUBLIC WORKS WATERSHED PROTECTION CONDITIONS OF APPROVAL
The following comments are required to be addressed prior to any future related permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance,
Street Work Permit, Encroachment Permit, etc.
48. DISCHARGE OF GROUNDWATER (PAMC 16.09.170, 16.09.040)
If groundwater is encountered then the plans must include the following procedure for
construction dewatering: Prior to discharge of any water from construction dewatering, the water
shall be tested for volatile organic compounds (VOCs) using EPA Method 601/602 or Method 624.
The analytical results of the VOC testing shall be transmitted to the Regional Water Quality Control
Type Size Quantity Pick-Up Frequency
Trash 4 CY 1 2-3x/wk
Recycling 4 CY 1 or 2 6x/wk
Compost 4 CY 1 4-5x/wk
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Plant (RWQCP) 650-329-2598. Contaminated ground water that exceeds state or federal
requirements for discharge to navigable waters may not be discharged to the storm drain system
or creeks. If the concentrations of pollutants exceed the applicable limits for discharge to the storm
drain system, then an Exceptional Discharge Permit must be obtained from the RWQCP prior to
discharge to the sanitary sewer system. If the VOC concentrations exceed the toxic organics
discharge limits contained in the Palo Alto Municipal Code (16.09.040(m)) a treatment system for
removal of VOCs will also be required prior to discharge to the sanitary sewer. Additionally, any
water discharged to the sanitary sewer system or storm drain system must be free of sediment.
49. UNPOLLUTED WATER (PAMC 16.09.055)
Unpolluted water shall not be discharged through direct or indirect connection to the sanitary
sewer system. And PAMC 16.09.175 (b) General prohibitions and practices.
Exterior (outdoor) drains may be connected to the sanitary sewer system only if the area in which
the drain is located is covered or protected from rainwater run-on by berms and/or grading, and
appropriate wastewater treatment approved by the Superintendent is provided. For additional
information regarding loading docks, see section 16.09.175(k)
50. COVERED PARKING (PAMC 16.09.180(b)(9))
If installed, parking garage floor drains on interior levels shall be connected to an oil/water
separator prior to discharging to the sanitary sewer system. The oil/water separator shall be
cleaned at a frequency of at least once every twelve months or more frequently if recommended
by the manufacturer or the superintendent. Oil/water separators shall have a minimum capacity of
100 gallons.
51. ARCHITECTURAL COPPER (PAMC 16.09.180(b)(14))
On and after January 1, 2003, copper metal roofing, copper metal gutters, copper metal down
spouts, and copper granule containing asphalt shingles shall not be permitted for use on any
residential, commercial or industrial building for which a building permit is required. Copper
flashing for use under tiles or slates and small copper ornaments are exempt from this prohibition.
Replacement roofing, gutters and downspouts on historic structures are exempt, provided that the
roofing material used shall be pre-patinated at the factory. For the purposes of this exemption, the
definition of "historic" shall be limited to structures designated as Category 1 or Category 2
buildings in the current edition of the Palo Alto Historical and Architectural Resources Report and
Inventory.
52. LOADING DOCKS (PAMC 16.09.175(k)(2))
(i) Loading dock drains to the storm drain system may be allowed if equipped with a
fail-safe valve or equivalent device that is kept closed during the non -rainy season and during
periods of loading dock operation.
(ii) Where chemicals, hazardous materials, grease, oil, or waste products are handled or
used within the loading dock area, a drain to the storm drain system shall not be allowed. A drain
to the sanitary sewer system may be allowed if equipped with a fail-safe valve or equivalent device
that is kept closed during the non-rainy season and during periods of loading dock operation. The
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area in which the drain is located shall be covered or protected from rainwater run-on by berms
and/or grading. Appropriate wastewater treatment approved by the Superintendent shall be
provided for all rainwater contacting the loading dock site.
53. LABORATORY SINKS (PAMC 16.09.175(i))
Laboratory countertops and laboratory sinks shall be separated by a berm which prevents
hazardous materials spilled on the countertop from draining to the sink.
54. CONDENSATE FROM HVAC (PAMC 16.09.180(b)(5))
Condensate lines shall not be connected or allowed to drain to the storm drain system.
55. COPPER PIPING (PAMC 16.09.180(b)(b))
Copper, copper alloys, lead and lead alloys, including brass, shall not be used in sewer lines,
connectors, or seals coming in contact with sewage except for domestic waste sink traps and short
lengths of associated connecting pipes where alternate materials are not practical. The plans must
specify that copper piping will not be used for wastewater plumbing.
56. MERCURY SWITCHES (16.09.180(12))
Mercury switches shall not be installed in sewer or storm drain sumps.
57. COOLING SYSTEMS, ETC (PAMC 16.09.205(a)) Cooling Systems, Pools, Spas, Fountains,
Boilers and Heat Exchangers - It shall be unlawful to discharge water from cooling systems,
pools, spas, fountains boilers and heat exchangers to the storm drain system.
58. STORM DRAIN LABELING (PAMC 16.09.165(h))
Storm drain inlets shall be clearly marked with the words "No dumping - Flows to San
Francisquito Creek," or equivalent.
59. REGULATION OF PCB MATERIAL – EFFECTIVE JULY 1st, 2019: New requirements regarding
stormwater control during building demolition for polychlorinated biphenyls (PCBs) became
effective starting July 1st, 2019, in accordance with the San Francisco Bay Region Municipal
Regional Stormwater NPDES Permit (MRP), Order No. R2-2015-0049. MRP Provision C.12.f. requires
that San Francisco Bay Area municipalities develop a program to ensure that PCBs from building
materials (e.g. caulk, paint, mastic) do not enter the storm drain system during building demolition.
Palo Alto City Council adopted the PCBs regulation in May 2019. For specific questions about your
project, please email CleanBay@cityofpaloalto.org, call 650-329-2122 or visit
http://www.cityofpaloalto.org/pcbdemoprogram . The following conditions shall apply to ALL
projects submitting for a Demolition Permit Application on or after July 1st, 2019:
a. The School shall complete and submit the “PCBs Applicant Package,” including any required
sampling reports (per the Applicant Package instructions), with the demolition permit application.
The Applicant Package will outline PCBs sampling and reporting requirements that must be met if
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the project meets ALL of the following conditions:
• The project is a commercial, public, institutional, or industrial stru cture constructed or
remodeled between January 1, 1950 and December 31, 1980. Single-family homes are
exempt regardless of age.
• The framing of the building contains material other than wood. Wood -frame structures
are exempt.
• The proposed demolition is a complete demolition of the building. Partial demolitions do
not apply to the requirements.
b. If the project triggers polychlorinated biphenyls (PCBs) sampling as identified on the “PCBs
Applicant Package,” then the project shall conduct representati ve sampling of PCBs concentration
in accordance with the “Protocol for Evaluating Priority PCBs-Containing Materials before Building
Demolition (2018).”
• If the representative sample results or records DO NOT indicate PCB concentrations ≥50
ppm in one or more “priority materials,” then the screening assessment is complete.
Applicant submits screening form and the supporting sampling documentation with the
demolition permit application. No additional action is required.
• If the representative sample results or records DO indicate PCBs concentrations ≥50 ppm
in one or more “priority materials,” then the screening assessment is complete, but the
Applicant MUST also contact applicable State and Federal Agencies to meet further
requirements. Applicant submits screening form and the supporting sampling
documentation with the demolition permit application, and also must contacts the State
and Federal Agencies as indicated on Page 3 of the “PCBs Screening Assessment Form.”
IMPORTANT: ADVANCED APPROVAL FROM THE UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY (USEPA) OR OTHER STATE AGENCIES MAY BE REQUIRED PRIOR TO
BUILDING DEMOLITION. IT IS RECOMMENEDED THAT APPLICANTS BEGIN THE PCBs
ASSESSMENT WELL IN ADVANCE OF APPLYING FOR DEMOLITION PERMIT AS THE PROCESS
CAN TAKE BETWEEN 1-3 MONTHS. C. The following conditions are required to be part of
any Planning application approval and shall be addressed prior to any future related permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of
Compliance, Street Work Permit, Encroachment Permit, etc. as further described below.
PRIOR TO THE ISSUANCE OF ANY BUILDING PERMIT:
60. STORMWATER TREATMENT MEASURES
o All Bay Area Municipal Regional Stormwater Permit requirements shall be followed.
o Refer to the Santa Clara Valley Urban Runoff Pollution Prevention Program C.3 Handbook
(download here: http://scvurppp-w2k.com/c3_handbook.shtml) for details. For all C.3 features,
vendor specifications regarding installation and maintenance should be followed and provided to
city staff. Copies must be submitted to Pam Boyle Rodriguez at
pamela.boylerodriguez@cityofpaloalto.org . Add this bullet as a note to the building plans.
o Staff from Stormwater Program (Watershed Protection Division) may be present during
installation of stormwater treatment measures. Contact Pam Boyle Rodriguez, Stormwater
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Program Manager, at (650) 329-2421 before installation. Add this bullet as a note to building plans
on Stormwater Treatment (C.3) Plan.
61. BAY-FRIENDLY GUIDELINES (rescapeca.org)
o Do not use chemicals fertilizers, pesticides, herbicides or commercial soil amendment. Use
Organic Materials Review Institute (OMRI) materials and compost. Refer to the Bay - Friendly
Landscape Guidelines: http://www.stopwaste.org/resource/brochures/bayfriendly-landscape-
guidelines-sustainable-practices-landscape-professional for guidance. Add this bullet as a note to
the building plans.
o Avoid compacting soil in areas that will be unpaved. Add this bullet as a note to the building
plans.
62. STORMWATER QUALITY PROTECTION
Temporary and permanent waste, compost and recycling containers shall be covered to prohibit
fly-away trash and having rainwater enter the containers.
o Drain downspouts to landscaping (outward from building as needed).
o Drain HVAC fluids from roofs and other areas to landscaping.
o Refuse enclosure areas shall include an interior floor drain with a fail-safe valve that is connected
to the sanitary sewer.
63. GUIDANCE/BEST PRACTICE RECOMMENDATIONS: The following comments and/or standard
Municipal Code requirements are provided for supplemental guidance, recommendation and/or
best practices:
a. PAMC 16.09.170, 16.09.040 Discharge of Groundwater Prior approval shall be obtained from the
city engineer or designee to discharge water pumped from construction sites to the storm drain.
The city engineer or designee may require gravity settling and filtration upon a determination that
either or both would improve the water quality of the discharge. Contaminated ground water or
water that exceeds state or federal requirements for discharge to navigable waters may not be
discharged to the storm drain. Such water may be discharged to the sewer, provided that the
discharge limits contained in Palo Alto Municipal Code (16.09.040(m)) are not exceeded and the
approval of the superintendent is obtained prior to discharge. The City shall be compensated for
any costs it incurs in authorizing such discharge, at the rate set forth in the Municipal Fee Schedule.
b. PAMC 16.09.180(b)(9) Covered Parking Drain plumbing for parking garage floor drains must be
connected to an oil/water separator with a minimum capacity of 100 gallons, and to the sanitary
sewer system
c. PAMC 16.09.180(b)(14) Architectural Copper On and after January 1, 2003, copper metal roofing,
copper metal gutters, copper metal down spouts, and copper granule containing asphalt shingles
shall not be permitted for use on any residential, commercial or industrial building for which a
building permit is required. Copper flashing for use under tiles or slates and small copper
ornaments are exempt from this prohibition. Replacement roofing, gutters and downspouts on
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historic structures are exempt, provided that the roofing material used shall be prepatinated at the
factory. For the purposes of this exemption, the definition of "historic" shall be limited to structures
designated as Category 1 or Category 2 buildings in the current edition of the Palo Alto Historical
and Architectural Resources Report and Inventory.
d. PAMC 16.09.175(k) (2) Loading Docks
(i) Loading dock drains to the storm drain system may be allowed if equipped with a fail-safe valve
or equivalent device that is kept closed during the non-rainy season and during periods of loading
dock operation.
(ii) Where chemicals, hazardous materials, grease, oil, or waste products are handled or used
within the loading dock area, a drain to the storm drain system shall not be allowed. A drain to the
sanitary sewer system may be allowed if equipped with a fail-safe valve or equivalent device that is
kept closed during the non-rainy season and during periods of loading dock operation. The area in
which the drain is located shall be covered or protected from rainwater run -on by berms and/or
grading. Appropriate wastewater treatment approved by the Superintendent shall be provided for
all rainwater contacting the loading dock site.
e. PAMC 16.09.180(b)(5) Condensate from HVAC Condensate lines shall not be connected or
allowed to drain to the storm drain system.
f. 16.09.215 Silver Processing Facilities conducting silver processing (photographic or X-ray films)
shall either submit a treatment application or waste hauler certification for all spent silver bearing
solutions. 650- 329-2421.
g. PAMC 16.09.205 Cooling Towers No person shall discharge or add to the sanitary sewer system
or storm drain system, or add to a cooling system, pool, spa, fountain, boiler or heat exchanger,
any substance that contains any of the following:
(1) Copper in excess of 2.0 mg/liter;
(2) Any tri-butyl tin compound in excess of 0.10 mg/liter;
(3) Chromium in excess of 2.0 mg/liter.
(4) Zinc in excess of 2.0 mg/liter; or
(5) Molybdenum in excess of 2.0 mg/liter.
The above limits shall apply to any of the above-listed substances prior to dilution with the
cooling system, pool, spa or fountain water. A flow meter shall be installed to measure the
volume of blowdown water from the new cooling tower. Cooling systems discharging
greater than 2,000 gallons per day are required to meet a copper discharge limit of 0.25
milligrams per liter.
h. PAMC 16.09.180(b)(b) Copper Piping Copper, copper alloys, lead and lead alloys, including brass,
shall not be used in sewer lines, connectors, or seals coming in contact with sewage except for
domestic waste sink traps and short lengths of associated connecting pipes where alternate
materials are not practical. The plans must specify that copper piping will not be used for
wastewater plumbing.
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i. PAMC 16.09.175(j) Traps Below Laboratory Sinks Sewer traps below laboratory sinks shall be
made of glass or other approved transparent materials to allow inspection and to determine
frequency of cleaning. Alternatively, a removable plug for cleaning the trap may be provided, in
which case a cleaning frequency shall be established by the Superintendent. In establishing the
cleaning frequency, the Superintendent shall consider the recommendations of the facility. The
Superintendent will grant an exception to this requirement for areas w here mercury will not be
used; provided, that in the event such an exception is granted, and mercury is subsequently used in
the area, the sink trap shall be retrofitted to meet this requirement prior to use of the mercury.
j. PAMC 16.09.175(i) Laboratory Sinks Laboratory countertops and laboratory sinks shall be
separated by a berm which prevents hazardous materials spilled on the countertop from draining
to the sink.
k. PAMC 16.09.205(a) Cooling Systems, Pools, Spas, Fountains, Boilers and Heat Exchangers It shall
be unlawful to discharge water from cooling systems, pools, spas, fountains boilers and heat
exchangers to the storm drain system.
l. PAMC 16.09.165(h) Storm Drain Labeling Storm drain inlets shall be clearly marked with the
words "No dumping - Flows to Adobe Creek," or equivalent.
PUBLIC ART CONDITIONS OF APPROVAL
64. PUBLIC ART: The following conditions shall be addressed prior to any future related permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance,
Street Work Permit, Encroachment Permit, etc. as further described below. If the School chooses to
pay in-lieu of commissioning art on site, the funds must be paid prior to the issuance of a building
permit.
• If the School chooses to commission art on site, then they must complete both initial and
final reviews and receive approval from the Public Art Commission prior to the issuance of a
building permit.
• If the School chooses to pay a contribution into the Public Art fund in-lieu of commissioning
art on site, the contribution must be made prior to the issuance of a building permit.
• All information and application materials may be found at www.cityofpaloalto.org/publicart
under “policies and documents” tab.
UTILITIES ELECTRICAL ENGINEERING CONDITIONS OF APPROVAL
The following comments are required to be addressed prior to any future rela ted permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance,
Street Work Permit, Encroachment Permit, etc.
65. ELECTRICAL SERVICE:
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a. Industrial and large commercial customers must allow sufficient lead-time for Electric Utility
Engineering and Operations (typically 8-12 weeks after advance engineering fees have been paid)
to design and construct the electric service requested.
b. A completed Utility Service Application and a full set of plans must be incl uded with all
applications involving electrical work. The Application must be included with the preliminary
submittal.
c. The School shall submit a request to disconnect all existing utility services and/or meters
including a signed affidavit of vacancy, on the form provided by the Building Inspection Division.
Utilities will be disconnected or removed within 10 working days after receipt of request. The
demolition permit will be issued after all utility services and/or meters have been disconnected and
removed.
d. All utility meters, lines, transformers, backflow preventers, and any other required equipment
shall be shown on the landscape and irrigation plans and shall show that no conflict will occur
between the utilities and landscape materials. In addition, all aboveground equipment shall be
screened in a manner that is consistent with the building design and setback requirements.
e. Contractors and developers shall obtain permit from the Department of Public Works before
digging in the street right-of-way. This includes sidewalks, driveways and planter strips.
f. At least 48 hours prior to starting any excavation, the customer must call Underground Service
Alert (USA) at 1-800-227-2600 to have existing underground utilities located and marked. The areas
to be checked for underground facility marking shall be delineated with white paint. All USA
markings shall be removed by the customer or contractor when construction is complete.
g. The customer is responsible for installing all on-site substructures (conduits, boxes and pads)
required for the electric service. No more than 270 degrees of bends are allowed in a secondary
conduit run. All conduits must be sized according to California Electric Code requirements and no
1/2 – inch size conduits are permitted. All off-site substructure work will be constructed by the City
at the customer’s expense. Where mutually agreed upon by the City and the Applicant, all or part
of the off-site substructure work may be constructed by the Applicant.
h. All primary electric conduits shall be concrete encased with the top of the encasement at the
depth of 30 inches. No more than 180 degrees of bends are allowed in a primary conduit run.
Conduit runs over 500 feet in length require additional pull boxes.
i. All new underground conduits and substructures shall be installed per City standards and shall be
inspected by the Electrical Underground Inspector before backfilling.
j. For services larger than 1600 amps, a transition cabinet as the interconnection point between the
utility’s padmount transformer and the customer’s main switchgear may be required. See City of
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Palo Alto Utilities Standard Drawing SR-XF-E-1020. The cabinet design drawings must be submitted
to the Electric Utility Engineering Division for review and approval.
k. For underground services, no more than four (4) 750 MCM conductors per phase can be
connected to the transformer secondary terminals; otherwise, bus duct or x-flex cable must be
used for connections to padmount transformers. If customer installs a bus duct directly between
the transformer secondary terminals and the main switchgear, the installation of a transition
cabinet will not be required.
l. The customer is responsible for installing all underground electric service conductors, bus duct,
transition cabinets, and other required equipment. The installation shall meet the California Electric
Code and the City Standards.
m. Meter and switchboard requirements shall be in accordance with Electric Utility Service
Equipment Requirements Committee (EUSERC) drawings accepted by Utility and CPA standards for
meter installations.
n. Shop/factory drawings for switchboards (400A and greater) and associated hardware must be
submitted for review and approval prior to installing the switchgear to: Gopal Jagannath, P.E.
Supervising Electric Project Engineer Utilities Engineering (Electrical) 1007 Elwell Court Palo Alto, CA
94303
o. For 400A switchboards only, catalog cut sheets may be substituted in place of factory drawings.
p. All new underground electric services shall be inspected and approved by both the Building
Inspection Division and the Electrical Underground Inspector before energizing. B 17. The customer
shall provide as-built drawings showing the location of all switchboards, conduits (number and
size), conductors (number and size), splice boxes, vaults and switch/transformer pads.
q. The follow must be completed before Utilities will make the connection to the utility system and
energize the service:
• All fees must be paid.
• All required inspections have been completed and approved by both the Building Inspection
Division and the Electrical Underground Inspector.
• All Special Facilities contracts or other agreements need to be signed by the City and applicant.
• Easement documents must be completed.
UTILITIES WASTE GAS WATER CONDITIONS OF APPROVAL
The following comments are required to be addressed prior to any future related permit
application such as a Building Permit, Excavation and Grading Permit, Certificate of Compliance,
Street Work Permit, Encroachment Permit, etc.
66. PRIOR TO ISSUANCE OF DEMOLITION PERMIT
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a. Prior to demolition, the applicant shall submit the existing water/wastewater fixture unit loads
(and building as-built plans to verify the existing loads) to determine the capacity fee credit for the
existing load. If the applicant does not submit loads and plans they may not receive credit for the
existing water/wastewater fixtures.
b. The applicant shall submit a request to disconnect all utility services and/or meters including a
signed affidavit of vacancy. Utilities will be disconnected or removed within 10 working days after
receipt of request. The demolition permit will be issued by the building inspection division after all
utility services and/or meters have been disconnected and removed.
c. The applicant shall submit plans showing all existing WGW utility. The plans must show the size
and location of all underground utilities within the development and the public right of way
including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts,
sewer lift stations and any other required utilities. Plans for new wastewater laterals and mains
need to include new wastewater pipe profiles showing existing potentially conflicting u tilities
especially storm drain pipes (existing 6” DIP water main and 6” VCP sewer main are in the area of
proposed underground parking garage), Plans for new sewer mains and laterals need to include
profiles showing existing potential conflicts with gas, water, and other utility.
67. FOR BUILDING PERMIT:
a. The applicant shall submit a completed water-gas-wastewater service connection application -
load sheet per parcel/lot for City of Palo Alto Utilities. The applicant must provide all the
information requested for utility service demands (water in fixture units/g.p.m., gas in b.t.u.p.h,
and sewer in fixture units/g.p.d.). The applicant shall provide the existing (prior) loads, the new
loads, and the combined/total loads (the new loads plus any existing l oads to remain).
b. The applicant shall submit improvement plans for utility construction. The plans must show the
size and location of all underground utilities within the development and the public right of way
including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts,
sewer lift stations and any other required utilities. Plans for new wastewater laterals and mains
need to include new wastewater pipe profiles showing existing potentially conflicting utilities
especially storm drain pipes (existing 6” DIP water main and 6” VCP sewer main are in the area of
proposed underground parking garage), electric and communication duct banks. Existing duct
banks need to be day lighted by potholing to the bottom of the duct bank to verify cross section
prior to plan approval and starting lateral installation. Plans for new storm drain mains and laterals
need to include profiles showing existing potential conflicts with sewer, water and gas.
c. The applicant must show on the site plan the existence of any auxiliary water supply, (i.e. water
well, gray water, recycled water, rain catchment, water storage tank, etc).
d. The applicant shall be responsible for installing and upgrading the existing utility mains and/or
services as necessary to handle anticipated peak loads. This responsibility includes all costs
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associated with the design and construction for the installation/upgrade of the utility mains and/or
services.
e. For contractor installed water and wastewater mains or services, the applicant shall submit to
the WGW engineering section of the Utilities Department four copies of the installation of water
and wastewater utilities off-site improvement plans in accordance with the utilities department
design criteria. All utility work within the public right-of-way shall be clearly shown on the plans
that are prepared, signed and stamped by a registered civil engineer. The contractor shall also
submit a complete schedule of work, method of construction and the manufacture's literature on
the materials to be used for approval by the utilities engineering section. The applicant's contractor
will not be allowed to begin work until the improvement plan and other submittals have been
approved by the water, gas and wastewater engineering section. After the work is complete but
prior to sign off, the applicant shall provide record drawings (as-builts) of the contractor installed
water and wastewater mains and services per City of Palo Alto Utilities record drawing procedures.
For contractor installed services the contractor shall install 3M marker balls at each water or
wastewater service tap to the main and at the City clean out for wastewater laterals.
f. An approved reduced pressure principle assembly (RPPA backflow preventer device) is required
for all existing and new water connections from Palo Alto Utilities to comply with requirements of
California administrative code, title 17, sections 7583 through 7605 inclusive. The RPPA shall be
installed on the owner's property and directly behind the water meter within 5 feet of the property
line. RPPA’s for domestic service shall be lead free. Show the location of the RPPA on the plans.
g. An approved reduced pressure detector assembly is required for the existing or new water
connection for the fire system to comply with requirements of California administrative code, title
17, sections 7583 through 7605 inclusive (a double detector assembly may be allowed for existing
fire sprinkler systems upon the CPAU’s approval). Reduced pressure detector assemblies shall be
installed on the owner's property adjacent to the property line, within 5’ of the property line. Show
the location of the reduced pressure detector assembly on the plans.
h. All backflow preventer devices shall be approved by the WGW engineering division. Inspection
by the utilities cross connection inspector is required for the supply pipe between the meter and
the assembly.
i. Existing wastewater laterals that are not plastic (ABS, PVC, or PE) may require to be replaced at
the applicant’s expense.
j. The applicant shall pay the capacity fees and connection fees associated with new utility service/s
or added demand on existing services. The approved relocation of services, meters, hydrants, or
other facilities will be performed at the cost of the person/entity requesting the relocation.
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k. Each unit or place of business shall have its own water and gas meter shown on the plans. Each
parcel shall have its own water service, gas service and sewer lateral connection shown on the
plans.
l. A new water service line installation for domestic usage is required. For service connections of 4-
inch through 8-inch sizes, the applicant's contractor must provide and install a concrete vault with
meter reading lid covers for water meter and other required control equipment in accordance with
the utilities standard detail. Show the location of the new water service and meter on the plans.
m. If a new water service line installation for fire system usage is required. Show the location of the
new water service on the plans. The applicant shall provide to the engineering department a copy
of the plans for fire system including all fire department's requirements.
n. If a new gas service line installation is required. Show the new gas meter location on the plans.
The gas meter location must conform to utilities standard details.
o. A new sewer lateral installation per lot is required. Show the location of the new sewer lateral on
the plans.
p. The School shall secure a public utilities easement for facilities installed in private property. The
School's engineer shall obtain, prepare, record with the county of Santa Clara, and provide the
utilities engineering section with copies of the public utilities easement across the adjacent parcels
as is necessary to serve the development.
q. Where public mains are installed in private streets/PUEs “Public Utility Easements: If the City’s
reasonable use of the Public Utility Easements, which are shown as P.U.E on the Map, results in any
damage to the Common Area, then it shall be the responsibility of the Association, and not of the
City, to Restore the affected portion(s) of the Common Area. This Section may not be amended
without the prior written consent of the City”.
r. All existing water and wastewater services that will not be reused shall be abandoned at the
main per WGW utilities procedures.
s. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot be placed
over existing water, gas or wastewater mains/services. Maintain 1’ horizontal clear separation from
the vault/cabinet/concrete base to existing utilities as found in the field. If there is a conflict with
existing utilities, Cabinets/vaults/bases shall be relocated from the plan location as needed to meet
field conditions. Trees may not be planted within 10 feet of existing water, gas or wastewater
mains/services or meters. New water, gas or wastewater services/meters may not be installed
within 10’ or existing trees. Maintain 10’ between new trees and new water, gas and wastewater
services/mains/meters.
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t. To install new gas service by directional boring, the applicant is required to have a sewer cleanout
at the front of the building. This cleanout is required so the sewer lateral can be videoed for
verification of no damage after the gas service is installed by directional boring.
u. All utility installations shall be in accordance with the City of Palo Alto current utility standards
for water, gas & wastewater.
v. No new sewer lateral connection is allowed to the existing 8” PE sewer main within the 25’ wide
public utilities easement.
w. The proposed underground tunnel shall maintain a minimum three -foot vertical clearance to
the existing 8” sewer main.
x. The proposed water main disconnection/abandonment procedure per the latest edition of
the CPA Utility Standards for Water, Gas and Wastewater, details drawing shall be provided to
the School’s engineer during the Building Permit, Street Work Permit or related permits.
FIRE DEPARTMENT CONDITION OF APPROVAL
68. The Fire Department access roadway along the softball field is required to have a hardscape
surface.
PLANNING ADDITIONAL CONDITIONS
69. Prior to issuance of a building permit for the underground parking garage, the School shall
record an egress easement for the garage exit ramp, as may be required.
70. The School shall adhere to the measures indicated in the Supplemental Information submitted
February 2, 2021 (Plan sheets T3.2 through T3.5) that clarifies the School’s additional protection
plan to provide positive treatment to reduce impact areas below 25% of the tree protection zones
(TPZ) for the following seven protected trees:
a. Tree #89 (Coast Live Oak) with no more than 20% of the TPZ impacted, given proposed
reconfiguration of stairwell, significant reduction of excavation, and intact central planter root
zone.
b. Tree #102 (Coast Live Oak) with no more than 20% of the TPZ impacted, given proposed vertical
shoring limiting excavation and supplemental root zone enhancements. See Planning AR condition
#2 for further requirements.
c. Tree #120 (Redwood) with no more than 10% of the TPZ impacted, given vertical shoring limiting
excavation and supplemental root zone enhancements.
d. Tree #14 (Coast Live Oak) with no more than 15% of the TPZ impacted, given increased planter
size, plus root zone soil enhancements on both sides of planter.
e. Tree #16 (Coast Live Oak) with no more than 20% of the TPZ impacted, with increased planter
size, plus root zone soil enhancements on both sides of planter.
f. Tree #38 (Coast Live Oak) with no more than 20% of the TPZ impacted, with significant reduction
in excavation.
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g. Tree #39 (Coast Live Oak) with no more than 20% of the TPZ impacted, with significant reduction
in excavation.
71. The School shall adhere to the measures indicated in the Supplemental Information
submitted February 2, 2021 (Plan sheets T3.2 and T3.3) that clarifies the School’s additional
protection plan to provide positive treatment to reduce impact areas below 25% of the tree
protection zones (TPZ) for the following six trees:
a. Tree #15 (Flowering Cherry) with no more than 15% of the TPZ impacted, with increased planter
size, plus root zone soil enhancements on both sides of planter
b. Tree #17 (American Sweet Gum) with no more than 20% of the TPZ impacted, with root zone
enhancements in all landscape zones around the tree.
c. Tree #18 (American Sweet Gum) with no more than 15% of the TPZ impacted, with root zone
enhancements in landscape areas, plus root zone soil enhancement under proposed paving.
d. Tree #30 (Trident Maple) with no more than 15% of the TPZ impacted, with significant reduction
in excavation plus root zone soil enhancements.
e. Tree #31 (Copper Beech) with no more than 15% of the TPZ impacted, with significant reduction
in excavation.
f. Tree #33 (Japanese Privet) with no more than 15% of the TPZ impacted, with significant reduction
in excavation.
URBAN FORESTRY ADDITIONAL CONDITIONS
72. Trees #89, 102, and 120 have proposed construction activities in the tree protection zone
that will result in the trees being “removed” by definition of Palo Alto Municipal Code, Chapter
8.10.020(k) and (i).
This definition is expounded upon by the Tree Technical Manual, Section 1-2, to include:
Excessive pruning may include the cutting of any root two (2) inches or greater in diameter and/or
severing in excess of 25% of the roots. Based on these definitions compared to proposed
construction activities, the applicant should show trees #89, 102, and 120 to be protected, but
mitigated for because of the amount of construction activity. Provide replacement trees and/or in-
lieu payment to mitigate these “removals”. Alternately, design modifications (such as reducing the
limits of construction for underground parking) could reduce construction activity in the tree
protection zones to tolerable (based on the health of the tree in comparison to the activities) and
thereby adjusting the determination that the trees are “removed” by definition.
73. Show tree #114 to be removed instead of transplanted because excavating the root ball will
compound the detrimental effects of proposed construction activities on the health of tree #102.
74. Verify consistency between sheets in the plan set. The information should be consistent on all
sheets.
75. At Building Permit, include tree numbers and appraised values in the Security Deposit
Agreement for all trees that will be transplanted and all trees with ANY construction activity (or a
transplanted tree excavation) within a tree protection zone of a retained tree.
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76. At Building Permit, show tree protection fencing that extends beyond the tree protection zone
where the applicant is proposing “root baiting” as an offsetting treatment, amounting to an area
equal or larger than the construction activity proposed.
SECTION 11. Indemnity.
To the extent permitted by law, the Applicant shall indemnify and hold
harmless the City, its City Council, its officers, employees and agents (the “indemnified
parties”)from and against any claim, action, or proceeding brought by a third party against the
indemnified parties and the applicant to attack, set aside or void, any permit or approval
authorized hereby for the Project, including (without limitation) reimbursing the City its actual
attorney’s fees and costs incurred in defense of the litigation. The City may, in its sole
discretion, elect to defend any such action with attorneys of its own choice.
SECTION 12. Term of Approval.
Architectural Review and Variance Approvals. These approvals shall expire three years
from the original date of approval, if construction has not commenced pursuant to the phased
development proposal within that time, in accordance with Palo Alto Municipal Code Section
18.77.090.
Conditional Use Permit Approval. This approval shall expire 12 months from the
original date of approval if the proposed use has not commenced pursuant to the CUP Approval
within that time, in accordance with Palo Alto Municipal Code Section 18.77.090.
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS: ATTEST: APPROVED:
_________________________ ____________________________
City Clerk Director of Planning and
Development Services
APPROVED AS TO FORM:
___________________________
Senior Asst. City Attorney
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PLANS AND DRAWINGS REFERENCED:
DocuSign Envelope ID: 9F9552A2-9ADB-4810-A3CC-5B9F531FDA2B
TO: HONORABLE COUNCIL MEMBERS
FROM: MOLLY STUMP, CITY ATTORNEY
DATE: MARCH 29, 2021
SUBJECT: AGENDA ITEM NUMBER 3- Castilleja School Continued Discussion
This item is continued from March 8 and March 15, 2021. Please refer to the previously
prepared staff report and accompanying at-places memo from March 8 for background and
staff recommendations.
During the March 15 meeting, staff suggested that public comment would be reopened for a
continued hearing on March 29. Upon further review, staff have determined that any materials
provided to the Council on March 29 will be merely illustrative rather than providing any new
substance for the Council’s deliberations. Specifically, the Council directed staff to provide
examples of text amendments related to the proposed underground garage; these text
amendments will require review by and recommendation from the Planning and Transportation
Commission before they can be presented to the Council for action. Accordingly, public
comment will remain closed on March 29 and the proceedings will be limited to continued
Council deliberations.
Molly Stump Ed Shikada
City Attorney City Manager
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