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HomeMy WebLinkAbout2025-09-18 Architectural Review Board Agenda PacketARCHITECTURAL REVIEW BOARD Regular Meeting Thursday, September 18, 2025 Council Chambers & Hybrid 8:30 AM   Architectural Review Board meetings will be held as “hybrid” meetings with the option to attend by teleconference/video conference or in person. To maximize public safety while still maintaining transparency and public access, members of the public can choose to participate from home or attend in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda. Masks are strongly encouraged if attending in person. The meeting will be broadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media Center https://midpenmedia.org. Visit https://bit.ly/PApendingprojects to view project plans and details. Commissioner names, biographies, and archived agendas and reports are available at https://bit.ly/paloaltoARB. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/96561891491) Meeting ID: 965 6189 1491 Phone: 1(669)900-6833   PUBLIC COMMENTS Public comments will be accepted both in person and via Zoom for up to three minutes or an amount of time determined by the Chair. All requests to speak will be taken until 5 minutes after the staff’s presentation. Written public comments can be submitted in advance to arb@PaloAlto.gov and will be provided to the Board and available for inspection on the City’s website. Please clearly indicate which agenda item you are referencing in your subject line. Spokespersons that are representing a group of five or more people who are identified as present at the meeting at the time of the spokesperson's presentation will be allowed up to fifteen (15) minutes at the discretion of the Chair, provided that the non-speaking members agree not to speak individually. The Chair may limit Public Comments to thirty (30) minutes for all combined speakers. The Chair may reduce the allowed time to speak for Study Sessions and Action Items to two (2) minutes or less to accommodate a larger number of speakers. PowerPoints, videos, or other media to be presented during public comment are accepted only by email to arb@PaloAlto.gov at least 24 hours prior to the meeting. Once received, the Clerk will have them shared at public comment for the specified item. To uphold strong cybersecurity management practices, USB’s or other physical electronic storage devices are not accepted. Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks, posts, poles or similar/other type of handle objects are strictly prohibited; (2) the items do not create a facility, fire, or safety hazard; and (3) persons with such items remain seated when displaying them and must not raise the items above shoulder level, obstruct the view or passage of other attendees, or otherwise disturb the business of the meeting. CALL TO ORDER/ ROLL CALL  PUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker.   AGENDA CHANGES, ADDITIONS AND DELETIONS The Chair or Board majority may modify the agenda order to improve meeting management.   CITY OFFICIAL REPORTS  1.Director's Report, Meeting Schedule, and Upcoming Agenda Items STUDY SESSION Public Comment is Permitted. Three (3) minutes per speaker. 2.Discussion of the Urban Land Institute Initiative with Palo Alto, Valley Transportation Authority (VTA), and Stanford related to the Palo Alto Transit Center and Designation of a Representative(s) to participate on behalf of the Board in the Urban Land Institute Initiative 3.San Antonio Road Area Plan: Provide Feedback on Existing Conditions Analysis and Land Use and Mobility Priorities. CEQA Status: Exempt under CEQA Guidelines Section 15262. ACTION ITEMS Public Comment is Permitted. Applicants/Appellant Teams: Ten (10) minutes, plus ten (10) minutes rebuttal. All others: Three (3) minutes per speaker. 4.PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [24PLN-00278]: Request by AT&T for Review of a Tier 2 Wireless Communication Facility Permit Application for Modification of an Existing Wireless Antenna and Associated Equipment at an Existing Streetlight Pole in the Public Right-of-Way fronting 1661 Page Mill Road. CEQA Status: Exempt pursuant to California Environmental Quality Act (CEQA) Guidelines Sections 15301 (Existing Facilities). Zoning District: Not Applicable (Public Right-of-Way). BOARD MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS AND AGENDAS Members of the public may not speak to the item(s).   ADJOURNMENT    PUBLIC COMMENT INSTRUCTIONS Members of the Public may provide public comments to teleconference meetings via email, teleconference, or by phone. 1.Written public comments may be submitted by email to arb@PaloAlto.gov. 2.Spoken public comments using a computer will be accepted through the teleconference meeting. To address the Board, click on the link below to access a Zoom-based meeting. Please read the following instructions carefully. ◦You may download the Zoom client or connect to the meeting in- browser. If using your browser, make sure you are using a current, up-to-date browser: Chrome 30, Firefox 27, Microsoft Edge 12, Safari 7. Certain functionality may be disabled in older browsers including Internet Explorer. ◦You may be asked to enter an email address and name. We request that you identify yourself by name as this will be visible online and will be used to notify you that it is your turn to speak. ◦When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will activate and unmute speakers in turn. Speakers will be notified shortly before they are called to speak. ◦When called, please limit your remarks to the time limit allotted. A timer will be shown on the computer to help keep track of your comments. 3.Spoken public comments using a smart phone will be accepted through the teleconference meeting. To address the Board, download the Zoom application onto your phone from the Apple App Store or Google Play Store and enter the Meeting ID below. Please follow the instructions above. 4.Spoken public comments using a phone use the telephone number listed below. When you wish to speak on an agenda item hit *9 on your phone so we know that you wish to speak. You will be asked to provide your first and last name before addressing the Board. You will be advised how long you have to speak. When called please limit your remarks to the agenda item and time limit allotted. CLICK HERE TO JOIN Meeting ID: 965 6189 1491 Phone: 1-669-900-6833 Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public programs, services and meetings in a manner that is readily accessible to all. Persons with disabilities who require materials in an appropriate alternative format or who require auxiliary aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at (650) 329-2550 (voice) or by emailing ada@paloalto.gov. Requests for assistance or accommodations must be submitted at least 24 hours in advance of the meeting, program, or service. Item No. 1. Page 1 of 2 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: September 18, 2025 Report #: 2509-5199 TITLE Director's Report, Meeting Schedule, and Upcoming Agenda Items RECOMMENDATION Staff recommends the Architectural Review Board (ARB) review and comment as appropriate. BACKGROUND This document includes the following items: ARB meeting schedule Upcoming ARB agenda items Recently submitted and pending projects subject to ARB review Board members are encouraged to contact Samuel Tavera (Samuel.Tavera@PaloAlto.gov) to notify staff of any planned absences one month in advance, if possible, to ensure the availability of an ARB quorum. Approved projects can be found on the City’s Building Eye webpage at https://paloalto.buildingeye.com/planning Any party, including the applicant, may request a hearing by the ARB on the proposed director’s decision(s) within the 10-day or 14-day appeal period by filing a written request with the planning division. There shall be no fee required for requesting such a hearing. However, there is a fee for appeals. Pursuant to 18.77.070(b)(5) any project relating to the installation of cabinets containing communications service equipment or facilities, pursuant to any service subject to Palo Alto Municipal Code Chapter 2.11, Chapter 12.04, Chapter 12.08, Chapter 12.09, Chapter 12.10, or Chapter 12.13 is not eligible for a request for hearing by any party, including the applicant. No action is required by the ARB for this item. Item 1 Item 1 Staff Report     Packet Pg. 5     Item No. 1. Page 2 of 2 UPCOMING ARB AGENDA ITEMS The following items are tentative and subject to change: MEETING DATE TOPICS October 2, 2025 340 Portage Avenue: Second Hearing 156 California Avenue: Builder’s Remedy RECENTLY SUBMITTED PROJECTS No new ARB projects have been submitted since the last ARB hearing. ATTACHMENTS Attachment A: 2025 Meeting Schedule & Assignments Attachment B: Pending ARB Projects AUTHOR/TITLE: ARB1 Liaison & Contact Information Steven Switzer, Historic Preservation Planner  (650) 329-2321  Steven.Switzer@PaloAlto.gov 1 Emails can be sent directly to the ARB using the following address: arb@paloalto.gov Item 1 Item 1 Staff Report     Packet Pg. 6     Architectural Review Board 2025 Meeting Schedule & Assignments 8 4 9 3 2025 Meeting Schedule Meeting Dates Time Location Status Planned Absences 1/2/2025 8:30 AM Hybrid Cancelled 1/16/2025 8:30 AM Hybrid Regular 2/6/2025 8:30 AM Hybrid Regular 2/20/2025 8:30 AM Hybrid Regular Adcock 3/6/2025 8:30 AM Hybrid Regular 3/20/2025 8:30 AM Hybrid Regular 4/3/2025 8:30 AM Hybrid CANCELED 4/17/2025 8:30 AM Hybrid Regular 5/1/2025 8:30 AM Hybrid Regular 5/15/2025 8:30 AM Hybrid Regular 6/5/2025 8:30 AM Hybrid CANCELED 6/19/2025 8:30 AM Hybrid CANCELED 7/3/2025 8:30 AM Hybrid Regular 7/17/2025 8:30 AM Hybrid Regular Adcock & Jojarth 8/7/2025 8:30 AM Hybrid Regular 8/21/2025 8/28/2025 8:30 AM 12:00PM Hybrid In Person Regular Special 9/4/2025 8:30 AM Hybrid Regular 9/18/2025 8:30 AM Hybrid Regular 10/2/2025 8:30 AM Hybrid Regular 10/16/2025 8:30 AM Hybrid Regular 11/6/2025 8:30 AM Hybrid Regular 11/20/2025 8:30 AM Hybrid Regular 12/4/2025 8:30 AM Hybrid Regular 12/18/2025 8:30 AM Hybrid Regular 2025 Ad Hoc Committee Assignments Assignments will be made by the ARB Chair January February March April May June 3/20 – Adcock & Rosenberg July August September October November December 7/17 – Chen & Hirsch 8/7 -Chen & Rosenberg 9/4 – Chen & Hirsch Item 1 Attachment A - 2025 Meeting Schedule & Assignments     Packet Pg. 7     ARCHITECTURAL REVIEW BOARD Pending ARB Projects The following projects will soon be reviewed by the ARB. For more information, visit the project webpages at bit.ly/PApendingprojects or via Building Eye at bit.ly/PABuildingEye. Permit Type Filed Permit #Address Type Work Description Status/Notes Major Architectural Review 9/16/20 20PLN-00202 250 Hamilton Ave Bridge Allow the removal and replacement of the Pope-Chaucer Bridge over San Francisquito Creek with a new structure that does not obstruct creek flow to reduce flood risk. The project will also include channel modifications. Environmental Assessment: The SFCJPA, acting as the lead agency, adopted a Final EIR on 9/26/19. Zoning District: PF. On-hold for redesign Major Architectural Review Zone Change 12/21/21 21PLN-00341 24PLN-00239 660 University 680 University Mixed-Use Planned Community (PC), to Combine 3 Parcels (511 Byron St, 660 University Ave, 680 University Ave/500 Middlefield Rd), Demolish Existing Buildings (9,216 SF Office) and Provide a New Four Story Mixed-Use Building with Ground Floor Office (9,115 SF) and Multi- Family Residential (all floors) Including a Two Level Below-Grade Parking Garage. Proposed Residential Proposed Residential (42,189 SF) Will Include 65 Units (47 Studios, 12 1-Bedroom, 6 2- Bedroom). NOI Sent. Request for Major Architectural Review to Allow SB330/Builder’s Remedy project and construct a new six (6) story mixed-use building. The proposal includes ground floor non- residential (5,670 SF), ground and sixth floor office (9,126 SF), multi-family residential (all floors), and a two level below-grade parking garage. Proposed residential will include 88 units with 20% on-site BMR. ARB 1st formal 12/1/22 ARB recommended approval 4/22 Revised Plans Submitted 6/23 Item 1 Attachment B - Pending ARB Projects     Packet Pg. 8     Permit Type Filed Permit #Address Type Work Description Status/Notes Major Architectural Review 6/8/23 23PLN-00136 23PLN-00277 (Map) 23PLN-00003 and -00195 – (SB 330) 24PLN-00230 (Code compliant version) 24PLN-00231 (Map) 3150 El Camino Real Housing – 380 units Request for Major Architectural Review for construction of a 380- unit Multi-family Residential Rental Development with 10% Below Market Rate. The project includes a 456,347 square foot apartment building with a 171,433 square foot garage that extends to 84 feet in height. Staff is reviewing the project to ensure the requested concessions and waivers are in accordance with the State Density Bonus laws. Focus Area Compliant Application Filed 8/7/24 Ad Hoc (Rosenberg, Hirsch) Reported out 5/4 on SB 330 Ad Hoc (Rosenberg, Hirsch) Reported out on 8/17 ARB 11/7 Rec. approval PTC 5/14 Council 7/17 PC Amendment 8/9/23 23PLN-00202 4075 El Camino Way Commercial 16 convalescent units Request for a Planned Community Zone Amendment to Allow New Additions to an existing Assisted Living and Memory Care Facility consisting of 121 Units. The additions include 16 Additional Assisted Living Dwelling Units; 5 Studios and 9 One Bedrooms. Zoning District: PC-5116 Community Meeting in October. 2/28/24 and 6/12/24 PTC hearing, 7/18/24 ARB hearing, ARB 10/17/24, PTC & Council hearings TBD. Ad Hoc (Baltay, Chen) reported out 6/1 Major Architectural Review – Builder’s Remedy 4/02/24 24PLN-00100 24PLN-00223 (Map) 156 California Mixed-Use Request for Major Architectural Review in accordance with California Government Code 65589.5(D)(5) “Builders Remedy" which proposes to redevelop two lots located at 156 California Avenue and Park Blvd. Lot A, 156 California Ave ( 1.14 ACRE) is situated at the corner of Park and California, Lot B, Park Blvd. (0.29 ACRE) is at the corner of Park and Cambridge Avenue; the reinvention of both sites will include the conversion of an existing parking lot and Mollie Stone's Grocery Store into a Mixed Use Multi Family Development. This project consists of three NOI Sent 5/2/2024; 60-day Formal Comments sent 6/1; Resubmitted, Request for Supplemental Info Sent 7/11; Pending Resubmittal. SB 330 Pre-app Item 1 Attachment B - Pending ARB Projects     Packet Pg. 9     Permit Type Filed Permit #Address Type Work Description Status/Notes integrated structures; (1) 7 Story Podium Building with 5 levels of TYPE IIIB Construction over 2 levels of TYPE I Construction, 15,000 square feet will be dedicated to the Mollie Stone Grocery Store, (1) 17 Story Tower, (1) 11 Story Tower, both Towers will be proposed and conceptualized as TYPE IV Mass Timber Construction. Environmental Assessment: Pending Zoning District: CC(2)(R)(P) and CC(2)(R) (Community Commercial) submitted 11/21/24 Ad Hoc (Baltay, Adcock) Deemed Complete 12/22/24 Supplementary info req. Major Architectural Review – Builder’s Remedy 4/23/24 24PLN-00120 762 San Antonio Housing – 198 Units Request for Major Architectural Review to Allow CA GOV CODE 65589.5(D)(5) “Builders Remedy" which proposes the demolition of three existing commercial buildings and the construction of a 7- story multi-family residential building containing 198 rental apartments. This is 100% Residential Project. Environmental: Pending. Zoning District: (CS) AD. NOI Sent 5/23/2024. Ad Hoc (Baltay, Chen) ARB 8/7 Major Architectural Review – Builder’s Remedy 6/10/24 24PLN-00161 24PLN-00048 (SB 330) 3781 El Camino Real Housing – 177 units Request for Major Architectural Review to demolish multiple existing commercial and residential buildings located at 3727-3737 & 3773-3783 El Camino Real, 378-400 Madeline Court and 388 Curtner Avenue to construct a new seven-story multi-family residential housing development with 177 units. Two levels of above ground parking, rooftop terraces, and tenant amenities are proposed. Environmental Assessment: Pending. Zoning District: CN & RM-30. (Previous SB 330 and Builder’s Remedy: 24PLN-00048) NOI Sent 7/10/2024. Resubmittal on 11/22/24 Deemed Complete 4/3/25 Supplementary info req. Major Architectural Review – Builder’s Remedy 6/10/24 24PLN-00162 24PLN-00047 (SB 330) 3606 El Camino Real Housing – 335 Units Request for Major Architectural Review to demolish multiple existing vacant, commercial, and residential buildings located at 3508, 3516, 3626-3632 El Camino Real, and 524, 528, 530 Kendall Avenue to construct a new seven-story, multi-family residential housing development project with 335 units. The new residential building will have a two levels of above ground parking, ground floor tenant amenities, and a rooftop terrace facing El Camino Real and Matadero Avenue. Environmental Assessment: Pending. Zoning District: CN, CS, RM-30, RM-40 NOI Sent 8/1/2024. Resubmittal on 11/22/24 Deemed Complete 12/25/24 Supplementary info req. Major Architectural Review – Builder’s Remedy 7/17/24 24PLN-00184 24PLN-00232 (Map) 3400 El Camino Real Housing – 231 units & Hotel – 92 rooms Major Architectural Review of a Builder's Remedy application to demolish several low-rise retail and hotel buildings located at 3398, 3400, 3450 El Camino Real and 556 Matadero Avenue and replace them with three new seven-to-eight story residential towers, one new seven-story hotel, one new three story NOI Sent 8/16/2024 and 9/12/2024; Pending Resubmittal. Item 1 Attachment B - Pending ARB Projects     Packet Pg. 10     Permit Type Filed Permit #Address Type Work Description Status/Notes townhome, and two new underground parking garages. Three existing hotel buildings will remain with one being converted to residential units. 231 total residential units and 192 hotel rooms. Environmental Assessment: Pending. Zoning District: various (SB330) Minor Architectural Review & Conditional Use Permit 9/24/24 24PLN-00263 3950 Fabian Way Private Education Request for Minor Board Level Architectural Review for exterior modifications to an existing 32,919 square foot, 2-story commercial building, site modifications and a new approximately 4200 sf addition to the North side. The project also includes a Request for a Conditional Use Permit for the change of use to private education to accommodate Girls Middle school. Environmental Assessment: Pending. Zoning District: GM. NOI Sent 10/24/2024. Early ARB 11/21 ARB 5/1 rec. approval Ad Hoc 8/7 Streamlined Housing Development Review 10/08/24 24PLN-00280 3997 Fabian Way Residential Request for Streamlined Housing Development Review to deconstruct two existing commercial buildings located at 3977 & 3963 Fabian Way and surface parking lot at 3997 Fabian Way to construct a new single structure of seven stories containing 295 multifamily residential rental apartment units (8% very low- income units – 19 units), 343 parking spaces, 295 secured bike parking spaces, open courtyards, several outdoor gathering spaces, a pool area, and a rooftop terrace. The project is proposed to comply with the City’s GM/ROLM Focus Area Development Standards and is proposed in accordance with State Density Bonus Law. Environmental Assessment: Pending. Zoning District: General Manufacturing (GM). (Housing Inventory Site & State Density Bonus Law) (Previous SB 330 Pre-Application: 24PLN-00111) NOI sent 1/16/25 Resubmittal 1/31/25 NOI Sent 2/21/25 Master Sign Program 11/7/24 24PLN-00322 340 Portage Av Mixed-Use Master Sign Program for the installation of 2 Project ID Monuments, 2 Entry ID's, 2 Parking ID's, 2 Directional Wall signs, 1 Brand/Tenant ID Wall sign, and 2 Tenant ID Canopy signs at The Cannery Palo Alto. Zoning District: RM-30 (Medium Density Multiple-Family Residence District). Environmental Assessment: Pending. NOI sent 1/09/25 Resubmittal 3/27/25 ARB 5/15 rec. to continue date uncertain Minor Architectural Review 12/03/24 24PLN-00339 2280 El Camino Real Restaurant Minor Board Level Architectural Review for the exterior and interior remodel of the existing Jack in the Box restaurant. Modification to the exterior of the building include the removal of the mansard roof, installation of new parapets, new finishes and branding panels. No increase in building footprint. NOI sent 1/22/25 Resubmittal 2/21/25 NOI sent 3/26/25 Item 1 Attachment B - Pending ARB Projects     Packet Pg. 11     Permit Type Filed Permit #Address Type Work Description Status/Notes Site and Design & Conditional Use Permit 12/8/24 24PLN-00356 24PLN-00357 (Map) 2100 Geng Rd Housing – 137 Units Tentative Map/Subdivision and Site and Design & Conditional Use Permit (CUP) for the transformation of an existing underutilized business park at 2100-2400 Geng Road into a new residential neighborhood with 137 multi-family townhome units and community space. Project site totals approximately 11-acres. NOI sent 1/24/25 Resubmittal on 4/16/25 NOI sent 5/22/25 Resubmittal on 7/25 Minor Architectural Review 2/6/2025 25PLN-00027 180 El Camino Real Restaurant Minor Board review for Cedar & Sage restaurant (formally Terrain Cafe) at Space #1301, Bldg. DD at the Stanford Shopping Center. Exterior improvements include new textured plaster and painted façade, new storefront glazing, and bi-folding door system, remodeled outdoor patio, new retractable canopy system, new railing, landscape planters, and new signage. Interior improvements will include partial interior remodel. No change of use, no new square footage. NOI sent 3/10/25 Resubmittal on 4/8/25 Tentatively scheduled 7/17 ARB rec. approval 7 Minor Architectural Review 4/07/25 25PLN-00092 180 El Camino Real Commercial Request for Minor Board Architectural Review to allow for exterior improvements including painting, new entry door, glazing, patio, and new signage for proposed Ralph Lauren & Ralph's Coffee approximately 5,200 Square Foot, Environmental Assessment: Pending. Zoning District: CC (Community Commercial). NOI sent 5/14 Resubmitted 6/9 Minor Architectural Review 4/14/25 25PLN-00100 975 Paige Mill Rd Commercial Minor Board review for the renovation of an existing building (approximately 50,000 square feet) with no net change in the building area proposed and a request for Conditional Use Permit for a new cafe (retail service use - 3,769 square feet) with Alcohol Service within the renovated building. ARB rec. Approval 7/3 Item 1 Attachment B - Pending ARB Projects     Packet Pg. 12     Item No. 2.. Page 1 of 2 Architectural Review Board Staff Report From: Deputy City Manager Lead Department: City Manager Meeting Date: September 18, 2025 Report #: 2509-5195 TITLE Discussion of the Urban Land Institute Initiative with Palo Alto, Valley Transportation Authority (VTA), and Stanford related to the Palo Alto Transit Center and Designation of a Representative(s) to participate on behalf of the Board in the Urban Land Institute Initiative RECOMMENDATION Staff recommends that the Architectural Review Board (ARB) receive an update about the Urban Land Institute initiative with Palo Alto and partners related to the Palo Alto Transit Center (PATC) and also for the ARB to recommend an representative(s) to participate in stakeholder group interviews with the Urban Land Institute the week of October 19, 2025. BACKGROUND AND ANALYSIS The City is partnering with Valley Transportation Authority (VTA), Stanford University, and the Urban Land Institute (ULI) to obtain advice and recommendations from ULI on long-term development and planning issues associated with the Palo Alto Transit Center (See below for list of questions). ULI will bring a group of panelists to group interview a wide variety of individuals in Palo Alto to develop recommendations for the Palo Alto Transit Center. The stakeholder group interviews will take place the week of October 19, 2025, and ULI will make a presentation of findings at the end of their engagement. The ARB should choose the individual(s) they would like to represent the ARB at the stakeholder interviews on October 21, 2025. This effort is being organized through the partners listed above based on the work of the VTA Mobility Hub Ad Hoc Committee. The Mobility Hub Ad Hoc Committee is looking at ways to transform the second most active train station in the Caltrain corridor into an active transit-friendly hub that enhances visitor experience, supports community engagement, and ensures long-term sustainability. The station is already recognized as a regional intermodal hub (with VTA, SamTrans, AC Transit, Stanford’s Marguerite bus system, and other transportation links found there). The train station building is a historic building and ideas for the transit center include adding attractions, lighting, Item 2. Item 2 Staff Report     Packet Pg. 13     Item No. 2.. Page 2 of 2 and improved circulation. The ULI effort will be an opportunity for discussion around longer- term interests for the site. The ULI initiative will ask participants to discuss a series of questions including: Proposed ULI Advisory Services Panel Scope Questions 1. What existing or future uses, onsite features, or amenities would make the PATC a more inviting gateway for both Downtown Palo Alto and Stanford, and draw in new transit users? 2. What could be done to make the transit center more accessible to a variety of nonvehicular commuters, and increase capacity throughput? 3. What are successful models of mixed-use transit centers of similar context (suburban, close to downtown, gateway location, etc.), how were the improvements funded, and what are some of the key ingredients to that success? 4. What mix of uses would be the most feasible? How does density play into this equation? 5. What are phasing and financing options that should be considered for the different aspects of the station’s revitalization? What are steps we can take short-, medium-, and long-term to advance the vision? This ARB discussion will inform the ARB representative(s) about interests that the ARB would like elevated during the stakeholder interviews in October on behalf of the ARB. FISCAL/RESOURCE IMPACT This effort with ULI has a total cost of $135,000, split between the three parties (Santa Clara Valley Transportation Authority, Stanford University, and the City of Palo Alto). No additional resources are needed for this discussion with the ARB. STAKEHOLDER ENGAGEMENT The ULI Initiative will engage local stakeholders in this process. Also, members of the public can also engage with the Mobility Hub Ad Hoc Committee at the regular Ad Hoc Committee meetings. ENVIRONMENTAL REVIEW Not a project. Report Author & Contact Information Chantal Cotton Gaines, Deputy City Manager (650) 329-2572 Chantal.Gaines@paloalto.gov ARB1 Liaison & Contact Information Steven Switzer, Historic Preservation Planner (650) 329-2321 Steven.Switzer@paloalto.gov 1 Emails can be sent directly to the ARB using the following address: arb@paloalto.gov Item 2. Item 2 Staff Report     Packet Pg. 14     Item No. 3.. Page 1 of 6 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: September 18, 2025 Report #: 2506-4805 TITLE San Antonio Road Area Plan: Provide Feedback on Existing Conditions Analysis and Land Use and Mobility Priorities. CEQA Status: Exempt under CEQA Guidelines Section 15262. RECOMMENDATION Staff recommends the Architectural Review Board (ARB) conduct a study session to: 1. Review and comment on the draft San Antonio Road Area Plan Existing Conditions Analysis Summary Report. 2. Provide preliminary feedback to staff on considerations discussed in this report in order to inform City Council decisions on the land use and mobility alternatives for this project. EXECUTIVE SUMMARY The draft Existing Conditions Analysis Summary Report (Attachment A) documents key findings related to the existing conditions of the Plan Area and how, combined with existing regulations, they create opportunities and challenges to development. These findings are summarized in the Executive Summary of Attachment A. Staff recommends that the ARB review the information presented and provide preliminary feedback on key project considerations and approaches critical for the next phase of the project. PROJECT DESCRIPTION The purpose of the San Antonio Road Area Plan (Area Plan) is to develop an integrated land use and transportation approach to guide new development in the 275.3-acre Plan Area along and adjacent to San Antonio Road. The Area Plan objectives include increased housing production, transportation and mobility improvements, open space, commercial and retail nodes, infrastructure, and sustainability measures. The creation of this plan implements policies and programs of the City’s Comprehensive Plan and the 2023-2031 Housing Element (Housing Item 3. Item 3 Staff Report     Packet Pg. 15     Item No. 3.. Page 2 of 6 Element). The Area Plan will establish policies, development standards, design guidelines, and the public infrastructure necessary to accelerate the envisioned growth and development. The Area Plan builds on other planning efforts, including the 2030 Comprehensive Plan, the 2022 Sustainability and Climate Action Plan, the Housing Element, the 2025 Safe Streets for All (SS4A) Safety Action Plan, and the 2026 Bicycle and Pedestrian Transportation Plan update (currently in process). BACKGROUND The City Council designated the Bayshore Alma San Antonio (BASA) Area as a Priority Development Area (PDA) on September 18, 20231. PDAs are locally created to support regional goals set forth by the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC), as described in Plan Bay Area. Plan Bay Area outlines the Bay Area’s Regional Growth Framework, Regional Transportation Plan, and Sustainable Community Strategies through 2050 and beyond. Key goals of PDAs include encouraging and guiding growth around transit and connecting housing to jobs and areas of interest. The approximately 275.3-acre San Antonio Road Area Plan project boundary includes a majority of the larger BASA PDA boundary and has 53 identified Housing Element Opportunity Sites that account for roughly 1,500 housing units per standards set in the Housing Element. The Area Plan will also be impacted by existing and proposed development in the surrounding area, including across the border in Mountain View. Currently, the Plan Area prioritizes vehicular traffic and lacks sufficient pedestrian and bicycle facilities and transit options. This, combined with speeds often exceeding the posted limit, raise safety concerns. In order to meet the goals of increasing housing production and improving multi-modal connections (as well as the City’s sustainability goals) an overarching integrated land use/circulation approach is necessary, with a key goal of creating easy and safe connect. The Area Plan budget was approved by Council in March 2025, and work began in April 2025. Phase one of the Area Plan includes analysis of the area through literature and regulatory review, site visits, collection of new data, stakeholder interviews, workshops, surveys, and other technical studies to determine the area’s existing conditions, strengths, and challenges. Staff convened both a Community Advisory Group (CAG) made up of area residents and stakeholders and a Technical Advisory Group (TAG) made up of City staff and subject matter experts on August 19 and August 21, 2025, respectively. The draft Existing Conditions Analysis Summary Report was/will be presented to the following boards, committees, and commissions: Planning and Transportation Commission (September 10, 2025) Architectural Review Board (September 18, 2025) Pedestrian and Bicycle Advisory Committee (September 9, 2025) City/School Transportation Safety Committee (September 25, 2025) 1 September 18, 2023, City Council Meeting: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13026 Item 3. Item 3 Staff Report     Packet Pg. 16     Item No. 3.. Page 3 of 6 Following these opportunities for stakeholder engagement and comments, the project will return to the City Council, tentatively scheduled for October 6, 2025, to discuss concepts to be explored in the land use and mobility alternatives. A Community Survey is being conducted in the month of October, and the first Community Workshop will be held on October 23, 2025. ANALYSIS The Existing Conditions Analysis is a crucial deliverable in the first phase of the project. Preliminary findings, included in Attachment A, are based on technical analysis, regulatory review, and literature review, including existing City and regional planning documents. The report considers the following topic areas: Land Use: Including a review of the existing built environment, applicable State laws, zoning regulations found in the Palo Alto Municipal Code, land use designations found in the 2030 Comprehensive Plan, and amenities such as schools, parks, community centers, and retail in and around the Plan Area. Housing, Growth, and Displacement: Including a review of existing housing stock, pipeline development projects, City planning documents, and housing affordability. Transportation: Including a review of the automobile, bicycle, pedestrian, and mass transit networks in and proximate to the Plan Area, as well as safety concerns related to those networks. Market Analysis: Including a review of the Plan Area’s housing market, retail market, and employment market. Hazards, Public Safety, and Historic Resources: Including an examination of flooding, geologic, and fire hazards, emergency response, and historic context of the built environment. Parks, Open Spaces, and Public Facilities: Including a review of the existing amenities within and adjacent to the Plan Area. Air Quality, Noise, and Vibration: Including a review of the existing conditions and local and regional thresholds for impacts. Infrastructure: Including a review of City owned utility facilities in the Plan Area. Climate and Resilience: Including a review of local and regional policies and data. Requested Direction Based on the key findings identified in the draft Existing Conditions Analysis Summary Report, there are several notable assets and opportunities identified for the Area Plan to consider. Staff believes that updating land use designations, development standards, and improving active transportation routes and connections to the San Antonio Caltrain Station are key to the Area Plan’s success, but in order to develop complete neighborhoods the plan will also address open space/parks, retail, transit, and utilities. Staff seeks ARB feedback on the following topics: 1. Vision • What built features could promote a high aesthetic quality environment and enhance the desirability of living conditions within the Area Plan? Item 3. Item 3 Staff Report     Packet Pg. 17     Item No. 3.. Page 4 of 6 2. Land Use • What types of development standards would help facilitate the transformation of corridor to one more focused on mixed-use residential development? • How might the choice to either limit retail uses to certain areas or allow throughout the corridor impact potential development? 3. Outdoor Space The City of Palo Alto has a wide variety of public outdoor spaces and community facilities, but within the Plan Area, there is a lack of parks or other spaces for community gathering, particularly in the Commercial Street/Industrial Avenue area, where there are no parks within a 10-minute walk. • Do you support the idea of locating a new outdoor space in the Commercial Street/ Industrial Avenue area? • Can you suggest examples of parks or alternative outdoor spaces you feel are appropriate for the Plan Area? • Do you support co-locating retail and services adjacent to a new outdoor space? • Do you support placing public outdoor spaces within infill development projects in the Plan Area? 4. Mobility/Circulation The project team has identified that the Plan Area has a number of challenges regarding vehicle speeds, vehicle congestion, and bicycle and pedestrian facilities. • How can circulation within individual project sites and their connections to the roadway improve these challenges? • What policies or development standards will help encourage active transportation within the Plan Area? 5. Guidance for Design Alternatives • What improvements, development scenarios, or other design concepts should the team explore in the land use and mobility alternatives? NEXT STEPS A community workshop is scheduled for October 23, 2025. The discussion with the community will include exercises to identify community needs in the Plan Area and the types of improvements most desired by the public. This will be supplemented by a community survey running during the month of October to allow feedback on specific questions from community members who are unable to attend the workshop. The direction received from the City Council, and feedback from advisory bodies and the community will inform the scope of the project team explores during the land use and mobility alternatives phase of the project. These alternatives will be brought back to advisory bodies in early 2026 and is planned to return to Council in the summer of 2026 before work on the final plan elements and the environmental documentation begin. Item 3. Item 3 Staff Report     Packet Pg. 18     Item No. 3.. Page 5 of 6 POLICY IMPLICATIONS Several of the City’s 2030 Comprehensive Plan policies relate directly to the Area Plan. Policies L-1.10, L-2.2, L-2.3, L-2.4, L-2.6, L-2.11, L-2.12, and L-3.4 relate to growth management, sustainable communities, and neighborhood character. Policies L-4.5, L-4.16, and L-5.4 relate to commercial centers and employment districts. Policies L-6.6 and L-6.7 relate to the design of buildings and public space. Policies L-8.6, L-9.3, L-9.6, and L-9.7 relate to parks, streets, and public spaces. Additionally, the 2023-2031 Housing Element includes Program 6.6(C) calling for the City to prepare an area plan for the San Antonio Road Corridor and increase housing opportunities. The Housing Element also identifies 53 Housing Opportunity Sites within the Plan Area and emphasizes increasing housing in close proximity to the San Antonio Caltrain station. The City has also adopted a Housing Incentive Program (HIP) in 2019, which was updated it in 2025, as a local alternative to encourage multi-family and mixed-use residential development. HIP currently covers significant parts of the Plan Area. STAKEHOLDER ENGAGEMENT The project team understands that Community Engagement is the key to the success of the planning effort, in addition to the technical, design, and expertise provided by subject matter experts. The project team has created a robust community engagement strategy, which includes a dedicated webpage, social media and email announcements, formation of the Community Advisory Group (CAG) and Technical Advisory Group (TAG), stakeholder interviews, community workshops, surveys, meetings with the City Council and advisory commissions, committees, and boards, and pop-ups including tabling at City events and Farmers Markets. The first CAG meeting was held on August 19, 2025, and the first TAG meeting on August 21, 2025. The first community workshop will be held on October 23, 2025, at the Cubberley Community Center. A survey for the project will also be available on the project webpage during the month of October. ENVIRONMENTAL REVIEW The actions recommended in this report are exempt from review under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15262: A project involving only feasibility or planning studies for possible future actions that has not been approved, adopted, or funded would not have significant impact on the environment. The City will prepare an environmental analysis for the San Antonio Road Area Plan when more project specifics have been identified. ATTACHMENTS Attachment A: Draft San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025 Attachment B: San Antonio Road Area Plan Map Item 3. Item 3 Staff Report     Packet Pg. 19     Item No. 3.. Page 6 of 6 Report Author & Contact Information Robert Cain, Senior Planner (650) 838-2892 Robert.Cain@paloalto.gov ARB3 Liaison & Contact Information Steven Switzer, Historic Preservation Planner (650) 329-2321 Steven.Switzer@paloalto.gov 3 Emails can be sent directly to the ARB using the following address: arb@paloalto.gov Item 3. Item 3 Staff Report     Packet Pg. 20     SEPTEMBER 4, 2025 DRAFT San Antonio Road Area Plan Existing Conditions Analysis Summary Report Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 21     INTRODUCTION ........................................................................................................... 1 About the Project .............................................................................................................. 1 How This Document Is Organized ..................................................................................... 2 EXECUTIVE SUMMARY ................................................................................................. 3 Location and Context ........................................................................................................ 3 Existing Uses and Character .............................................................................................. 3 Housing Market Conditions............................................................................................... 4 Housing Initiatives ............................................................................................................ 4 Housing Affordability ........................................................................................................ 5 Existing Employment and Businesses ................................................................................ 5 Climate Resilience and Environmental Hazards ................................................................ 6 Potential Impacts on Services from Population Growth .................................................... 6 I. LAND USE AND ZONING ............................................................................................ 7 Existing Uses and Built Character ...................................................................................... 7 Regulatory Context and City Initiatives ............................................................................. 8 Pipeline Projects ............................................................................................................... 9 Outdoor Space and Placemaking Opportunities ............................................................. 10 Key Findings and Conclusions ......................................................................................... 11 2. HOUSING, GROWTH, AND DISPLACEMENT RISK ...................................................... 13 Introduction .................................................................................................................... 13 Existing Housing Characteristics ...................................................................................... 13 Residential Displacement Risk ........................................................................................ 14 Housing Need and Policy ................................................................................................ 16 Key Findings and Conclusions ......................................................................................... 19 3. TRANSPORTATION AND MOBILITY .......................................................................... 20 Introduction .................................................................................................................... 20 Road Network ................................................................................................................. 20 Bicycle Network .............................................................................................................. 23 Pedestrian Network ........................................................................................................ 25 Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 22     Transit Services ............................................................................................................... 26 Safety .............................................................................................................................. 26 Key Findings and Conclusions ......................................................................................... 28 4. MARKET AND ECONOMIC ANALYSIS ....................................................................... 30 Introduction .................................................................................................................... 30 Housing Market Conditions............................................................................................. 31 Retail Market Conditions and Trends .............................................................................. 32 Employment Profile and Trends ...................................................................................... 33 Key Findings and Conclusions ......................................................................................... 34 5. HAZARDS, PUBLIC SAFETY, AND HISTORIC RESOURCES ........................................... 36 Hazards ........................................................................................................................... 36 Public Safety ................................................................................................................... 37 Historic Resources .......................................................................................................... 38 Key Findings and Conclusions ......................................................................................... 38 6. PARKS, OPEN SPACE, AND PUBLIC FACILITIES .......................................................... 39 Schools............................................................................................................................ 39 Parks and Recreational Facilities ..................................................................................... 40 Key Findings and Conclusions ......................................................................................... 40 7. NOISE AND AIR QUALITY ......................................................................................... 41 Noise and Vibration ........................................................................................................ 41 Air Quality ....................................................................................................................... 42 Conclusions ..................................................................................................................... 42 8. INFRASTRUCTURE ................................................................................................... 43 Storm Drain Infrastructure .............................................................................................. 43 Sanitary Sewer Infrastructure ......................................................................................... 44 Domestic and Recycled Water Infrastructure ................................................................. 44 Natural Gas and Electricity Infrastructure ....................................................................... 45 Key Findings and Conclusions ......................................................................................... 45 9. CLIMATE AND RESILIENCE ....................................................................................... 46 Policies Regarding Climate Hazard Planning ................................................................... 46 Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 23     Baseline Conditions and Projections ............................................................................... 46 Key Findings and Conclusions ......................................................................................... 48 TABLE OF FIGURES Figure 1. Plan Area And Surrounding Context .................................................................. 2 Figure 2. Crash Severity In The Plan Area, 2015-2024 ...................................................... 3 Figure 3. Plan Area Zoning, Hip And Focus Area Boundaries ............................................ 4 Figure 4. Open Space Access In The Plan Area ................................................................. 5 Figure 1.1. Existing Uses, Built Form And Character Areas ............................................... 7 Figure 1.2. Zoning, Focus Areas And Hip Boundaries ....................................................... 8 Figure 1.3. Plan Area Pipeline Projects ............................................................................. 9 Figure 1.4. Open Space Access ....................................................................................... 10 Figure 1.5. Critical Areas Of Safety And Mobility Focus .................................................. 10 Figure 1.6. Development Opportunities ......................................................................... 12 Figure 2.1. Plan Area Census Block Groups .................................................................... 13 Figure 2.2. Household Income, 2019-2023 ..................................................................... 15 Figure 2.3. 5th And 6th Cycle Rhna Goals And Progress, 2025 ....................................... 17 Figure 3.1. Roadway Classification ................................................................................. 20 Figure 3.2. Pm Peak Hour Traffic Volumes By Intersection............................................. 21 Figure 3.3. Existing Bicycle Facilities ............................................................................... 23 Figure 3.4. Bicycle Level Of Traffic Stress ....................................................................... 24 Figure 3.5. Pedestrian Facilities ...................................................................................... 25 Figure 3.6. Crash Severity ............................................................................................... 27 Figure 4.1. Plan Area Census Block Groups .................................................................... 30 Figure 4.2. Household Types, 2019-2023 ....................................................................... 30 Figure 5.1. Fema Special Flood Hazard Area In The Plan Area ........................................ 36 Figure 6.1. School Districts In The Plan Area .................................................................. 39 Figure 8.1. 2015 Storm Drain Master Plan Priority Projects ........................................... 43 Figure 9.1. Slr Exposure Projections ............................................................................... 47 Figure 9.2. Existing And Projected Groundwater Depth ................................................. 47 Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 24     TABLE OF TABLES Table 1.1. Plan Area Pipeline Projects .................................................................................... 9 Table 2.1. Housing Units by Building Type .............................................................................. 14 Table 2.2. Housing Element Units from Opportunity Sites .......................................................... 17 Table 3.1. Average Daily Traffic Volumes and Speed Surveys ...................................................... 22 Table 4.1. Permitted Housing Units by Building Type, 2018-2024 ................................................ 31 Table 4.2. Percent Change in Employment in Plan Area, 2012-2022. ............................................ 33 Table 9.1. Summary of Hazard Projections ............................................................................. 46 Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 25     1 INTRODUCTION This is a draft report summarizing the existing conditions within and around the boundaries of the San Antonio Road Area Plan. Please note that some sections of this analysis are in progress as of the publication of this draft, and analysis will continue as part of the Area Plan’s compliance with the California Environmental Quality Act. About the Project The San Antonio Road Area Plan (Area Plan) is a multi-year initiative by the City of Palo Alto to reimagine land use, transportation, and community development for an area of 275 acres encompassing the roadway and private properties on both sides of San Antonio Road, one of the City’s and region’s key transportation corridors. This area, referred to in this document as the Plan Area, is located along the south-eastern edge of Palo Alto, adjacent to its boundary with Mountain View, and covers most of the Bayshore Alma San Antonio (BASA) Priority Development Area (PDA) boundary. Initiated in March 2025, the Area Plan will have five phases and is anticipated to be completed by 2028. It will build on recent City efforts including the 2023-2031 Housing Element, which established “Focus Areas” for the Plan Area, the Housing Incentive Program (HIP), the 2025 Safe Streets for All (SS4A) Safety Action Plan, and the Bicycle and Pedestrian Transportation Plan Update (in progress). The Area Plan will include a land use program; development standards; policies for transportation, housing, and environmental sustainability among other topics; implementation recommendations; and financing strategies. Community input will be critical to shaping the Area Plan outcomes. The project includes robust engagement including community workshops, pop-up events, surveys, advisory groups, and public meetings. Key goals of the Area Plan include: • Create a more livable community. Promote compact, mixed-use development with housing options at all income levels, local businesses, and well-designed public spaces. • Improve mobility and safety. Enhance streets, sidewalks, bike lanes, and transit connections for easier and safer travel and crossings, and improved access to the San Antonio Caltrain Station. • Support sustainability. Integrate green infrastructure, reduce emissions, and ensure resilience to climate change. • Enhance economic vitality. Attract new businesses and strengthen Palo Alto’s economy while preserving cherished local establishments and community character. San Antonio Road is an important regional arterial connecting US-101 (Bayshore Freeway) in the east to Alma Street/Central Expressway in the west, and beyond to El Camino Real and Foothill Expressway. It serves as an important truck route and facilitates access to key employment centers. Within the Plan Area, major crossings along San Antonio Road include US-101, East Charleston Road, Middlefield Road, and Alma Street/Central Expressway. The San Antonio Station of the Caltrain commuter rail line is located near the south-western corner of the Plan Area. Adjacent to the Plan Area are residential neighborhoods in Palo Alto and Mountain View. At present, the Plan Area has a mix of industrial, office, service commercial, and residential uses, with some properties transforming from commercial or industrial uses to residential and mixed use. There are only a few retail stores and no parks or other community spaces. While there are several community amenities in the vicinity, including parks, schools, grocery stores, and institutions (refer Figure 1); access to these destinations is difficult at present because of inadequate pedestrian and bicycle safety and connectivity. Substantial placemaking Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 26     2 efforts, including urban design, public realm, and safety improvements such as Complete Streets, are required to provide safer, more convenient transportation options. These improvements can enhance the attractiveness of the Plan Area for current and future residents, and help meet the City’s housing, sustainability, and mobility goals. Figure 1. Plan Area and Surrounding Context How This Document Is Organized This Summary Report presents key findings from analysis carried out by the project team to assess existing conditions within the Plan Area. Serving as an introduction to the project, it offers a concise overview of current conditions and key findings, organized by topic. For the purposes of this document, true cardinal directions are not used, but rather descriptors consistent with northbound/southbound as used for Highway 101: San Francisco is north, San Jose is south, and the San Francisco Bay is east. Source: Raimi + Associates, Google Earth Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 27     3 EXECUTIVE SUMMARY Location and Context San Antonio Road is an important transportation corridor for Palo Alto and the surrounding region. The Area Plan includes approximately 275 acres on either side of a 1.8-mile segment of San Antonio Road. Located along the boundary of Palo Alto and Mountain View, the Plan Area is influenced by development trends and movement patterns in both cities. Connections to US-101 (Bayshore Freeway), Alma Street/Central Expressway, and proximity to the San Antonio Caltrain station influence the area as well. Existing Uses and Character The Plan Area has a diverse mix of industrial, office, service commercial, and residential uses; and some properties are starting to transform from commercial or industrial uses to mixed-use. At present, the built character varies across the Plan Area, and the land use pattern is fragmented. The Plan Area itself lacks community spaces such as parks, and has only a few retail establishments, but in its vicinity, there are a number of community destinations such as parks, schools, grocery stores, institutions, and other uses. Connectivity to these amenities is, however, limited at present because of inadequate pedestrian and bicycle facilities. Substantial placemaking efforts, including urban design, public realm, and safety improvements such as Complete Streets, are required to provide safer, more convenient transportation options. These improvements can help meet the City’s housing, mobility, and sustainability goals, and enhance the accessibility and usability of the Plan Area for current and future residents. Mobility The current condition of San Antonio Road prioritizes vehicles and is less accommodating for pedestrians and cyclists. Limited bicycle infrastructure, known gaps in the pedestrian network, such as the absence of continuous sidewalks and unprotected crossings, as well as the lack of shade, restrict bicycle and pedestrian travel to major neighborhood destinations. Transit is Figure 2. Crash Severity in the Plan Area, 2015-2024 Source: Raimi + Associates, City of Palo l Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 28     4 available within the Plan Area; however, bus service is limited and there is poor connectivity to the San Antonio Caltrain Station, despite its proximity. Comprehensive improvements to ensure multimodal connectivity and safety may be necessary to provide sustainable travel options for Plan Area residents, workers, and visitors as its population increases. These improvements will be designed to reduce traffic congestion as mixed-use development increases. Safety is one of the key issues that need to be addressed in the Plan Area. Vehicle speeds along San Antonio Road often exceed posted limits, associated with a significant share of collisions. Figure 2 shows key locations and severity of collisions within the Plan Area. Investments in street, bicycle, and sidewalk infrastructure will improve safety and strengthen connections both within the Plan Area, to San Antonio Caltrain Station, and to other destinations in Palo Alto and Mountain View. Housing Market Conditions Although few housing projects have been built in the Plan Area since the 1990s, it has attracted development interest in recent years, and several pipeline projects could yield up to 750 housing units if completed as proposed. This would be a significant increase over the 802 residential units that currently exist in the Plan Area. There is strong demand for housing in Palo Alto, and the Plan Area may attract mid-rise multifamily projects, which align with the City’s regulatory and policy priorities for higher- density development. As the area evolves, development standards will be needed to guide compatibility between adjacent uses, and transitions in built form and scale. Because all pipeline projects are located on privately owned land, they remain subject to market volatility and other development uncertainties. Successful implementation may depend on targeted incentives that encourage the provision of community amenities as part of private development. Housing Initiatives The City of Palo Alto’s 2023–2031 Housing Element identifies 53 opportunity sites in the Plan Area, representing 1,559 new housing units, and designated the GM- and ROLM-zoned districts as Focus Areas to stimulate housing production. In addition, the City’s Housing Incentive Program (HIP) applies to a portion of the Plan Area, as shown in Figure 3. Together, these initiatives have already expanded development capacity along San Antonio Road. Given strong demand for housing in Palo Alto, and the available housing development opportunities within the Plan Area, the area is well-positioned to capture demand for additional housing units associated with projected household and employment growth. Figure 3. Plan Area Zoning, HIP and Focus Area Source: Raimi + Associates, City of Palo Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 29     5 Housing Affordability The Plan Area currently contains about 250 deed-restricted affordable housing units across four properties, as well as a small number of “naturally affordable” rental housing units (that have lower rents than City averages but are not deed-restricted). While homeowners and residents of deed-restricted units face lower displacement risk, renters in market-rate units may be more vulnerable to displacement as the Plan Area redevelops. With many sites identified for future housing, the Plan Area is well positioned to support lower-income households through inclusionary requirements, affordable housing fees, and, when funding is available, new or preserved deed- restricted affordable housing projects. The addition of housing in the Plan Area that is affordable at a range of income levels can help meet the needs of current and future residents and workers in Palo Alto. Existing Employment and Businesses According to U.S. Census data, as of 2022, the Plan Area accounted for about four percent of the City’s total jobs, but nearly 40 percent of its jobs in the Manufacturing sector. Small office and light industrial spaces, particularly near Commercial Street and Industrial Avenue, provide flexible, relatively affordable options for local businesses. As these spaces redevelop for housing or higher- intensity employment uses, existing small-scale businesses may be at risk of displacement, especially given the limited supply of comparable spaces elsewhere in Palo Alto. Community Amenities The Plan Area includes some religious institutions and community spaces, including the Oshman Family Jewish Community Center, and is adjacent to the Cubberley Community Center and Baylands Nature Preserve. However, the Plan Area itself has no parks or open spaces and is limited in retail nodes or other “third places” for community gathering. As the Plan Area adds more residents, such spaces will need to be included. A portion of the Plan Area is also “park deficient” by being more than a 10- minute walk away from an open space nearby, as shown in Figure 4. While there are limited retail uses within the Plan Area at present, there are a few valued local businesses. Retail offerings in the vicinity, including on El Camino Real and Mountain View’s San Antonio Center, can meet many day-to-day shopping needs. As the Plan Area redevelops, it is more likely to serve as a secondary retail location Figure 4. Open Space Access in the Plan Area Source: Raimi + Associates, City of Palo Alto GIS Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 30     6 that is better suited to neighborhood-serving restaurants, coffee shops, drugstores, and personal services. Retail demand is projected to grow gradually and may require a larger resident base before supporting significant new retail amenities, such as a new grocery store. The Area Plan will need to incorporate a vision and policies to encourage concentration of future retail at key locations with high visibility and access, such as the intersections of San Antonio Road with Middlefield Road and East Charleston Road. Climate Resilience and Environmental Hazards The Plan Area has some susceptibility to environmental challenges, including flooding, sea-level rise, urban heat events, and ground liquefication from seismic events. The portion of the Plan Area east of East Charleston Road is subject to a one percent annual chance flood and sea-level rise, while the rest of it faces a 0.2 percent annual chance of flooding. New development will need to meet base flood elevation standards and incorporate resilience measures. Air quality is another concern, particularly near US-101 and during regional wildfire events. Potential Impacts on Services from Population Growth Growth will place additional demands on public services and infrastructure. Emergency Medical Services (EMS) may require more staff, new equipment, and fire station upgrades. Overall school enrollment is down across all three school districts that service the Plan Area (Palo Alto Unified School District, Mountain View-Whisman School District, and Mountain View-Los Altos Union High School District), indicating their capacity to absorb new students. The City owns and provides stormwater, wastewater, domestic water, recycled water, natural gas, and electrical utilities. Additional development could require upgrades to all these utilities, including installation of larger water mains to produce necessary fire flow and service levels. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 31     7 I. LAND USE AND ZONING Existing Uses and Built Character The City of Palo Alto’s Comprehensive Plan assigns a mix of residential and non-residential land use designations to the Plan Area. The San Antonio Road/Bayshore Corridor is an important employment center and has a variety of light industrial, research, and office uses. Within the Plan Area, these uses are concentrated mainly east of East Charleston Road, transitioning to a mix of commercial and residential uses west of East Charleston, with some research and office uses west of Middlefield Road. Residential units within the Plan Area are primarily low-rise multifamily buildings. Existing building heights in the Plan Area are predominantly one to two stories, with a few buildings exceeding four stories, such as those in the Taube Koret Campus, and two hotels along San Antonio Road. Floor Area Ratios (FARs) range from 0.5 to 1.0, with a few buildings such as the AC Hotel reaching a higher FAR of 2.8. A built form analysis of the Plan Area identified distinct character areas, each with a unique mix of uses and built form characteristics, as shown in Figure 1.1. Across the Plan Area, parcel sizes, building types, and development patterns vary considerably, with little consistency in setbacks, building orientation, or scale transitions. By contrast, the character areas are more cohesive, with similar parcel sizes, building scale and land uses. Several developments along San Antonio Road, such as the Greenhouse Community, were designed to be inward facing, with limited interaction between building edges and adjacent streets or sidewalks. Such inactive frontages discourage pedestrian activity and placemaking and may need to be addressed as part of future development. Figure 1.1. Existing Uses, Built Form and Character Areas Source: City of Palo Alto GIS, Raimi and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 32     8 Regulatory Context and City Initiatives Zoning districts within the Plan Area, as shown in Figure 1.2, allow a mix of residential, commercial, office, and light industrial uses. Development standards regulate the scale and form of buildings in each district. Most zoning districts in the Plan Area allow multifamily housing at various densities. The Plan Area also has a few Planned Communities with site-specific development standards. Recent regulatory changes have focused on encouraging more housing City-wide, and the Plan Area in particular. The City’s 2023-2031 Housing Element identified 53 housing opportunity sites within the Plan Area, with a combined capacity for 1,559 new housing units at various income levels. It also designated the GM and ROLM zoning districts —areas that allow manufacturing, office, and research uses—within and adjoining the Plan Area as “Focus Areas”, allowing housing. The City’s Housing Incentive Program (HIP) that applies to a section of the Plan Area east of Middlefield Road, was also expanded to include the GM and ROLM Focus Areas, as well as multifamily residential zoning districts (RM-20, RM-30, and RM-40). In addition, Program 6.6C of the 2023- 2031 Housing Element directs the City to prepare a plan for the San Antonio Road corridor, including the GM and ROLM Focus Areas. These initiatives aim to promote multifamily housing through development incentives such as increased density, higher Floor Area Ratios (FARs), and reduced parking requirements. In addition, a 24-foot Special Setback applies to portions of Charleston Road, Middlefield Road, and San Antonio Road. Originally designated for future road widening, this setback presents an opportunity for public realm improvements as part of future development. Figure 1.2. Zoning, Focus Areas and HIP Boundaries Source: Raimi + Associates, City of Palo Alto GIS Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 33     9 Pipeline Projects The Plan Area has attracted recent development activity and there are several projects at various stages of proposal review and entitlement. These include mid-rise residential and mixed-use projects located along San Antonio Road between East Charleston Road and Middlefield Road (in the HIP district), and along Fabian Way. Figure 1.3 shows the large number of 2023-2031 Housing Element sites in the Plan Area, along with key projects currently in the development pipeline (also listed in Table 1.1). In total, these could yield more than 750 housing units should all the development occur as proposed. To be feasible in Palo Alto’s housing market, future development is anticipated to be larger and taller than what exists currently; as indicated by recent development proposals that typically feature five- to seven-story residential and mixed-use buildings with FARs of 3.0 or more, and parking ratios of fewer than two parking spaces per unit. Pipeline Project Lot Area Density, No. of Units FAR, Height Pkg Ratio Commercial Status 1. 3950 Fabian Way 1.51 ac None (school project) 0.5, 2 stories 0.12 None (school) Entitled 2. 3997 Fabian way 2.16 ac 135 du/ac, 295 units 3.19, 7 stories 1 to 1.5 None Pending approval 3. 824 San Antonio Rd. 0.45 ac 56 du/ac, 28 units 1.99, 4 stories 0.57 2,948 sf Entitled 4. 800,808 San Antonio Rd. 0.88 ac 85 du/ac, 75 units 3.0, 5 stories 1.97 None Entitled 5. 788 San Antonio Rd. 0.99 ac 169 du/ac, 168 units 3.31, 8 stories 0.43 None Building Permits Issued 6. 762 San Antonio Rd. 1.78 ac 112 du/ac, 197 units 3.33, 7 stories 1.24 None Pending approval Figure 1.3. Plan Area Pipeline Projects Source: City of Palo Alto GIS, Raimi and Associates Table 1.1. Plan Area Pipeline Projects Source: City of Palo Alto Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 34     10 Outdoor Space and Placemaking Opportunities Palo Alto has approximately 4,000 acres of open space (outdoor space), including the Baylands Nature Preserve, larger regional parks such as Mitchell Park (21 acres), smaller neighborhood parks such as Ramos Park (4 acres), community gardens, and other types of parks and recreation amenities. However, the Plan Area itself has no parks or other spaces for recreation or community gathering within it. Figure 1.4 shows parks and open spaces in the vicinity of the Plan Area, and pedestrian “walksheds” around each for 5-minute (approximately ¼ mile) and 10-minute (approximately ½ mile) walk distances. While most parts are within a 10-minute walkshed to neighboring parks, a significant portion is “park deficient” with inadequate access, meaning no parks are located within a 10-minute walking distance. Creating new open spaces, such as parks, as part of future development will be a key focus of the Area Plan. Placemaking and public realm improvements will also be important not only to improve safety and connectivity, but also to create distinct character districts along San Antonio Road that relate to the existing uses and functions of each segment. Figure 1.5 highlights potential focus areas for urban design improvements, as well as key streets and intersections where multimodal safety and connectivity improvements will be most critical. Figure 1.4. Outdoor Space Access Figure 1.5. Critical Areas of Safety and Mobility Focus Source: City of Palo Alto GIS, Raimi and Associates Source: City of Palo Alto GIS, Raimi and Associates Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 35     11 Key Findings and Conclusions Key findings from the existing conditions analysis are summarized below. DESIGN OPPORTUNITIES • Location and Access. San Antonio Road is an important transportation corridor for Palo Alto and the surrounding region. The Plan Area has good auto access from US-101, and being located adjacent to the San Antonio Caltrain station offers the potential for enhanced transit connectivity if pedestrian and bicycle access to the station is improved. Located along the boundary between Palo Alto and Mountain View, the Plan Area is influenced by development trends and movement patterns in both cities and benefits from employment opportunities, as well as access to community and open space amenities, in both cities. • Existing Uses and Built Character. The Plan Area has a diverse mix of industrial, office, service commercial, and residential uses. While land use and built form patterns are currently fragmented, and San Antonio Road functions primarily as a circulation corridor; the Plan Area has distinct “character areas” with the potential to evolve into mixed-use neighborhoods. Several properties in the Plan Area are already transitioning from commercial and industrial uses to residential and mixed-use development. • Development Trends. The Plan Area has attracted development interest in recent years and has several proposed projects in the pipeline that could produce more than 750 housing units, should all these projects be built as proposed. • Housing Initiatives. The City of Palo Alto’s 2023-2031 Housing Element identified 53 opportunity sites in the Plan Area, designated the GM- and ROLM-zoned districts within the Plan Area as Focus Areas, and directed the City through Program 6.6C to develop a plan for this area to stimulate housing production. Additionally, the City’s Housing Incentive Program (HIP) applies to a portion of the Plan Area. These housing-focused initiatives substantially increase the development capacity along San Antonio Road. SITE CHALLENGES • Inconsistent Character. Inconsistent land uses and built character in the Plan Area that exist currently are not supportive of the Plan Area’s envisioned transition to a mixed-use area with additional housing. Substantial placemaking efforts, along with urban design and public realm improvements, may be needed to support future development and population growth. • Inadequate Pedestrian, Bicycle and Transit Facilities. The current condition of streets and sidewalks is not friendly or accommodating for pedestrians and bicyclists, and transit connectivity is inadequate. Comprehensive improvements are needed to ensure multimodal connectivity and safety to serve future residents, workers and visitors, and to meet the City’s mobility, sustainability, and housing goals. • Limited Community Amenities. The Plan Area itself has no parks, open spaces, or other “third places” for community gathering. A portion of the Plan Area is also “park deficient” by being more than a 10-minute walk (half a mile) from nearby open spaces. Additionally, the Plan Area has no defined retail nodes or similar community destinations. Creating such “third places” may be considered as part of the Area Plan. • Compatibility in Built Form and Uses. As the area transforms over time, incompatibility between adjacent land uses, as well as building height and massing transitions, must be addressed through updated development standards. • Market Conditions. All pipeline projects are located on privately-owned properties and subject to housing market volatility and other development uncertainties. Successful implementation will require development incentives to encourage the provision of community amenities in private development projects. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 36     12 DEVELOPMENT OPPORTUNITIES The Plan Area’s characteristics and anticipated projects indicate a valuable opportunity to guide large-scale development in targeted locations within the Plan Area. Future development can be leveraged to create mixed- use neighborhoods with safe and convenient access to transportation, employment, community services, and recreation. To achieve this, placemaking will be an important design tool, and will likely include a combination of streetscape improvements to promote safety and walkability, as well as design enhancements to create a distinct identity for this neighborhood with a strong sense of place. Figure 1.6 maps key development opportunities within the Plan Area by identifying areas with the highest probability of transformation — the potential “opportunity areas” with projects that are in the development pipeline, Housing Element opportunity sites, and areas eligible for the Housing Incentive Program (HIP). An example of a potential opportunity area is the E Charleston Commercial/ Industrial character area (area around Commercial Street and Industrial Avenue), which has good visibility and auto access from East Charleston and San Antonio Roads, and includes several small-scale office and light industrial uses. It also has a large concentration of Housing Element sites within it, signaling an increase in population in the coming years. However, this area is also “park deficient.” These characteristics suggest potential priorities to consider as part of future development: the need for connectivity improvements, measures to prevent displacement of neighborhood-serving uses, and an opportunity to create a new open space, potentially coupled with neighborhood-serving retail and amenities. Figure 1.6. Development Opportunities Source: City of Palo Alto GIS, Raimi and Associates Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 37     13 2. HOUSING, GROWTH, AND DISPLACEMENT RISK Introduction This section looks at current housing characteristics, potential residential displacement risks, and relevant City housing policies impacting the Area Plan. The findings of these analyses will help inform the City of Palo Alto’s efforts to increase affordable and market-rate housing production in the Plan Area, preserve existing affordable housing (including both deed-restricted affordable housing as well as market-rate housing that is not deed-restricted yet relatively affordable), and protect households vulnerable to displacement. Data and findings in this section describe conditions within the “Plan Area Census Block Groups,” a set of Census block groups with existing housing that encompass the Plan Area, as shown in Figure 2.1. Since detailed U.S. Census data is only available for specific predetermined geographies, the selected block groups best cover the Plan Area while providing sufficient information for analysis. The analyses only cover the most recent available Census data since the block group boundaries differ from previous years. Existing Housing Characteristics The Plan Area has approximately 750 existing housing units, most of which are located on San Antonio Road west of East Charleston Road. This number represents approximately three percent of the City’s total housing stock. These include two large concentrations of housing—Greenhouse Community (228 units) and Palo Alto Gardens (156 units)—that together make up just under half of the Plan Area’s existing housing. Three condominium communities, each with between 30 and 50 housing units, and a cluster of small apartment buildings (totaling approximately 40 units) on Byron Street are also located on or just off San Antonio Road. Housing along Alma Street contributes approximately 100 units to the Plan Area’s total, mostly as attached single-family housing units (as defined by the U.S. Census, whose classifications of housing types may differ from other sources such as the California Building Code and Palo Alto Municipal Code). HOUSING TYPES The Plan Area’s housing mix includes a significantly higher share of multifamily and attached single-family housing than in Palo Alto overall. These attached housing products provide housing comparably more affordable than detached single-family homes. As shown in Table 2.1, 39 percent of the Plan Area’s housing units are attached single-family homes (such as townhomes), compared to six percent Citywide. Small multifamily buildings with fewer than 20 housing units account for 54 percent of all housing in the Plan Area, compared to 16 percent Source: City of Palo Alto GIS, Strategic Economics, 2025. Figure 1.1. Plan Area Census Block Groups Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 38     14 Citywide. The majority of housing in the Plan Area consists of two- to three-story buildings dating to the 1970s, as most of the Plan Area was built-out from the 1950s through the 1980s. With two exceptions, the development of new housing projects largely ceased in the Plan Area after 1990. Based on recent zoning changes and recent patterns of redevelopment of industrial and commercial uses, the Plan Area is now positioned to accommodate significant new mid-rise housing development. Table 2.1. Housing Units by Building Type Plan Area Palo Alto Mountain View Units by Building Type Count Percent Count Percent Count Percent Single-Family (Detached) 4 0% 16,298 56% 10,516 27% Single-Family (Attached) 312 39% 1,671 6% 5,378 14% Multiple Units (2 Units) 0 0% 330 1% 694 2% Multiple Units (2-19 Units) 430 54% 4,794 16% 8,607 22% Multiple Units (20+ Units) 56 7% 5,911 20% 12,340 32% Mobile Home 0 0% 100 0% 1,235 3% Total (% may not sum due to rounding) 802 100% 29,104 100% 38,770 100% AFFORDABLE HOUSING The Plan Area has 252 deed-restricted affordable housing units that constitute over 30 percent of the Plan Area’s existing housing and equate to 15 percent of Palo Alto’s total deed-restricted affordable housing inventory. Of the Plan Area’s 252 affordable units, 80 consist of senior housing for residents 65 and older. Residential Displacement Risk Maintaining household income diversity and affordability in the Plan Area requires not only strategies to produce and preserve affordable housing, but also to protect lower-income residents from potential displacement risks. Variables such as household tenure, income, and education help determine households’ displacement risk. The U.S. Census data representing the “Plan Area Census Block Groups” (Figure 2.1) was used for this analysis, and the conclusions drawn from the data were compared to findings from the Urban Displacement Project, a research project affiliated with the University of California at Berkeley, which models displacement risk at the Census tract level. HOUSING TENURE The Plan Area Census Block Groups include 766 renter-occupied housing units, 364 of which were built before 1960 and may be relatively affordable due to their age. Renter households do not constitute a relatively high share of occupied housing units in the Plan Area Census Block Groups, at 42.6 percent of occupied housing units, compared to 45.8 percent Citywide. However, the Plan Area’s more than 350 households occupy older rental housing units that may be relatively more affordable. Unlike ownership housing with fixed-rate mortgages and limited allowable property tax increases, renter households in Palo Alto are vulnerable to significant rent increases. Palo Alto lacks a rent control program, although some limits under the State’s California Tenant Protection Act apply to all cities which lack local rent control regulations. The Act limits annual rent increases for Source: U.S. Census, Strategic Economics, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 39     15 most rental housing units to five percent plus the change in the regional Consumer Price Index, or 10 percent total (whichever is lower). HOUSING COST BURDEN Cost-burdened households (those paying more than 30 percent of total household income toward housing expenses) are especially concentrated among lower-income renter households in Palo Alto. Although corresponding data is not available for the Plan Area, the 2023-2031 Housing Element indicated that 17 percent of the City’s renters and 15 percent of its homeowners were defined as cost-burdened as of 2018, and renters were more likely to experience cost burdens compared to homeowners. Nearly 65 percent of Palo Alto’s extremely low-income renter households were cost-burdened, with 42 percent paying more than half their income toward housing expenses. As shown in Figure 2.2, nearly 30 percent of households living in the Plan Area Census Block Groups earn household incomes of less than $100,000 per year and 13 percent of households earn less than $50,000 per year. Although some of these households may be served by existing deed-restricted affordable housing in the Plan Area, there are only 250 deed-restricted units in the Plan Area and approximately 525 households earning less than $100,000 in the Block Groups. For reference, a single-person household earning $111,700 qualifies as low-income based on Santa Clara County’s area median income limits used for affordable housing development. Figure 2.2. Household Income, 2019-2023 HOUSEHOLD INCOME TRENDS Median household income in the Plan Area Census Block Groups is $200,001, which is lower than that for Palo Alto as a whole ($220,408) but higher than that for Mountain View ($179,917). Between 2011 and 2021, median household incomes rose at a faster rate in Palo Alto (81 percent) and Mountain View (85 percent) than the regional increase of 74 percent for Santa Clara County and 77 percent for San Mateo County. Increasing household incomes in Palo Alto are driven by growth of very high-income households and declines in lower- and middle-income households—leading to increased displacement risk as lower-income households compete for housing with higher-income households. The number of these high-income households grew by 33 percent from 2000 to 2022 during a period when total households only grew by three percent. At the same time, households earning $60,000 to $100,000 declined by 66 percent, the largest loss among income groups. 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Plan Area (Block Groups) Palo Alto Mountain View Santa Clara County San Mateo County Per c e n t o f H o u s e h o l d s More than $200,000 $100,000-$199,999 $50,000 - $99,999 Less than $50,000 Source: U.S. Census, Strategic Economics, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 40     16 URBAN DISPLACEMENT PROJECT ANALYSIS The Urban Displacement Project is a research lab and collaborative of four universities—including the University of California at Berkeley—that estimates displacement risk at the Census tract level. The Urban Displacement Project did not identify displacement risk for very low-income and low-income residents for any of the Census tracts in the Plan Area. However, this analysis does not address past exclusion, which is a form of displacement that impacts low-income renters’ ability to afford to live in a community. High housing costs, high household incomes, and high levels of educational attainment in Palo Alto make it especially difficult for lower-income households to afford market-rate rents and sales prices. The U.S. Census data that informs the Urban Displacement Project is also focused on housed residents and therefore does not account for unhoused residents in the Plan Area subject to displacement if, for example, regulatory changes force people living in vehicles to relocate. Furthermore, regardless of aggregated data findings, the risk of displacement can remain a concern at the level of the individual resident or household. NATURALLY OCCURRING AFFORDABLE HOUSING Naturally Occurring Affordable Housing (NOAH) refers to unsubsidized market-rate (and often rental) housing that is especially affordable to lower-income residents based on 30 percent of their annual household incomes. The relatively lower rents found in NOAH units are usually related to building age, condition, or location. NOAH properties are a means for lower-income residents to be able to live in otherwise unaffordable communities. Although the Plan Area’s overall diversity of housing types provides relative affordability compared to single- family homes, few unsubsidized properties affordable to lower-income residents exist in the Plan Area overall. However, approximately 40 units of multifamily rental housing on Byron Street potentially represent NOAH properties. The Plan Area also includes two examples of preservation of long-term affordability: Ferne Apartments, built in 1963, was converted into deed-restricted affordable housing in 1981 and is currently managed by the nonprofit Alta Housing. MidPen Housing acquired Palo Alto Gardens in 1999 after residents organized to protect the property from significant rent increases as market-rate property. Housing Need and Policy RHNA PROGRESS The City of Palo Alto’s housing production goals are identified through the Regional Housing Needs Allocation (RHNA), a State-wide process which breaks down housing production goals into income categories for eight-year cycles. The City’s 2023-2031 Housing Element plans for the production of 6,086 housing units between 2023 and 2031. The distribution of units across income groups reflects adopted City policy regarding Palo Alto’s overall housing needs during the current RHNA cycle. Palo Alto succeeded in meeting its previous RHNA cycle’s production goal in the above moderate-income category but fell short of production goals for all other lower- income groups. During the fifth RHNA cycle covering 2015 to 2023, the estimated need was highest for housing affordable to very low-income households. However, only 100 units meeting these affordability needs were proposed and approved, permitted, or built. Similarly, low- and moderate-income housing production fell short of the fifth cycle RHNA goals. Palo Alto’s current RHNA goals consist primarily of housing affordable to above moderate-income households and very low-income households. The likely housing need by affordability level based on the mix of jobs and occupations found in Palo Alto closely aligns with current RHNA goals—reinforcing the need to produce housing that is affordable at a variety of income levels. The Plan Area also includes a significant share of jobs paying wages that would likely require deed- Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 41     17 restricted affordable housing for the worker household to reside in Palo Alto. For example, within the Plan Area itself, U.S. Census data from the Longitudinal Employer-Household Dynamics data set indicates that approximately 16 percent of “primary” jobs (i.e., the highest-paying job held by a worker) in 2022 paid less than $40,000 annually. Figure 2.3. 5th and 6th Cycle RHNA Goals and Progress, 2025 ROLE OF PLAN AREA IN MEETING HOUSING GOALS The Plan Area was allocated 25 percent of the Citywide Opportunity Sites inventory capacity in the current RHNA cycle, while the area currently includes just 2.8 percent of Citywide housing units. Table 2.2 shows the 2023-2031 Housing Element sites inventory by income category. The Opportunity Sites inventory anticipates further housing production through redevelopment of existing older commercial and light industrial buildings, and most designated sites are concentrated east of Middlefield Road and west of US-101. No sites are located west of Middlefield Road, where many of the Plan Area’s existing housing units are located. Table 2.2. Housing Element Units from Opportunity Sites Lower-Income (0-80% AMI) Moderate-Income (80-120% AMI) Above Moderate-Income (120%+ AMI) All Units Total Percent Total Percent Total Percent Total Percent Plan Area 614 25% 332 33% 613 23% 1,559 26% Other 1,838 75% 681 67% 2,008 77% 4,527 74% Total 2,452 100% 1,013 100% 2,621 100% 6,086 100% Source: U.S. Census, Strategic Economics, 2025. Source: U.S. Census, Strategic Economics, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 42     18 AFFORDABLE HOUSING CONSIDERATIONS FOR THE PLAN AREA The City of Palo Alto has existing tools and policies for affordable housing production, the preservation of affordable housing, and protection of tenants. Tools focused on affordable housing production are most relevant to the Plan Area, given the number of sites identified as future Housing Opportunity Sites. The following are most relevant to the Plan Area: • The City of Palo Alto’s Housing Incentive Program (HIP) provides incentives for housing development in the Plan Area that are coupled with contributions to affordable housing production. • The City also ensures that the overall supply of housing in the Plan Area will be sustained through its “no net loss” policy in which future redevelopment of existing housing stock must include at least as many units as are proposed for demolition. • Other requirements linking affordable housing production or revenue contributions to new development will be especially relevant for ensuring the Plan Area remains a mixed-income community. • The City must consider the tradeoffs between immediately delivering affordable housing units in the Plan Area via an emphasis on inclusionary requirements (currently in place for ownership housing developments and via the HIP) versus providing fee resources (including via current impact fees applied to rental housing developments) for City contributions to more deeply affordable 100 percent affordable projects. • The Plan Area presents opportunities to leverage the City’s existing affordable housing resources to support the development of 100 percent affordable housing projects if the City can acquire sites or partner with developers seeking master plan development agreements for large properties. • The Plan Area’s ability to compete for outside affordable housing funding varies by location. The California Tax Credit Allocation Committee (TCAC) and Department of Housing and Community Development (HCD) define the Plan Area as representing “highest resource” and “high resource” areas. This designation improves the Plan Area’s ability to score and compete for critical funding sources such as Low-Income Housing Tax Credits (LIHTC) and other State resources. However, most large, underutilized sites best positioned for cost-efficient housing development in the Plan Area are located outside the half-mile radius of robust transit access at the Caltrain station, which reduces the area’s ability to compete for funding sources tied to transit and reductions of greenhouse gas emissions. • The City’s support for the Homekey Palo Alto project (at 1237 North San Antonio Road), currently under construction, helps achieve the City’s homelessness services and alternative housing program goals. The project is an example of leveraging City funds to provide diverse housing options in the Plan Area. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 43     19 Key Findings and Conclusions The findings of these analyses will help inform the City of Palo Alto’s efforts to increase affordable and market- rate housing production in the Plan Area, preserve existing affordable housing, and protect households vulnerable to displacement. Key conclusions are summarized below. • Few new housing projects have been built in the Plan Area since the 1980s. Housing in the Plan Area largely consists of two- to three-story condominium and rental multifamily buildings built from the 1950s through the 1980s, except for assisted living housing built at the Taube Koret Campus in 2010 and affordable housing units at the Alta Torre senior affordable housing project. The Plan Area’s 802 housing units constitute approximately 2.8 percent of Palo Alto’s 29,104 units. • The Plan Area’s existing housing helps in meeting Palo Alto’s affordable housing needs, with approximately 250 deed-restricted affordable housing units at four properties. • A limited quantity of relatively affordable market-rate rental housing—known as “naturally-occurring affordable housing,” or “NOAH”—exists within the Plan Area at properties along Byron Street. NOAH units can potentially represent future opportunities for conversion to deed-restricted affordable housing as part of a strategy to preserve existing relatively affordable housing. An example of this occurred in the Plan Area at Palo Alto Gardens in 1999. • Although modeling by the UC Berkeley Urban Displacement Project does not indicate a significant risk of displacement for low-income renter households in and near the Plan Area, City tenant protection policies can play a role in supporting the nearly 40 percent of households that are renters in and near the Plan Area. • The addition of housing in the Plan Area that is affordable to households with diverse income levels can help meet the needs of workers at jobs in Palo Alto and the Plan Area itself. Wages associated with the industry sector mix of jobs in Palo Alto suggest that 35 percent of worker households may qualify as low- or very low- income and would benefit from deed-restricted affordable housing in the City. This share is similar to the assigned RHNA targets the City is seeking to achieve as part of its current Housing Element of the Palo Alto Comprehensive Plan. • Within the Plan Area, U.S. Census data indicates that approximately 16 percent of “primary” jobs (i.e., the highest-paying job held by a worker) in 2022 paid less than $40,000 annually. • Given the number and magnitude of sites identified as future Housing Opportunity Sites within it, the Plan Area is especially well-positioned to expand its role in meeting the housing needs of lower-income households. This can be achieved through application of inclusionary housing policies and affordable housing fee payments in conjunction with future housing development, and through production of deed- restricted 100 percent affordable housing developments. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 44     20 3. TRANSPORTATION AND MOBILITY Introduction The transportation network studied for the Plan Area consists of roadways, pedestrian facilities, bicycle facilities, and transit facilities, as well as the suggested walk and roll routes from the City’s Safe Routes to School Program. Road Network Roads within the Plan Area and its vicinity can be categorized into three classifications: arterial, collector, and local, shown in Figure 3.1. Posted speed limits within the Plan Area range from 25 to 45 miles per hour (mph). The Plan Area includes a network of designated truck routes including US-101 (Bayshore Freeway), San Antonio Road, Alma Street, Fabian Way, and East and West Bayshore Roads. San Antonio Road is classified as a critical east-west arterial and truck route providing access to key employment centers, and has a speed limit of 35 mph. There are six signalized intersections within the Plan Area, and major crossings include Alma Street, Middlefield Road, East Charleston Road, and US-101. From Alma Street to East Charleston Road, the roadway features a divided four- lane cross-section, that transitions to a three-lane undivided cross-section east of East Charleston Road, and narrows to a two-lane cross-section as it approaches and crosses US-101. TRAFFIC COUNTS Vehicle, truck, bicyclist, and pedestrian counts were collected at 25 intersections for the weekday AM (7:00–10:00 AM) and PM (4:00–7:00 PM) peak periods. The data was collected on three separate weekdays: Thursday May 15, Wednesday May 21, Figure 3.1. Roadway Classification Source: City of Palo Alto GIS, Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 45     21 and Tuesday May 27, 2025. It is worth noting that one of the count days (May 15, 2026) coincided with Bike-to- Work Day, which may have influenced bicyclist volumes. For each intersection, the peak hour was determined based on the highest observed total vehicle volume within the respective time window. PM peak hour volumes were higher at each intersection. Figure 3.2 summarizes PM peak hour volumes at each intersection. Figure 3.2. PM Peak Hour Traffic Volumes by Intersection Source: Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 46     22 TRAFFIC SPEEDS Table 3.1 shows Average Daily Traffic (ADT) data collected over a 72-hour period along San Antonio Road between Alma Street and Casey Avenue, including vehicle speeds and volumes. The highest observed 85th percentile speed was on the segment between East Charleston Road and US-101, indicating an increase as vehicles approach the highway. The lowest speeds are recorded on the segment between Bayshore Road and Casey Avenue, aligned with the change in cross-section to two undivided lanes in this segment. A notable percentage of high-speed vehicles was observed along San Antonio Road. On the segment between East Charleston Road and US-101, around one-third of vehicles exceed 40 mph where the posted speed limit is 35 mph. Average Daily Traffic (ADT) volumes remain within a similar range along Alma Street to US-101, with eastbound volumes ranging from 10,410 to 11,916 and generally higher westbound volumes between 11,559 and 17,593. Table 3.1. Average Daily Traffic Volumes and Speed Surveys Roadway Segment 85th Percentile Speed (mph) Vehicles > 40mph (%) ADT Eastbound Westbound Eastbound Westbound Eastbound Westbound San Antonio Road between East Charleston Road and US-101 44 43 35 33 11,779 17,593 San Antonio Road between Middlefield Road and East Charleston Road 35 38 5 10 10,410 11,559 San Antonio Road between Alma Street and Middlefield Road 40 40 17 15 11,916 17,368 San Antonio Road between Bayshore Road and Casey Avenue 29 28 0 0 1,390 1,511 Source: Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 47     23 Bicycle Network The City of Palo Alto has developed a robust bike network with a mix of bicycle boulevards, bike lanes, separated bikeways, and trails; but the Plan Area lacks a fully connected bicycle network. There are currently no continuous bicycle facilities on San Antonio Road. A bike route is present between Middlefield Road and Charleston Road. Fabian Way has a bike lane from East Bayshore Road, which discontinues near the intersection with East Charleston Road. The only continuous north- south bikeways are found on East Charleston Road, which includes both standard and buffered bike lanes on both sides of the roadway. Middlefield Road provides a short segment of bike lane south of San Antonio Road on the west side of the roadway. The pedestrian and bicycle bridge that crosses US-101 provides a grade-separated facility that enables uninterrupted crossing for people walking, biking, and rolling across the highway barrier. Overall, the limited presence of bike facilities, combined with high vehicle speeds and volumes, contributes to conditions that are not conducive to bicycle travel. Figure 3.3 illustrates the existing bicycle facilities. Figure 3.3. Existing Bicycle Facilities Source: City of Palo Alto GIS, Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 48     24 BICYCLE LEVEL OF COMFORT Bicycle Level of Traffic Stress (LTS) is an evaluation that quantifies the amount of discomfort that people feel when bicycling based on attributes such as vehicle speed, vehicle volume, number of lanes, bicycle lane blockage, presence of on-street parking, and ease of intersection crossing. There are four LTS ratings (LTS 1 through LTS 4). The higher the LTS, the higher the expected discomfort for the rider traveling along the facility. Figure 3.4 illustrates the Segment Bicycle LTS analysis from the City of Palo Alto’s Bicycle and Pedestrian Transportation Plan (BPTP) Update (in progress). Based on the BPTP Update, the Plan Area exhibits generally high levels of bicycle traffic stress. While most minor streets are classified as LTS 1 (low traffic stress), most major corridors are rated LTS 3 or LTS 4. The most stressful segments in the Plan Area are located along Alma Street and San Antonio Road (both LTS 4), Middlefield Road, East Charleston Road, Fabian Way, and Bayshore Road (all LTS 3). Among the intersections in the Plan Area, six are signalized and are assigned LTS 1, as traffic signals provide dedicated crossing time for cyclists. The other low-stress intersections are typically along residential streets with lower speeds and minimal vehicular activity. Many high-stress intersections are found along Alma Street, San Antonio Road, Middlefield Road, East Charleston Road, and Fabian Way, consistent with the high-stress classifications of these corridors. San Antonio Road features 12 intersections in the Plan Area, of which five are rated LTS 4 and one is rated LTS 3. Figure 3.4. Bicycle Level of Traffic Stress Source: City of Palo Alto GIS, Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 49     25 MAJOR BARRIERS The BPTP Update identified three primary linear barriers within and connecting to the Plan Area: US-101, the Caltrain rail corridor, and the waterway near Fabian Way and Bayshore Road. The most critical connectivity gap lies between Adobe Creek and Embarcadero Road pedestrian and bicycle bridges, which limits access to the Adobe Creek Loop Trail and adjacent destinations. Within the Plan Area, the San Antonio Caltrain Station provides a pedestrian and bicycle crossing over the rail corridor, improving connectivity across this barrier. Barriers near transit also occur at San Antonio Road, where the absence of continuous sidewalks along certain segments limits direct pedestrian and bicyclist access to transit. Pedestrian Network Figure 3.5 shows pedestrian facilities in the Plan Area. Sidewalks are largely continuous, with most streets in the Plan Area providing sidewalks approximately four to five feet wide on both sides of the roadway. While this width meets minimum standards in many residential contexts, it may be inadequate for higher pedestrian volumes, accessibility needs, or areas with high levels of adjacent traffic. In some areas, sidewalks are separated from the roadway by landscaped strips and tree coverage, which help buffer pedestrians from vehicle traffic. However, notable gaps exist in certain locations. The Plan Area’s six signalized intersections are equipped with standard marked crosswalks, ADA ramps, and pedestrian-activated countdown signal heads, with each intersection providing at least one crosswalk and corresponding pedestrian signal. The Plan Area features pedestrian safety treatments such as mid-block crossings, a Rectangular Rapid Flashing Beacon (RRFB) and refuge islands. Within the Plan Area, San Antonio Road does not provide continuous pedestrian or bicycle crossings over US-101. Figure 3.5. Pedestrian Facilities Source: City of Palo Alto GIS, Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 50     26 Transit Services The Santa Clara Valley Transportation Authority (VTA) operates bus services within Palo Alto. Key features of existing transit services in the Plan Area include: • There are currently five bus stops located along San Antonio Road, four bus stops along Fabian Way, and two bus stops along East Charleston Road. None of the associated services are classified as high frequency. • VTA Route 21 travels twice an hour from the Stanford Shopping Center to the Santa Clara Transit Center via the Mountain View Transit Center. The route runs along San Antonio Road between Alma Street and Middlefield Road, with stops at Middlefield Road and at Nita Road and San Antonio Court. • VTA Route 288 is a school-day-only tripper route with one daily service to and from Gunn High School. It operates along East Charleston Road and Fabian Way, before continuing west on Meadow Drive and Arastradero Road toward Gunn High School. • ACE Orange Route provides four daily commuter shuttle service between Meadow Drive and Meadow Circle, east of the Plan Area, and the Great America ACE/Amtrak Station, including stops at Fabian Way and East Meadow Drive, Fabian Way and East Charleston Road, and San Antonio Road and Casey Avenue within the Plan Area. • MVgo Routes D and C operate along San Antonio Road, connecting Mountain View employment centers with Caltrain and light rail stations. However, these routes do not stop within Palo Alto. • Palo Alto Link, an on-demand rideshare service, also provides point-to-point service to popular destinations throughout the City. • Located just outside the Plan Area boundary, the San Antonio Caltrain Station, a regional commuter rail system operated by the Peninsula Joint Powers Board, provides service at 15- or 30-minute headways (depending on peak or off-peak times) between San Francisco and San Jose, with additional service as far as Gilroy. Caltrain recently completed electrification of its right-of-way between San Francisco and San Jose, improving service frequency and speeds. A large portion of the plan area is located within a half mile walk, and the entire plan area is within a 2-mile bicycle ride, of San Antonio Caltrain station. • Future plans for California’s High-Speed Rail include a proposed four-track segment through Palo Alto for high-speed train service alongside Caltrain. Safety An assessment of reported crashes was conducted using the latest 10 years of the University of California, Berkeley's Transportation Injury Mapping System (TIMS) data (2015 to 2024). A total of 143 crashes occurred in the Plan Area over the past 10 years, including two fatal and three severe injury crashes. One fatal crash occurred at the intersection of Commercial Street and Charleston Road, and another near the intersection of San Antonio Road and Nita Avenue. Throughout the 10-year review period, a total of five pedestrian and 15 bicycle crashes were reported in the Plan Area. Among the pedestrian crashes, one crash was fatal, and one resulted in a severe injury. For bicycle-involved crashes, one crash resulted in a severe injury, and 11 crashes involved visible injuries. No bicycle crashes were fatal. Most collisions occurred along key access points and intersections along San Antonio Road including Charleston Street, Middlefield Road, and Alma Street. Approximately 30 percent of the reported crashes occurred along Fabian Way. Primary collision factors among fatal crashes were unsafe speeds and pedestrian right-of-way Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 51     27 violations. For severe injury crashes, the leading factors were unsafe speed, driving or cycling under the influence (DUI), and traffic signal and sign violations. HIGH-INJURY LOCATIONS The Safe Streets for All (SS4A) Safety Action Plan identified a High-Injury Network (HIN) composed of corridors with a disproportionate share of fatalities and severe injuries between 2018 and 2022. These corridors were prioritized for safety interventions as part of the City’s commitment to Vision Zero and the Safe System Approach. The SS4A Safety Action Plan includes San Antonio Road from Alma Street to East Charleston Road, Middlefield Road from San Antonio Road to Lytton Avenue, and East Charleston Road from San Antonio Road to Los Palos Avenue. SAFE ROUTES TO SCHOOLS The local Safe Routes to School (SRTS) Partnership between the City, the Palo Alto Unified School District (PAUSD), and the Palo Alto Council of PTAs (PTAC) works to reduce risk to students in routes to and from school and encourages more families to choose alternatives to driving solo more often. Within the Plan Area, the Palo Alto SRTS program has identified suggested walking routes on San Antonio Road and Middlefield Road, while Fabian Way and East Charleston Road include segments designated for both walking and biking. Greendell School, a public PAUSD site, is located near these suggested routes and is included in the City’s SRTS Walk and Roll Map program. Other private schools in the Plan Area are located near suggested corridors; however, these schools are not formally evaluated by the SRTS program. Private institutions may choose to reference existing Walk and Roll Maps and develop their own recommended routes. PARKING Both on-street and off-street parking is permitted throughout the Plan Area. San Antonio Road has a total of 145 on-street parking spaces, Fabian Way has 135 total spaces, and most residential streets also allow on-street parking. In the Plan Area, bicycle parking appears to be insufficient overall, with limited availability near public Figure 3.6. Crash Severity Source: City of Palo Alto GIS, Kittelson and Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 52     28 spaces, intersections, and key pedestrian corridors. The distribution of bicycle racks is concentrated in the eastern portion of the corridor near dense commercial areas, while significant gaps exist along the western segment of San Antonio Road. Key Findings and Conclusions Key findings, challenges and opportunities for transportation and mobility are identified in the following list. BICYCLE AND PEDESTRIAN NETWORKS • The Plan Area includes key destinations within a walking, biking or rolling distance, such as Ramos Park, Cubberley Community Center, San Antonio Caltrain Station, and nine public and private schools. • Existing bicycle facilities are limited along San Antonio Road, with only a short bike route present between Middlefield Road and East Charleston Road. • Bicycle Level of Traffic Stress (LTS) analysis identifies segments on San Antonio Road, Alma Street, and Middlefield Road that are particularly uncomfortable and have the highest LTS rating of 4. • There are gaps in the existing pedestrian network where the absence of continuous sidewalks limits direct access to key destinations. Existing pedestrian facilities are present along most segments of San Antonio Road, but key gaps exist near the Bayshore Freeway interchange and between Nita Avenue and Alma Street. TRANSIT SERVICES • VTA Route 21 provides public transit access at 30-minute headways along a short segment of San Antonio Road between Alma Street and Middlefield Road, with the highest weekday ridership activity observed at the Middlefield Road stop. No other active bus routes currently operate within the Plan Area. • A large portion of the plan area is also within a half-mile walk, and the entire plan area is within a 2-mile bicycle ride, of San Antonio Caltrain station, which provides regional transit access between San Francisco and San Jose. SAFETY • The City’s Safe Routes to School (SRTS) program identifies suggested walking routes on San Antonio and Middlefield Roads, and shared walking/biking routes on Fabian Way and Charleston Road. Public schools like Greendell are formally included, while private schools may reference the City’s Walk and Roll Maps to develop their own routes. • Vehicle volumes are highest at the intersection of San Antonio Road and Middlefield Road with 3,741 cars observed between 8:00 AM and 9:00 AM and 4,391 observed between 4:55 PM and 5:55 PM. A total of 88 trucks were counted at this location during the weekday AM peak hour and 40 trucks were counted during the weekday PM peak hour, or 2.3 percent and 0.9 percent respectively. • Truck volumes are generally higher during the morning and are consistently higher near US-101 ramps, where trucks made up 95 of the 2,411 vehicles, or 3.9 percent of the vehicle traffic at that location during the weekday AM peak hour (which occurred between 8:05 AM and 9:05 AM). • Speed surveys show that 85th percentile speeds exceed the posted 35 mph limit on multiple segments of San Antonio Road, particularly between East Charleston Road and US-101, where nearly one-third of vehicles travel above 40 mph. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 53     29 • San Antonio Road has a total of 145 on-street parking spaces. Bicycle parking is limited and unevenly distributed, particularly along the western portion of San Antonio Road. • Over the last 10 years, 143 crashes were reported in the Plan Area, including two fatal and three severe injury crashes. 14 percent of reported crashes involved pedestrians or bicyclists. The most common primary collision factor was unsafe speed, accounting for 34 percent of the reported crashes and many of the fatal and severe injury crashes. • The City of Palo Alto’s Safe Streets for All Safety Action Plan (2025) identifies San Antonio Road, from Alma Street to East Charleston Road, as part of the City’s High Injury Network based on its crash history and collision severity. • The City of Palo Alto’s Bicycle and Pedestrian Transportation Plan Update (in progress) and City of Palo Alto Bicycle and Pedestrian Transportation Plan (2012) propose redesigning San Antonio Road as part of the San Antonio Road Area Plan to accommodate anticipated housing growth along and near the corridor as well as continued development and improvement of the San Antonio Caltrain Station as an important transportation node for the City. • City of Palo Alto Bicycle and Pedestrian Transportation Plan (BPTP) Update (in progress) recommends the following improvements: o Class I shared use path along San Antonio Road from East Charleston Road to Terminal Boulevard, o Class IV separated bikeways on San Antonio Road between Alma Street and East Charleston Road, on Charleston Road within City limits, and on Alma Street from Meadow Drive to San Antonio Avenue, o Class IIb buffered bikeway on Fabian Way from Meadow Drive to East Charleston Road, and o Class IIIb bicycle boulevard on Mackay Drive, continuing along Shasta Drive and Nelson Drive. The existing conditions assessment for the San Antonio Road corridor identifies several critical challenges that limit safe and equitable multimodal access to key destinations. The issues include the lack of continuous and protected bicycle infrastructure along San Antonio Road, which is classified as high stress (LTS 4) and creates a major barrier to travel. Sidewalk gaps, minimal landscaping buffers, and long crossings and block lengths further hinder pedestrian comfort and accessibility. Driver speeding is prevalent, with 85th percentile speeds exceeding posted limits on multiple segments, and crash data reveal a history of severe and fatal collisions involving pedestrians, cyclists, and motorcyclists. Transit service is minimal, with only two active VTA routes (route 21 and ACE Orange Mountain View Shuttle) and no operating school or shuttle services. Finally, the shortage and poor distribution of public bike parking undermines the potential for short local bike trips and first/last mile connectivity. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 54     30 4. MARKET AND ECONOMIC ANALYSIS Introduction The primary relevant local market for the Plan Area includes the cities of Palo Alto and Mountain View, with the regional area consisting of Santa Clara County and San Mateo County. Figure 4.1 shows the census block groups used for the Plan Area analysis of demographic and household trends. Since detailed U.S. Census data is only available for specific predetermined geographies, the selected block groups best cover the Plan Area while providing information for analysis. DEMOGRAPHIC AND HOUSEHOLD TRENDS The Plan Area Census Block Groups have a higher presence of families with children, slightly lower median household income, and a more diverse population than Palo Alto. • Population. As of 2021, the Plan Area Census Block Groups had 4,975 people (7 percent of Palo Alto’s population), in 1,798 households (7 percent of Palo Alto’s households). • Median Household Income. The Plan Area Census Block Groups’ median income of $200,001 is lower than that of Palo Alto ($220,408) and higher than Mountain View ($179,917). Median household income in Palo Alto increased by 81 percent from 2011 to 2021, driven by increases in high-income households, and losses of middle- and lower-income households. • Household Characteristics. Average household sizes in Mountain View and Palo Alto are much smaller than in Santa Clara County and San Mateo County overall. Figure 4.2 shows details of household types. • Race and Ethnicity. Palo Alto and Mountain View are less racially and ethnically diverse than Santa Clara County and San Mateo County overall. Compared to Palo Alto, the ratio of Non-Hispanic Black residents to the total population is higher for the Plan Area at 11 percent, compared to 2 percent for the City. 38%33%27%33%31% 37%35% 27% 37%38% 17%25% 33% 22%24% 9%7%13%8%8% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Plan Area Census Block Groups Palo Alto Mountain View Santa Clara County San Mateo County Per c e n t a g e o f H o u s e h o l d s Other Non-Family Household Householder Living Alone Families without Children Families with Children Figure 4.2. Household Types, 2019-2023 Source: U.S. Census, American Community Survey, 5-year Estimate, 2019-2023; Strategic Economics, 2025. Figure 4.1. Plan Area Census Block Groups Source: U.S. Census, Strategic Economics, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 55     31 Housing Market Conditions EXISTING HOUSING SUPPLY Analysis of the Plan Area’s existing housing supply including Key Findings is described in Section 2, “Housing, Growth, and Displacement Risk” of this report. HOUSING MARKET POTENTIAL AND TRENDS Palo Alto home sales prices are significantly higher than those for neighboring cities and the County. In 2025, the median single-family home value in Palo Alto was $3.69 million, 76 percent higher than Mountain View ($2.09 million), 94 percent higher than Santa Clara County ($1.73 million), and 99 percent higher than San Mateo County ($1.61 million). Between 2015 and 2025, single-family home values increased by 43 percent in Palo Alto and 62 percent in Mountain View. Condominiums are relatively more affordable but still significantly more expensive than surrounding areas. Palo Alto’s average effective rents per square foot increased by nearly 18 percent from 2015 to 2025, similar to Mountain View. High absorption and low vacancy rates for multifamily rental housing in Palo Alto and Mountain View indicate strong demand for this product type. Recent developments have been trending towards multifamily housing as well, as shown in Table 4.1. Table 4.1. Permitted Housing Units by Building Type, 2018-2024 Number Percent Single- Family ADU Multi-family Total Single- Family ADU Multi-family Local Market Area 813 825 5,177 6,815 12% 12% 76% Palo Alto 15 574 363 952 2% 60% 38% Mountain View 798 251 4,814 5,863 14% 4% 82% Regional Market Area 8,533 10,393 46,233 65,159 13% 16% 71% Santa Clara County 7,209 7,294 36,611 51,114 14% 14% 72% San Mateo County 1,324 3,099 9,622 14,045 9% 22% 69% Notes: “ADU”s are accessory dwelling units, which are accessory to a single-family home or other residential structure. 14 manufactured units were also permitted in Santa Clara County during this period. Source. California Department of Housing and Community Development Annual Progress Reports, Table A2, 2018-2024; Strategic Economics, 2025. The Plan Area benefits from a variety of indicators that suggest strong ongoing demand for new housing: high- performing housing markets in Palo Alto and Mountain View, demographic trends suggesting demand from senior and working-age adult households; and recent developer interest, with pipeline projects potentially adding 750 new housing units to the Plan Area. Regional forecasts anticipate housing growth translating to an average of 974 housing units per year for Palo Alto and Mountain View combined. Given this strong demand, available development opportunities, and its access to jobs, the Plan Area is well-positioned to capture projected demand for additional housing units. The Plan Area is most likely to attract development of mid-rise multifamily rental housing products, which are most compatible with the Plan Area’s existing built environment of light industrial sites positioned for Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 56     32 redevelopment, patterns of development in nearby areas of Mountain View at similar sites, and the City of Palo Alto’s regulatory and policy priorities focused on promoting higher-density development in the Plan Area. Developers interviewed shared that ideal sites for cost-efficient mid-rise housing development are rectangular or square, allow multiple access points, are at least one to two acres in size, are relatively underutilized (typically vacant or with light industrial uses), and located near existing or future transportation access and retail amenities. Retail Market Conditions and Trends EXISTING RETAIL The Plan Area currently has a small retail inventory consisting of approximately 69,000 square feet of retail space concentrated around the intersections of San Antonio Road at East Charleston Road and Middlefield Road. This includes 38,000 square feet of automobile-oriented retail and one car dealership (28,000 square feet) that is currently for sale. Other uses include small stores and quick-serve restaurants. The Plan Area is within the service radius of regional retail centers such as Stanford Shopping Center and Town & Country Village in Palo Alto, San Antonio Center in Mountain View, and retail centers near El Camino Real. Other retail centers in the vicinity include the Rengstorff Center and two grocery-anchored neighborhood shopping centers along Middlefield Road in Palo Alto and Mountain View. The Plan Area is reasonably well covered by the trade areas of existing food stores, including two supermarkets (Joya Supermarket and Piazza’s Fine Foods), a specialty food store (Crossroads), Costco in Mountain View, and multiple grocery stores west of the Plan Area at and near San Antonio Center. These existing retail uses can serve the Plan Area’s near-term needs. The eastern portion of the Plan Area has lower access to grocery stores than other parts. The City of Palo Alto has a policy priority to preserve existing retail, which is enacted through the Retail Preservation Ordinance (RPO). The RPO generally requires replacement of existing ground floor retail. However, specific requirements vary by location in the City and project type. Under State Law, the RPO does not apply at sites included in Palo Alto’s 2023-2031 Housing Element sites inventory, and the replacement requirement is limited to 1,500 square feet for housing projects with densities of 30 or more dwelling units per acre. RETAIL MARKET POTENTIAL AND TRENDS The analysis for potential retail development in the Plan Area is based on current market conditions and competitive retail supply in the surrounding trade area, interviews with local retail brokers, and examining pipeline projects. As the Plan Area adds more households, it is best positioned to attract neighborhood-serving retail that typically has a service radius of one to three miles. These can include dining, personal services, and potentially future grocery stores and drug stores, with each new household generating a demand for approximately 34 square feet of new retail space. Local retail brokers interviewed noted that the most desirable retail locations in the Plan Area are at the intersections of Middlefield Road and San Antonio Road, and East Charleston Road and San Antonio Road, due to visibility from large quantities of through traffic and accessibility from existing residents and new residents at proposed housing projects. Future retail development in the Plan Area is anticipated to follow recent trends in the area, that consist of small quantities of ground floor retail in mixed-use development projects or expansions and modernizations of existing major shopping centers. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 57     33 Employment Profile and Trends EMPLOYMENT IN THE PLAN AREA Most jobs in the Plan Area today are in the manufacturing sector, accounting for 43 percent of total Plan Area employment, with Maxar as a major employer. As of 2022, the Plan Area had 40 percent of Palo Alto’s Manufacturing sector jobs, and 36 percent of the City’s construction jobs. Between 2012 to 2022, the Plan Area lost a large number of manufacturing jobs and gained jobs in other sectors, with health care as the largest sector. Employment trends are shown in Table 4.2. Table 4.2. Percent Change in Employment in Plan Area, 2012-2022. Industry 2012 2022 Change (Number) Change (%) Manufacturing 3,788 2,043 -1745 -46% Other 764 722 -42 -5% Professional, Scientific, and Technical Services 481 640 159 33% Health Care and Social Assistance 184 564 380 207% Retail Trade 184 360 176 96% Construction 209 315 106 51% Information 130 52 -78 -60% Total 5,740 4,696 -1044 -18% Source. U.S. Census, LEHD OnTheMap, 2022; Strategic Economics, 2025. EMPLOYMENT TRENDS Jobs in the Plan Area today include a larger share of opportunities for workers with lower levels of educational attainment compared to jobs in Palo Alto overall. The Information and Professional, Scientific and Technical Services industry sectors are associated with very high average wages, but also high education, training, and skill requirements. In contrast, the Manufacturing and Construction industry sectors typically include a larger share of middle-skill, middle-wage jobs. Development of new housing in the Plan Area is likely to primarily occur at properties with these types of existing employment, such as the small office and light industrial spaces near Commercial Street and Industrial Avenue. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 58     34 Key Findings and Conclusions HOUSING MARKET ANALYSIS FINDINGS • Robust demand for a variety of housing products exists in the Plan Area and surrounding market area, as indicated by relatively high sales prices for ownership housing, relatively high achievable rents, and low residential vacancy rates. • Given strong demand for housing in Palo Alto and the available housing development opportunities within the Plan Area, the area is well-positioned to capture demand for additional housing units associated with projected household and employment growth, as forecasted by the Association of Bay Area Governments for Santa Clara and San Mateo Counties. • Despite demand for a range of housing products in Palo Alto—including lower-density ownership housing such as luxury townhomes—the Plan Area is most likely to attract development of mid-rise multifamily housing products. These products are most compatible with the City of Palo Alto’s regulatory and policy priorities focused on promoting higher density development in the Plan Area. • Recent housing development proposals in the Plan Area demonstrate developer interest in mid-rise, relatively higher-density housing products. Housing development proposals in and near the Plan Area primarily consist of buildings that are most often seven to eight stories tall and with densities ranging from 110 to 170 dwelling units per acre. • The likelihood and timing of housing development on specific sites in the Plan Area will depend on site characteristics, existing uses, and location. Ideal sites for cost-efficient mid-rise housing development are rectangular or square, allow multiple access points, are at least one to two acres in size, are relatively underutilized (typically vacant or with light industrial uses), and located near existing or future transportation access and retail amenities. Developers can assemble smaller sites to create a site with these characteristics, but parcel assembly takes time and adds development risk. • Improvements to local amenities, the pedestrian environment, and multimodal transportation options can support the attractiveness of the Plan Area for future residents and potentially accelerate housing development activity. RETAIL MARKET ANALYSIS FINDINGS • Existing retail offerings (with “retail” inclusive of shopping, dining, services, and entertainment) are limited within the Plan Area. However, much of the area is located within a half mile of existing neighborhood and community shopping centers that can meet many day-to-day shopping needs for existing residents and residents of any early future housing developments. • The best performing retail locations near the Plan Area are primarily closer to El Camino Real, with retail brokers noting that the Plan Area itself is more likely to serve as a secondary retail location that is better suited to supporting neighborhood-serving retail—such as dining, personal services, and potentially future grocery stores and drug stores—rather than major regional shopping destinations. The San Antonio Center adjacent to the Plan Area functions as a larger regional retail center that can serve current and future households in the Plan Area. • Over time, additions of new residents in the Plan Area will generate demand for additional local retail space to accommodate dining, services, and day-to-day shopping needs. The total magnitude of supportable retail space will vary depending on the projected buildout of housing units in the Plan Area. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 59     35 • Given the likely incremental process of housing development in the Plan Area, retail demand is likely to grow gradually and take time to achieve a critical mass of residents to support significant new retail amenities such as a new grocery store. Existing nearby retail amenities will largely meet demand from early residential growth, and early retail opportunities within the Plan Area will primarily consist of dining and personal services. • New retail space is likely to best perform in Plan Area locations that are near areas of future housing growth, visible and readily accessible from higher-traffic streets, and allow for a concentration of retail tenants. Real estate brokers interviewed for this study noted that the intersection of Middlefield Road and San Antonio Road is likely to be a desirable retail location within the Plan Area due to visibility from large quantities of pass-through traffic and accessibility from existing residents and new residents at proposed housing projects to the east. Locations along East Charleston Road and San Antonio Road near the intersection of these streets also benefit from visibility and access. • Given the gradual pace of housing buildout to achieve a critical mass of residents to support larger quantities of new retail space, the San Antonio Road Area Plan will need to incorporate a vision and policies to ensure development of retail space at preferred future retail concentrations. ECONOMIC ANALYSIS FINDINGS • Although the Plan Area constitutes a relatively small share of jobs in Palo Alto overall, the area includes a notable concentration of manufacturing jobs. The U.S. Census estimates that the Plan Area included approximately 4.3 percent of jobs in Palo Alto as of 2022, but nearly 40 percent of jobs classified in the Manufacturing industry sector. The Plan Area includes major employers such as Maxar along Fabian Way and a limited quantity of Google offices east of US-101. • The diverse small office and light industrial spaces in the Plan Area—especially near Commercial Street and Industrial Avenue—accommodate a wide variety of small businesses seeking flexible and relatively affordable space within Palo Alto. Tenant lease data indicates that at least two thirds of businesses in the Plan Area have 50 or fewer employees. • Redevelopment of existing smaller light industrial and flex buildings in the Plan Area for housing and other uses creates a displacement risk for businesses in these spaces. Relocation within Palo Alto and even neighboring communities is challenging due to the limited and declining inventory of similar spaces due to their redevelopment for higher-intensity employment and housing uses. • The addition of housing in the Plan Area that is affordable to households with diverse income levels can help meet the needs of workers at jobs in Palo Alto and the Plan Area itself. Analysis of wages associated with the industry sector mix of jobs in Palo Alto found that 35 percent of worker households may qualify as low- or very low-income and likely require deed-restricted affordable housing to be able to live in Palo Alto. Within the Plan Area itself, U.S. Census data indicates that approximately 16 percent of “primary” jobs (i.e., the highest-paying job held by a worker) in 2022 paid less than $40,000 annually. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 60     36 5. HAZARDS, PUBLIC SAFETY, AND HISTORIC RESOURCES Note: Some of the topics discussed in this section (such as sea level rise) overlap with topics discussed in Sections 8 and 9. Since these topics are relevant for each of these subject areas, they have been included in each section. Hazards Environmental hazards studied as part of the analysis to date include sea level rise and wildfire. The study of seismic hazards and soil and groundwater contamination is currently in process, and additional content will be provided when the studies are completed. SEA LEVEL RISE A portion of the Plan Area is located in the Federal Emergency Management Agency (FEMA) Flood Zone AE, a Special Flood Hazard Area (SFHA) designation with a one percent (100-year flood) or greater annual chance of flooding in any given year. Within the Plan Area, the AE Zone covers a large area generally from East Charleston Road to the San Francisco Bay, shown in Figure 5.1. The remainder of the Plan Area is located in SFHA Zone X, with a 0.2% (500-year event) annual chance of flood. The City of Palo Alto completed a Sea Level Rise Vulnerability Assessment in 2022 which documents potential sea level rise (SLR) hazards to City and community assets from increments between 12 to 84 inches of SLR. Portions of the Plan Area north and east of East Charleston Road are predicted to be inundated under a 36-inch SLR scenario during an average tide. Areas north of the Plan Area could experience overtopping by Bay waters. WILDFIRE The Plan Area is not located in a Fire Hazard Severity Zone (FHSZ) as defined by the California Department of Forestry and Fire Protection (CAL FIRE). Source: City of Palo Alto GIS, David J Powers & Associates, 2025. Figure 5.1. FEMA Special Flood Hazard Area in the Plan Area Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 61     37 SEISMIC HAZARDS As detailed in the 2024 Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan, the Bay Area is located in a geologically active area. The impact of an earthquake on buildings and infrastructure largely depends on ground shaking, the distance from the earthquake’s source, and the potential for liquefaction. Liquefaction generally occurs in soft, unconsolidated sedimentary soils with a shallow water table. The City of Palo Alto’s Safety Element identifies areas near the Bay and along creeks as having very high liquefaction susceptibility levels, and the entire Plan Area has at least a moderate liquefaction susceptibility level. Additional analysis of the seismic hazard within the Plan Area is underway. SOIL AND GROUNDWATER CONTAMINATION The portion of the Plan Area between East Charleston Road and US-101 has long been a light industrial and manufacturing area, which increases the possibility of soil and/or groundwater contamination. Sites with known or suspected contamination could require remediation prior to any new development. The California Department of Toxic Substances Control (DTSC) has identified seven properties within the Plan Area with known or suspected contamination issues. The following addresses within the Plan Area are listed on the DTSC EnviroStor tool: 821 San Antonio Road, 844 East Charleston Road, 899 East Charleston Road, 3825 Fabian Way, 3839 Fabian Way, 890 Commercial Street, and 936 Industrial Avenue. 1275 North San Antonio Road (a City-owned parcel) is the site of the former Los Altos Treatment Plant, and required some remediation efforts prior to developing the HomeKey project. Additional analysis of these sites and the Plan Area is underway. Public Safety Police and fire services are essential components of a well-functioning and resilient community. Growth within the Plan Area may increase calls for service and place additional demands on personnel, equipment, and emergency access. POLICE Law enforcement protection services in Palo Alto are provided by the Palo Alto Police Department (PAPD) that employs a total of 141 positions (2025). The 2030 Comprehensive Plan EIR found that the existing police station is inadequate to accommodate growth under the General Plan. The PAPD is currently constructing a new Public Safety Building (PSB) at 250 Sherman Avenue which will serve as the new headquarters of the Police Department, 911 Emergency Dispatch Center, the Emergency Operations Center, the Office of Emergency Services, and the administration needs of the Fire Department. The new PSB building is scheduled to open in Fall 2025. With the new police station, police services are anticipated to be adequate to accommodate current and future needs of the City. FIRE The Palo Alto Fire Department’s (PAFD’s) service area covers the jurisdictional boundaries of Palo Alto in addition to some of the unincorporated land surrounding the City limit, much of which is occupied by Stanford University. The PAFD staffs six full-time fire stations (Stations 1 through 6) and one seasonal fire station (Station 8), located strategically throughout the City. In addition to the PAFD’s primary service area, the City has entered into mutual aid and automatic aid agreements with the City of Mountain View, the City of Menlo Park, CAL FIRE, the Santa Clara County Fire Department (SCCFD), and the Woodside Fire Protection District. The City has set a service goal at responding to all fire emergencies in 8 minutes or less 90% of the time. For medical emergencies, the goal is 8 Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 62     38 minutes or less 90% of the time and ambulance response, 12 minutes or less 90% of the time. Emergency medical services (EMS) in the PAFD service area are expected to increase incrementally with both the increase in population and the aging of the population. To meet increased demand, the PAFD is launching a new EMS ambulance program to enhance staffing and resource availability for the increase in EMS ambulance transports during peak hours. The City is also in the process of replacing Fire Station 4, the closest station to the Plan Area, which is estimated to be completed in 2027. Historic Resources The City’s Historic Preservation Program began in 1979, with subsequent Local Inventory updates in 2001 and 2023. Any individual or group may propose designating a historic structure, site, or district to the Inventory according to the procedure found in the Historic Preservation Ordinance (Municipal Code Section 16.49.040). Properties nominated for designation are recommended by the Historic Resources Board and decided upon by the City Council. In addition to the City’s Historic Inventory, there are number of Palo Alto properties and four historic districts that are listed in the National Register of Historic Places (NRHP), including the Greenmeadow Historic District immediately adjacent to the Plan Area. The California Office of Historic Preservation recognizes the Greenmeadow Historic district, as well as Native American shell mounds in the vicinity and two sites in the Plan Area: 844 East Charleston Road as the site where Dr. Robert Noyce of Fairchild Semiconductor Corporation invented the first integrated circuit that could be produced commercially in 1959 and the Secundino Robles Adobe Site north-east of the San Antonio Road and Alma Street intersection. As of this report, there are no properties located within the Plan Area listed on the NRHP or on the Palo Alto Historic Inventory. Most existing structures within the Plan Area were constructed between approximately 1940 and 1980. Evaluation of the properties in the Plan Area for significant historical, archeological, and/or architectural value is in process. Key Findings and Conclusions The following environmental issues would need to be addressed as part of future development in the Plan Area. Please note that some sections of this analysis are in progress as of the publication of this draft report, and analysis will continue as part of the Area Plan’s compliance with the California Environmental Quality Act. • A large area within the Plan Area is designated as a Special Flood Hazard Area (SFHA). • Adapting to sea level rise would need to be addressed in the areas east of East Charleston Road. • Increased demand for EMS services may require increased EMS staffing and/or new apparatus and fire station improvements to support new development. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 63     39 6. PARKS, OPEN SPACE, AND PUBLIC FACILITIES Schools The Plan Area is served by the Palo Alto Unified School District (PAUSD), Mountain View-Whisman School District (MVWSD), and Mountain View-Los Altos Union High School District, as shown in Figure 6.1. The PAUSD operates 13 elementary schools, three middle schools, and three high schools (including Middle College at Foothill College) within their service area. There is available capacity for more students at all PAUSD schools. Projections forecast a decline in enrollment district-wide across a 10-year period based upon historical enrollment trends and projected new development. The MVWSD operates one preschool, nine K-5 elementary schools, and two 6-8 middle schools. There is capacity for additional enrollment in all the MVWSD schools. The Mountain View-Los Altos Union High School District operates two high schools within its boundaries. The portions of the Plan Area within the district’s boundaries are served by Los Altos High School, which is also currently enrolled at below its capacity. Figure 6.1. School Districts in the Plan Area Source: City of Palo Alto GIS, David J Powers & Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 64     40 Parks and Recreational Facilities The City of Palo Alto owns and operates 32 parks and four open space preserves. There are also a variety of other facilities in Palo Alto and the vicinity which are not City-owned and which serve some of the same demand for City-owned and operated facilities. These include PAUSD-owned land used for recreation, Stanford University open space and recreation lands, privately owned recreational facilities, land managed by conservation groups, and State and regional parks in the vicinity of Palo Alto. There are also open space preserves that serve larger service areas and contain a broad range of facilities, including picnic grounds, hiking and biking trails, wildlife watching and camping. In addition, the City of Palo Alto Recreation Services Division offers youth and adult sports, teen and middle school activities, after-school programs, a variety of classes for all ages, and a wide range of special events. Recreation facilities include the Cubberley, Lucie Stern, and Mitchell Park Community Centers; the Children’s Theater and Community Theater; Rinconada Pool; Junior Museum and Zoo; Baylands Golf Course; Art Center; Baylands Nature Interpretive Center; and the Skateboard Park at Greer Park. The nearest parks and open spaces to the Plan Area include Henry W. Seale Park, Ramos Park, Mitchell Park, Monroe Park, Del Medio Park (Mountain View), Wyandotte Park (Mountain View), Thaddeus Park (Mountain View), Monta Loma School Field (Mountain View), Heritage Park (Mountain View), Baylands Nature Preserve, Shoreline at Mountain View Park (Mountain View). Under Comprehensive Plan Policy C-28, the City’s desired ratios are two acres of neighborhood parks plus two acres of district parks per 1,000 residents (four acres total) and a parkland dedication requirement of five acres of neighborhood park, district park, recreational facilities, and open space for every 1,000 residents. The City of Palo Alto operates five community libraries, all of which were renovated between 2006 and 2015 and are considered to be in good condition. The Mitchell Park library is nearest to the Plan Area. Key Findings and Conclusions In terms of parks and public facilities, the Plan Area would need to consider the following as part of future development: • Overall school enrollment is down across all three school districts that service the Plan Area (Palo Alto Unified School District, Mountain View-Whisman School District and Mountain View-Los Altos Union High School District). • The City has a policy to reach two acres of neighborhood parks plus two acres of district parks per 1,000 residents (four acres total per 1,000 residents) and a parkland dedication requirement of five acres of neighborhood park, district park, recreational facilities, and open space for every 1,000 residents. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 65     41 7. NOISE AND AIR QUALITY Noise and Vibration The analysis for noise and vibration for the Plan Area includes a description of the fundamentals of environmental noise and ground-borne vibration, summarizes applicable regulatory criteria, and discusses the existing noise environment. It also identifies constraints for potential noise-sensitive uses and provides guidance to attain noise and land use compatibility. A noise measurement survey was completed to establish existing noise levels from substantial sources in the Plan Area, including both long- and short-term measurements at several locations. SOURCES OF ENVIRONMENTAL NOISE Primary sources of noise in the Plan Area include: • Major ground transportation corridors such as US-101, Central Expressway/Alma Street, San Antonio Road, and Middlefield Road. • Minor ground transportation corridors, such as small arterial roadways and collector streets, produce noise levels that contribute to ambient conditions on a localized basis. • The Union Pacific Railroad, located west of Central Expressway/Alma Street, provides a thoroughfare for freight and passenger (Caltrain) trains that produce noise and vibration during pass-by events. • Palo Alto Airport lies approximately 1.7 miles north-east of the Plan Area, and Moffett Federal Airfield lies approximately 2.2 miles south-east of the Plan Area, producing intermittent noise due to aircraft overflights. • Noise sources located on private property such as mechanical equipment, including fans, blowers, chillers, compressors, boilers, pumps, and air conditioning systems that may run continuously, and other intermittent sources of noise, including emergency generators, horns, and loading activities. Sensitive land uses within and around the Plan Area include residences, hotels, religious institutions, schools, medical facilities, and libraries. Residential development is sensitive to community noise, both outdoors and indoors. Single-family residential development, schools, libraries, hospitals, convalescent homes, and places of worship are considered the most noise-sensitive land uses. High-density/mixed-use residential, commercial, and industrial development is considered less noise-sensitive because uses are primarily indoors and can be mitigated with building design and construction. DESIGN CONSIDERATIONS • Locate sensitive land uses in noise and vibration environments that are compatible with the proposed uses. The possibility of sensitive development encroaching on existing noise sources could result in some land use conflicts, requiring careful consideration during the planning process. • Ensure that new noise-generating land uses do not substantially increase ambient noise levels at adjacent sensitive land uses. • Ensure that increase in traffic does not substantially increase ambient noise levels at sensitive land uses. • Mitigate construction noise and construction vibration to the extent possible to not adversely affect adjacent sensitive land uses. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 66     42 Air Quality The Bay Area Air Quality Management District (Air District) publishes California Environmental Quality Act (CEQA) Air Quality Guidelines and provides tools and recommendations to develop plans that are consistent with Clean Air Plan goals. Air quality and greenhouse gas (GHG) emissions analysis for the Plan Area found the following issues: • Meeting Ambient Air Quality Standards. The region is considered to be in non-attainment for the criteria air pollutants ozone (O3) and particulate matter (respirable particulate matter [PM10] and fine particulate matter [PM2.5]). Criteria air pollutant levels have generally decreased over the last 25 years, as regional emissions of pollutants and precursor pollutants have decreased. An increase in episodes of wildfire smoke in recent years, however, has caused spikes in the number of days that air quality standards have been exceeded. While overall trends for air pollutants remain downward over the last 25 years, the trend in annual PM2.5 concentrations has only slightly decreased; however, the levels are at or below standards. A large number of exceedances occurred in the years 2017 through 2020 due to episodes of wildfire smoke. • Toxic Air Contaminants (TACs). The Plan Area is less burdened with TACs than 50 percent of the State (a CalEnviroScreen range of 5 to 50 percentile). The Air District considers 70 percentile or higher as overburdened. While efforts to control TAC emissions have been quite effective, some areas are still exposed to levels that exceed the Air District’s recommended thresholds. Common sources of TAC exposure include large volumes of truck traffic, construction activity, diesel generators, and gasoline stations. Air monitoring data published by the Air District for benzene shows dramatic decreases in ambient concentrations at all Bay Area stations. Conclusions For the Plan Area to grow while maintaining air quality, the following challenges will need to be resolved: • Reducing Vehicle Miles Traveled (VMT). The Air District’s CEQA Air Quality Guidelines recommend that land use plans demonstrate the growth in vehicle travel (measured as trips or VMT) at a lower rate than the population growth rate. This could be accomplished through land uses and policies that encourage non- motorized travel and shorter commute distances. • Compliance with Clean Air Plan Measures and Air District Recommendations. Planned land uses will need to be in conformity with Clean Air Plan measures, including periodic updates by the Air District to ensure progress in attaining and maintaining ambient air quality standards. • Reducing Unhealthy Exposure to TAC and Air Pollutants. The effects of TACs on the public is typically evaluated through health risk assessments (HRAs) that predict excess cancer risk, non-cancer health hazards, and exposure to PM2.5. The Plan Area is affected by a large number of TAC sources. The primary sources that drive overall exposures are busy roadways, diesel locomotives using Caltrain, and stationary sources permitted by the Air District. The Air District provides screening tools to assess the risks that these sources pose to the Area. Refined modeling can be conducted at a project level to further assess these impacts and predict future exposures as controls to reduce TACs become more effective. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 67     43 8. INFRASTRUCTURE Note: Some of the topics discussed in this section (such as sea level rise) overlap with topics discussed in Sections 5 and 9. Since these topics are relevant for each of these subject areas, they have been included in each section. Storm Drain Infrastructure Storm drainage facilities in and around the Plan Area are owned and maintained by the City of Palo Alto. Per the 2015 City of Palo Alto Storm Drain Master Plan, the Plan Area is located within the Adobe Creek Watershed and surface water drains north towards Adobe Creek and towards the San Francisco Bay. Local stormwater infrastructure is located in the rights-of-way of San Antonio Road, East Charleston Road, Fabian Way, and along Adobe Creek, which runs on the north side of the Plan Area. The Master Plan found that portions of the storm drain system are currently under capacity, and identified high priority system upgrades for East and West Bayshore Road, East Meadow Drive, East Meadow Circle, East Charleston Road and Adobe Creek, and Fabian Way, as shown in Figure 8.1. FLOODING FEMA Flood Insurance Rate Maps (FIRM) indicate a range of flood hazard risk levels for parcels within the Plan Area. As discussed in Section 5, the Plan Area between East Charleston Road and the San Francisco Bay falls within Zone AE, a Special Flood Hazard Area (SFHA) subject to inundation by a one percent annual chance flood, known as the base flood with an elevation of 10.5. The rest of the Plan Area falls within Flood Zone X with a lower probability of flooding. The Plan Area periodically experiences flooding during large storm events at the area bound by East Bayshore Road and Adobe Creek, West Bayshore Road and Adobe Creek, East Meadow Circle and Fabian Drive upstream of the Adobe Pump Station. The flooding experienced is generally due to flap gates unable to open when the water level in the creek exceeds the height of the gate at the outfall. In 2024 Public Works Engineering completed Source: City of Palo Alto’s 2015 Storm Drain Master Plan, Schaaf & Wheeler, 2015. Figure 8.1. 2015 Storm Drain Master Plan Priority Projects Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 68     44 the necessary improvements along East Meadow Circle and East Meadow Drive and eliminated the flooding potential that would otherwise occur when the gravity fed line was unable to discharge into the creek. Public Works Engineering is working on a separate construction contract to install two small pump stations and storm drainpipe upgrades on both East and West Bayshore Road to eliminate the street flooding that occurs near Adobe Creek. These projects will be completed by December 2026. Future development projects should anticipate implementation measures to protect from flooding and sea level rise, and to reduce impact on existing drainage infrastructure. Sanitary Sewer Infrastructure The City of Palo Alto owns and maintains the wastewater system. Local wastewater is collected and conveyed to sewer mains on all public roads and public utility easements on private property, with the trunk main located at the north-east side of the Plan Area. All wastewater is then conveyed to the Palo Alto Regional Water Quality Control Plant for treatment and discharge or reuse as recycled water. The 2004 Wastewater Collection System Master Plan – Capacity Assessment by MWH Americas evaluated the capacity of the existing wastewater system and identified areas with limited capacities and need for system improvements and rehabilitation. According to the 2023 Sanitary Sewer Management Plan, all the identified projects have been completed. The City is planning to complete a new Sanitary Sewer Master Plan Study which will include an updated capacity assessment and recommendations for Capital Improvement Projects (CIP). Future development projects should anticipate implementing system upgrades that align with identified deficiencies in the future Master Plan Study. Additionally, there are several sewer mains within the Plan Area smaller than eight inches that should be replaced with larger pipe sizes as part of future development. Domestic and Recycled Water Infrastructure The City of Palo Alto owns and maintains the water distribution system. The Plan Area is adequately served, with water mains in the rights-of-way of Fabian Drive, San Antonio Road, East Charleston Road, Middlefield Road, Alma Street, and East and West Bayshore Road. Future development with a change in land use should anticipate implementing system upgrades, with review on a project-by-project basis. Some of the smaller existing water mains may need to be upsized to meet localized fire flow requirements, depending on actual building heights, locations, densities, and construction types. Currently, only the areas east of US-101 and Greer Park are serviced with recycled water. The City has also identified future expansions of the recycled water distribution system within City extents but outside of the Plan Area. Given the proximity of the Plan Area to the existing recycled water system, the City may consider expanding the recycled water distribution system within the Plan Area to offset future water demand and usage. New recycled water pipelines would need to be extended across US-101 to serve the majority of the Plan Area. Distribution pipelines would also need to be built within the street rights-of-way to serve individual properties, and new buildings in the Plan Area would need to be dual plumbed for both domestic and recycled water use. Further study is required to evaluate the feasibility of expanding the existing recycled water distribution system into the Plan Area. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 69     45 Natural Gas and Electricity Infrastructure The City of Palo Alto provides natural gas and electricity. Multiple gas mains serve the Plan Area that are located within the rights-of-way of every public street as well as on several private roads and properties. With current policies encouraging new development to be designed as “all electric,” the demand for natural gas is expected to decrease. Existing electrical and fiber optic lines adequately serve the Plan Area. Existing electrical utilities consist of both underground and overhead lines. It should be anticipated that existing overhead electrical lines will be converted to underground lines in conjunction with future development. It should also be anticipated that future development will increase electrical demand. Undergrounding existing overhead electrical lines could represent an opportunity to upgrade the network in anticipation of potential increases in electrical demand. Key Findings and Conclusions • The City of Palo Alto owns and provides stormwater, wastewater, domestic water, recycled water, natural gas, and electrical utilities. • Stormwater. Stormwater drains north towards Adobe Creek and the San Francisco Bay via catch basins and pipes in public rights-of-way. The Adobe Pump Station is located within the Plan Area, and outfalls into Adobe Creek. The 2015 Storm Drain Master Plan identified seven high priority improvement projects in the vicinity of the Plan Area to alleviate flooding caused by large storm events. Two of these projects are complete, three are under construction and two others will be completed by 2032. • Flooding. The portion of Plan Area that falls within FEMA Flood Zone AE is subject to inundation by a one percent annual chance flood, also known as the base flood with an elevation of 10.5. The remaining portion of the Plan Area that falls within FEMA Flood Zone X, has a 0.2 percent annual chance of flooding. Future developments in the Plan Area will have to account for the base flood elevation and implement measures to protect new buildings from flooding and sea level rise in accordance with Building Codes. For example, under FEMA regulations, basement levels are not permitted beneath residential buildings within FEMA Flood Zones. • Wastewater. Local wastewater is collected and conveyed via sewer mains in public rights-of-way and public utility easements on private property, then conveyed to the Palo Alto Regional Water Quality Control Plant for treatment and discharged into the San Francisco Bay, or reused as reclaimed water. According to the 2023 Sanitary Sewer Management Plan, all improvement projects identified in the 2004 Wastewater Master Plan have been completed. Future development projects should anticipate implementing system upgrades that align with identified deficiencies in any future Master Plan studies. • Domestic Water. The area is served by water mains in all public rights-of-way and public utility easements on private property. Some smaller water mains may need to be upsized with future development in order to meet localized fire flow requirements. • Recycled Water. The only recycled water line in the vicinity of the Plan Area runs along East Bayshore Road. Given its proximity to existing lines, the City may consider expanding the recycled water distribution system within the Plan Area to offset future water demand and usage. • Natural Gas. With current policies encouraging the transition of new developments to be designed as “all electric,” a decrease in demand for natural gas is expected. • Electricity. Existing electrical utilities consist of both underground and overhead lines. In conjunction with future development and anticipated increase in demand for electricity, there can be opportunities to underground existing overhead electrical lines when upgrading the electrical network. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 70     46 Source: Cal-Adapt, Raimi + Associates 9. CLIMATE AND RESILIENCE Note: Some of the topics discussed in this section (such as sea level rise) overlap with topics discussed in Sections 5 and 8. Since these topics relevant for each of these subject areas, they have been included in each section. Policies Regarding Climate Hazard Planning Hazards related to climate change studied for the Plan Area include sea level rise (SLR), shallow groundwater rise, flooding, changes to precipitation and drought, extreme heat, and wildfire. Plan Area-specific information regarding impacts from climate change is referenced from the Santa Clara County Multi-Hazard Mitigation Plan and Palo Alto Annex (2024), the Palo Alto Sea Level Rise Vulnerability Assessment, and data from Cal-Adapt. The Safety Element of the City of Palo Alto’s Comprehensive Plan addresses natural and human-caused hazards. It contains a Natural Hazards policy framework that includes general safety measures and measures to address flood and fire risk. In 2023-24, Santa Clara County led the update of the Santa Clara County Multi-Jurisdictional Hazard Mitigation Plan (SCC MJHMP) with 15 participating jurisdictions and three special districts. As a participating jurisdiction, Palo Alto adopted its own Annex to the SCC MJHMP with more City-specific information. The ratings in the Annex are from an emergency management lens so they do not consider how climate change will increase the probability and impacts of each hazard in the future. Rather, it considers climate change as a hazard on its own. The City of Palo Alto’s 2022 Sustainability and Climate Action Plan (S/CAP) aims to reduce carbon emissions to 80 percent below 1990 levels by 2030 and achieve carbon neutrality by 2030. Though the S/CAP’s main purpose is climate action (greenhouse gas mitigation) one of its “Key Issues” is “Climate Adaptation and Sea Level Rise”. The S/CAP has two goals and eight actions related to climate adaptation, and also has goals and associated actions to “minimize the impacts of wildland fire hazards,” but they are not as directly relevant to the Plan Area because it is not located in a Fire Hazard Severity Zone. Future development in the Plan Area will also be affected by new SLR planning processes. SB 272 (2023) requires that all local governments in the jurisdiction of the San Francisco Bay Conservation and Development Commission (BCDC) adopt a subregional Shoreline Adaptation Plan that complies with the requirements of the BCDC Regional Shoreline Adaptation Plan (RSAP) by January 2034. Palo Alto is in BCDC’s jurisdiction and can adopt a plan on its own or be part of a plan with other entities. Baseline Conditions and Projections Climate projections from the Cal-Adapt database and other reports completed by the City are summarized in Table 9.1. Table 9.1. Summary of Hazard Projections Climate Hazard Trend Sea level rise More areas potentially exposed to inundation and flooding Shallow groundwater rise Higher groundwater levels and more areas where groundwater comes above the surface of the ground (emergent groundwater) Flooding Flooding may exceed mapped FEMA floodplains Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 71     47 SEA LEVEL RISE The Bayward portion of the Plan Area up to East Charleston Road may only experience temporary flooding during a 100-year storm tide under current conditions and for up to 24 inches of SLR. However, the SLR Vulnerability Assessment found that the average high tide with 36 inches of SLR is a tipping point when many areas of the City become vulnerable to permanent inundation (Figure 9.1). With SLR at 36 inches and above, and without further shoreline protections, the Bayward portion of the Plan Area up to East Charleston Road may experience permanent inundation with the average high tide, and the extent of temporary flooding will extend further inland. SHALLOW GROUNDWATER RISE Currently, the existing depth of groundwater surface within the Plan Area ranges from more than 10 feet farthest away from the Bay (inland from Mackay Drive), to less than zero feet in the area that is part of the Baylands Nature Preserve (Figure 9.2). However, groundwater within the Plan Area is projected to rise as SLR occurs. In general, areas close to the Bay shoreline (and former wetland areas) are more likely to experience emergent groundwater flooding. The area of emergent groundwater expands inland with higher SLR scenarios. LIQUEFACTION Elevation of the groundwater table can affect liquefaction hazards during large earthquakes. Nearly all the Plan Area has only “Moderate” liquefaction susceptibility. However, a portion of the Plan Area across US-101 close to tidal marshes has “Very High” susceptibility. Precipitation and drought Longer dry spells and more extreme storms Extreme heat Higher average and maximum temperatures, more heatwaves with longer duration, more warm nights Wildfire More wildfire smoke Figure 9.1. SLR Exposure Projections Source: City of Palo Alto SLR Vulnerability Assessment, 2024; Raimi + Associates, 2025. Figure 9.2. Existing and Projected Groundwater Depth Source: City of Palo Alto SLR Vulnerability Assessment, 2024; Raimi + Associates, 2025. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 72     48 FLOODING As mentioned previously in Sections 5 and 8 of this report, portions of the Plan Area are in the Federal Emergency Management Agency (FEMA) Flood Zone AE, which designates a Special Flood Hazard Area (SFHA) with a one percent or greater annual chance of flooding. Within the Plan Area, the AE Flood Zone covers a large area generally from Middlefield Road to the Bay. The remainder of the Plan Area is designated as Flood Zone X, which falls inside the 500-year flood zone. Key Findings and Conclusions • The Plan Area is projected to experience varying degrees of flooding from Sea Level Rise (SLR). Temporary flooding may occur under existing conditions and up to 24 inches of SLR. However, 36 inches of SLR is a tipping point at which permanent flooding could occur in the Bayward portion of the Plan Area up to East Charleston Road. • The Bayward portion of the Plan Area up to East Charleston Road is within FEMA Flood Zone AE, which means it could be flooded by a one percent chance annual flood event. The rest of the Plan Area is within FEMA Flood Zone X, which means it is at moderate-to-low flood risk. • Groundwater is projected to rise as sea levels rise. An increase of 36 inches of SLR is the point at which groundwater may begin emerging above the ground surface in the Plan Area. • All available indicators of extreme heat (e.g., average daily temperatures, duration of heat waves) are projected to increase in the Plan Area. • The Plan Area is not directly in a Fire Hazard Severity Zone, but it may experience more wildfire smoke in the future, due to an increased likelihood and severity of wildfires in other parts of the City and region. Item 3. Attachment A - San Antonio Road Area Plan Existing Conditions Analysis Summary Report, September 4, 2025, Draft     Packet Pg. 73     Item 3. ​Attachment B - San Antonio Road Area Plan Map     Packet Pg. 74     Item No. 4. Page 1 of 11 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: September 18, 2025 Report #: 2508-5059 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [24PLN-00278]: Request by AT&T for Review of a Tier 2 Wireless Communication Facility Permit Application for Modification of an Existing Wireless Antenna and Associated Equipment at an Existing Streetlight Pole in the Public Right-of-Way fronting 1661 Page Mill Road. CEQA Status: Exempt pursuant to California Environmental Quality Act (CEQA) Guidelines Sections 15301 (Existing Facilities). Zoning District: Not Applicable (Public Right-of-Way). RECOMMENDATION Staff recommends that the Architectural Review Board (ARB) conduct a public hearing and take the following action: 1. Recommend that the Director of Planning and Development Services approve the Tier 2 Wireless Communications Facility (WCF) application for modifications to an existing wireless communications site in the public right-of-way (ROW) based on the findings set forth in Attachment C and Conditions of Approval in Attachment B. EXECUTIVE SUMMARY This report provides background information on the proposed Tier 2 WCF application, which includes modifications to a wireless antenna and associated equipment on an existing steel streetlight pole (Pole #167) in the public ROW, located near 1661 Page Mill Road. Staff, in consultation with the applicant, determined that the proposed project constitutes a Tier 2 wireless facility project and is therefore subject to Council’s recently modified review process for Tier 2 and 3 WCFs in the public ROW. The City Council revised the City’s wireless facility approval process on May 19, 2025, to repeal objective standards and add ARB review of Tier 2 and Tier 3 WCFs in the public ROW as of July 2025 (Ordinance 5655 provided in Attachment H). This report provides the ARB with both the project analysis and a summary background on the current regulatory framework for WCFs. Unlike typical local land use development applications, the scope of local review of wireless facility applications is significantly limited by Federal and State laws and regulations, further Item 4 Item 4 Staff Report     Packet Pg. 75     Item No. 4. Page 2 of 11 summarized in this report. The City has some authority over WCF siting, but that authority is subject to both procedural and substantive limitations. This Tier 2 project is subject to a 60-day shot clock, and the ARB hearing on September 18, 2025, will occur on day 21 of 60 days. The shot clock period is also expected to accommodate a potential appeal to Council of the Director’s decision on the project by any party in accordance with the Palo Alto Municipal Code (PAMC), and for a project approval decision, issuing all City- required permits. BACKGROUND The City has authority over the siting of WCFs. However, its authority is limited by various Federal and State laws, including: The Federal Telecommunications Act (notably, 47 U.S.C. § 332(c)(7) re: preservation of local zoning authority) and the Spectrum Act (47 U.S.C. § 1455, re: deployment of eligible facilities); Federal Communications Commission (FCC) regulations and orders interpreting and implementing these statutes; California Public Utilities Code § 7901 (granting telephone companies a limited franchise to use public ROW); Government Code § 65964.1 (providing deemed granted remedies to applicants, meaning a project is deemed approved as submitted in the project application if City fails to act on the application within a reasonable time); and Applicable regulations of the California Public Utilities Commission (CPUC) such as General Order 95 (regulating safety of utility infrastructure). Within this legal framework, local agencies retain authority to enforce reasonable aesthetic design standards, protect community character, and ensure safe and aesthetically appropriate deployment of wireless infrastructure (notably, safety considerations exclude consideration of radiofrequency (RF) emissions that meet the current federal regulatory requirements). The principal restrictions on local wireless siting authority are found in a Federal law dating from 1996 (47 U.S.C. § 332(c)(7)). Current Federal law and clarifying regulations applicable to this report’s application to modify an existing small wireless facility (defined below) require the following: 1. Final action on applications to be within a reasonable period of time (for this project, a 60-day project review “shot clock” is presumed reasonable). Note that State law provides a deemed granted remedy if no final action is taken within the shot clock (i.e. project is deemed approved without further revision or review). 2. Local regulations and siting decisions may not prohibit or effectively prohibit provision of personal wireless services. Local regulations may not “materially inhibit” installation of new or replacement small wireless facilities).1 FCC regulations further clarify that local 1 The FCC notes the following examples of material inhibition: “…a state or local legal requirement could materially inhibit service in numerous ways—not only by rendering a service provider unable to provide an existing Item 4 Item 4 Staff Report     Packet Pg. 76     Item No. 4. Page 3 of 11 service in a new geographic area or by restricting the entry of a new provider in providing service in a particular area, but also by materially inhibiting the introduction of new services or the improvement of existing services.” (FCC 18-133 (2018) at par. 37). Item 4 Item 4 Staff Report     Packet Pg. 77     Item No. 4. Page 3 of 11 aesthetic requirements must be reasonable (technically feasible) and published in advance. Note that relevant State law grants a franchise right to telephone companies, including wireless providers, to use the ROW so long as their use does not “incommode” the public use. The City’s evaluation can include the consideration of aesthetics. 3. Denials must be in writing and supported by substantial evidence in the record. 4. Prohibits any consideration of the environmental or health effects of RF emissions in siting decisions if the applicant’s proposed facility meets current FCC standards regulating RF emissions exposure. 5. Provides for expedited appeals to court. Palo Alto Regulations Between April 2019 and July 2025, the City relied on Council-adopted objective standards to review small wireless projects in the public ROW. In May 2025, Council repealed these standards and amended the PAMC through an interim ordinance to direct WCF Tier 2 and Tier 3 applications in the public ROW to a public hearing before the ARB for a recommendation to the Director. In place of the detailed objective standards (which may still be used for guidance), the City’s current published findings for approving a Tier 2 project includes three sections of the PAMC: 1. Confirming the project satisfies all the architectural review findings in PAMC Section 18.76.020(d) Architectural Review Findings (Attachment C) 2. Confirming the project’s compliance with the development standards in PAMC Section 18.42.110(i) Generally Applicable Development Standards (Attachment H); and 3. Confirming the project’s compliance with the conditions of approval in PAMC Section 18.42.110(j) Conditions of Approval (Attachment B). WCF Permit Tiers and Architectural Review Understanding wireless terminology is essential for determining the appropriate permit type and scope of review. The complete list of definitions is listed under PAMC Section 18.42.110(b) (with references to applicable Federal regulations), but the following are some important terms for the purpose of this report. 1.Collocation: Installation of wireless equipment on an existing support structure. 2.Small Wireless Facility: Antennas not exceeding 3 cubic feet and associated equipment not exceeding 28 cubic feet; subject to specific dimensional criteria under FCC rules. 3.Substantial Change: A physical modification that exceeds specified thresholds set by FCC regulations (e.g., height increases of more than 10% or 10 feet, installation of additional equipment cabinets, or changes defeating concealment elements). Item 4 Item 4 Staff Report     Packet Pg. 78     Item No. 4. Page 4 of 11 The City’s WCF permitting process is divided into three tiers, each with distinct thresholds, procedures, and review authority; the definitions of each tier are provided for context, but planning staff and applicant have determined the subject application is a Tier 2 application to modify existing infrastructure on a streetlight pole in the public ROW as it defeats the concealment element previously approved at this wireless facility and is therefore a substantial change. Tier 1: Eligible Facilities Request Tier 1 applications, under Federal law, are defined as modifications that do not “substantially change” the physical dimensions of an existing wireless facility. These applications are processed at staff level applying criteria set forth in FCC regulations and are not subject to public hearings or appeal. If the applicant satisfies the criteria, the City has no discretion to deny the application. Tier 2: Non-Tier 1 Modifications and Small Wireless Facilities Tier 2 applications include collocations or modifications that exceed Tier 1 thresholds but do not involve a new support structure (i.e. poles or towers), and small wireless facilities (as defined by FCC) either on private property or in the public ROW. ARB review is only required for projects in the public ROW. Final action is taken by the Director of Planning and is subject to appeal to City Council. Tier 3: New Facilities Tier 3 thresholds apply to proposals for entirely new support structures (excluding replacement utility or streetlight poles). These applications require ARB review and a Conditional Use Permit (CUP). Final action is taken by the Director of Planning and is subject to appeal to City Council. Shot Clock Timelines WCF permit applications have a unique application process involving a “shot clock” timeline, whereby a final decision on each wireless application must take place within a specified period of time which is presumed to be reasonable, unless the City and applicant mutually agree to a longer time via a Tolling Agreement. This “shot clock” timeframe would include the need to make a decision on this entitlement application, as well as to process any street work and encroachment permit(s) if the project application was conditionally approved. The City initially received this project application as a Tier 1 WCF request, on October 8, 2024. Staff determined that the proposed modification did not qualify as a Tier 1 application as the installation of the side-mounted equipment onto the light pole defeated the concealment element by introducing additional equipment that was not incorporated into the underlying approval. This proposed change would increase the visibility of the facility at the ground level in a frequently traversed part of Palo Alto and qualify as a substantial change per FCC regulations. The Tier 1 WCF request was denied and the project therefore was required to be processed as a Tier 2 application. The applicant submitted a Tier 2 WCF application on August 7, 2025, after Item 4 Item 4 Staff Report     Packet Pg. 79     Item No. 4. Page 5 of 11 the City’s revision of its wireless ordinance to repeal the objective standards and require ARB hearings for Tier 2 and Tier 3 projects. Therefore, this project requires ARB review. Per Federal law, final decision for a Tier 2 project in the public ROW must be made within 60 days of the application. Because this application involves a small wireless facility, the 60-day timeline is reset if the initial application is incomplete, and the City notifies the applicant of missing items in a timely manner per FCC regulations. For this project, the initial application of August 7, 2025 was incomplete, and the applicant was timely notified.3 The resubmitted application was received August 28, 2025, and the 60-day period to issue a decision and, if applicable, hold an appeal hearing and/or issue all permits, expires October 28, 2025. Applicable Review Criteria All WCF project applications are submitted to the City using the application checklist appropriate to the project’s Tier (1, 2, or 3) to determine that a project is ready for City review. Prior to July 2025, Planning staff reviewed all wireless applications for WCFs in the ROW (except eligible facilities requests) according to (1) the City’s Objective Standards (Attachment D), and (2) the applicable tier approval process in the City’s wireless ordinance. In May 2025, effective July 2025, Council repealed the objective standards. Since July 2025, staff has received only one application categorized as a Tier 2 or 3 facility subject to ARB review and applying architectural review findings. Although repealed and therefore not required as standards to evaluate a right of way WCF application, the Objective Standards may be used as guidelines in commenting on the size, location, and aesthetic appearance of the proposed wireless project. The repealed Objective Standards previously adopted under Resolution 9873 in 2019 can be viewed in Attachment D. PROJECT DESCRIPTION Project Information Owner:City of Palo Alto (Owner of Wood Utility Poles and Streetlight Poles in the ROW) Architect:Modus LLC on behalf Cingular Wireless PCS, LLC dba AT&T Mobility Representative:Justin Giarritta (Modus LLC) Property Information Address:Public ROW fronting 1661 Page Mill Road Protected/Heritage Trees:Yes; Protected and Regulated Trees Exist in Public ROW Existing Improvement(s):Existing steel light pole #167 Existing Land Use(s):Residential and commercial 3 The reset only happens once, in response to the first notice of incompleteness. The notice must be sent within 10 calendar days. If there are subsequent timely notices of incompleteness and resubmittals, the shot clock is paused between the notice and the resubmittal, but the shot clock runs while the City is reviewing the resubmittal. Item 4 Item 4 Staff Report     Packet Pg. 80     Item No. 4. Page 6 of 11 Adjacent Land Uses & Zoning: North: Research Park (RP) West: County-owned land / Residential East: Research Park (RP) South: Research Park (RP) Aerial View of Pole Location: Source: Google Maps Land Use Designation & Applicable Plans Zoning Designation:Not Applicable (Public ROW) Comp. Plan Designation:Not Applicable (Public ROW) The proposed project is comprised of modifications to an existing wireless communications site on City-owned streetlight pole in the public ROW, as shown in the aerial map on Sheet T-1 (Title Sheet) of the plans. The Tier 2 classification for this application is defined under PAMC Section 18.42.110. The applicant has provided a detailed project description in Attachment G. The scope of work includes removal of existing wireless equipment, including one (1) canister antenna, one (1) radio, one (1) equipment cabinet and related noise producing equipment from the existing pole. New proposed equipment includes three (3) new Convection Cooled Remote Radio Units (RRUs), and two (2) new antennas. The Convection Cooled Radios have a fan-less design and will not produce any noise. There is no new lighting proposed as a part of this application. The existing light mast will be maintained. This modified wireless facility would operate in conjunction with a larger network of WCFs . Through this effort, AT&T aims to enhance the wireless network serving the area and provide additional capacity and coverage for its users. Item 4 Item 4 Staff Report     Packet Pg. 81     Item No. 4. Page 7 of 11 Figures 1 and 2 show the existing wireless equipment on the streetlight pole and a photo simulation of the proposed modifications. The renderings are also included in the project plans. Figure 1: Existing and Proposed Conditions at Streetlight Pole #167 (from Page Mill Road looking northwest at subject site) Figure 1: Existing and Proposed Conditions at Streetlight Pole #167 (from Page Mill Road looking northeast at subject site) The project plans (Attachment J) show the location of the proposed WCF and the following above-ground equipment within the design configuration: 2 antennas with splitters 3 antenna shrouds 3 RRUs Safety signage Item 4 Item 4 Staff Report     Packet Pg. 82     Item No. 4. Page 8 of 11 Cabling (within streetlight pole) 1 streetlight pole with light mast 1 disconnect box with shutdown signage Requested Entitlements, Findings, and Purview The applicant requests the following discretionary approvals for the proposed wireless modifications: A Tier 2 Wireless Communication Facility (Tier 2 WCF) Permit as outlined in PAMC Section 18.42.110(g). The WCF permit application must comply with or meet: Development Standards, subsection (i) of PAMC Section 18.42.110 (Attachment H); Conditions of Approval in PAMC Section 18.42.110(j) (Attachment B); and Architectural Review findings in PAMC Section 18.76.020(d) (Attachment C). All findings must be made in the affirmative to approve each Tier 2 WCF permit. Failure to make any one finding requires project redesign or denial, within the project’s shot clock period. ANALYSIS This application was evaluated for completion under the Tier 2 in public ROW application checklist (Attachment E) and must meet all relevant requirements of the Architectural Review findings in PAMC Section 18.76.020(d), and the City’s Wireless Ordinance (PAMC 18.42.110), including the Generally Applicable Development Standards (PAMC 18.42.110(i)) and Conditions of Approval (PAMC 18.41.110(j)). Staff finds that the proposed project meets the required findings for approval and project standards and conditions. Federal Preemption & Radio Frequency (RF) Emissions The FCC’s guidelines for evaluating human exposure to RF signals were first established in 1985. The current guidelines were adopted in August 1997 in FCC OET Bulletin 65.5 The guidelines are expressed in terms of Maximum Permissible Exposure (MPE) to electric and magnetic field strength and power density. The guidelines, which cover the frequency range of 300 kHz to 100 GHz, address two separate tiers of exposure: 1. Occupational/controlled exposure limits apply to situations in which persons are exposed as a consequence of their employment and in which those persons who are exposed have been made fully aware of the potential for exposure and can exercise control over their exposure. 2. General population/uncontrolled exposure limits apply to situations in which the general public may be exposed or in which persons who are exposed as a consequence of their employment may not be made fully aware of the potential for exposure or cannot 5 “Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields,” OET Bulletin 65, edition 97-01. https://www.fcc.gov/general/oet-bulletins-line#65 Item 4 Item 4 Staff Report     Packet Pg. 83     Item No. 4. Page 9 of 11 exercise control over their exposure. Under the Telecommunications Act of 1996, Federal regulations preempt the State and local governments from regulating RF emissions generated by WCFs. The City’s authority in this area is limited to ensuring that the proposed installation complies with comprehensive emissions standards established by the FCC. To this end, the applicant’s consultant at Waterford Consultants prepared a RF Emissions Compliance Report on September 9, 2024, to document the predicted General Population (i.e. ground level) and Occupational (i.e. antenna height level) exposure levels. These measurements are often calculated under the scenario where antennas are operating at full power, rather than the normal operating conditions. As a result, on-site measurements, which are required of the applicant under Condition of Approval #10, are often lower than the predicted levels calculated. The antennas will be mounted on a 30’-2” Streetlight Pole with centerlines 30’-0” above ground level; other appurtenances such as the RRUs and cabling are not sources of RF emissions. In their evaluation of the potential for exposure to the general public, the consultants confirmed that the power density decreases significantly with distance from the antenna. The panel-type antennas to be employed at this site are highly directional by design and the orientation in azimuth and mounting elevation, as documented in the RF emissions report, serves to reduce the potential to exceed MPE limits at any location other than directly in front of the antennas at antenna height. For accessible areas at ground level, the maximum predicted power density level resulting from all AT&T Mobility operations is 1.46% of the FCC General Population limits; this could be up to 100% of the FCC allowed thresholds and still be deemed compliant provided the appropriate mitigation measures were in place. Incident at adjacent Structures, the maximum predicted power density level resulting from all AT&T Mobility operations is 0% of the FCC General Population limits. The proposed operation will not expose members of the General Public to hazardous levels of RF energy at ground level or in the buildings in the vicinity. On the pole in front of the antennas, predicted MPE levels will exceed the FCC General Population limits within 37 feet in front of the antennas at antenna height and within 7 feet below the antennas. The maximum predicted power density level resulting from all AT&T Mobility operations directly in front of the antennas is 5212.86% of the FCC General Population limits (1042.572% of the FCC Occupational limits). RF signage will be posted three (3) feet below the antennas which will be visible upon approach that informs personnel accessing this area of basic precautions to be followed when working around the antennas. This signage will also match the existing steel streetlight pole and meet the camouflage element. The power densities depicted on aerial maps are included in Attachment F. Noise The ambient noise environment is noted in the City’s Comprehensive Plan and Municipal Code; it is referenced therein in goals, policies, requirements, and thresholds to address potential Item 4 Item 4 Staff Report     Packet Pg. 84     Item No. 4. Page 10 of 11 noise impacts from new development. As currently designed, the proposed project would not be a source of new ambient noise, since the configurations include convection-cooled radios which are fan-less and utilize natural convection to dissipate heat. A Noise Assessment Letter was provided as a part of the application materials which is included in Attachment I. Wireless Communication Facility Development Standards and Architectural Review Findings Staff reviewed the proposed project with respect to the Development Standards in PAMC Section 18.42.110, particularly in regard to the utilization of the smallest footprint possible, minimization of overall, mass, and size of the equipment shrouds, minimization of visibility, utilization of stealth or camouflage design, and architectural compatibility. The existing streetlight pole design can be understood by looking at the renderings shown in the proposed plans. However, staff seeks ARB input on the cohesiveness and integration of the design, color, and materiality of the antenna shrouds relative to the streetlight pole and light mast. Staff also recommends a condition of approval to ensure that no cabling would be visible and that all cabling would be housed within the pole and antenna shroud. Given the pole is situated on a sidewalk in the public ROW, there may not be an opportunity to plant additional trees, but the existing trees screen the streetlight pole and proposed wireless equipment from the Stanford residences located to the north. The project has been reviewed by Urban Forestry staff who has recommended approval of this project. Overall, important considerations for placement of wireless equipment include maintaining minimum horizontal and vertical clearances for pedestrians and bicyclist safety, as well as paint color, screening of cabling, and other aesthetic cohesiveness factors. As shown in the project plans in Attachment J, placing wireless equipment in underground vaults or mounting it underneath the antenna within shrouding is more effective in meeting the current development standards in PAMC Section 18.42.110. Further analysis of the project’s compliance with wireless development standards and the Architectural Review Findings is in Attachment C. FISCAL/RESOURCE IMPACT Per the Municipal Fee Schedule, all WCF Permit applications are processed as Cost Recovery applications; the City charges the applicant for the staff time necessary for processing tasks, such as application review and analysis, preparation of staff reports, and presentations to ARB and Council. The Municipal Fee Schedule established that when a timely appeal is filed by a party, applicants then submit a deposit for the processing of that appeal. Processing costs are retained by the City when an appeal upholds the PDS Director’s decision, but are refunded if an appeal reverses the Director’s decision. STAKEHOLDER ENGAGEMENT The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Item 4 Item 4 Staff Report     Packet Pg. 85     Item No. 4. Page 11 of 11 Post on September 5, 2025, which is 12 days in advance of the meeting. Postcard mailing occurred on September 4, 2025, which is 13 days in advance of the meeting. Public Comments As of the writing of this report, no project-related public comments were received. Comments were received related to the City’s continued analysis and development of WCF project review standards. Staff anticipates preparing a future staff report on that topic. ENVIRONMENTAL REVIEW In accordance with the California Environmental Quality Act (CEQA), the Director has determined that this project decision is categorically exempt pursuant to CEQA Guidelines Section 15301 (Existing Facilities). ALTERNATIVE ACTION(S) In addition to the recommended action, the Architectural Review Board may: 1. Approve the project with modified findings or conditions; 2. Continue the project to a date certain, with applicant’s consent (which may require a tolling agreement); or 3. Recommend project denial based on substantial evidence in the record supporting revised findings. ATTACHMENTS Attachment A: Location Map Attachment B: Conditions of Approval of Application 24PLN-00278 Attachment C: Architectural Review Findings for Approval of Application 24PLN-00278 Attachment D: (Repealed) Resolution No. 9873 Wireless Objective Standards Attachment E: Tier 2 Right-of-Way Application Checklist Attachment F: RF Emissions Report Attachment G: Applicant’s Project Description Attachment H: Ordinance 5655 Attachment I: Noise Assessment Letter Attachment J: Project Plans Report Author & Contact Information ARB7 Liaison & Contact Information Nishita Kandikuppa, Associate Planner Steven Switzer, Historic Preservation Planner (650) 838-2806 (650) 329-2321 nishita.kandikuppa@palolato.gov steven.switzer@paloalto.gov 7 Emails may be sent directly to the ARB using the following address: arb@cityofpaloalto.org Item 4 Item 4 Staff Report     Packet Pg. 86     50 50 50 200 Bld Lobby 2Bldg E Cor 20-082ABldg A Deer Creek 403.2' 801.3' 381.0' 400.0' 361.0' 30.3' 381.1' 381.0' 400.9' 31.4' 557.6' 575.2' 618.1' 30.0' 75.2'492.5' 3145 1661 1651 1701 855 861 849 8 826 834 840 810 843 837 831 825 819 813 807801 1085 1091 1073 1079 1067 1061 1055 1047 10 10621087 PAGE MILL ROAD PAGE MILL ROAD PORTER DRIVE PAGE MILL ROAD CART WAY L L A R D I C E W A Y This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Project Site 0'102' Attachment A: Location MapStreetlight Pole #167 (near 1661 Page Mill Road) CITYOF PALOALTOINCORPORATED CALIFORNIA P a l o A l t oT h e C i t y o f APRIL 16 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Altonkandik, 2025-09-09 16:04:33Attachment A. Location Map (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 4 Attachment A - Location Map     Packet Pg. 87     24PLN-00287 250 Hamilton Avenue Page 1 of 3 ATTACHMENT B TIER 2 WIRELESS COMMUNICATION FACILITY CONDITIONS OF APPROVAL This approval is based upon the finding that the proposed project complies with the Tier 2 WCF permit process and applicable findings set forth in PAMC Section 18.42.110 (f). The approval of this project shall be subject to the following conditions of approval. Planning Division – Planning and Development Services Department 1. COMPLIANCE WITH APPROVED PLANS. The proposed project shall be constructed in conformance with the approved plans under 24PLN-00278 uploaded to the Palo Alto Online Permitting Services Citizen Portal on August 28, 2025, and stamped as approved on September XX, 2025, as modified by these conditions of approval. 2. BUILDING PERMIT. This approval letter, including the associated conditions of approval, shall be printed on the plan sets submitted for building permit review. 3. DEVELOPMENT STANDARDS. The proposed collocation and modification shall be screened from public view and shall not defeat any existing concealment elements of the streetlight pole. The proposed top mounted antennas and associated cabling and supporting equipment shall be painted to match the color of the metal utility pole. 4. NOISE ORDINANCE. The project shall not exceed the noise standard specified in Municipal Code Chapter 9.10.050. 5. MODIFICATIONS TO APPROVED PLANS. Any modifications, additions and intensification of use (i.e. additional antennas, change location) shall require an amended entitlement as specified in the Palo Alto Municipal Code. Any amended permits shall be reviewed and approved by the Director of Planning prior to implementation. 6. REMOVAL OF ABANDONED EQUIPMENT. Any components of the Wireless Communication Facility (WCF) that cease to be in use for more than ninety (90) days shall be removed by the applicant, Wireless Communications Service provider, or property owner within ninety (90) days of the cessation of use of that WCF. A new conditional use permit shall not be issued to an owner or operator of a WCF or a Wireless Communications Service provider until the abandoned WCF or its component is removed. 7. ANTENNA CABLING. All cables/wires shall be held as tightly to the tower/structure as possible so that the cabling does not appear loose and mismanaged. 8. COMPLIANCE WITH FCC REQUIREMENTS. The applicant shall comply with all FCC signage and barrier requirements related to siting of wireless equipment to the extent that they can clearly Item 4 Attachment B - Conditions of Approval of Application 24PLN-00278     Packet Pg. 88     24PLN-00287 250 Hamilton Avenue Page 2 of 3 9 1 0 5 demarcate areas around antennas or EME emitting sources as hazardous to the relevant GENERAL or OCCUPATIONAL POPULATION thresholds. 9. ANTENNA MODEL NUMBERS, TILTS, AND AZIMUTHS. The antenna model numbers, tilts, and azimuths for the antennas shall remain consistent between the permit plans and RF reports. Any additional azimuths or antennas are not approved. Prior to the issuance of streetwork and encroachment permits, any changes in antenna model numbers, tilts, and azimuths shall be accompanied by updated plans and RF reports; the City may elect to peer review these RF reports at the applicant’s sole expense. 10. RADIO FREQUENCY EMISSION. The applicant shall hire a radio engineer licensed by the State of California to measure the actual radio frequency emission of the WCF and determine if it meets Federal Communications Commission standards. A report, certified by the engineer, of all calculations, required measurements, and the engineer's findings with respect to compliance with the FCC's radio frequency emission standards shall be submitted to the Planning Division within one year of commencement of operation. The report shall have a methodology section outlining instrumentation, measurement direction, heights and distances, and other protocols outlined in FCC Bulletin OET 65. The report shall include a list and identify any nearby RF sources, nearby reflecting surfaces or conductive objects that could produce regions of field intensification, antenna gain and vertical and horizontal radiation patterns, type of modulation of the site, polarization and emissions orientation(s) of the antenna(s), a log of all equipment used, and a map and list of all locations measured indicating the maximum power observed and the percentage of the FCC Uncontrolled/General Population guidelines at the measurement location. At the applicant’s expense, the City may elect to have a City-staff observer during the measurements, may elect to receive raw test measurements by location provided in electronic format to the observer, and may elect to have the report independently peer reviewed prior to report acceptance. Applicant may be required to submit these reports periodically for the life of the project, as determined by the Director of Planning and Development Services. (APPLICANT FOLLOW-UP REQUIRED) 11. AS-BUILT PLANS. An as-built set of plans and photographs depicting the entire WCF as modified, including all Transmission Equipment and all utilities, shall be submitted to the Planning Division within thirty (30) days after the completion of construction. (APPLICANT FOLLOW-UP REQUIRED) 12. INDEMNIFICATION. 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 for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion and at Applicant’s expense, elect to defend any such action with attorneys of its own choice. Item 4 Attachment B - Conditions of Approval of Application 24PLN-00278     Packet Pg. 89     24PLN-00287 250 Hamilton Avenue Page 3 of 3 9 1 0 5 13. COMPLIANCE WITH APPLICABLE LAWS. The applicant shall comply with all applicable provisions of the Code, any permit issued under this Code, and all other applicable federal, state and local laws (including without limitation all building code, electrical code and other public safety requirements). Any failure by the City to enforce compliance with any applicable laws shall not relieve any applicant of its obligations under this code, any permit issued under this code, or all other applicable laws and regulations. 14. PERMIT EXPIRATION. The project approval shall be valid for a period of one year from the original date of approval. In the event a building permit(s), if applicable, is not secured for the project within the time limit specified above, the approval shall expire and be of no further force or effect. A written request for a one-year extension shall be submitted prior to the expiration date in order to be considered by the Director of Planning and Development Services. 15. REVOCATION. The Director of Planning and Development Services may revoke any WCF permit if the permit holder fails to comply with any conditions of the permit. The Director's decision to revoke a permit shall be appealable pursuant to the process for architectural review set forth in Section 18.77.070 and the process for conditional use permits set forth in Section 18.77.060. 16. PLANNING FINAL INSPECTION. A Planning Division Final inspection will be required to determine substantial compliance with the approved plans prior to the scheduling of a Building Division final. Any revisions during the building process must be approved by Planning. Contact your Project Planner at the number above to schedule this inspection. Public Works Department 17. STREETWORK/ENCROACHMENT PERMIT. This approval letter, including the associated conditions of approval, shall be printed on the plan sets submitted for permit review. The RF report associated with this application shall be printed in the streetwork/encroachment permit plan set. Electrical Engineering Division – Utilities Department 18. ESTIMATED MONTHLY ENERGY CALCULATIONS. At the time of building permit, the applicant shall provide an estimated monthly energy consumption for the entire installation including the loads in the existing cabinet. A new meter may have to be installed. Fire Department 19. HAZARDOUS MATERIALS DISCLOSURE PERMIT. Battery removals will require a separate Hazardous Materials Disclosure Permit from Palo Alto Fire Department. Item 4 Attachment B - Conditions of Approval of Application 24PLN-00278     Packet Pg. 90     ATTACHMENT C ARB FINDINGS FOR APPROVAL In order for the ARB to make a future recommendation of approval, the project must comply with the following Findings for Architectural Review as required in PAMC Chapter 18.76.020. Finding #1: The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan, Zoning Code, coordinated area plans (including compatibility requirements), and any relevant design guides. The project is consistent with Finding #1 because: There are no applicable design guidelines or coordinated area plan relevant to this project. However, the Comprehensive Plan includes Program L9.11.2, which provides that the City identifies City-owned properties where combinations of wireless facilities can be collocated, assuming appropriate lease agreements are in place. The streetlight pole on which the collocation of wireless equipment is proposed presently has an antenna above the light mast which was previously approved by staff. No new lease agreements are required at this time. The proposed project also complies with applicable local regulations for WCFs, specifically the development standards listed in PAMC 18.42.110 (i). The Municipal Code provides a process to permit WCFs that blend with their existing surroundings and do not negatively impact the environment, historic properties, or public safety. The proposed equipment will be mounted on an existing streetlight pole with existing WCF equipment and will not impact the environment or public safety given its negligible ground-level radiofrequency (RF) emissions (1.46% of the allowable 100% FCC General Population limits at ground level) and design that will blend in with the streetlight pole. 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 adjacent residential areas. The project is consistent with Finding #2 because: Item 4 Attachment C - Architectural Review Findings for Approval of Application 24PLN-00278     Packet Pg. 91     The project includes the installation of mechanical equipment, antennas and associated cabling on an existing streetlight pole in the public ROW. The wireless facility is designed to balance the aesthetic interests to minimize the visibility of the wireless equipment in the smallest footprint feasible. The antennas and radio units’ exterior surfaces will be painted to match the existing streetlight pole (gray). The wireless facility is located on a streetlight utility pole that is not recognized as a historic resource and is not intended to be occupied. The proposed equipment is not an atypical use of the City’s streetlight utility poles, which would not impact the scale, mass or character of adjacent land uses. The proposed project does not include residential uses and placement of WCFs on streetlight poles does not disrupt living conditions in adjacent residential areas. In fact, many residents may benefit from improved wireless coverage. 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 is consistent with Finding #3 because: The proposed project includes the replacement and addition of mechanical equipment, cabling, antennas and screening material (the shrouds). The components necessarily by design and function must be well-integrated and employ appropriate construction techniques. The proposed materials and colors have been reviewed and determined appropriate for the proposed wireless antenna and associated equipment. The proposed material and colors were selected to blend in with the surrounding environment. 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.). The project is consistent with Finding #4 because: The proposed project has been designed in compliance with local, state, and federal safety standards, construction techniques and clearances required to allow for the ease and safety of pedestrian and bicycle traffic. The design is functional for its intended use and includes components necessary for its operation and screening. 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. The project is consistent with Finding #5 because: Item 4 Attachment C - Architectural Review Findings for Approval of Application 24PLN-00278     Packet Pg. 92     The project is consistent with the finding in that the project preserves the existing street trees located along Page Mill Road. The project includes only wireless equipment installation on the existing streetlight pole and does not modify existing landscaping elements. Finding #6: The project incorporates design principles that achieve sustainability in areas related to energy efficiency, water conservation, building materials, landscaping, and site planning. The project is consistent with Finding #6 because: The proposed project draws energy from the city’s utility service according to the applicable city rate schedule, requires no water, and is designed with materials appropriate to the proposed wireless facility. Item 4 Attachment C - Architectural Review Findings for Approval of Application 24PLN-00278     Packet Pg. 93     1 Resolution No. 9873 Resolution of the Council of the City of Palo Alto Amending Objective Aesthetic, Noise, and Related Standards for Wireless Communication Facilities in the Public Rights of Way The Council of the City of Palo Alto RESOLVES as follows: SECTION 1. Findings and Declarations. a. On April 15, 2019, the City Council adopted Resolution 9825, establishing objective aesthetic, noise, and related standards for Wireless Communication Facilities (WCFs) on Streetlight and Wood Utility Poles in the Public Rights-of-Way. b. On June 17, 2019, the City Council adopted Resolution 9847, amending the standards to delete inadvertently added language, clarify existing standards, and adopt an interim setback from public schools. c. On August 12, 2019, the City Council adopted Resolution 9855, amending the standards to address a conflict with other City standards and to clarify the allowable height for WCFs on Streetlights and Wood Utility Poles. d. The City Council wishes to consolidate the existing objective standards previously described in Resolution 9855 for clarity and update the objective standards in order to address Council specified location, design, and other preferences in the City for WCF on Streetlight Poles and Wood Utility Poles. SECTION 2. Objective Standards for WCFs on Streetlight Poles and Wood Utility Poles in the Public Rights-of-Way Amended. The City Council hereby adopts the objective standards in Exhibit 1, attached to and incorporated into this resolution, for Wireless Communication Facilities in the Public Rights of Way on Streetlight Poles and Wood Utility Poles. The City Council hereby adopts Exhibit 2 that illustrates the Residential Zone of Exclusion and Exhibit 3 that illustrates the City of Palo Alto roadway network and locations of special setbacks relative to generalized zoning designations for the sole purpose of supplementing the objective standards in Exhibit 1. SECTION 3. If any section, subsection, clause or phrase of this resolution or the attached standards is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the resolution and exhibits. The Council hereby declares that it should have DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 94     2 adopted the resolution and exhibits, and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid. SECTION 4. Environmental Review. The Council finds that this resolution is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it does not authorize the construction of Wireless Communication Facilities in any locations where such facilities are not already permitted; therefore it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment. The resolution is further exempt under CEQA Guidelines sections 15301, 15302, 15303 and 15305 because it represents part of a comprehensive regulatory scheme governing minor alterations to existing facilities or small structures. INTRODUCED AND PASSED: December 16, 2019 AYES: CORMACK, DUBOIS, FILSETH, KNISS, KOU, TANAKA NOES: FINE ABSENT: ABSTENTIONS: ATTEST: City Clerk Mayor APPROVED AS TO FORM: APPROVED: Deputy City Attorney City Manager Director of Planning and Development Services DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 95     3 Exhibit 1 Objective Standards for Wireless Communication Facilities in the Public Rights of Way on Streetlight Poles and Wood Utility Poles A Wireless Communication Facility (WCF) proposed for the public right of way must comply with the applicable provisions of the City’s Municipal Code and all of the following objective standards. In each instance where a proposed facility is unable to comply with the City’s objective standards, a WCF Exception may be requested and evaluated in accordance with this resolution and PAMC Section 18.42.110(k).1The following standards apply to both streetlight poles and wood utility poles, unless otherwise noted. WCF SITING STANDARDS Permitted Zoning Districts WCF placement is permitted in non-residential zoning districts. Public School Boundary A WCF shall not be placed within 600 feet of a parcel containing a public school. No WCF Exception shall be granted allowing a WCF to be placed closer than 300 feet to a parcel containing a public school. Residential Zone of Exclusion (this standard applies to WCF Exception requests to locate in residential districts) No WCF shall be placed within the public right of way in the area between the street centerline and the central fifty percent (50%) of the immediately adjacent parcel’s front lot line. The central fifty percent standard shall be based on the parcel’s lot width2. For corner lots, the central fifty percent standard along the street lot line3 shall be based on the parcel’s lot depth4. Exhibit 2 illustrates this requirement. Residential Roadways (this standard applies to WCF Exception requests to locate in residential districts) Any request for a WCF Exception involving placement of a WCF within a residential zoning district shall prioritize WCF placement on the following roadway types (See Exhibit 3):  Expressways  Arterials  Residential Arterials  Roadways identified with a Special Setback (including collector and local streets). 1 The City may hire an independent consultant to evaluate WCF Exceptions at applicant’s expense. 2 Palo Alto Municipal Code Section 18.04.030(a)(93) 3 Palo Alto Municipal Code Section 18.04.030(a)(91)(E) 4 Palo Alto Municipal Code Section 18.04.030(a)(87) DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 96     4 In each instance above, the priority shall be for placement of a WCF most distant from residential property. An additional WCF Exception request must be made to place a WCF on a collector or a local roadway that does not have an identified special setback. Building or Structure Setback A WCF shall not be placed closer than 20 feet from any building used for occupancy in any zoning district. Distance Between WCFs A WCF shall not be placed less than 600 feet away from another WCF. This requirement does not preclude WCFs collocating on the same structure where otherwise allowed. Intersection Corners5 A WCF shall not be placed less than 20 feet away from any roadway intersection. An intersection is measured from the start of the curb radius. Scenic Routes6 A WCF shall not be placed along an identified scenic route. Historic Districts, Sites, and Structures A WCF shall not be placed within a listed historic district, nor immediately adjacent to a parcel with an historic structure, nor immediately adjacent to an historic site, as those terms are defined by PAMC Section 16.49.020. A WCF shall not be placed in a potential historic district, or immediately adjacent to a potential historic structure or site, where the application for historic designation was filed with the City prior to the filing of a WCF application, until a final decision has been made regarding that pending historic designation. WCF DESIGN STANDARDS Underground Design (Preferred Option) Radio equipment shall be placed in an underground vault. The associated antenna(s) shall be placed in a shroud at the top of a nearby pole. Underground vaults shall be the minimum volume necessary to house WCF equipment and include information detailing why the proposed dimensions are required. Maximum vault size shall not exceed 5 feet 8-inches x 8 feet 2-inches x 5 feet 7-inches or 260 cubic feet, excluding space required for ventilation or sump pump equipment. 5 Gateway intersections are identified on Map L-4 in the Comprehensive Plan. 6 Scenic routes are identified in Policy L-9.1 in the Comprehensive Plan. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 97     5 Top-Mounted Design (Secondary Option) Radio equipment and the associated antenna(s) shall be enclosed within a shroud at the top of the pole. Minimal Sunshield Design Use of this design requires a WCF Exception Radio equipment shall be enclosed within one or two sunshields not exceeding 8 inches wide nor 0.75 cubic feet in volume each, mounted directly to the side of the pole. The associated antenna(s) shall be placed in a shroud at the top of the pole. Sunshields shall be attached at least 12 feet above ground level and, when located on wood utility poles, shall not interfere with the identified communication space. Existing Signage Design Use of this design requires a WCF Exception Radio equipment shall be attached to a pole behind existing signage under the following conditions: i) Radio equipment shall be placed within a shroud that does not exceed the dimensions of the sign in height and width, nor 4 inches in depth, including any required mounting bracket. ii) In no event shall WCF equipment obscure or interfere with the visibility or functioning of the signage. The associated antenna(s) shall be placed in a shroud at the top of the pole. WCF Antenna and Shroud Dimensions (Diameter / Height) Antennas shall have the smallest size possible to achieve the coverage objective. The diameter of the antenna and shroud shall not exceed 15 inches at their widest. For Streetlight Poles: The maximum WCF height shall not exceed 3 feet (or 5.5 feet for top-mounted designs) from the top of the streetlight pole that meets the City standards for the proposed location. The associated “antenna skirt” shall taper to meet the pole above the mast arm. For Wood Utility Poles: In no circumstance shall the total height of a pole and all WCF equipment exceed 55 feet. For wood utility poles carrying power lines, replacement poles shall be the minimum height necessary to provide GO 95 mandated clearance between WC equipment and power lines. For wood utility poles without power lines, any WCF equipment shall not increase the height of the pole by 5.5 feet when compared with the height of the existing pole. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 98     6 The associated “antenna skirt” shall taper to meet the top of the pole if wider than the pole. WCF Design Quality Antennas and/or equipment at the top of the pole shall be covered by a single integrated shroud and “antenna skirt” designed without gaps between materials or sky visible between component surfaces and between the shroud or skirt and the top of the pole. All components external to the pole shall have an integral color or shall be painted to match the color and/or materials of the pole. Equipment shall be oriented to face in either of the directions of travel in the right of way and shall not face or extend toward private property or the curb line. WCF Equipment Adjustment For Streetlight Poles: Equipment that cannot propagate an adequate signal within the shrouding required by the standard designs shall be attached to a streetlight pole at a height of 2 feet below the light mast or higher. Each instance of such equipment shall not exceed 0.85 cubic feet, nor shall the total volume of such equipment and any shrouding exceed 2.6 cubic feet per streetlight pole. For Wood Utility Poles: Equipment that cannot propagate an adequate signal within the shrouding required by the standard designs shall be attached to the top of the pole or on a cross arm or brace protruding from the pole the minimum extent necessary to comply with safety standards, including GO 95. Such cross arm shall be placed as high on the pole as technically feasible. Each instance of such equipment shall not exceed 0.85 cubic feet nor shall the total volume of such equipment exceed 2.6 cubic feet per wood utility pole. Curb Clearances Any WCF attachments placed below 16 feet above ground level shall not be placed closer than 18 inches to the curb, nor shall they extend over the sidewalk (Caltrans Highway Design Manual Section 309). All WCF equipment shall maintain at least 3 feet from any curb cut. WCF Wires and Cabling For Streetlight Poles: All wires and cabling shall be routed entirely underground and within the pole and any attached shroud. For Wood Utility Poles: All wires and cabling to equipment shall be within the shroud or shall be within conduit. All conduit shall be mounted flush to the pole. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 99     7 Safety Signs Safety signs shall be the smallest size possible to accomplish its purpose. Power Disconnects For Streetlight Poles: Power disconnects shall be labeled and placed in a vault near the base of the pole. For Wood Utility Poles: Power disconnects shall be labeled and placed on the wood pole or in a vault near the base of the pole. Ground Mounted Equipment Except as provided in these standards, no equipment cabinets may be placed at grade. Existing Pole Locations A WCF shall utilize an existing streetlight pole or wood utility pole location. Any new pole locations are prohibited unless approved through a City Public Works/Utilities pole placement application. WCF PERFORMANCE STANDARDS Pole Replacement For Streetlight Poles: An existing streetlight pole proposed for a WCF installation shall be replaced with a new pole.7 For Wood Utility Poles: An existing wood utility pole proposed for a WCF installation shall be replaced with a new pole.8 Landscaping Replacement Any existing landscaping removed or damaged by installation shall be replaced in kind. Landscape Screening A WCF shall be placed where existing street tree foliage or new street tree or amenity tree foliage within 35 feet of the WCF provides interruption of direct views of the WCF. 7 Replacement streetlight poles must meet the currently applicable City standards for the pole, including foundation and bolt designs, conduit separation, aluminum material, color, width, height, light mast characteristics (examples: orientation, design, height, color temperature and photometrics), and the presence/absence of decorative features. Replacement poles will conform to Public Works Department (PWD) style guidelines and Utilities-Electrical (CPAU) standards where the City has adopted standards and will match the pole being replaced where no standards exist. Standard specifications for streetlight poles in the City can be obtained from the Utilities-Electrical (CPAU) and Public Works (PWD) Departments. 8 Replacement wood utility poles must meet the currently applicable City standards for the pole, including width, height, color, material, structural capacity, and GO 95 compliance. Replacement poles shall be no greater in diameter or other cross-sectional dimension than is necessary for the proper functioning of the pole with all attachments. Existing pole functionality shall be maintained, such as in regard to electrical lines, climbing space, light masts (examples: orientation, design, height, color temperature and photometrics), and provision of communication space, unless existing functionality, such as transformers, can be relocated with the approval of the Utilities-Electrical Department (CPAU). Standard specifications for pole replacement in the City can be obtained from CPAU. For wood utility poles carrying power lines, replacement poles shall be the minimum height necessary to provide GO-95 mandated clearance between WCF equipment and power lines. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 100     8 Noise9 Noise from a WCF shall comply with PAMC Chapter 9.10 and shall be consistent with noise-related Comprehensive Plan goals and policies. City Marketing Banners WCF installations shall not require any changes in the City’s existing banner marketing program. WCF EXCEPTIONS A WCF applicant may file an application(s) containing a request for one or more WCF Exceptions to the objective standards set forth in this resolution or any other provision of PAMC Section 18.42.110. The request for a WCF Exception(s) does not exempt a WCF from complying with other objective wireless administrative standards adopted by City Council resolution or any other provision of PAMC Section 18.42.110. Each WCF Exception request must be made at the time an application is submitted and must include both the specific provision(s) from which the exception is sought and the basis of the request, including all supporting evidence on which the applicant relies. The applicant has the burden of proving that federal law, state law, or both, compel the decision-making authority to grant the requested exception(s). The WCF Exception must satisfy the requirements of PAMC Section 18.42.110(k) and demonstrate why the standard is infeasible. Failure to identify all required WCF Exceptions upon application submittal may result in application denial. No WCF Exception may be granted that allows a WCF to be placed: 1) within 300 feet of a parcel containing a public school, 2) within 20 feet of a habitable residential building in a residential zoning district, 3) on wood utility poles within the Residential Zone of Exclusion described in this resolution, or 4) in an alley within a residential zoning district. 9 In residential areas with an average 24-hour noise level (Ldn) at or below 60 decibels (dB), noise generated by WCF equipment shall not cause the Ldn to exceed 60dB or to increase by 5.0 dB or more, even if the resulting Ldn would remain below 60 dB. In residential areas with a Ldn above 60 dB, noise generated by WCF equipment shall not cause the average to increase by 3.0 dB or more. DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 101     144.2' ' 100.1' 70.0' 144.2' 60.0' 100.1' 30.0' 100.1' 60.0'160.0' 139.1' 160.0' 7' ' '64.9' 100.0' 100.0' 64.9' 100.0' This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend 0'53' Ex h i b i t 2 WC F RZO E D I A G R A M CITYOF PALOALTOINCORPORATED CALI FORNIA P a l o A l t oT h e C i t y o f APRIL 1 6 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto rrivera, 2019-11-25 17:25:35 (\\cc-maps\Encompass\Admin\Personal\rrivera.mdb) ROAD CENTERLINE RZOE - central 50% of parcel's lot width 50% of 139.1 lot width = 69.55 ft RZOE - central 50%of parcel's lot width RZOE - central 50%of parcel's lot width RZOE - central 50%of parcel's lot depth 35 f t 50% of 70 ft lot width = 35 ft ROAD CENTERLINE CURB LIP PARCEL/PROPERTY LINE 30 ft 30.0' 30 ft 30 ft RZOE - c e n t r a l 50% o f par c e l ' s l o t wid t h RZOE - c e n t r a l 50% o f par c e l ' s l o t wid t h RZOE - c e n t r a l 50% o f par c e l ' s l o t wid t h RO A D CEN T E R L I N E RZOE - c e n t r a l 50% o f par c e l ' s l o t wid t h Residential Zone of Exclusion (RZOE) (this standard applies to WCF Exception requests to locate in residential districts) No WCF shall be placed within the public right of way in the area between the street centerline and the central fifty percent (50%) of the immediately adjacent parcel’s front lot line. The central fifty percent standard shall be based on the parcel’s lot width. For corner lots, the central fifty percent standard along the street lot line shall be based on the parcel’s lot depth. Fro n t S e t b a c k L i n e 139.1'100.1' 60 . 0 ' 60 . 0 ' 60. 0 ' 70.0' 64.9'64.9' 30 . 2 4 ft 32.44 ft 50.05 ft32.45 ft 30 . 2 4 ft 35 . 0 7 ft 69.38 ft 30 . 2 4 ft 50.39 ft 32.44 ft 32.45 ft 69.55 ft DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4Attachment D - (Repealed)Resolution No. 9873Wireless ObjectiveStandards    Packet Pg. 102     24 24 2424 2424 2424 2424 24 24 24 24 2424 24 2424 24 24 24 24 24 2424 24 2424 24 24 15 24 24 1010101010 24 20 10 151515 15 15 10 10 10 1524 15 1515 15 15 24 24 24 24 20 2424 50 30 30 50 50 24 24 25 25 25 25 25 2525 25 50 24 24 24 50 24 50 50 5050 30 50 50 50 25 25 25 25 2525 25 25 25 25 2424 50 50 5050 50 50 50 50 50 242424 24 24 24 24 25 25 25 25 25 24 24 24 2424 30 25 50 24 24 24 24 24 7777 6 6 6 77 77 77 77 77 77 77 24 25 6 24 24 2424 2424 24 2424 24 24 24 2424 2424 2424 24 24 24 24 24 24 24 2424 3535351010 2410 53 204 418 2010351035 242424 24 24 24 24 24 24 2424 24 24 24 2424 2424 24 30 77 717 24 30 2424 24 30 177 7 17 7 17 30 24242424 24 24 24 24 30 24 2424 2424 2440 40 24 2424 24 24 24 40 40 40 24 24 2424 2424 40 40 40 40 40 40 4040 4040 40 40 2424 24 2424 24 2424242424242424 24 24 24 24 60 60 60 3030 40 30 24 24 24 24 24 24 30 6060 6060 5050 40 40 24 24 24 24 24242424 2424 24 30 24 2424 24 24 24 24 24 30 24 24 24 30 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 24 2424 24 24 2424 24 2430 30 24 24 168 2416 816 24 24 24 24 2424 24 24 15 30 24 2025 24 24 24 24 2424 24 24 24 24 24 24 24 30 24 24 2020 24 25 25 25 25 2525252020 2525 24 24 24 2424 24 2424 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 2424 2424 24 24 2424 2424 24 24 242424 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 5050 5050 24 24 Special ConditionsSpecial Conditions Special Conditions ACK_FOR_MIXED d e l a s Pu l g as n d H i l l R o a d J u n i pero Se r r a B o u l ev ard Pa ge M ill Road Ara s t rade ro Road E l C a m i n o R e a l S an Antonio A v en u e Cha r l e s t o n Ro ad Or ego n Ex p r es sway Mi d d l e f i e l d Ro a d University Avenue e e w a y 101 A l ma S t r e e t El Camino Real A l p i n e R o a d F o o t h i l l E x p r e ssw ay H i g h Hillview East Bayshore West Bayshore Fabian Central Expressway Sand Hill Road Embarcadero Road Fab i a n W a y Newell Rd California St Latham St Cl Pu Middle Ave Welch Coyote H i l l Rd Hansen Way Matadero Ave Loma Verde Ave Colorado Ave Park Blvd Birch N. California Ave Amaranta El Ca mino Way Lytton Ave Hamilton Ave Homer Ave Channing Ave Channing Ave Guinda Stanford Av e Waverley St. Churchill Ave tPee r Coutts Serra St Arboretum Galvez Park Blvd Amphi theat re Pkwy Charleston RdAlma St Los Altos Ave Hillview Ave Old PageMillRd ol d e n OvantesR d This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Residential Zone Districts Non- Residential Zone Districts Public Facilities/Open Space Zone Districts Special Setback Frontages Local Collector Residential Arterial Arterial Expressway City Jurisdictional Limits 0'2670' Ex h i b i t 3 Ro a d N e t w o r k a n d S p e c i a l S e t b a c k s wi t h R e s i d e n t i a l , C o m m e r c i a l , and Pu b l i c F a c i l i t i e s Z o n i n g D i s t r i c t s v.2 0 1 9 1 1 2 5 CITYOF PALOALTOINCORPORATED CALIFORNIA P a l o A l t oT h e C i t y o f APRIL 16 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Altorrivera, 2019-11-25 13:00:40 (\\cc-maps\Encompass\Admin\Personal\rrivera.mdb) DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 4Attachment D - (Repealed)Resolution No. 9873 WirelessObjective Standards    Packet Pg. 103     Certificate Of Completion Envelope Id: ECCACC0E18AC4D5E9AEE0C930810BD0A Status: Completed Subject: Please DocuSign: RESO 9873 WCF Resolution with Exhibit 1.docx, RESO 9872 Exhibit 2.pdf, RESO 98... Source Envelope: Document Pages: 10 Signatures: 5 Envelope Originator: Certificate Pages: 2 Initials: 0 Kim Lunt AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 250 Hamilton Ave Palo Alto , CA 94301 kimberly.lunt@cityofpaloalto.org IP Address: 199.33.32.254 Record Tracking Status: Original 1/7/2020 1:32:22 PM Holder: Kim Lunt kimberly.lunt@cityofpaloalto.org Location: DocuSign Security Appliance Status: Connected Pool: StateLocal Storage Appliance Status: Connected Pool: City of Palo Alto Location: DocuSign Signer Events Signature Timestamp Aylin Bilir Aylin.Bilir@CityofPaloAlto.org Deputy City Attorney Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 1/7/2020 1:36:35 PM Viewed: 1/7/2020 1:40:55 PM Signed: 1/7/2020 4:08:48 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Jonathan Lait Jonathan.Lait@CityofPaloAlto.org Interim Director Planning and Community Environment City of Palo Alto Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 199.33.32.254 Sent: 1/7/2020 4:08:51 PM Resent: 1/13/2020 8:54:57 AM Resent: 1/15/2020 8:58:56 AM Resent: 1/16/2020 11:39:30 AM Viewed: 1/16/2020 12:31:49 PM Signed: 1/16/2020 12:32:05 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Ed Shikada ed.shikada@cityofpaloalto.org Ed Shikada, City Manager City of Palo Alto Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 1/16/2020 12:32:09 PM Viewed: 1/16/2020 5:51:30 PM Signed: 1/16/2020 5:51:37 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Eric Filseth eric.filseth@cityofpaloalto.org Mayor Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 108.169.4.229 Sent: 1/16/2020 5:51:41 PM Viewed: 1/16/2020 11:04:09 PM Signed: 1/16/2020 11:04:20 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 104     Signer Events Signature Timestamp Beth Minor Beth.Minor@CityofPaloAlto.org City Clerk City of Palo Alto Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 1/16/2020 11:04:23 PM Viewed: 1/17/2020 7:52:37 AM Signed: 1/17/2020 7:52:54 AM Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 1/16/2020 11:04:23 PM Certified Delivered Security Checked 1/17/2020 7:52:37 AM Signing Complete Security Checked 1/17/2020 7:52:54 AM Completed Security Checked 1/17/2020 7:52:54 AM Payment Events Status Timestamps Item 4 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 105     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST April 2019 Page 1 of 7 TIER 2 WIRELESS COMMUNICATIONS FACILITIIES PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST In-person appointments are required to submit all applications. Appointments can be scheduled by calling the Planning Division at (650) 329-2442 or scheduled in-person at the City‘s Development Center, located at 285 Hamilton Avenue. The following information is required for the review of Tier 2 Wireless Communications Facilities (WCF) as defined in Palo Alto Municipal Code 18.42.110 and proposed for location in the public right-of-way. Instructions: Complete and submit all items listed in the checklist below that are applicable to the application. The information identified below must be provided in order to accept the application as complete for review. If an item does not apply, write “N/A” (not applicable). The Planning Department is available to answer applicant questions in advance of application submittal and can be contacted at 650- 329-2442. Project Location(s)/Address(es): Project Description (include Applicant name and Carrier name): Application Basic Information (Please circle the applicable response): Y, N, or N/A Materials contain more than one wireless communication facility and the applications are batched. Y, N, or N/A Materials show one or more wireless communication facility designs that meet all of the City’s rules, regulations, and Objective Standards (Refer to City Council Action on December 16, 2019). Y, N, or N/A Materials request one or more WCF exception requests to the City’s rules, regulations, or Objective Standards. Y, N, or N/A Materials show one or more wireless communication facilities that qualify as a “small wireless facility,” as defined by any valid regulations adopted by the FCC. Y, N, or N/A Materials show one or more wireless communication facilities that do not qualify as a “small wireless facility,” as defined by any valid regulations adopted by the FCC. Y, N, or N/A Materials show one or more wireless communication facilities that are subject to the applicant’s Master License Agreement. Y, N, or N/A Materials show one or more wireless communication facilities that are not subject to a Master License Agreement. Application Submittal Requirements: Additional copies of application materials may be required if the application is referred after intake for review by the Architectural Review Board, City Council, Responsible Agency, or other reviewing body.  Application Forms. Per PAMC Section 18.42.110(d) and PAMC Section 18.42.110(e), all required application forms and required application materials necessary to initiate and process all entitlement and all permit reviews and decisions shall be submitted so that they can be processed concurrently. Application forms include the Planning Application with original wet signatures of the applicant and property owner(s). The Planning Application Number will be assigned at application intake. Copies of completed additional application forms are also required, as applicable, including but not limited to: Building Permit Application, Excavating and Grading Permit Application, Electrical or Other Utilities Permit Application, Street Work Permit Application, (NEAR) 1661 Page Mill Road See description document. Carrier is AT&T and application is Justin Giarritta, NextEdge Networks 4 Item 4 Attachment E - Tier 2 Right- of-Way Application Checklist     Packet Pg. 106     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 2 of 7 Insurance Certificate, and/or an Encroachment Permit Application. A Master License Agreement Exhibit (commonly referred to as Exhibit G) and a Utility Map Request will have likely been submitted to the City’s Utilities Department as part of the applicant team gathering information necessary to investigate siting and prepare project plans and do not constitute entitlement or permit filing. List the numbers and dates submitted for each applicable application and permit: •Planning Application Number & Date Submitted: ____________________________________ •Building Permit Application Number & Date Submitted: ______________________________ •Excavation and Grading Permit Application Number & Date Submitted: __________________ •Street Work Permit Application Number & Date Submitted: ___________________________ •Encroachment Permit Application Number & Date Submitted: _________________________ •Insurance Certificate Submittal Information & Date Submitted: ________________________ •Electrical Permit Application Number & Date Submitted: _____________________________ •Other Application Number(s) & Date(s) Submitted: __________________________________ •Master License Agreement Exhibit Tracking Information & Date Submitted: ______________ •Utility Map Request Form Tracking Information & Date Submitted: _____________________  One (1) hardcopy of this TIER 2 WIRELESS COMMUNICATIONS FACILITIIES PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST completed and signed.  One (1) hardcopy of the Cost Recovery Form with original wet signature of applicant. A signed cost recovery agreement may substitute for the cost recovery form.  Application Fees/Deposits. Application submittal fees/deposits shall be invoiced and submitted during application intake. For batched applications, an invoice shall be prepared and the fees/deposits paid for each proposed location, unless the applicant coordinates with the City to prepare a mutually agreed upon separate cost recovery agreement. Consistent with the City’s Municipal Fee Schedule, a separate deposit(s) may also be necessary to submit after application intake to cover the cost of the City’s use of consultants to conduct independent review of application material(s) and/or serve as an extension of staff to conduct application reviews.  Application numbers for any existing and/or approved wireless communication facilities at the proposed location and/or within 1,500 feet of the proposed WCF location on either public or private property: _______________________________________________________________________  One (1) electronic copy of all application materials listed in this checklist.  Three (3) hardcopies of a Radio Frequency Report, prepared by a professional engineer, that discusses and confirms the wireless communication facility planned compliance with the FCC regulations. The report shall include a list of the proposed equipment models, frequency bands, power, azimuths, minimum and maximum downtilts, distances to ground and adjacent single and multiple-story buildings, clarification if there are any other nearby wireless facilities considered as part of the analysis of cumulative conditions, a description of the standards, equations, and other methodology utilized, color maps and/or statements of distances and zones for public and occupational exclusion and/or exposure limits, and required signage and any other measures necessary for the facility to operate in compliance with FCC standards. The City may elect to have an outside consultant to perform a peer review of this report at the applicant's expense.  One (1) hardcopy of the manufacturer’s specifications for proposed equipment, including power operations and noise generation information.  Three (3) color hardcopies of existing and proposed coverage and capacity maps with a legend and other graphics that describe the goals for the proposed wireless communication facility.  Three (3) hardcopies of the completed “A Local Government Official’s Guide to Transmitting Antenna RF Emission Safety: Rules, Procedures, and Practical Guidance - APPENDIX A Optional N/A 4 4 4 4 4 4 4 4 4 Item 4 Attachment E - Tier 2 Right- of-Way Application Checklist     Packet Pg. 107     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 3 of 7 Checklist for Local Government To Determine Whether a Facility is Categorically Excluded” form.  Three (3) hardcopies of the completed “HAZARDOUS MATERIALS DISCLOSURE CHECKLIST” form.  Three (3) hardcopies of the completed “ENVIRONMENTAL IMPACT ACCESSMENT WORKSHEET” form.  One (1) hardcopy of a list of all of the carrier’s existing or entitled antenna locations, including the street address and latitude/longitude coordinates, within the City limits. Each site listed should include the type of installation (e.g. roof-mounted, monopole, faux tree, etc.).  One (1) color hardcopy of the location map from the project plans printed on 11” x 17” paper.  One (1) color and materials board including samples of actual colors and materials mounted on 8” x 14” foam board to be retained by the city as part of the permanent file.  Three (3) hardcopies of a Tree Protection Report (TPR) and arborist assessment. Report shall be required for any new facility or construction within the tree protection zone (TPZ) of a protected and/or designated tree, and may be required for others, including street trees as deemed necessary by the City Arborist. The report shall be consistent with the City Tree Technical Manual and shall be prepared by an ISA certified Arborist. See Overview of Regulated Trees. If required, this report shall also be incorporated into the project plans.  Twelve (12) color hardcopies of a project description that includes the following information, at minimum: •the existing and proposed use at the proposed location, •the proposed wireless carrier, •the purpose and goals for the wireless facility (e.g. network design, frequency bands, new technology use), •the proposed scope of work, including work above and below ground, •the dimensions and volume of the antenna and the dimensions and volume of other additional equipment and the overall facility, •the efforts taken to minimize visual impacts of the proposed design (e.g. substantial setback from major roads, presence of trees, stealth design, slim line monopole, reducing the number of proposed facilities, increasing distances from nearby windows and other openings; placing some equipment in an underground vault, avoidance of scenic corridors or gateways, avoidance of nearby historic buildings), •map and the pole numbers for the alternative project locations considered, including in regard to network design, search ring/polygons, and specific site selection criteria, as well as a description of the reasons why these alternatives were not selected as the WCF proposed, •graphic portrayal and description of the proposed design and the alternative designs considered, •the efforts to locate at existing wireless facilities, •the basis of how the project qualifies as a Tier 2 WCF under PAMC Section 18.42.110, •identification of the underlying Master License Agreement, if any, •statement that clarifies if the application materials contain more than one wireless communication facility, •statement that clarifies that either the application materials show one or more wireless communication facilities that meet all of the City’s rules, regulations, and Objective Standards or a detailed statement detailing any and all requested WCF exceptions to any of the City’s rules, regulations, or Objective Standards (See PAMC Section 18.42.110(k) for more information on requesting exceptions. The WCF exception(s) must satisfy the requirements of PAMC Section 18.42.110(k) and demonstrate why the rule, regulation, or Objective Standard is infeasible), 4 4 4 4 4 4 4 Item 4 Attachment E - Tier 2 Right- of-Way Application Checklist     Packet Pg. 108     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 4 of 7 •clarification of the materials, colors, and construction methods to be used, •clarification if one or more wireless communication facilities will generate any noise, •clarification on how any future expansion, including the addition of 5G equipment if not currently proposed, would be designed in accordance with applicable laws and the City’s Objective Standards, •list of all wireless communication facilities proposed in application, including the applicant site identification number, closest adjacent APN, address of closest adjacent APN, existing zoning district, existing underground utility district number (if any), existing pole number, existing pole height, proposed pole height with facility, and proposed color of facility.  Twelve (12) hardcopies of a reduced-size (minimum of 11” x 17” and maximum 18” x 24”) set of bound project plans that include a north arrow, a graphic scale, and a notation of the drawing scale as either at 1/8” or 1/4” scale. All sheets shall be oriented in the same direction. Plans shall be legible and internally consistent. Plans shall include all information necessary for permitting and construction, as they will be the same plans submitted for Electrical permits, Street Work Permits, and/or Encroachment Permits. Applicants are encouraged to provide additional information where helpful. Project data and site information listing the wireless communication facility(ties) proposed in the application, applicant site identification number(s), latitude/longitude coordinates, elevation(s), closest adjacent parcels, address(es) of closest adjacent parcels, historic status of closest adjacent parcels, roadway type at the proposed location (expressway, arterial, residential arterial, collector, or local roadway), existing zoning district(s), existing underground utility district number (if any), existing pole number(s), and a brief description of work. Vicinity map showing the location of the proposed wireless communication facility within the City of Palo Alto. Location map showing north arrow, scale, parcel lines, and the distance and location of scenic routes, residence(s), schools, and other WCF facilities within 600 feet of the proposed wireless communication facility. Stamped and signed site survey of the wireless communication facility site area and pole completed within the last 12 months serving as the basis for other plan sheets. Stamped and signed structural/loading calculations completed for the proposed wireless communication facility design. Separate and detailed existing and proposed site/landscape/utility plans of the wireless communication facility site area including the following information: •North arrow (orient all sheets in the same direction), •Scale (1/8 minimum), •Dimensioned property lines and location of the right of way, including streets, paths, curb lines, sidewalks, planting strips, driveways, curb cuts, and utility lines, •Dimensioned residential zone of exclusion area, if the WCF is proposed in a residential zoning district, •Existing and proposed above ground and underground site improvements in the right-of- way within 50 feet of the proposed wireless communication facility, including signs, light fixtures, bicycle parking, trash and recycling (including proposed containers or related equipment), enclosures, fences, backflow preventers, above-ground electrical utilities, 4 Item 4 Attachment E - Tier 2 Right- of-Way Application Checklist     Packet Pg. 109     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 5 of 7 boxes, transformers, meter mains, fire standpipes, vaults, underground utilities (sewer, gas, electric, water), communication facilities (fiber optic, conduit and any other facilities), and similar. (Applicants must submit a Utility Map Request form in order to receive existing underground utilities information), •Easements, encumbrances, and/or roadway special setback lines, •Proposed species and size for any new trees and the location, species, size, dripline area, and any necessary tree protection zone (TPZ) for all existing trees within 50 feet of the site area, including trees on neighboring properties that overhang the wireless communication facility site area. Dimension the distance from trees to the work area when the tree is located closer than 10’ to proposed construction, •Footprint of all buildings and structures on adjacent parcels with distances from the proposed WCF indicated, •Creeks or waterways on or adjacent to the site, •Azimuth direction(s), •Distance to closest habitable/occupied structure for each azimuth proposed or distance to closest habitable/occupied structures in each direction if an omni-directional antenna is proposed, •Pole quadrants showing proposed and existing risers, location of climbing space and/or working space and location of proposed and existing attached equipment, •Single line diagram, equipment grounding diagrams, and panel schedule, •Plan showing all proposed conduits or substructures, location of directional bores, receiving and exit pits indicated, size(s) of bore pits, boring profiles at utility crossings, location, size and extent of trenching, location and size of potholing, and volume of soil to be disturbed in cubic feet. Additional information to include in project plans: •Information necessary to determine GO 95 compliance, •Model number and manufacturer dimensioned diagrams of proposed equipment, mounting brackets, shrouding, underground vaults and associated equipment, •Manufacturer’s pole specifications, decorative features (if any) and details, • Equipment volume information summary with dimensioned front and side elevations that can be used to confirm equipment volume. Project elevations, sections, and schematic details: •Elevations showing all existing conditions, including all existing pole features and attachments and all proposed pole features and attachments. Elevations shall include all sides of the wireless communication facility, all existing and proposed signage and lighting, notation of grade elevation from where the maximum height is measured, notations of the type, colors, materials and finish for all project elements, notations of the height and dimensions for all project elements, and notations of the point of service for power, fiber, and similar, •Illustrative vertical section including foundation to maximum height in context with surrounding site features, such as curb lines, sidewalks, electrical lines, communication lines, landscaping features, trees, and underground structures (drawing should be at a minimum of ½” = 1’ scale), •Illustrative horizontal section(s) showing the attachments and clearances for equipment and conduit mounted to pole(s), •Schematic details demonstrating the quality and nature of the wireless communication facility design and code compliance of the design, including details of structural Item 4 Attachment E - Tier 2 Right- of-Way Application Checklist     Packet Pg. 110     TIER 2 WCF PROPOSED FOR THE PUBLIC RIGHT-OF-WAY APPLICATION SUBMITTAL REQUIREMENTS CHECKLIST December 2019 Page 6 of 7 connections and attachments and the aesthetic details of how adjacent, dissimilar materials connect. Examples include: mounting of the equipment to poles and wires and cabling behind shrouds or internal to the pole, •Details, colors, and text of all new safety, power disconnect, and other signage and location/method of attachment. Color photographs: Photos of the existing site showing the relationship of the proposed wireless communication facility to adjacent buildings and to the neighborhood. Color visual simulation(s): Visual simulations prepared to scale comparing existing and proposed conditions and context utilizing views consistent with the existing and proposed elevations. Lighting plan (if any changes to existing lighting are proposed or required) showing photometric drawings including foot-candle numbers and catalog cut sheets of proposed exterior fixtures. Urban Forestry Division Standard Tree Protection Plan Sheet (T-1) filled out and signed by the property owner or applicant. When required, include completed Tree Protection Report(s) as Sheet T-2 and T-3. Current City Standard Specifications sheets: DWGs 401, 402, 403, 404, and 405. Standard Public Works Engineering Services Standard Sheets (Stormwater Pollution Prevention and Standard Conditions). Traffic Logistics and Control Plan. Does Applicant seek an exception from any of the City’s rules, regulations, or Objective Standards applicable to the application? Yes No (If “Yes,” provide a description of the specific exceptions sought and the manner in which the application complies with all applicable rules, regulations, and Objective Standards to the greatest extent feasible.) Does Applicant allege that strict application on a City rule, regulation, or Objective Standard or failure to approve this application will violate preemptive state or federal law? Yes No (If “Yes,” provide all documentation to support allegation.) Certification under Penalty of Perjury I declare under penalty of perjury that the foregoing is true and correct. Executed on (date) at (location), California. Name (print): Signature: Relationship to the Applicant of Record: Justin Giarritta Applicant 4 4 6/9/25 Palo Alto Item 4 Attachment E - Tier 2 Right- of-Way Application Checklist     Packet Pg. 111     Page 1 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Compliance Statement Based on information provided by AT&T Mobility and predictive modeling, the CRAN_RSFR_PALO2_054 installation proposed by AT&T Mobility will be compliant with Radiofrequency Radiation Exposure Limits of 47 C.F.R. §§ 1.1307(b)(3) and 1.1310. RF alerting signage and restricting access to the antenna to authorized personnel that have completed RF safety training is required for Occupational environment compliance. The proposed operation will not expose members of the General Public to hazardous levels of RF energy at ground level or in adjacent buildings. Certification I, Tim Alexander, am the reviewer and approver of this report and am fully aware of and familiar with the Rules and Regulations of both the Federal Communications Commissions (FCC) and the Occupational Safety and Health Administration (OSHA) with regard to Human Exposure to Radio Frequency Radiation, specifically in accordance with FCC’s OET Bulletin 65. I have reviewed this Radio Frequency Exposure Assessment report and believe it to be both true and accurate to the best of my knowledge. General Summary The compliance framework is derived from the Federal Communications Commission (FCC) Rules and Regulations for preventing human exposure in excess of the applicable Maximum Permissible Exposure (“MPE”) limits. At any location at this site, the power density resulting from each transmitter may be expressed as a percentage of the frequency-specific limits and added to determine if 100% of the exposure limit has been exceeded. The FCC Rules define two tiers of permissible exposure differentiated by the situation in which the exposure takes place and/or the status of the individuals who are subject to exposure. General Population / Uncontrolled exposure limits apply to those situations in which persons may not be aware of the presence of electromagnetic energy, where exposure is not employment-related, or where persons cannot exercise control over their exposure. Occupational / Controlled exposure limits apply to situations in which persons are exposed as a consequence of their employment, have been made fully aware of the potential for exposure, and can exercise control over their exposure. Based on the criteria for these classifications, the FCC General Population limit is considered to be a level that is safe for continuous exposure time. The FCC General Population limit is 5 times more restrictive than the Occupational limits. Radio Frequency Emissions Compliance Report For AT&T Mobility Site Name: CRAN_RSFR_PALO2_054 Site Structure Type: Utility Pole Address: (NEAR) 1661 PAGE MILL RD Latitude: 37.410145 PALO ALTO, CA 95304 Longitude: -122.152965 Report Date: September 09, 2024 Project: Modification R E G I S T E R E D P R O F E S S I O N A L E N G I N E E R E L E C T R I C A L No. E18344 S T A T E O F C A L I F O R N I A T I M ALEXANDER EL E C T R I C A LSTA NIA Exp, 31 MAR 2026 SIGNED, 10 SEP 2024 Item 4 Attachment F - RF Emissions Report     Packet Pg. 112     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 2 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Table 1: FCC Limits Frequency (MHz) Limits for General Population/ Uncontrolled Exposure Limits for Occupational/ Controlled Exposure Power Density (mW/cm2) Averaging Time (minutes) Power Density (mW/cm2) Averaging Time (minutes) 30-300 0.2 30 1 6 300-1500 f/1500 30 f/300 6 1500-100,000 1.0 30 5.0 6 f=Frequency (MHz) In situations where the predicted MPE exceeds the General Population threshold in an accessible area as a result of emissions from multiple transmitters, FCC licensees that contribute greater than 5% of the aggregate MPE share responsibility for mitigation. Based on the computational guidelines set forth in FCC OET Bulletin 65, Waterford Consultants, LLC has developed software to predict the overall Maximum Permissible Exposure possible at any location given the spatial orientation and operating parameters of multiple RF sources. The power density in the Far Field of an RF source is specified by OET-65 Equation 5 as follows: 𝑆𝑆= 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸4⋅𝜋𝜋⋅𝐸𝐸2 (mW/cm2) Where EIRP is the Effective Radiated Power relative to an isotropic antenna and R is the distance between the antenna and point of study. Additionally, consideration is given to the manufacturers’ horizontal and vertical antenna patterns as well as radiation reflection. At any location, the predicted power density in the Far Field is the spatial average of points within a 0 to 6-foot vertical profile that a person would occupy. Near field power density is based on OET-65 Equation 20 stated as 𝑆𝑆=�180𝜃𝜃𝐵𝐵𝐵𝐵� ⋅100⋅ 𝑃𝑃𝑖𝑖𝑖𝑖𝜋𝜋 ⋅ 𝑅𝑅 ⋅ ℎ (mW/cm2) Where Pin is the power input to the antenna, θBW is the horizontal pattern beamwidth and h is the aperture length. Some antennas employ beamforming technology where RF energy allocated to each customer device is dynamically directed toward their location. In the analysis presented herein, predicted exposure levels are based on all beams at full utilization (i.e. full power) simultaneously focused in any direction. As this condition is unlikely to occur, the actual power density levels at ground and at adjacent structures are expected to be less that the levels reported below. These theoretical results represent maximum-case predictions as all RF emitters are assumed to be operating at 100% duty cycle. For any area in excess of 100% General Population MPE, access controls with appropriate RF alerting signage must be put in place and maintained to restrict access to authorized personnel. Signage must be posted to be visible upon approach from any direction to provide notification of potential conditions within these areas. Subject to other site security requirements, occupational personnel should be trained in RF safety and equipped with personal protective equipment (e.g. RF personal monitor) designed for safe work in the vicinity of RF emitters. Controls such as physical barriers to entry imposed by locked doors, hatches and ladders or other access control mechanisms may be supplemented by alarms that alert the individual and notify site management of a breach in access control. Waterford Consultants, LLC recommends that any work activity in these designated areas or in front of any transmitting antennas be coordinated with all wireless tenants. Item 4 Attachment F - RF Emissions Report     Packet Pg. 113     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 3 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Analysis AT&T Mobility proposes the following installation at this location: • INSTALL (2) NEW 2' PANEL ANTENNA ON TOP OF LIGHT POLE • INSTALL (1) NEW RADIO 4415, (1) RADIO 4435 AND (1) RADIO 4449 ON LIGHT POLE The antennas will be mounted on a 30’-2” Utility Pole with centerlines 30’-0” above ground level. Proposed antenna operating parameters are listed in Appendix A. Other appurtenances such as GPS antennas, RRUs and hybrid cable below the antennas are not sources of RF emissions. No other antennas are known to be operating in the vicinity of this site. Figure 1.1: Antenna Locations Power density decreases significantly with distance from any antenna. The panel-type antennas to be employed at this site are highly directional by design and the orientation in azimuth and mounting elevation, as documented, serves to reduce the potential to exceed MPE limits at any location other than directly in front of the antennas. For accessible areas at ground level, the maximum predicted power density level resulting from all AT&T Mobility operations is 1.46% of the FCC General Population limits. Incident at adjacent Structure Item 4 Attachment F - RF Emissions Report     Packet Pg. 114     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 4 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com depicted in Figures, the maximum predicted power density level resulting from all AT&T Mobility operations is 0% of the FCC General Population limits (Figure 1.2). The proposed operation will not expose members of the General Public to hazardous levels of RF energy at ground level or in adjacent buildings On the pole in front of the antennas, predicted MPE levels will exceed the FCC General Population limits within 37 feet in front of the antennas and within 7 feet below the antennas. The maximum predicted power density level resulting from all AT&T Mobility operations directly in front of the antennas is 5212.86% of the FCC General Population limits (1042.572% of the FCC Occupational limits). Waterford Consultants, LLC recommends posting RF alerting signage (ACP Caution) on the pole visible upon approach that informs personnel accessing this area of basic precautions to be followed when working around antennas. This recommendation is depicted in Figure 2. Any work activity in front of transmitting antennas should be coordinated with AT&T Mobility. The following plots show the cumulative spatial average predicted power density levels in the reference plane indicated as a percentage of the General Public Limits. Please note that 100% of the General Public Limits corresponds to 20% of the Occupational Limits. Item 4 Attachment F - RF Emissions Report     Packet Pg. 115     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 5 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Figure 1.1: Antenna Level Item 4 Attachment F - RF Emissions Report     Packet Pg. 116     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 6 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Figure 1.2: All Level Item 4 Attachment F - RF Emissions Report     Packet Pg. 117     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 7 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Figure 1.3: Elevation Level Item 4 Attachment F - RF Emissions Report     Packet Pg. 118     CRAN_RSFR_PALO2_054 – Modification 08.15.2024 Page 8 7430 New Technology Way, Suite 150 Frederick, Maryland 21703 (703) 596-1022 Phone www.waterfordconsultants.com Compliance Requirement Diagram (Access Location) Recommendations AT&T Mobility Access Location Install (2) ACP Caution “Above” signs at 6ft below the antenna or 24ft AGL, 180 degrees opposite to each other viewable from each direction. Materials (2) ACP Caution “Above” signs sized 7”x7” Safe Distance = 21ft Bottom Distance = 6ft Proposed Signs/Barriers Existing Signs/Barriers Figure 2: Mitigation Recommendations 21 21 Item 4 Attachment F - RF Emissions Report     Packet Pg. 119     1355 Windward Concourse, Suite 410 Alpharetta, GA 30005 www.modusllc.com June 16, 2025 Via Web Delivery City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 (650) 329-2496 RE: Justification Letter: ATT Mobility Light Pole Address ATT Mobility & Palo Alto Filing Number ATT Mobility Site ID 1661 Page Mill Road PALO2_054 The scope of work to be complete: 6409 Wireless Facility Request Permit Application to modify existing AT&T wireless facility on a City of Palo Alto owned metal street pole in the public ROW. Removal of existing equipment; including (1) canister antenna, (1) radio, and (1) equipment cabinet from pole. Removal all noise producing elements. Addition of new equipment; including (3) new convection cooled radios, and (2) new antennas. NOTE: Convection Cooling means the radios have a fanless design and will not produce any noise. 24PLN-00278 Item 4 Attachment G - Applicant's Project Description     Packet Pg. 120     The existing and proposed use: The existing use of this location is a wireless facility for AT&T Mobility in the public right-of- way. The proposed use will remain as a wireless facility for AT&T Mobility in the public right- of-way. The purpose of the proposed changes: The purpose of the proposed changes is to further enhance network by deploying additional spectrum designed to provide more capacity for users. The measures taken to minimize visual impacts of the project (e.g. substantial setback from major roads, trees, stealth design, slim line monopole). Include other proposed site enhancements that will benefit the project site): Remove the large and noise producing battery backup from above the existing radio. Replace the existing powerwaveradio with three compact radios mounted side by side to each other on the pole in a neat and tight manner. Replace the existing canister antenna with one of the same size. The proposed does not defeat the preexisting concealment / elements. The proposed design will have less visual impact on the surrounding environment than the current build. All AT&T added appurtenances shall be painted to match pole color (non-glossy "Sable" by Sherwin Williams or equivalent. Sincerely, AT&T Mobility, NorCal Cc: Justin Giarritta City of Palo Alto Sean Randall Marc Grabisch Item 4 Attachment G - Applicant's Project Description     Packet Pg. 121     May 21, 2025 Via Web Delivery City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 (650) 329-2496 ________________________________________________________________________________ Re: Community Meeting for proposed AT&T Mobility facility at 1661 Page Mill Rd. Dear Planning, On May 21, 2025, AT&T Mobility conducted a community meeting regarding the proposed modification to the wireless facility at 1661 Page Mill Rd. The attached notification announced that the community meeting was to be held at the VC Nest at 567 University Ave., at 6:00 pm on May 21, 2025. Notice of the community meeting was mailed to building owners and tenants within 600 feet of the proposed installation. I conducted the meeting on behalf of AT&T Mobility as the project sponsor. No building owners or tenants attended the meeting and no questions or comments were received via phone or email. The meeting ended around 8:00pm. Additionally, copies of the sign-in sheet and the declaration of mailing affidavit with a map and list of residence within 600 ft., and meeting notice are attached. Sincerely, Justin Giarritta, Project Manager NextEdge Networks 1355 Windward Concourse, Suite 410 Alpharetta, GA 30005 707-225-2865 Item 4 Attachment G - Applicant's Project Description     Packet Pg. 122     1 027120324 Ordinance No. 5655 Ordinance of the Council of the City of Palo Alto Amending Chapter 18.42 (Standards for Special Uses) of the Palo Alto Municipal Code on a Temporary Basis to Modify the Procedure and Standards Governing the Review of Wireless Communications Facilities Applications; and repealing Resolution 9873 (Amending Objective Aesthetic, Noise, and Related Standards for Wireless Communication Facilities in the Public Rights of Way) The Council of the City of Palo Alto does ORDAIN as follows: SECTION 1. Findings and Declarations. The City Council finds and declares as follows: A.The City Council has adopted a Wireless Communication Facilities (WCF) code to regulate the various health, welfare, and safety impacts presented by the proliferation of WCFs and to balance these impacts with the interests of consumers in receiving the benefits of wireless technologies. B.Federal and state law place significant limits on the City’s exercise of local control over WCF matters. On September 26, 2018, the Federal Communications Commission adopted a Declaratory Ruling and Third Report and Order (WT Docket No. 1779; WC Docket No. 1784; FCC 18-133), further limiting local control. C.On August 12, 2020, in a decision in the City of Portland v. FCC, the United States Court of Appeals for the Ninth Circuit invalidated certain elements of the FCC’s Order 18-133 restricting local aesthetic regulations of WCFs. Specifically, the Court struck down the requirements that local standards be “objective” and “no more burdensome” than those applied to similar types of infrastructure installations. Now, a city’s aesthetic regulations for small wireless facilities will not be preempted by federal law if they are: (1) reasonable technically feasible and reasonably directed at remedying aesthetic harms) and (2) published in advance. D.As a result of the Portland decision, the City Council wishes to modify the WCF ordinance provisions relating to the permit review process for Tier 2 and Tier 3 Facilities in the public right-of-way, to repeal references to the Objective Aesthetic, Noise, and Related Standards and to require review of such applications by the Architectural Review Board ARB) under the City’s architectural review findings. E.Section 18.80.090 of the Palo Alto Municipal Code authorizes the City Council to change or suspend operation of the Zoning Code for temporary periods without review by the Planning and Transportation Commission when in the determination of the council such suspension or change is necessary for the public health, safety or welfare. SECTION 2. Resolution 9873, Amending Objective Aesthetic, Noise, and Related Standards for Wireless Communication Facilities in the Public Rights of Way, adopted December 16, 2019, is hereby repealed. For the avoidance of doubt, by this action Council repeals all prior versions of these objective standards, including Resolution 9825 April 19, 2019), Resolution 9847 (June 17, 2019), and Resolution 9855 (August 12, 2019). Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 123     2 027120324 SECTION 3. Section 18.42.110 Wireless Communication Facilities is hereby amended to read as follows (additions in underline format and deletions in strikethrough format): 18.42.110 Wireless Communication Facilities a)Purpose and Interpretation The purpose of this section is two-fold: (A) to implement within the jurisdictional boundaries of the city the applicable zoning, land use and other laws, rules, regulations and policies and procedures applicable to siting applications filed with the city by wireless communications facilities infrastructure owners and operators and wireless communications service providers, which seek to install or attach their facilities at locations in Palo Alto; and (B) to accommodate new wireless technologies and continued improvements to existing wireless communications facilities while minimizing their adverse visual and structural health and safety impacts. Consistent with that purpose, the provisions of this section are to be construed in a manner that is consistent with (1) the interest of consumers in receiving the benefits of the deployment of ultra-high-speed and -capacity broadband wireless communication facilities technology and innovations and the delivery of ultra-high-speed and -capacity broadband wireless communications facilities services, (2) the interest in safeguarding the environment, preserving historic properties, and addressing aesthetics and other local values, and (3) the interest in promoting the public health, safety and welfare in Palo Alto. Although this section implements and references provisions of preemptive state and federal law, nothing in this section shall be interpreted to create an independent source of the rights provided an applicant by such state or federal law. A wireless communications facility is permitted to be sited in Palo Alto subject to applicable requirements imposed by this chapter. These processes are intended to permit wireless communications facilities that blend with their existing surroundings and do not negatively impact the environment, historic properties, or public safety. The procedures prescribed by this section are tailored to the type of wireless communication facility that is sought. Building- mounted wireless communications facilities and collocation of facilities are preferred and encouraged, subject to all other provisions of this section. b)Definitions The following abbreviations, phrases, terms and words shall have the meanings assigned in this section or, as appropriate, in Section 18.04.030 and Section 1.04.050 of the Palo Alto Municipal Code, as may be amended from time to time, unless the context indicates otherwise. Words that are not defined in this section or other chapters or sections of the Palo Alto Municipal Code shall have the meanings as set forth in Chapter 6 of Title 47 of the United States Code, Part 1 of Title 47 of the Code of Federal Regulations, and, if not defined therein, their common and ordinary meaning. 1)"Antenna" means that part of a wireless communications facility designed to radiate or receive radio frequency signals or electromagnetic waves for the provision of personal wireless services, as defined in 42 U.S.C. § 332(c)(7)(C)(i). This definition does not include antennas designed for amateur or household use. Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 124     3 027120324 2)"Associated equipment" means any and all on-site equipment, including, without limitation, back-up generators and power supply units, cabinets, coaxial and fiber optic cables, connections, shelters, radio transceivers, regular power supply units, and wiring, to which a wireless antenna is attached in order to facilitate mobile broadband service and personal wireless service delivered on mobile broadband devices. 3)"Base Station" means the same as defined by the FCC at 47 C.F.R. § 1.6100(b), as it may be amended from time to time. For the purpose of convenience only, this definition is stated as follows: a structure or equipment at a fixed location that enables FCC-licensed or authorized wireless communications between user equipment and a communications network. The term does not encompass a tower as defined herein or any equipment associated with a tower. Base Station includes, without limitation: A.Equipment associated with wireless communications services such as private, broadcast, and public safety services, as well as unlicensed wireless services and fixed wireless services such as microwave backhaul. B.Radio transceivers, antennas, coaxial or fiber-optic cable, regular and backup power supplies, and comparable equipment, regardless of technological configuration (including Distributed Antenna Systems ("DAS") and small-cell networks). C.Any structure other than a tower that, at the time the relevant application is filed with the city under this section, supports or houses equipment described in paragraphs (i)-(ii) above and has been previously reviewed and approved by the city. 4)"Collocation" means the same as defined in valid regulations promulgated by the FCC, including 47 C.F.R. §§ 1.6002(g) or 1.6100(b), as those sections may be amended from time to time. For the purpose of convenience only, the definition provided in 47 C.F.R. § 1.6100(b), for eligible facilities requests, is stated as follows: the mounting or installation of transmission equipment on an eligible support structure for the purpose of transmitting and/or receiving radio frequency signals for communications purposes. 5)"Eligible Facilities Request" means the same as defined by the FCC at 47 C.F.R. § 1.6100(b), as it may be amended from time to time. For the purpose of convenience only, this definition is stated as follows: any request for modification of an existing tower or base station that, within the meaning of the Spectrum Act, does not substantially change the physical dimensions of that tower or base station, and involves (a) the collocation of new transmission equipment, (b) the removal of transmission equipment, or (c) the replacement of transmission equipment. 6)"Eligible Support Structure" means the same as defined by the FCC at 47 C.F.R. § 1.6100(b), as it may be amended from time to time. For the purpose of convenience only, this definition is stated as follows: any existing tower or base station that exists at the time the application is filed with the city. 7)"Existing" means the same as defined by the FCC at 47 C.F.R. § 1.6100(b), as it may be amended from time to time. For the purpose of convenience only, this definition is stated as follows: a constructed tower or base station is existing for purposes of an eligible facilities request if has been previously reviewed and approved under the applicable city zoning or siting Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 125     4 027120324 process, or under another applicable state or local regulatory review process, provided that a tower that has not been reviewed and approved because it was not in a zoned area when it was built, but was lawfully constructed, is "Existing" for purposes of this definition. 8)"FCC" means the Federal Communications Commission or successor agency. 9)"Project" means a WCF to be located in Palo Alto for which a permit is required by the city. 10)"RF" means radio frequency on the radio spectrum. 11)"Spectrum Act" means Section 6409(a) of the Middle Class Tax Relief Act and Job Creation Act of 2012, 47 U.S.C. § 1455(a) (providing, in part, "… a State or local government may not deny, and shall approve, any Eligible Facilities Request for a modification of any existing wireless Tower or Base Station that does not substantially change the physical dimensions of such Tower or Base Station."). 12)"Small Wireless Facility" means the same as defined in any valid regulations adopted by the FCC. For purposes of convenience only, the definition provided at 47 C.F.R. Section 1.1312(e)(2) is stated here as follows: a facility that meets each of the following conditions: A.The structure on which antenna facilities are mounted: i.Is 50 feet or less in height, or ii.Is no more than 10 percent taller than other adjacent structures, or iii.Is not extended to a height of more than 10 percent above its preexisting height as a result of the collocation of new antenna facilities; and B.Each antenna (excluding associated antenna equipment) is no more than three cubic feet in volume; and C.All antenna equipment associated with the facility (excluding antennas) are cumulatively no more than 28 cubic feet in volume; and D.The facility does not require antenna structure registration under 47 C.F.R. Section 17; and E.The facility is not located on Tribal lands, as defined under 36 C.F.R. § 800.16(x); and F.The facility does not result in human exposure to radiofrequency radiation in excess of the applicable safety standards specified by the FCC. 13)"Substantially Changes" means the same as defined by the FCC at 47 C.F.R. § 1.6100(b), as it may be amended from time to time. For the purpose of convenience only, this definition is stated as follows: in the context of an eligible support structure, a modification of an existing tower or base station where any of the following criteria is met: A. For a tower not located in the public rights-of-way: Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 126     5 027120324 i.The height of the tower is increased by (I) more than ten (10) percent, or (II) by the height of one additional antenna array with separation from the nearest existing antenna not to exceed twenty (20) feet, whichever is greater; or ii. There is added an appurtenance to the body of the tower that would protrude from the edge of the tower by (I) more than twenty (20) feet, or (II) more than the width of the tower at the level of the appurtenance, whichever is greater. B.For a tower located in the public rights-of-way and for all base stations: i.The height of the tower or base station is increased by more than ten (10) percent or ten (10) feet, whichever is greater; or ii. There is added an appurtenance to the body of that structure that would protrude from the edge of that structure by more than six (6) feet; or iii.It involves the installation of ground cabinets that are more than ten (10) percent larger in height or overall volume than any other ground cabinets associated with the structure; or iv. It involves the installation of any new equipment cabinets on the ground if there is no pre-existing ground cabinet associated with that structure. C.For any eligible support structure: i.It involves the installation of more than the standard number of new equipment cabinets for the technology involved, but not to exceed four (4) cabinets; or ii. There is entailed in the proposed modification any excavation or deployment outside of the current site of the tower or base station; or iii.The proposed modification would cause the concealment/camouflage elements of the tower or base station to be defeated; or iv.The proposed modification would not comply with the conditions associated with the prior siting approval of construction or modification of the tower or base station, unless the non-compliance is due to an increase in height, increase in width, addition of cabinets, or new excavation that does not exceed the corresponding thresholds in this section. D.To measure changes in height for the purposes of this section, the baseline is: i. For deployments that are or will be separated horizontally, measured from the original support structure; ii. For all others, measured from the dimensions of the tower or base station, inclusive of originally approved appurtenances and any modifications that were approved by the city prior to February 22, 2012. E.To measure changes for the purposes of this section, the baseline is the dimensions that were approved by the city prior to February 22, 2012. Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 127     6 027120324 14)"Tower" means any structure built for the sole or primary purpose of supporting any FCC-licensed or -authorized antenna, including any structure that is constructed for wireless communications service. This term does not include a base station. 15)"Transmission Equipment" means the same as defined by the FCC at 47 C.F.R. § 1.6100(b), as it may be amended from time to time. For the purpose of convenience only, this definition is stated as follows: equipment that facilitates transmission of any FCC-licensed or authorized wireless communication service. 16)"Wireless Communications Facility" or "WCF" means any antenna, associated equipment, base station, small wireless facility, tower, and/or transmission equipment located in Palo Alto, but does not include: A.A facility that qualifies as an amateur station as defined by the FCC, 47 C.F.R. Part 97, or its successor regulation; B.An antenna facility that is subject to the FCC Over-The-Air-Receiving Devices rule, 47 C.F.R. Section 1.4000, or any successor regulation; C.Portable radios and devices including, but not limited to, hand-held, vehicular, or other portable receivers, transmitters or transceivers, cellular phones, CB radios, emergency services radio; D. Mobile services providing public information coverage of news events of a temporary nature; E.Telecommunications facilities owned and operated by any government agency or emergency medical care provider. c) Types of WCF Permits Required 1)A Tier 1 WCF Permit shall be required for an eligible facilities request, as defined in this section. 2)A Tier 2 WCF Permit shall be required for: A.Any modification of an eligible support structure, including the collocation of new equipment, that substantially changes the physical dimensions of the eligible support structure on which it is mounted; or B.Any collocation of a small wireless facility; or C.Any collocation not eligible for a Tier 1 WCF Permit. 3)A Tier 3 WCF Permit shall be required for the siting of any WCF, including a small wireless facility, that is not a collocation subject to a Tier 1 or 2 WCF Permit. An application shall not require a Tier 3 WCF Permit solely because it proposes the replacement in-place of an existing streetlight or wood utility pole. d) WCF Application Requirements All applications for a WCF Permit shall include the following items: Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 128     7 027120324 1)Any applicant for a WCF Permit shall participate in an intake meeting with the Planning and Community Environment Department when filing an application; 2)The applicant must specify in writing whether the applicant believes the application is for an eligible facilities request subject to the Spectrum Act, and if so, provide a detailed written explanation as to why the applicant believes that the application qualifies as an eligible facilities request; 3)The applicant shall complete the city's standard application form, as may be amended from time to time; 4)The applicant shall include a completed and signed application checklist available from the city, including all information required by the application checklist; 5)Payment of the fee prescribed by the Municipal Fee Schedule; 6)The application must be accompanied by all permit applications with all required application materials for each separate permit required by the city for the proposed WCF, including a building permit, an encroachment permit (if applicable) and an electrical permit (if applicable); 7)For Tier 2 and 3 WCF Permits, the applicant must host a community meeting at a time and location designed to maximize attendance by persons receiving notice under this subparagraph to provide outreach to the neighborhood around the project site. The applicant shall give notice of the community meeting to all residents and property owners within 600 feet of the project site at least 14 days in advance of the community meeting. Applicants are encouraged to host the meeting before submitting an application. Before an application may be approved, the applicant shall provide a proof of notice affidavit to the city that contains: A.Proof that the applicant noticed and hosted the community meeting no later than 15 days after filing the application; B.A summary of comments received at the community meeting and what, if any, changes were made to the application as a result of the meeting; 8)For Tier 3 WCF Permits, the plans shall include a scaled depiction of the maximum increase in the physical dimensions of the proposed project that would be feasible and permitted by the Spectrum Act, using the proposed project as a baseline; and 9)Satisfy other such requirements as may be, from time to time, required by the Planning and Community Environment Department Director ("Director"), as publically stated in the application checklist. e)Permit Review ("Shot Clock") Time Periods. The city shall review and act upon application materials in a manner consistent with any timeframes provided in controlling state or federal law, including valid regulations and orders promulgated by the FCC. f)Tier 1 WCF Permit Process and Findings 1)A Tier 1 WCF Permit shall be reviewed by the Director. The Director's decision shall be final and shall not be appealable; Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 129     8 027120324 2)The Director shall grant a Tier 1 WCF Permit provided that the Director finds that the applicant proposes an eligible facilities request; 3)The Director shall impose the following conditions on the grant of a Tier 1 WCF Permit: A.The proposed collocation or modification shall not defeat any existing concealment elements of the support structure; and B.The conditions of approval in Section 18.42.110(j). g)Tier 2 WCF Permit Process and Findings 1)A Tier 2 WCF Permit shall be reviewed by the Director, who may, in his or her sole discretion, refer an application to the Architectural Review Board. For WCF installations in the public right of way, the Director shall refer applications to the Architectural Review Board for review. The Director's decision shall be appealable directly to the City Council. An appeal may be set for hearing before the City Council or may be placed on the Council's consent calendar, pursuant to the process for appeal of architectural review set forth in Section 18.77.070(f). 2)The Director, or Council on appeal, shall grant a Tier 2 WCF Permit provided the proposed WCF complies with the conditions of approval in Section 18.42.110(j), and all objective standards adopted and amended from time to time by resolution of the City Council or the development standards in Section 18.42.110(i). If such objective standards are repealed, an application shall not be granted unless, in addition to the other requirements of this section, and all of the architectural review findings in Section 18.76.020(d) can be made. 3)The Director, or Council on appeal, shall deny a Tier 2 WCF Permit if the above findings cannot be made. h)Tier 3 WCF Permit Process and Findings 1)A Tier 3 WCF Permit shall be reviewed by the Director, who may, in his or her sole discretion, refer an application to the Architectural Review Board and/or Planning and Transportation Commission. For WCF installations in the public right of way, the Director shall refer applications to the Architectural Review Board for review. The Director's decision shall be appealable directly to the City Council. An appeal may be set for hearing before the City Council or may be placed on the Council's consent calendar, pursuant to the process for appeal of architectural review set forth in Section 18.77.070(f). 2)The Director or Council on appeal shall grant a Tier 3 WCF Permit provided the conditional use permit findings in Section 18.76.010(c) can be made, and the proposed WCF complies with the conditions of approval in Section 18.42.110(j), and all objective standards adopted and amended from time to time by resolution of the City Council or the development standards in Section 18.42.110(i)., and If the City Council repeals all objective standards, an application shall not be granted unless, in addition to the other requirements of this section, all of the architectural review findings in Section 18.76.020(d) can be made. 3)The Director, or Council on appeal, shall deny a Tier 3 WCF Permit if the above findings cannot be made. i)Generally Applicable Development Standards Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 130     9 027120324 Unless the City Council has adopted more specific standards, and except as otherwise provided in this section, a proposed WCF Project shall comply with the following standards: 1)Shall utilize the smallest antennae, radio, and associated equipment, as measured by volume, technically feasible to achieve a network objective; 2)Shall be screened from public view; 3)When attached to an existing structure, shall be shrouded or screened using materials or colors found on existing structure; 4)Shall be placed at a location that would not require the removal of any required landscaping or would reduce the quantity of landscaping to a level of noncompliance with the Zoning Code; 5)An antenna, base station, or tower shall be of a "camouflaged" or "stealth" design, including concealment, screening, and other techniques to hide or blend the antenna, base station, or tower into the surrounding area, such as the use of a monopine design; 6)Shall not be attached on a historic structure/site, as designated by Chapter 16.49; 7)Except as otherwise permitted by the Spectrum Act, a building-mounted WCF may extend no more than fifteen (15) feet beyond the permitted height of the building in the zone district; 8)Except as otherwise permitted by the Spectrum Act, a tower or other stand-alone Tier 3 WCF Project shall not exceed beyond sixty-five (65) feet in height; and 9)A tower or other stand-alone Tier 3 WCF may encroach into the interior/street side and rear setback. j)Conditions of Approval In addition to any other conditions of approval permitted under federal and state law and this Code that the Director deems appropriate or required under this Code, all WCF Projects approved under this chapter, whether approved by the Director, City Council, or deemed granted by operation of law, shall be subject to the following conditions of approval: 1)Permit conditions. The grant or approval of a WCF Tier 1 Permit shall be subject to the conditions of approval of the underlying permit, except as may be preempted by the Spectrum Act. 2)As-built plans. The applicant shall submit to the Director an as-built set of plans and photographs depicting the entire WCF as modified, including all transmission equipment and all utilities, within ninety (90) days after the completion of construction. 3)Applicant shall hire a radio engineer licensed by the State of California to measure the actual radio frequency emission of the WCF and determine if it meets FCC's standards. A report, certified by the engineer, of all calculations, required measurements, and the engineer's findings with respect to compliance with the FCC's radio frequency emission standards shall be submitted to the Planning Division within one year of commencement of operation. Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 131     10 027120324 4)Indemnification. 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 for its actual attorneys' fees and costs incurred in defense of the litigation. The city may, in its sole discretion and at Applicant's expense, elect to defend any such action with attorneys of its own choice. 5)Compliance with applicable laws. The applicant shall comply with all applicable provisions of the Code, any permit issued under this Code, and all other applicable federal, state and local laws (including without limitation all building code, electrical code and other public safety requirements). Any failure by the City to enforce compliance with any applicable laws shall not relieve any applicant of its obligations under this code, any permit issued under this code, or all other applicable laws and regulations. 6)Compliance with approved plans. The proposed Project shall be built in compliance with the approved plans on file with the Planning Division. 7)Subject to city uses. Any permit to install or utilize poles or conduit in the public rights- of-way is subject to the city’s prior right to use, maintain, expand, replace or remove from use such facilities in the reasonable exercise of its governmental or proprietary powers. Such permit is further subject to the city’s right to construction, maintain, and modify streets, sidewalks, and other improvements in the public rights-of-way. The city, in its sole discretion, may require removal or relocation of a permittee’s equipment, at permittee’s sole cost and expense, if necessary to accommodate a city use. 8)Replacement. Where feasible, as new technology becomes available, the applicant shall place above-ground equipment below ground and replace equipment remaining above-ground with smaller equipment, as determined by volume. The applicant shall obtain all necessary permits and approvals for such replacement. 9)Permit length. WCFs permits shall be valid for the time provided in Section 18.42.110(n), except that a permit shall automatically expire after twelve months from the date of approval if within such twelve month period, the applicant has not obtained all necessary permits to commence construction. The director may, without a hearing, extend such time for a maximum period of twelve additional months only, upon application filed with him or her before the expiration of the twelve-month limit. k) Exceptions 1)The decision-making authority may grant exceptions to objective standards adopted by City Council resolution or any provision of this Section 18.42.110, upon finding that: A.The proposed WCF complies with the requirements of this Section 18.42.110 and any other requirements adopted by the City Council to the greatest extent feasible; and either B.As applied to a proposed WCF, the provision(s) from which exception is sought would deprive the applicant of rights guaranteed by federal law, state law, or both; or Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 132     11 027120324 C.Denial of the application as proposed would violate federal law, state law, or both. 2)An applicant must request an exception at the time an application is initially submitted for a WCF permit under this Section 18.42.110. The request must include both the specific provision(s) from which exception is sought and the basis of the request, including all supporting evidence on which the applicant relies. Any request for exception after the City has deemed an application complete constitutes a material change to the proposed WCF and shall be considered a new application. 3)If the applicant seeks an exception from objective standards adopted by City Council resolution or generally applicable development standards, the Director may refer the application to the Architectural Review Board for recommendation on whether the application complies with such standards to the greatest extent feasible. 43)The applicant shall have the burden of proving that federal law, state law, or both compel the decision-making authority to grant the requested exception(s), using the evidentiary standards applicable to the law at issue. The Ccity shall have the right to hire independent consultants, at the applicant’s expense, to evaluate the issues raised by the exception request and to submit rebuttal evidence where applicable. l)Removal of Abandoned Equipment A WCF (Tier 1, Tier 2, or Tier 3) or a component of that WCF that ceases to be in use for more than ninety (90) days shall be removed by the applicant, wireless communications service provider, or property owner within ninety (90) days of the cessation of use of that WCF. A new WCF permit shall not be issued to an owner or operator of a WCF or a wireless communications service provider until the abandoned WCF or its component is removed. m)Revocation The Director may revoke any WCF Permit if the permit holder fails to comply with any condition of the permit. The Director's decision to revoke a Permit shall be appealable pursuant to the process applicable to issuance of the Permit, as provided in subdivisions (f), (g), and (h) of this section. n)Expiration Except as otherwise provided in the permit or in a lease or license agreement with the City of Palo Alto, WCF permits shall be valid for a period of ten years from the date of approval. An applicant may seek extensions of an approved WCF permit in increments of no more than ten years and no sooner than twelve months prior to the expiration of the permit. The Director shall approve an extension request upon finding that that applicant has complied with all conditions of approval for the WCF permit and will comply with all other requirements applicable to WCFs at the time the extension is granted. Prior to issuing a decision on an extension request, the Director may seek additional studies and information to be prepared at the applicant’s expense. Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 133     12 027120324 SECTION 4. Severability. If any provision, clause, sentence or paragraph of this ordinance, or the application to any person or circumstances, shall be held invalid, such invalidity shall not affect the other provisions of this Ordinance which can be given effect without the invalid provision or application and, to this end, the provisions of this Ordinance are hereby declared to be severable. SECTION 5. Effective Date. This Ordinance shall be effective on the thirty-first date after the date of its adoption. SECTION 6. This ordinance shall be of no further force or effect as of June 10, 2027, or unless repealed earlier by the Council. SECTION 7. CEQA. The City Council finds and determines that this Ordinance is not a project within the meaning of section 15378 of the California Environmental Quality Act CEQA”) Guidelines because it has no potential for resulting in physical change in the environment, either directly or ultimately. In the event that this Ordinance is found to be a project under CEQA, it is subject to the CEQA exemption contained in CEQA Guidelines section 15061(b)(3) because it can be seen with certainty to have no possibility of a significant effect on the environment in that this Ordinance simply clarifies existing local regulations. INTRODUCED: MAY 19, 2025 PASSED: JUNE 9, 2025 AYES: BURT, LAUING, LU, LYTHCOTT-HAIMS, RECKDAHL, STONE, VEENKER NOES: ABSTENTIONS: ABSENT: ATTEST: APPROVED: City Clerk Mayor APPROVED AS TO FORM: City Manager City Attorney or designee Director of Planning and Community Environment Docusign Envelope ID: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Item 4 Attachment H - Ordinance 5655     Packet Pg. 134     Certificate Of Completion Envelope Id: 8DE517EC-EF9A-4596-B46B-F576F16C8176 Status: Completed Subject: ORD 5655 - Wireless Communications Facilities Source Envelope: Document Pages: 12 Signatures: 5 Envelope Originator: Certificate Pages: 2 Initials: 0 Christine Prior AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) PacificTime (US & Canada) 250 Hamilton Ave Palo Alto , CA 94301 Christine.Prior@PaloAlto.gov IP Address: 165.225.242.87 Record Tracking Status: Original 6/12/2025 7:36:30 AM Holder: Christine Prior Christine.Prior@PaloAlto.gov Location: DocuSign Security Appliance Status: Connected Pool: StateLocal Storage Appliance Status: Connected Pool: City of Palo Alto Location: Docusign Signer Events Signature Timestamp Aylin Bilir Aylin.Bilir@paloalto.gov Security Level: Email, Account Authentication None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 6/12/2025 7:39:45 AM Viewed: 6/12/2025 9:35:48 AM Signed: 6/12/2025 9:40:52 AM Electronic Record and Signature Disclosure: Not Offered via Docusign Jonathan Lait Jonathan.Lait@paloalto.gov Director, Planning and Development Services City of Palo Alto Security Level: Email, Account Authentication None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 6/12/2025 9:40:54 AM Viewed: 6/12/2025 9:47:47 AM Signed: 6/12/2025 9:48:13 AM Electronic Record and Signature Disclosure: Not Offered via Docusign Ed Shikada Ed.Shikada@paloalto.gov Ed Shikada City of Palo Alto Security Level: Email, Account Authentication None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 6/12/2025 9:48:14 AM Viewed: 6/12/2025 11:51:32 AM Signed: 6/12/2025 11:51:40 AM Electronic Record and Signature Disclosure: Not Offered via Docusign Ed Lauing Ed.Lauing@paloalto.gov Security Level: Email, Account Authentication None) Signature Adoption: Pre-selected Style Using IP Address: 67.188.59.65 Sent: 6/12/2025 11:51:42 AM Viewed: 6/12/2025 2:04:42 PM Signed: 6/12/2025 2:05:15 PM Electronic Record and Signature Disclosure: Not Offered via Docusign Item 4 Attachment H - Ordinance 5655     Packet Pg. 135     Signer Events Signature Timestamp Mahealani Ah Yun Mahealani.AhYun@paloalto.gov Security Level: Email, Account Authentication None) Signature Adoption: Pre-selected Style Using IP Address: 199.33.32.254 Sent: 6/12/2025 2:05:17 PM Viewed: 6/13/2025 1:34:14 PM Signed: 6/13/2025 1:34:28 PM Electronic Record and Signature Disclosure: Not Offered via Docusign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 6/12/2025 7:39:45 AM Certified Delivered Security Checked 6/13/2025 1:34:14 PM Signing Complete Security Checked 6/13/2025 1:34:28 PM Completed Security Checked 6/13/2025 1:34:28 PM Payment Events Status Timestamps Item 4 Attachment H - Ordinance 5655     Packet Pg. 136     1 Small Cell Noise Assessment Letter Prepared for: AT&T and Modus Site Name: CRAN_RSFR_PALO2_054 FA Number: 16140524 EBI Project Number: 027908 -PR Address: (Near) 1661 Page Mill Road Palo Alto, California September 5, 2024 1. Site Description: Site 16140524 / CRAN_RSFR_PALO2_054 involves the installation of one (1) antenna and three (3) remote radio units (RRUs) mounted on a pole, located near 1661 Page Mill Road in Palo Alto, California, Santa Clara County. 2. Purpose: This letter provides calculated sound pressure levels from the proposed equipment when measured at the nearest property line from the proposed noise sources. Calculations were performed using site drawings dated August, 16 2024, information provided by Modus, and data from the equipment manufacturer, per the calculation methodology shown in Appendix A. Subsequent changes to the site design may yield changes in the projected post construction noise levels or compliance with applicable regulations and guidelines. 3. Regulatory Setting Palo Alto: Municipal Code Chapter 6.16 - Noise Control The City of Palo Alto Municipal Code 18.42.190 Noise and Vibration requirements for Wireless Communication Facilities states: 1. All projects must comply with Chapter 9.10 of the Palo Alto Municipal Code (the Noise Ordinance). 2. All projects that are predicted to result in sounds levels that are within 5dB or less of the applicable Noise Ordinance Limit shall require demonstration of the installed equipment and certification of compliance with the Noise Ordinance prior to final building inspection approval. As outlined in Section 9.10.30 the exterior noise limit for residential uses cannot exceed six (6) dB over the existing ambient. Section 9.10.40 states the exterior noise limit for commercial uses cannot exceed eight (8) dB over the existing ambient condition. The exterior “local ambient” is assumed to be 40 dBA, per 19.10.020 (d). Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 137     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 2 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com 4. Relevant Proposed Equipment The proposed site design includes a proposed Small Cell Wireless Facility in an existing right of way. Manufacturer specifications were reviewed for each of these units to assess the noise properties of each unit. Noise properties of the proposed equipment are described in Table 1. The site design does not include installation of emergency back-up generators, equipment cabinets or other noise-generating equipment typically associated with traditional wireless telecommunications sites. The proposed installations will not utilize any external alarms. The following Equipment is proposed for installation at this site: Table 1 – Proposed Equipment Quantity Description Manufacturer Model Number Sound Pressure Level (dBA) @ 1 meter 1 Antenna Galtronics GP2414-06844 none 1 RRU (passive cooling) Ericsson 4490 26 1 RRU (passive cooling) Ericsson 4890 26 1 RRU (passive cooling) Ericsson 4467 26 Manufacturer acoustic data specifies a sound pressure or power level per each unit. See Appendix B. Available specifications and product information were reviewed for the equipment listed in Table 1. Exclusions include measured ambient noise, existing equipment, fencing, walls, landscaping, topography, and property line setbacks. Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 138     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 3 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com 5. Calculated Sound Levels. Sound level propagation calculations were performed to determine the sound pressure level of the proposed equipment when measured at the distances referenced below. Equipment was assumed to be operating continuously 24-hours per day to simulate worst-case conditions. The sources and receiver were assumed to be at the same reference height to account for balconies, open windows and changes in elevation at adjacent properties. All calculations shown in Table 2 assume a free-field environment with no ground absorption, reflecting surfaces, barriers, or other obstructions. Actual results may vary due to field and environmental conditions. Table 2 – Calculated Sound Pressure Level Equipment Sound Power from Table 1 (combined) 41.76 dB Distance to Nearest Property Line is greater than 50 feet Proposed Equipment Sound Level Contribution at Nearest Property Line 7.11 dBA Lowest Applicable Noise Limit (ambient + 6dB) 46 dBA Presumed Ambient 40 dBA Total Predicted Sound Level at Nearest Residential Property Line (Ambient + Proposed Equipment) 40 dBA Change in Ambient +/- 0 6. Statement of Compliance Based on the results of this analysis, and as presented in Table 2, EBI concludes that the noise produced from operation of the proposed equipment will comply with the noise limits set forth in the City of Palo Alto Municipal Code Sections18.42.190 and 9.10.30. 7. Limitations This report was prepared for the use of Modus and AT&T. It was performed in accordance with generally accepted practices of other consultants undertaking similar studies at the same time and in the same locale under like circumstances. The conclusions provided by EBI are based solely on the information provided by the client. The observations in this report are valid on the date of the investigation. Calculations contained in this report should be considered accurate to within one decibel. Any additional information that becomes available concerning the site should be provided to EBI so that our conclusions may be revised and modified, if necessary. This report has been prepared in accordance with Standard Conditions for Engagement and authorized proposal, both of which are integral parts of this report. No other warranty, expressed or implied, is made. Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 139     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 4 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Appendix A Calculation Methodology Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 140     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 5 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com NOISE CALCULATION METHODOLOGY All sounds originate from a source. The sound energy, produced by a source, creates variations in air pressure which travel in all directions much like a wave ripples across the water. The “loudness” or intensity of a sound is a function of the sound pressure level, defined as the ratio of two pressures: the measured sound pressure from the source divided by a reference pressure (i.e., threshold of human hearing). Sound level measurements are most commonly expressed using the decibel (dB) scale. The decibel scale is logarithmic to accommodate the wide range of sound intensities to which the human ear is capable of responding. On this scale, the threshold of human hearing is equal to 0 dB, while levels above 140 dB can cause immediate hearing damage. One property of the decibel scale is that the combined sound pressure level of separate sound sources is not simply the sum of the contributing sources. For example, if the sound of one source of 70 dB is added to another source of 70 dB, the total is only 73 dB, not a doubling to 140 dB. In terms of human perception of sound, a 3 dB difference is the minimum perceptible change for broadband sounds (i.e., sounds that include all frequencies). A difference of 10 dB represents a perceived halving or doubling of loudness. Environmental sound is commonly expressed in terms of the A-weighted sound level (dBA). The A- weighting is a standard filter to make measured sound levels more nearly approximate the frequency response of the human ear. Table 1 and Figure 1 show the adjustments made at each octave band frequency to contour un-weighted sound levels (dB) to A-weighted sound levels (dBA). This frequency response is defined in the American National Standards Institute Standard No. 5.1 and most other relevant standards related to measurement of noise levels. Table 1 A-Weighted Octave Band Adjustment (+/- dB) Octave Band Center Frequency (Hz) 32 64 125 250 500 1000 2000 4000 8000 16000 A-weighting Adjustment (±dB) -39.4 -26.2 -16.1 -8.6 -3.6 0.0 +1.2 +1.0 -1.1 -6.6 FIGURE 1 - WEIGHTED OCTAVE BAND ADJUSTMENTS (±dB) Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 141     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 6 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Environmental sound varies depending on environmental conditions. Some sounds are sharp impulses lasting for short periods, while others rise and fall over longer periods. There are various measures (metrics) of sound pressure designed for different purposes. The Leq, or equivalent sound level, is the steady-state sound level over a period of time that has the same acoustic energy as the fluctuating sound that was measured over the same period. The Leq is commonly referred to as the average sound level and is calculated automatically by the sound level meter using methods defined in ANSI S1.4-19831. Manufacturer-provided data for noise-generating equipment typically includes a measured sound pressure level (Lp), expressed in A-weighted decibels, taken at a specific distance from the equipment, known as a reference distance. For the purposes of this report, L1 refers to the measured sound level, and r1 refers to the reference distance from the source. Sound varies inversely as the square of the distance from the source increases. This property of sound propagation is used to determine the sound levels at various distances from the source when L1 and r1 have been provided. In an unobstructed free-field environment, without any barriers or reflecting surfaces, sounds pressure drops by 6 dBA with each doubling of distance. This relationship is expressed in the following equation: 𝐿𝐿2 =𝐿𝐿1 −|20 ∗log �𝑟𝑟1𝑟𝑟2�| Where r2 refers to the distance at distance 2 and L2 refers to the sound level in dBA at distance 2. When multiple sound sources are combined, the LP values for each source must first be converted to sound power (LW). 𝐿𝐿𝑊𝑊=𝐿𝐿𝑃𝑃+|10 ∗log �𝑄𝑄4𝜋𝜋∗𝑟𝑟2�| In this report, EBI has assumed Q (directionality) is equal to 1 to represent full-sphere propagation. The resultant LW values are then added together, using logarithmic decibel addition, where 𝐿𝐿∑refers to the total level, and L1, L2, etc. refer to the sound power of different individual sources. 𝐿𝐿∑=10 ∗ 𝑙𝑙𝑙𝑙𝑙𝑙10 �10𝐿𝐿110 +10𝐿𝐿210 +⋯10𝐿𝐿𝑛𝑛10�𝑑𝑑𝑑𝑑 1 American National Standards Institute, ANSI S1-4-1983, American National Standard Specification for Sound Level Meters, 1983 Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 142     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 7 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Appendix B Excerpts from Equipment Specifications Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 143     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 8 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 144     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 9 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 145     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 10 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 146     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 11 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com Appendix C Certification Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 147     Small Cell Noise Assessment Letter Site: CRAN_RSFR_PALO2_054 / 16140524 EBI Project No. 027908 -PR 1661 Page Mill Road, Palo Alto, California 12 T: (781) 273-2500 E: info@ebiconsulting.com W: ebiconsulting.com CERTIFICATION This report has been reviewed and approved by: Michael McGuire PE Professional Electrical Engineer California License# E18898 mike@h2dc.com Note that EBI’s scope of work is limited to an evaluation of the Sound Properties of the equipment noted in this report. The engineering and design of the building and related structures, as well as the impact of the antennas and broadcast equipment on the structural integrity of the building, are specifically excluded from EBI’s scope of work. sealed 06sep2024 Item 4 Attachment I - Noise Assessment Letter     Packet Pg. 148     If you need assistance reviewing the above documents, please contact the Project Planner or call the Planner-on-Duty at 650-617-3117 or email planner@cityofpaloalto.org Project Plans In order to reduce paper consumption, a limited number of hard copy project plans are provided to Board members for their review. The same plans are available to the public, at all hours of the day, via the following online resources. Directions to review Project plans and environmental documents online: 1. Go to: bit.ly/PApendingprojects 2. Scroll down to find “250 Hamilton Avenue” and click the address link 3. On this project-specific webpage you will find a link to the project plans and other important information Direct Link to Project Webpage: Tier 2 Wireless Communications Facility (WCF) in Public Right-of-Way – City of Palo Alto, CA Materials Boards: A digital color and materials board is included in the project plans. Item 4 Attachment J - Project Plans     Packet Pg. 149