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HomeMy WebLinkAbout2025-10-16 Architectural Review Board Agenda PacketARCHITECTURAL REVIEW BOARD Regular Meeting Thursday, October 16, 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  AGENDA CHANGES, ADDITIONS AND DELETIONS The Chair or Board majority may modify the agenda order to improve meeting management.   PUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker.   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.PUBLIC HEARING / QUASI-JUDICIAL. 2100-2400 Geng Road [24PLN-00356]: Consideration of a Site and Design and Conditional Use Permit Application to Demolish Four Existing Commercial Buildings and Construct 65 Three-Story Buildings Containing 145 For Sale Townhome Units. Thirteen Percent of the Units (19 Units) Would Be Deed Restricted to Serve Tenants Meeting 60% of Area Median Income or Below. The Project is Proposed in Accordance with California Government Code Section 65589.5(d) (5) “Builders Remedy." A Senate Bill 330 Pre-Application was Filed on July 8, 2024. CEQA Status: Initial Study is being prepared. Zoning District: ROLM (E)(D)(AD) -Research, Office and Limited Manufacturing (Embarcadero) (Site & Design) (Automobile Dealership) Combining District. ACTION ITEMS Public Comment is Permitted. Applicants/Appellant Teams: Ten (10) minutes, plus ten (10) minutes rebuttal. All others: Three (3) minutes per speaker. 3.PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [24PLN-00278] (Continued from September 18): Request by AT&T for Review of a Tier 2 Wireless Communication Facility Permit Application for a Small Wireless Facility with Modifications to the 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). APPROVAL OF MINUTES Public Comment is Permitted. Three (3) minutes per speaker. 4.Draft Architectural Review Board Meeting Minutes for September 4, 2025 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: October 16, 2025 Report #: 2510-5299 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 November 6, 2025 No items to report RECENTLY SUBMITTED PROJECTS No new ARB projects were submitted since the last ARB meeting. ATTACHMENTS Attachment A: 2025 Meeting Schedule & Assignments Attachment B: 2026 Tentative Meeting Schedule & Assignments Attachment C: Pending ARB Projects AUTHOR/TITLE: ARB Liaison1 & Contact Information   Steven Switzer, Senior Historic Planner   (650) 329-2321   Steven.Switzer@PaloAlto.gov 1 Emails can be sent directly to the ARB at the following email: 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 Rosenberg 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     DRAFT Architectural Review Board 2026 Meeting Schedule & Assignments 8 4 9 3 Tentative 2026 Meeting Schedule Meeting Dates Time Location Status Planned Absences 1/1/2026 8:30 AM Hybrid Cancelled 1/15/2026 8:30 AM Hybrid Regular 2/5/2026 8:30 AM Hybrid Regular 2/19/2026 8:30 AM Hybrid Regular 3/5/2026 8:30 AM Hybrid Regular 3/19/2026 8:30 AM Hybrid Regular 4/2/2026 8:30 AM Hybrid Regular 4/16/2026 8:30 AM Hybrid Regular 5/7/2026 8:30 AM Hybrid Regular 5/21/2026 8:30 AM Hybrid Regular 6/4/2026 8:30 AM Hybrid Regular 6/18/2026 8:30 AM Hybrid Regular 7/2/2026 8:30 AM Hybrid Regular 7/16/2026 8:30 AM Hybrid Regular 8/6/2026 8:30 AM Hybrid Regular 8/20/2026 8:30 AM Hybrid Regular 9/3/2026 8:30 AM Hybrid Regular 9/17/2026 8:30 AM Hybrid Regular 10/1/2026 8:30 AM Hybrid Regular 10/15/2026 8:30 AM Hybrid Regular 11/5/2026 8:30 AM Hybrid Regular 11/19/2026 8:30 AM Hybrid Regular 12/3/2026 8:30 AM Hybrid Regular 12/17/2026 8:30 AM Hybrid Regular 2026 Ad Hoc Committee Assignments Assignments will be made by the ARB Chair January February March April May June July August September October November December Item 1 Attachment B - 2026 Tentative Meeting Schedule & Assignments     Packet Pg. 8     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 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 Item 1 Attachment C - Pending ARB Projects     Packet Pg. 9     Permit Type Filed Permit #Address Type Work Description Status/Notes 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 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) 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 submitted 11/21/24 Ad Hoc (Baltay, Adcock) Deemed Complete 12/22/24 Supplementary info req. ARB 10/2 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. Item 1 Attachment C - Pending ARB Projects     Packet Pg. 10     Permit Type Filed Permit #Address Type Work Description Status/Notes 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 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) NOI Sent 8/16/2024 and 9/12/2024; Pending Resubmittal. 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). NOI sent 1/09/25 Resubmittal 3/27/25 ARB 5/15 rec. to continue ARB 10/2 Item 1 Attachment C - Pending ARB Projects     Packet Pg. 11     Permit Type Filed Permit #Address Type Work Description Status/Notes 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 ARB 8/21 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 ARB 10/16 Planned Home Rezoning 9/10/25 25PLN-00225 808 San Antonio Housing 175 units Rezoning to Planned Community/Planned Home Zoning to allow the merging of lots 800 and 808 San Antonio Road, to form an 0.88-acre site. The Project will be a 175-unit residential building with 26 BMR units. The project will include 2,294 square feet of commercial space at the ground floor. The building is designed as an 8-story building with two levels of subterranean construction. The project also includes an interior courtyard, exterior courtyard, and roof deck. Item 1 Attachment C - Pending ARB Projects     Packet Pg. 12     Item No. 2. Page 1 of 10 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 16, 2025 Report #: 2509-5222 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 2100-2400 Geng Road [24PLN-00356]: Consideration of a Site and Design and Conditional Use Permit Application to Demolish Four Existing Commercial Buildings and Construct 65 Three-Story Buildings Containing 145 For Sale Townhome Units. Thirteen Percent of the Units (19 Units) Would Be Deed Restricted to Serve Tenants Meeting 60% of Area Median Income or Below. The Project is Proposed in Accordance with California Government Code Section 65589.5(d)(5) “Builders Remedy." A Senate Bill 330 Pre- Application was Filed on July 8, 2024. CEQA Status: Initial Study is being prepared. Zoning District: ROLM (E)(D)(AD) -Research, Office and Limited Manufacturing (Embarcadero) (Site & Design) (Automobile Dealership) Combining District. RECOMMENDATION Staff recommends the Architectural Review Board (ARB) review and provide initial comments. EXECUTIVE SUMMARY The application proposes an exclusively residential project including 145 for sale townhome units with thirteen percent of the units (19 units) deed restricted to serve tenants meeting 60% of area median income or below. The project would be located on two contiguous parcels located at 2100-2400 Geng Road. A separate Vesting Tentative Map is also requested to merge the parcels and for a condominium subdivision. The project would replace four existing office buildings that currently are on the project site. The applicant filed a compliant pre-application in accordance with Senate Bill (SB) 330 on July 8, 2024 (24PLN-00181). Therefore, the project analysis is based on the applicable standards at the time the compliant SB 330 pre-application was submitted. In addition, the project is considered a “builder’s remedy project” as defined in the recently adopted Assembly Bill (AB) 1893. Accordingly, the project may not be denied on the basis of inconsistency with the Zoning Ordinance or Comprehensive Plan land use designation. The project is further afforded numerous protections detailed below. Item 2 Item 2 Staff Report     Packet Pg. 13     Item No. 2. Page 2 of 10 Consistent with Section 15183 of the CEQA Guidelines, the City is currently preparing an Initial Study checklist to determine consistency with the Certified Environmental Impact Report for the 2030 Comprehensive Plan (SCH #2014052101) and identify potential significant environmental impacts that are specific to this project. BACKGROUND Project Information Owner:San Francisco No. 69 LLC Architect:Dahlin Group Representative:Strada Investment Group Property Information Address:2100-2400 Geng Road Neighborhood:Baylands Lot Dimensions & Area:APN 008-02-035: Approximately 748 feet wide, 300 feet deep, 239,800 square feet APN 08-02-036: Approximately 1178 feet wide, 500 feet deep, 240,430 square feet Total: 480,230 square feet (~11 acres) Housing Inventory Site:Yes (APN 008-02-035) 175 Units Located w/in a Plume:No Protected/Heritage Trees:Yes Historic Resource(s):No Existing Improvement(s):Four two-story office buildings totaling 192,000 square feet built in 1984 Existing Land Use(s):General Office Adjacent Land Uses & Zoning: North: Public Facility (PF), Baylands Park West: Public Facility (PF), Post Office, & ROLM (E)(D)(AD), Offices East: ROLM (E)(D)(AD), Offices South: ROLM (E)(D)(AD), Offices Item 2 Item 2 Staff Report     Packet Pg. 14     Item No. 2. Page 3 of 10 Aerial View of Property: Source: Google Satellite Maps Land Use Designation & Applicable Plans Comp. Plan Designation:Research/Office Park (RO) Zoning Designation:Research, Office and Limited Manufacturing (Embarcadero) (Site & Design) (Automobile Dealership) Combining District [ROLM (E)(D)(AD)] Yes Yes Yes Baylands Master Plan/Guidelines (2008/2005) El Camino Real Guidelines (1976) Housing Development Project Downtown Urban Design Guidelines (1993) South El Camino Real Guidelines (2002) Utilizes Chapter 18.24 - Objective Standards Individual Review Guidelines (2005) Within 150 feet of Residential Use or District Context-Based Design Criteria applicable SOFA Phase 1 (2000)Within Airport Influence Area Annual Office Limit SOFA Phase 2 (2003)Housing Incentive Program Item 2 Item 2 Staff Report     Packet Pg. 15     Item No. 2. Page 4 of 10 Project Description: The proposed project is a request for a Site and Design Permit and Conditional Use Permit for development of 65 three-story buildings containing 145 for sale townhome units. Thirteen percent of the units (19 units) would be deed restricted to serve owners meeting 60% of area median income or below. The project would replace the four existing office buildings currently located on the project site. A vesting tentative map is also requested for condominium purposes. The project site has frontage on Geng Road and an easement connecting to East Bayshore Road. Driveways are proposed at both locations, each providing ingress and egress to the site. Associated site improvements include rooftop amenity spaces, landscaping, and substantial utility improvements. The applicant submitted a SB 330 pre-application on July 8, 2024 (24PLN-00181). Therefore, the project analysis is based on the applicable standards at the time the compliant SB 330 preapplication was submitted. The project is also being proposed in accordance with California Government Code Section 65589.5(d)(5) (also known as Builder’s Remedy) and qualifies for additional protections as a “builder’s remedy project,” under AB 1893. The applicant’s project description is provided in Attachment C. Attachment C includes a list of requested waivers requested in accordance with State Density Bonus Law. As detailed further in this report, if the project is designed to comply with all relevant objective standards, after application of density bonus incentives, concessions, and waivers, the City cannot impose conditions that would preclude construction of the project as proposed. Requested Entitlements, Findings, and Purview: The following discretionary applications are being requested and are subject to the ARB’s purview: Site and Design Permit: The process for evaluating this type of application is set forth in PAMC 18.30(G). Site and design is intended to provide a review process for development in environmentally and ecologically sensitive areas, including established community areas which may be sensitive to negative aesthetic factors, excessive noise, increased traffic or other disruptions, in order to assure that use and development will be harmonious with other uses in the general vicinity, will be compatible with environmental and ecological objectives, and will be in accord with the Palo Alto Comprehensive Plan. If recommended for approval, the project requires review before the Architectural Review Board before the project is forwarded to the City Council for final action of all requested entitlements. Site and design applications are evaluated to specific findings. All findings must be made in the affirmative to approve the project. The following discretionary applications are being requested and are subject to the PTC and/or Council’s purview: Conditional Use Permit: The process for evaluating this type of application is set forth in PAMC Section 18.77.060. CUP applications are reviewed by staff and the Director will prepare a written decision to approve, approve with conditions, or deny the application Item 2 Item 2 Staff Report     Packet Pg. 16     Item No. 2. Page 5 of 10 based on the Findings set in PAMC Section 18.76.010(c). Applications would be forwarded to the Planning & Transportation Commission (PTC) for a recommendation and then to the City Council for a final decision. Vesting Tentative Map: The process for evaluating this type of application is set forth in Title 21 of the Palo Alto Municipal Code (PAMC) and California Government Code 66474. The process for approval of a Vesting Tentative Map for a condominium subdivision is outlined in PAMC Sections 21.12.010 and 21.13.020. Vesting Tentative maps require PTC review. The PTC reviews whether the amended subdivision is consistent with the Subdivision Map Act (in particular, Government Code 66474), Title 21 of the Palo Alto Municipal Code, the Palo Alto Comprehensive Plan, and other applicable provisions of the Palo Alto Municipal Code and State Law. The PTC’s recommendation is forwarded to the City Council for final approval. In accordance with Title 21 of the Palo Alto Municipal Code, all entitlements are required to be completed prior to approval of the Vesting Tentative Map. In compliance with this requirement, the applicant’s request for Streamlined Housing Development Review was tentatively approved on March 19, 2024. The ARB’s purview of the formal application is limited by the following State law in the following ways: Housing Accountability Act (Government Code 65589.5): The project constitutes a “housing development project,” as well as “housing for very low, low-, or moderate income households” under the Housing Accountability Act. The Housing Accountability Act Section 65589.5(d) states that a city cannot deny such a project or impose conditions of approval that would render it infeasible unless it makes specified findings. Among those findings are: (1) that the project would have a specific, adverse impact upon the public health or safety that cannot be mitigated. Because the project is a “builder’s remedy project,” as defined in AB 1893, the City is further limited to only enforcing those objective standards that exist in a zone district or land use designation that allows the density requested. If there are no such zoning districts or general plan designations in the City, then the applicant may identify any City standards that facilitate the project and only those standards shall apply. If the project meets these identified standards, the City cannot impose conditions of approval that preclude the project from being constructed as proposed by the applicant. Because the project is a “builder’s remedy project,” as defined in AB 1893, the “base density” for purposes of State Density Bonus Law shall be the maximum density permitted for builder’s remedy projects (e.g. three times the density permitted in the zoning code or general plan). The project applicant is also able to utilize incentives, concessions, and waivers under State Density Bonus Law when demonstrating compliance with the enforceable standards. ANALYSIS The City is still evaluating the proposed project in accordance with all of the City’s goals, policies, and regulations across its departments in addition to evaluating the project in Item 2 Item 2 Staff Report     Packet Pg. 17     Item No. 2. Page 6 of 10 conformance with CEQA. Staff will provide a complete review of the project’s consistency with all applicable goals and policies as part of the next report once all review and the environmental analysis are complete. However, to facilitate input on the project design, preliminary conclusions of the project’s consistency with applicable plans, goals, and policies are provided in this report. Neighborhood Setting and Character The project site is located on the eastern side of Highway 101 adjacent to the Baylands Nature Preserve. The Baylands is an approximately 1,976-acre open space located along the edge of San Francisco Bay (Bay) including multiple habitats and a wide variety of recreational and educational benefits. Approximately 90 acres of industrial research, office, and commercial uses are concentrated along Embarcadero Road and East Bayshore frontage road. In the surrounding vicinity of the project site, there is a Post Office, International School of the Peninsula, two automobile agencies, and office uses. To the north of the project site is the Baylands Athletic Center that offers a softball/baseball lighted fields on a 6-acre facility. Adjacent uses to the south, east, and west are office buildings. Consistency with the Comprehensive Plan, Area Plans, and Guidelines1 The Comprehensive Plan land use designation for the project site is Research/Office Park, which states: "Office, research and manufacturing establishments whose operations are buffered from adjacent residential uses… in some locations, residential and mixed-use projects may also locate in this category. Maximum allowable FAR ranges from 0.3 to 0.5, depending on site conditions. Consistent with the Comprehensive Plan, multifamily housing may be allowed in specific locations.” Because a portion of the site is identified as a Housing Inventory site in accordance with the City’s adopted Housing Element, the proposed land use is consistent with the Comprehensive Plan though it exceeds the floor area allowance set forth for this land use designation. A detailed review of the project’s consistency with relevant goals and policies set forth in the Comprehensive Plan will be completed prior to a formal recommendation. However, staff notes that the proposed application was filed in accordance with the Builder’s Remedy provision in the Housing Accountability Act. This provision applies to jurisdictions where a compliant Housing Element has not been adopted by the jurisdiction and certified by the Department of Housing and Community Development (HCD). Although the City has an adopted and certified Housing Element as of August 2024, the compliant SB 330 pre-application was filed on January 9, 2024, and therefore froze development standards in effect at the time of submittal. Therefore, a project cannot be denied for inconsistency with the Comprehensive Plan. Consistency with these policies is still evaluated in accordance with CEQA to determine whether inconsistency would result in a significant environmental Impact. Staff does not anticipate that inconsistency with any policy would be likely to result in a significant environmental impact. 1 The Palo Alto Comprehensive Plan is available online: bit.ly/PACompPlan2030 Item 2 Item 2 Staff Report     Packet Pg. 18     Item No. 2. Page 7 of 10 Housing Element Consistency One of the two parcels on which the proposed project would be located is identified as a housing inventory site. The Housing Element anticipated the development of 175 units on this proposed site at moderate income limits. The project is providing 30 units less than the estimated capacity by merging two parcels and redeveloping the site with a 145-unit development. Nineteen (19) units (13%) are designated to be provided at below-market rate (BMR) at a rate affordable to low-income tenants (60% of Area Median Income or below). The project is not subject to any additional area plans. The Housing Element identifies the maximum density for this site as 20 dwelling units per acre (du/ac), which would allow up to 220 dwelling units on the subject property. However, the maximum density for builder's remedy projects under 1893 is three times the zoning maximum, which would be 60 du/ac. An additional 35 du/ac would also apply because the project site is in a highest resource census tract (Gov. Code § 65589.5(h)(11)(C)). Accordingly, the maximum allowed density for the site is 95 du/ac. The project proposed a density of 18 du/ac is therefore allowed pursuant to State law. Baylands Master Plan and Bayland Design Guidelines The project is located within the boundaries of the Baylands Master Plan on the area identified as Private Lands. The following are Bayland Master Plan policies that affect sites within the Private Lands designation of this Master Plan: 1. Be sure any future development is consistent with the Comprehensive Plan and continues to receive extensive design review utilizing the Site and Design Review Process and the Site Assessment and Design Guidelines Palo Alto Nature Preserve. 2. Provide screen planting along the southerly urbanized edge of the private property facing the former ITT property. The project is located across Embarcadero Road from sites that create the urbanized edge fronting the former ITT property. The project is subject to Site and Design review, as detailed in this report, consistent with the Baylands Master Plan Policy 1 for Private Lands. Site Assessment and Design Guidelines The Site Assessment and Design Guidelines, Palo Alto Baylands Nature Preserve, developed in 2005, are intended to be used when designing or reviewing projects located in any part of the Baylands—including projects on privately-owned land. Conformance with these Guidelines will help to ensure compatibility with the special aesthetic qualities and environmental conditions unique to the Baylands. The following design principles are suggested to reflect and preserve the Baylands’ unique landscape character and have been used to review this application: Use only muted, natural colors. Choose materials and finishes that will weather without degrading. Preserve the horizon line with low and horizontal elements. Mount fences, enclosures, and identity signs low to the ground. Reduce the size and mounting heights of regulatory sign. Item 2 Item 2 Staff Report     Packet Pg. 19     Item No. 2. Page 8 of 10 Staff seeks comment and direction from the ARB regarding the design of the rear of the building as they relate to these guidelines but notes that signs are not proposed as part of the project. Any future signage would be evaluated in accordance with these guidelines if and when proposed. Palo Alto Comprehensive Airport Land Use Plan (CLUP) The CLUP is intended to be used to safeguard the general welfare of the inhabitants within the vicinity of an airport. The project site is located within the Traffic Pattern Zone, a portion of the airport area routinely overflown by aircraft operating in the airport traffic pattern. The potential for aircraft accidents is relatively low and the need for land use restrictions is minimal. There are no limits on residential units within the Traffic Pattern Zone. Zoning Compliance3 Attachment C includes a summary of the project’s consistency with zoning development standards, including the base ROLM (E)(D)(AD) zoning (as modified by the housing opportunity site standards under PAMC Chapter 18.14), and the standards that are enforceable under AB 1893 - in this case ROLM (E)(D)(AD) as modified by housing opportunity site standards under PAMC Chapter 18.14. Additionally, Attachment E includes a summary of the project’s consistency with the objective design standards set forth in PAMC Section 18.24. Comparison to ROLM (E) Zone District Standards The project is inconsistent with the following standards which are applicable to housing opportunity sites within the ROLM Zone District as set forth in PAMC Chapters 18.14 and 18.20. It is worth noting that exclusively residential uses in the ROLM (E) District requires compliance with the development standards prescribed for the RM-20 zoning district found in Chapter 18.13: Floor Area Ratio (FAR) (0.97:1 where 0.5:1 maximum is allowed for ROLM(E) residential uses) Height (42 feet where 30 feet maximum is allowed) Front Setback (16.5 feet where 20 feet is required) Additionally, the objective standards set forth in PAMC Chapter 18.24 also apply to housing development projects within the ROLM(E) Zone District. The project is inconsistent with the following Objective Design Standards: PAMC 18.24.020(b)(4)): Though bike racks are provided in each Townhome, no on-site micromobility infrastructure within 30 feet of the 65 buildings is proposed. Rather the public bike racks are centrally located on the project. A waiver is requested for this. PAMC 18.24.020(b)(4): No seating areas or benches are provided within 30 feet of all of the 65 buildings on the project site. A waiver is requested to have benches and seating areas centrally located on the site. PAMC 18.24.040(b)(6): Each unit should have at least 3 The Palo Alto Zoning Code is available online: bit.ly/PAZoningCode Item 2 Item 2 Staff Report     Packet Pg. 20     Item No. 2. Page 9 of 10 one usable side yard at least six feet wide. The applicant is requesting a waiver to this provision citing that providing 6 feet wide side yards would preclude density. It is also worth noting that the current proposal is inconsistent with the General Standards and Exceptions for rooftop gardens provided in Chapter 18.40: PAMC 18.04.030(a)(iii): All fixtures shall not intersect a plane measured at a forty-five degree angle from the edge of the building starting at the rooftop garden surface sloping upward and inward toward the center of the property. The applicant is requesting a waiver to this to allow a wider rooftop garden space. Staff is requesting the ARB’s feedback on consistency with the objective standards, including but not limited to the diversity of building typologies. Multi-Modal Access & Parking Valley Transit Authority (VTA) bus line 81 and ACE transit AE-F line are the nearest bus lines to the project site. The California Avenue Caltrain Station is located approximately 2.2 miles from the project site. There are currently separate bicycle lanes on Embarcadero Road. The project would include above-grade parking, with 333 spaces. Of those spaces, 290 spaces would be provided in the townhome garages (70 tandem spaces) with 43 on-street parking spaces, including 4 accessible spaces. One (1) electrical vehicle parking space is provided in each garage for 145 units. Access to the site would be through Geng Road and through an easement connecting to East Bayshore Road. Under the Zoning Code, 290 parking spaces are required. Bicycle parking is currently shown within each garage totaling 145 bike spaces and a centrally located bike rack on the project site. The proposed centrally located bike parking area holds 16 short-term bike racks. Trees Due to the site’s location in a flood zone, the development will need to raise the site to meet floodplain requirements. This will require trees on the parcel and adjacent to the parcel on the City property to be removed. The applicant is exploring options to reduce tree removals on City property. Staff anticipates that a Park Improvement Ordinance may be required depending on the work on City property. STAKEHOLDER ENGAGEMENT The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post on September 26, 2025, which is 12 days in advance of the meeting. Postcard mailing occurred on September 25, 2025, which is 13 days in advance of the meeting. Public Comments As of the writing of this report the City has not received any public comments related to the proposed project. Item 2 Item 2 Staff Report     Packet Pg. 21     Item No. 2. Page 10 of 10 ENVIRONMENTAL REVIEW The subject project is being assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. Specifically, the City is currently preparing a Class 32 exemption for the proposed project. ATTACHMENTS Attachment A: Location Map Attachment B: ARB Findings for Approval Attachment C: Zoning Consistency Attachment D: Applicant’s Project Description Letter Attachment E: Objective Design Standards Consistency Analysis Attachment F: Project Plans Author and ARB Liaison ARB Liaison5 & Contact Information   Steven Switzer, Senior Historic Planner   (650) 329-2321   Steven.Switzer@PaloAlto.gov 5 Emails can be sent directly to the ARB at the following email: ARB@PaloAlto.gov Item 2 Item 2 Staff Report     Packet Pg. 22     Gas Station #1 EMB 4 EMB-3 EMB-2 EMB-1 U.S. Post Office 717.7' 404.1' 98.4' 153.7' 5.2'19.5'26.6' 377.7' 693.0' 303.6' 330.0' 117.5' 198.0' 475.0' 290.4' 273.9' 175.0' 20.1' 345.2' 7.6' 172.1' 17.8' 31.4' 168.2' 99.8' 7.3' 60.5' 60.0' 31.4' 70.0' 72.0' 63.1' 19.3' 88.1' 30.0' 290.6' 52.3' 17.9' 207.4' 25.0' 103.7' 5.0' 191.2' 60.0' 73.2' 68.3'77.6'5.2'19.5' 124.0' 587.5' 349.6' 25.0' 278.9' 94.8' 349.6' 119.7' 58.3' 163.8' 187.2'45.7'25.0' 103.7' 132.8' 312.2' 272.9' 278.9' 262.6' 20.3' 747.80 169.0' 104.4' 1181.7' 587.5' 94.8' 30.0'28.0' 240.7 52.3' 26.8' 35.2'27.3' 61.6' 14.8' 187.5'6.3' 248.8' 236.4' 139.0' 18.7' 139.8' 162.5' 207.7' 168.3' 279.4' 240.6' 72.8' 46.7' 123.8' 175.0' 20.1' 418.5' 20.0' 452.1' 420.5' 345.2' 7.6' 241.3' 393.7' 230.0' 47.1' 129.2' 25.1' 84.3'18.7' 139.0' 206.3' 312.7' 341.8' 229.3' 30.1' 358.7' 59.7'115.1' 437.7' 149.5' 159.5' 57.6' 153.2' 281.9' 1.9'89.8' 48.4' 39.5'16.4' 386.6' 167.3' 171.5' 115.1'59.7' 386.6' 169.1' 368.1' 32.7' 526.8' 265.6' 175.1' 248.8' 24.4' 76.5' 153.7' 77.6'68.3'3.0' 108.7' 119.5' 148.9' 59.5' 108.7' 20.5' 41.1' 42.1' 161.9' 119.5' 66.5' 572.4' 1178.7' 150.6'377.7' 693.0' 303.6' 330.0' 117.5' 198.0' 475.0' 290.4' 273.9' 188.6' 159.5' 57.6' 153.2' 281.9' 438.6' 71.9' 148.9' 59.5'3.0' 73.2' 162.5' 207.7' 204.1' 89.1' 279.8' 47.1' 129.2' 25.1' 95.2' 38.9' 76.5' 38.9' 29.1'47.7'42.1' 41.1' 393.7' 251.5' 42.8' 3.5'17.8' 172.1' 589.5' 180.0' 40.2' 50.5' 100.0' 1717 1731 1755 1766 2100 Bldg 1 2200 Bldg 2 2300 Bldg 3 2400 Bldg 4 2191 2197 2275 2479 2085 2225 2452 2450 2525 2370 1700 1735 1730 2000 1900 EAST BAYSHORE ROAD BAYSHORE FREEWAY EMBARCADERO ROAD EAST BAYSHORE ROAD WATSON COURT LAURA LANE GENG ROAD BAYSHORE FREEWAY BAYSHORE FREEWAY BAYSHORE FREEWAY O'BRINE LANE WEST BAYSHORE ROAD WEST BAYSHORE ROAD PF PC-4847 CS(D) GM ROLM (E)(D)(AD) PC-4846 ROLM (E)(D)(AD) ROLM (E)(D)(AD) ROW Baylands Athletic Center Tom Casey Field 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' 309' Attachment A Location Map 2100-2400 Geng Rd CITY OF PALO ALTOINCORPORATED 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 sswitze, 2025-10-08 06:58:18 (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 2 Attachment A - Location Map     Packet Pg. 23     Item 2 Attachment B - ARB Findings for Approval     Packet Pg. 24     ATTACHMENT C ZONING COMPARISON TABLE 2100-2400 Geng Road, 24PLN-00356 Table 1: COMPARISON WITH CHAPTER 18.20 (ROLM (E) DISTRICT) Note: Exclusively Residential Use are subject to RM-20 District Standards. Regulation Required Proposed Minimum/Maximum Site Area, Width and Depth 8,500 sf area, 70 foot width, 100 foot depth APN 008-02-035: Approximately 748 feet wide, 300 feet deep, 239,800 square feet APN 08-02-036: Approximately 1178 feet wide, 500 feet deep, 240,430 square feet Total: 480,230 square feet (~11 acres) Minimum Front Yard 20 feet 16.5 feet Rear Yard 10 feet 10 feet Street Side Yard 16 feet N/A Interior Side Yard (for lots greater than 70 feet in width) 10 feet 10 feet Max. Building Height 30 feet 42 feet Max. Site Coverage 35% (plus an additional 5% for covered patios or overhangs)29% Max. Total Floor Area Ratio 0.5:1 0.97:1 Residential Density 11 to 20 units per acre (5 to 10 units)18 DU on 11 acres = 145 units per acre Minimum Site Open Space 35%44% Minimum Usable Open Space 150 sf per unit (21,750 sf)91,672 sf Minimum Common Open Space 75 sf per unit (10,875 sf)22,292 sf Minimum Private Open Space 50 sf per unit (7,250 sf)63,380 sf Item 2 Attachment C - Zoning Consistency     Packet Pg. 25     Table 2: CONFORMANCE WITH CHAPTER 18.52 (Off-Street Parking) for Multiple-Family Residential Type Required Proposed Housing 2 per 2-bedroom or larger unit; 290 spaces Tandem parking allowed for any unit requiring two spaces (one tandem space per unit, associated directly with another parking space for the same unit, up to a maximum of 25% of total required spaces for any project with more than four (4) units) 145- 2-bedroom; 290 spaces Includes: 70 Tandem spaces (24%) 43 additional on-street spaces 4 Accessible stalls Vehicle Parking Total 290 Residential 333 Residential Bicycle Parking One (1) per unit; 145 Long-Term 145 Long-term Item 2 Attachment C - Zoning Consistency     Packet Pg. 26     201 Spear Street, Suite 1650 San Francisco, CA 94105 P: 415.263.9151 www.stradasf.com September 26, 2025 Claire Raybould, AICP Manager of Current Planning, City of Palo Alto 285 Hamilton Avenue, Suite 100 Palo Alto, CA 94301 Email: Claire.Raybould@CityofPaloAlto.org Re: 2100 – 2400 Geng Road, Planning Application resubmittal Dear Claire: Please find included in this submittal the following documents associated with our resubmittal of the application for the housing development project located at 2100 – 2400 Geng Road. We have filed several applications associated with this project. Our SB 330 pre-application dated 7/8/24 is number 24PLN-00181. Our site and design / CUP / planning application originally dated 12/18/24 is 24-PLN-00356. Our vesting tentative map application originally dated 12/18/24 is number 24-PLN- 00357. We received comments from the City on 1/17/25 and 1/24/25. We then resubmitted C2 materials on 4/16/25 and received additional comments on C2 on 5/22/25. We then resubmitted C3 materials on 7/25/25 and received additional comments on C3 on 8/29/25. The updated materials in this submittal are in response to those City Comments. These materials replace and supersede the materials previously submitted, although certain project documents that did not change have not been updated and included in this submittal. As requested in the City Comments, the materials will be submitted in three PDF documents – one for the project plans, one for the supporting documents, and one for the response to City comments. Project Plans: 1. Architecture Plans 2. Civil Plans 3. Landscape Plans (Including Preliminary Arborist Report) Supporting Documents: 1. 2. 3. 4. 5. a. b. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 27     201 Spear Street, Suite 1650 San Francisco, CA 94105 P: 415.263.9151 www.stradasf.com Response to City Comments: 1. Response to City Comments dated 8/29/25 * * * additional discussion and engagement about the project. Sincerely, Strada PA Manager, LLC, Authorized Signatory Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 28     201 Spear Street, Suite 1650 San Francisco, CA 94105 P: 415.263.9151 www.stradasf.com September 26, 2025 Jonathan Lait Director, Planning & Development Services City of Palo Alto 285 Hamilton Avenue, Suite 100 Palo Alto, CA 94301 Email: Jonathan.Lait@CityofPaloAlto.org Re: Proposed Mixed-Income Housing Project at 2100 – 2400 Geng Road, Palo Alto Dear Mr. Lait: Strada PA Manager, LLC is pleased to resubmit updated application materials for our proposed mixed-income housing project at 2100-2400 Geng Road, which will transform an existing low-density office development into much needed sustainable housing in the City of Palo Alto and region. This resubmittal follows our SB 330 preliminary application submitted to the City on July 8, 2024, our original entitlement and vesting tentative map applications submitted on December 18, 2024, our C2 resubmittal on April 18, 2025, and our C3 resubmittal on July 25, 2025. We are committed to working in partnership with the City and the broader Palo Alto community to achieve the following goals and Project objectives. Overall Goals and Project Objectives B , re-purposing low-and . H , low-density into a new for-sale medium-density new homeownership , through an environmentally sustainable design. Build family-sized townhouses –- and seniors downsizing. Support Palo Alto’s 6th Cycle Housing Element and RHNA goals by delivering new market and below- market rate (BMR) . housing streamlining tools at the local and state level to increase deliver new housing as soon as possible. , including but not limited to: o ng the Project site’s proximity to the Baylands Nature Preserve and Palo Alto airport; o space and trails, and a 10-and o . Housing Program Overview The Project consists of 145 for-sale townhomes, with new internal streets and pedestrian paths, open space, and new utility infrastructure. The townhome units will have a range of three- and four bedrooms to accommodate larger family-size and multigenerational households. These for-sale units will provide new homeownership Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 29     2100-2400 Geng Road – Mixed-Income Housing Project | Cover Letter 2 opportunities for families looking to establish or maintain their roots in the Palo Alto community. The Project is specifically designed to accommodate growing families and first-time home buyers. The Project was identified in the City’s recently approved 6th Cycle Housing Element as an appropriate site for residential development and the proposed project will bring this vision to reality while helping the City meet its ambitious State-mandated housing production goals. Importantly, the project will incorporate 19 BMR housing units onsite, providing an enhanced opportunity for homeownership at affordable pricing that is largely missing from City and region, resulting in the benefits of homeownership for working families who otherwise would be priced out of the community. The Project BMR units will be offered for-sale to low-income households, which, based on Santa Clara County current area median incomes, would have annual incomes of up to $157,000 for a household of four. For-sale BMR units affordable to families at these income levels are rare in Palo Alto and will allow for new residents working for local government, healthcare, non-profits, or in other essential roles to live near their jobs. These 19 BMR units represent 13 percent of the 145 total units in the Project. This level of affordability is authorized under Assembly Bill (AB) 1893, a state law that became effective January 1, 2025, that is designed to facilitate approval and construction of housing development projects that have submitted SB 330 preliminary project applications in advance of a local jurisdiction receiving its Housing Element certification. While the 13 percent low-income allocation authorized under AB 1893 is lower than the 20 percent BMR that otherwise would be required by the City’s Municipal Code, the 19 BMR units are more deeply affordable than those required by the City’s Code, meaning they will be affordable to families with more modest incomes. This proposed BMR program under AB 1893 results in a Project that is financially viable and financeable, and thus, much more likely to be built quickly under current and foreseeable economic conditions. Site and Neighborhood Context The existing use of the Project site is a low-density office complex, consisting of four, two-story office buildings. Under current conditions, the existing office project is not fully leased and given the current office space supply and demand in Palo Alto, an aging office project is not the highest and best use of an 11-acre site in this location without significant near-term reinvestment. Overall, the current market conditions and the City’s 6th Cycle Housing Element’s identification of the Project site for housing makes this the appropriate time to pursue conversion of the existing office use to new residential use, which will also further help address Palo Alto’s historic jobs-housing imbalance. The Project site’s location east of 101 is in an area of Palo Alto that has not historically had housing; the Project provides an opportunity to bring new residents to this area who will contribute positively to the neighborhood by increasing bike and foot traffic, activating the area, and supporting local businesses. Sustainability and Resilience In keeping with the Project’s commitment to environmental sustainability, the Project will feature all-electric design with no natural gas service; incorporate solar panels and electric car charging connections for all units; utilize modern high-efficiency water fixtures; and store and treat stormwater onsite to reduce impacts on the City’s existing stormwater system. The existing Project site (and much of the area east of 101) lies in a FEMA flood zone of AE-11. To address this risk, the Project will raise the site finished grade to a level that will be safe from flooding and will set a standard for climate-sensitive development in Palo Alto, paving the way for a more resilient City. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 30     2100-2400 Geng Road – Mixed-Income Housing Project | Cover Letter 3 One consequence of this necessary flood protection is that the grade of the entire Project site area will need to be raised by adding multiple feet of soil, which will impact many of the trees on site. While our view is that tree removal should be a strategy of last resort, based on the Flood Zone conditions, there is no feasible way to change the grade of the Project site without severely impacting the roots of existing trees. The weight of the additional soil will negatively impact the existing trees’ root systems, ultimately adversely affecting tree health and resulting in tree death. To respond to this flood zone mitigation and resulting tree removals, the Project has prioritized replacing and ultimately improving the tree density and eventual mature tree canopy on site. By replacing the existing surface parking lots with a new network of green vegetative areas that connect future residents to the internal open spaces, the Project will more than double existing tree quantities. While many of the existing trees are non-native or even invasive, the proposed trees will be mostly native and adapted drought tolerant species that will bolster native tree species quantities for the City, ensure replacement habitat for birds, and reduce irrigated water demand. At the same time, the trees will be selected to enhance the Project neighborhood and adjacent Baylands Athletic Center public open spaces with tree character, color, texture and form. In addition to new tree plantings, the Project will create new roads and pedestrian paths to allow connections across and through the site. Additionally, the Project will create new open spaces, including a central green with a large lawn and other amenities to serve as a gathering point for the Project community. The Project is also exploring the potential to accommodate a future connection to the San Francisquito Creek trail, which lies north of the Project site. Additional Benefits Finally, the Project will positively contribute to the Palo Alto community through creating opportunities for future residents. These families will start and work at Palo Alto businesses, will increase the tax base through their property and sales taxes, will shop at local businesses such as those at Edgewood Plaza, and will send their children to Palo Alto schools. The transformation of 2100-2400 Geng Road from an underutilized office complex to a thriving, family-oriented residential community will provide broad and diverse benefits to the City of Palo Alto. * * * We look forward to continuing working with the City to deliver this Project and advancing the City’s important goal of bringing viable residential projects to fruition. Sincerely, Nikolas Krukowski Strada PA Manager, LLC, Authorized Signatory Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 31     1 2100-2400 Geng Road Project Description Updated: 9/26/2025 The proposed project would transform an existing underutilized business park located at 2100-2400 Geng Road into a new residential neighborhood with 145 multifamily townhome units and community open spaces. All units will be offered for-sale with either three-bedroom or four-bedroom configurations, providing both much-needed housing and new homeownership opportunities in the city and region. Section I of this project description provides an overview of the project site and existing conditions; Section II describes the project land use program and site plan features; Section III describes the project’s affordability and State Density Bonus Law strategy, including information regarding the project site’s Housing Element site inventory status. I. Project Site Overview The project site totals approximately 11-acres and is comprised of two parcels: APN 008-02-035 (addressed as 2100-2200 Geng Road, totaling approximately 5 acres) and APN 008-02-036 (addressed as 2300-2400 Geng Road, totaling approximately 6 acres). The property is zoned ROLM (E)(D)(AD), in which multifamily development is permitted subject to the RM-20 district development standards. A portion of the project site is also identified in the City’s 6th Cycle Housing Element as a housing opportunity site, as further described in Section III below. The project site is currently improved with four, two-story office buildings and surface parking. In connection with development of the proposed project, the existing buildings will be demolished, and necessary site improvements will be undertaken to redevelop the property. The project site is bounded by Geng Road to the east, the Baylands Athletic Center to the north, and office buildings to the west and south. Primary access to the property is from Geng Road, with secondary access (via an adjacent property) from East Bayshore Road. II. Proposed Project & Land Use Program Overview The proposed project includes 145 multifamily residential units comprised of seven different townhome unit types. Along the northern boundary, adjacent to the Baylands Athletic Center, are 22 front-loaded pull-apart (detached) townhomes, in two different unit plans. These homes feature backyards that transition to the parkland, creating a buffer between the development and the park. Across the street from these units are 26 alley-loaded pull-apart (detached) townhomes, in two different unit plans. The remaining units consist of traditional attached townhomes arranged in clustered buildings of five, six, and eight units, comprised of three different unit plans. The site plan layout is designed to minimize visibility of alleys from public viewpoints. The variety of housing types is cohesively arranged around shared green spaces and connected by pedestrian paseos. The project design features contemporary architectural design that blends well with the surrounding context while setting a precedent for the transformation of predominantly office-oriented uses in the East of 101 area into residential neighborhoods. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 32     2100-2400 Geng Road | Project Description 2 Site Circulation Primary access to the project will be from Geng Road, with a clearly defined major circulation loop providing access to all areas of the site. Secondary access (via an adjacent property) is provided from East Bayshore Road. Offsite parking is provided within each unit. On-street parking is strategically placed along this loop to provide convenient access for visitors. Building entries and porches are oriented towards this loop road to create a pedestrian-friendly streetscape. Project Open Space & Pedestrian Circulation At the center of the site is a large communal central open space surrounded by residential units. This central open space will serve as the community's focal point and is within easy walking distance for all residents. Guest parking is located along the edges of the green space to provide convenient access for visitors. A fully landscaped pedestrian network will connect the housing to the central open space and provide a natural and green environment throughout the project site. The central open space will provide passive and programmed uses for the residents including quiet seating areas and outdoor cooking and dining areas. The programmed areas will be distributed around a large central lawn area that can be used by residents for a variety of purposes, including outdoor games and picnics. The planting character throughout the site will consist of drought tolerant, native, and adapted species of a variety of shape, sizes, and colors. All buildings are three stories tall (approximately +/- 42’-2” in height), with living areas complemented by balconies and roof decks. The combination of individual balconies, roof decks and backyards ensure ample private outdoor space, while the central green space offers a communal gathering area for all residents. Utilities & Services The project will have electricity service from City of Palo Alto, and the proposed project site plan allows ample space for meter and utility connections. The project will be “electric only,” and will not have gas service. The project will have water, wastewater, and sanitary sewer service from the City of Palo Alto. The project will utilize solid waste service from GreenWaste of Palo Alto. The HOA will contract with a service to collect trash, recycling and compost from each unit and bring it to a central enclosure where it will be stored until picked up by GreenWaste. Sustainability A key project objective is to provide modern, energy-efficient and sustainable housing units that limit new emissions and natural resource usage. To that end, the project incorporates a range of sustainability features, including solar photovoltaic panels on building roofs, cool roofs, electric vehicle charger ready garages, energy efficient fixtures and appliances, low-water use fixtures, construction waste reduction, low VOC materials, and both private and shared bicycle parking on site. The project landscaping and tree placement planting plan focuses on incorporation of native and drought tolerant species, with an anticipated tree planting plan that yields over 50% California native species. The project would result in a net increase in landscaped areas and pervious surface at buildout, reducing the heat island effect of the site which is currently improved with significant surface parking. Tree and plant species have additionally been selected to help create a high-quality habitat that will support biodiversity and bird populations. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 33     2100-2400 Geng Road | Project Description 3 In recognition of the project site’s proximity to the San Francisquito Creek and Baylands Nature Preserve and Shoreline Park, the project design also incorporates lighting reduction design features to reduce the spillover of lighting or glare/increased luminance perceived by birds and other wildlife, all of which follow recommendations by the International Dark-Sky Association. Project Affordability & Density Bonus Law Relief The project includes 19 affordable for-sale units on-site (13% of the total units) that will be restricted to low-income households. This onsite affordability percentage meets the requirements of the Housing Accountability Act as amended by AB 1893 that went into effect as of January 1, 2025 (see Gov. Code Section 65589.5(h)(3)(C)(i)(II)). Under the Housing Accountability Act, as amended, the project is entitled to utilize this reduced affordability percentage, along with the other associated amendments to the Housing Accountability Act, because it meets the definition of a builder’s remedy project (see Gov. Code Section 65589.5(f)(7)(A)). The State Density Bonus Law applies to the Project because it is a housing development project that proposes to include a qualifying percentage of units onsite as affordable to low-income households. The project’s density of 145 units (approximately 13 dwelling units per acre) is within the 11 du/a minimum density and 20 du/a maximum density allowed under the applicable RM-20 zoning requirements, no bonus residential density is required. However, the project will utilize waivers or reductions of development standards and is also entitled to three incentives/concessions. One incentive/concession is provided under the State Density Bonus Law for projects proposing at least ten percent of total units for low-income households (see Gov. Code Section 65915(d)(2)), and two additional incentives/concessions are provided pursuant to the Housing Accountability Act as amended by AB 1893 (see Gov. Code Section 65589.5(f)(6)(C)). Density Bonus Waivers/Reductions Under the State Density Bonus law, the project is entitled to a waiver of all development standards that would physically preclude the development at the density permitted and with the concession(s) granted. The project is requesting the following waivers/reductions of development standards. The project reserves the right to identify additional waivers as the project advances through the entitlement process. Chapter 18.13 – RM-20 Development Standards 1. Maximum FAR (0.5:1) Waiver requested to exceed the maximum FAR allowance to achieve the proposed residential density, which is consistent with the applicable residential zoning density controls. Maintaining a 0.5 FAR would physically preclude the density of the project as proposed. Proposed project FAR is 1.0:1. 2. Height (30’ max.) Waiver requested to exceed the height allowance. The proposed height of each residential building is approximately +/- 42’ -2”. The proposed project uses compact footprints to achieve the proposed density, which requires additional height to accommodate the proposed project unit types and bedroom counts. Maintaining the 30’ height limit would physically preclude the density of the project as proposed. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 34     2100-2400 Geng Road | Project Description 4 Chapter 18.24 – Contextual Design Criteria and Objective Design Standards 3. Mobility Infrastructure – Proximity to Primary Building Entry Under PAMC 18.24.020(b)(4)(A), micromobility infrastructure, such as locations to lock bicycles and scooters, shall be located within 30 feet of the primary building entry and/or a path leading to the primary building entry. This standard may be satisfied by existing infrastructure already located within 50 feet of the project site and located in the public right-of-way. Based on the project’s townhome unit type configurations, the project has one primary entry per unit, and providing bike racks within 30 feet of all entries would physically preclude the project as proposed. However, the project would provide bike racks in the community open space area, which is centrally located and accessible from all units. By providing the bike racks in a central location, the project meets the intent of the standard to provide bike racks in a convenient location that is easily accessible by all users and visitors. 4. Detached Unit Side Yards Under PAMC 18.24.040(b)(6)(A), each detached dwelling unit shall have at least one usable side yard, at least six feet wide, between the house and fence or other structure, to provide outdoor passage between the front and rear yards. Some of the project’s pull- apart townhomes have side yards of four feet. The project is requesting a waiver from this development regulation as increasing the side yard to six feet would physically preclude the project as proposed. Chapter 18.40 – General Standards and Exceptions 5. Height Limits on Rooftop Garden Fixtures Under PAMC 18.40.230, certain permanent fixtures on the rooftop may exceed applicable height limits, however, the Code provides that such fixtures “shall not intersect a plane measured at a forty-five-degree angle from the edge of the building starting at the rooftop garden surface sloping upward and inward toward the center of the property.” The project is requesting a waiver from the requirement as this would require the units to be much wider than currently planned and therefore would physically preclude the project as proposed. Chapter 21.20 – Subdivision Design 6. Private Street Width Requirement Under PAMC 21.20.240, private streets serving five or more lots are required to maintain a street width of thirty-two feet, whereas private streets serving four or less lots are required to maintain a street width of twenty-two feet. The project proposes a private street loop that will range in width from 26’ wide in certain areas to 35’ wide in other areas. The project is requesting a waiver from this PAMC 21.20.240 development regulation as increasing the streets and alleys to 32’ would reduce the allowable buildable area and thus Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 35     2100-2400 Geng Road | Project Description 5 physically preclude the project as proposed. The proposed onsite private street allows day to day traffic, service, and emergency vehicles. Incentives/Concessions The project is entitled to three concessions pursuant to State Density Bonus Law and AB 1893. Under the State Density Bonus law, the City can only deny a concession if it finds that it would not result in identifiable and actual cost reductions; would have an unmitigable/unavoidable specific, adverse impact on public health and safety or any real property listed on the California Register of Historical Resources; or would violate state or federal law. With respect to identifiable and actual cost reductions, applicants do not bear the burden to prove that incentives would result in actual cost reductions; rather, requested incentives are presumed to result in cost reductions, and local governments must either accept this presumption or make written findings based on substantial evidence to the contrary. At this time the project is requesting the following concession: Chapter 16.65.075 – Distribution of Affordable Units Under PAMC 16.65.075(a)(2), affordable units “shall be reasonably dispersed” within the residential project, with unit locations “comparable” to those of the market-rate units. Further, affordable units must have a comparable number of bedrooms to the market rate units. PAMC 16.65.075(a)(2) also allows for the Planning Director to approve clustering of BMR units within the residential project “when this furthers affordable housing opportunities.” The proposed site plan proposes larger, four-bedroom pull-apart townhouse units in the northern section of the site and smaller, three- and four-bedroom attached townhouse units in the balance of the site. The project’s 19 BMR units have been well distributed throughout the attached townhouse buildings and are all located within Unit Plan 11 units – a three-bedroom unit type with a two-car tandem garage. The project’s proposed BMR distribution plan is provided on Sheet A.7 of the plan sets and is intended to meet the City’s distribution standard. However, we understand that Planning staff have indicated that the BMR distribution as proposed may not meet its PAMC 16.65.075(a)(2) requirement. As a result, if staff ultimately determines that the proposed BMR distribution plan does not meet its PAMC 16.65.075(a)(2) standard, the project seeks a concession for this requirement. This request meets the State Density Bonus Law requirements for issuance of a concession, as further detailed below. The project development costs are significantly reduced by providing the required BMR units in Unit Plan 11 units. It would cost considerably more to build these BMR units as pull-apart, detached townhouses or as larger, four-bedroom units in attached townhouse buildings. Construction costs scale directly with square footage: larger units require more framing, drywall, finishes, HVAC ducting, and flooring than smaller units. Detached units additionally require construction of significantly more building envelope without the cost efficiencies of shared walls because they are fully detached. Additionally, the project relies on reasonable market returns in order to be financially feasible to construct. Because the pull-apart units and four-bedroom townhome units will sell at a premium to the Unit Plan 11 three-bedroom attached townhouse units, selling larger units at BMR prices would significantly reduce the sales revenue relative to the proposed plan of selling Unit Plan 11 attached townhouse units at BMR prices. This reduced sales revenue will directly reduce the Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 36     2100-2400 Geng Road | Project Description 6 financial viability of the project, resulting in a delayed financing process, additional construction cost escalation, and increased costs to deliver the on-site affordable housing. The project reserves the right to identify and utilize the available two additional incentives/concessions as the project advances through the entitlement process. Housing Inventory Site Status As described above, the project is comprised of two parcels. One of the parcels, APN 008-02-035 (~5 acres) is listed in the City’s 6th Cycle Housing Element as a Housing Inventory Site with a target yield of 175 units. The other parcel, APN 008-02-036 (~6 acres), is not listed as a Housing Inventory Site. The project is proposing to provide 145 units, which is below the target yield of 175 units for APN 008-02-035. Based on the information provided in the Housing Element, it is not clear how a determination of 175-unit yield for APN 008-02-035 was made; however, there are several reasons why the project is unable to meet the target unit yield and why the proposed 145 units is the appropriate density for the project site: • The project seeks to be consistent with the existing zoning density of 11 du/a – 20 du. Height, setback, lot coverage, and FAR maximums in the ROLM(E) district, pursuant to the RM-20 district standards that apply to residential development in the ROLM(E) district, limit density and development potential and thus limit the feasibility of achieving the target unit yield. While the project utilizes Density Bonus Law waivers to achieve relief from some of these standards, the project seeks to minimize deviations from these standards wherever possible. • An important design consideration for the project is to be sensitive to the context of the site and surrounding uses. The project is adjacent to low office buildings, the Baylands Athletic Center, and more generally is in the vicinity of San Francisquito Creek and the Baylands. Keeping the buildings to three stories in height ensures that the project maintains a context-sensitive design and minimizes visual impacts of the project. • A key goal of the project is to provide family sized units, including on-site BMR family sized units, to help meet the needs of the residents of Palo Alto. One consequence of providing larger units is that the project ends up providing fewer units in the same amount of development area. • Achieving a unit yield of 175 units on just a five-acre portion of the site would require utilization of a construction typology that is far more expensive to build on a per square foot basis as compared to townhome construction costs. Because of this, a denser project that meets the prosed target unit yield would reduce the project’s financially feasibility, and thus be less likely to be financed and built than the proposed, lower density townhome project. By including on-site affordable units and offering a range of housing types, the project’s mixed- income units provide the "missing middle" housing needed by the Palo Alto community, offering new opportunities for home ownership, which will be a valuable addition to the housing fabric of Palo Alto. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 37     City of Palo Alto - Objective Design Standards Checklist Page 1 Objective Design Standards Checklist The Objective Design Standards Checklist is a tool to evaluate a project’s compliance with the Zoning Ordinance (Chapter 18.24). The Checklist is not the Zoning Ordinance. Applicants shall be responsible for meeting the standards in the Zoning Ordinance. To simplify evaluation of the Zoning Ordinance, language in the Checklist may vary from the Zoning Ordinance. (Note: sf = square feet) If a standard is not applicable to applicant’s project, please write N/A in Applicant’s Justification column. 18.24.020 Public Realm/Sidewalk Character Check Standard Sheet # Applicant’s Justification (b)(1) Sidewalk Widths ☐ (A) In the following districts, public sidewalk width (curb to back of walk) is at least: • Commercial Mixed-Use District: CN, CS, CC, CC(2), CD-C, CD-S, CD-N, PTOD: 10 ft • El Camino Real: 12 ft • San Antonio Road, from Middlefield Road to East Charleston Road: 12 ft And consists of: Pedestrian clear path width of 8 foot minimum: ______ feet Landscape or furniture area width of 2 foot minimum: ______ feet ☐ If the existing public sidewalk does not meet the minimum standard, a publicly accessible extension of the sidewalk, with corresponding public access easement, shall be provided. ☐ (B) Public sidewalks or walkways connecting through a development parcel (e.g. on a through lot with a public access easement, leading to a commercial entry) must be at least 6 feet wide. ☐ (C) The width of walkways designed to provide bicycle access (e.g. pathway to bike racks/lockers) must be at least 12 feet wide, consisting of: Pedestrian clear path width (8 feet min.): ____ ft Clear space/buffer – (2 feet min. on each side of path, ground cover is allowed): ____ ft & ____ ft Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 38     City of Palo Alto - Objective Design Standards Checklist Page 2 Pic k O n e ☐ (B) Primary building entries shall provide at least one seating area or bench within 30 feet of building entry and/or path leading to building entry. On arterials (see Map T-5), except Downtown, seating areas or benches shall not be located between the sidewalk and the curb; OR ☐ Existing seating areas or benches that are already located in the public right-of-way within 50 feet of the building entry. Check Standard Sheet # Applicant’s Justification (B)(2) Street Trees ☐ 1. One street tree provided for every 30 linear feet of public sidewalk length and located within six feet of the sidewalk. a. Length of parcel frontage/public sidewalk length: ____ ft b. Street Trees required (i.e. frontage/30 feet): ____ ft c. Street Trees provided: ____ ft (B)(3) Accent Paving ☐ Parcels abutting University Avenue between Alma Street and Webster include accent paving along the project frontages, as indicated below: • Brick paving at corners • Brick trim mid-block ☐ Parcel abutting California Avenue between El Camino Real and Park Blvd include decorative glass accent paving along project frontages (B)(4) Mobility Infrastructure Pic k O n e ☐ (A) On-site micromobility infrastructure (e.g. bike racks/lockers) is located within 30 feet of the primary building entry and/or on a path leading to the primary building entry; OR ☐ Existing micromobility infrastructure (e.g. bike racks/lockers) is already located within 50 feet of project site and located in a public right-of-way. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 39     City of Palo Alto - Objective Design Standards Checklist Page 3 18.24.030 Site Access Check Standard Sheet # Applicant’s Justification (b)(1) Through Lot Connections ☐ Through lots located more than 300 feet from an intersecting street or pedestrian walkway shall provide a publicly accessible sidewalk or pedestrian walkway (with public access easements) connecting the two streets. (b)(2) Building Entries ☐ Primary Building Entries shall be located from a public right-of-way. If there is no public right-of-way adjacent to the building, entries shall be located from a private street or Pedestrian Walkway. (b)(3) Vehicle Access ☐ (A) Vehicle access shall be located on alleys or side streets when they abut the property. ☐ (B) Except for driveway access and short-term loading spaces (e.g. taxi), off-street parking, off-street vehicle loading (delivery trucks), and vehicular circulation areas are prohibited between the building and primary building frontage. (b)(4) Loading Docks and Service Areas Loading and service areas shall be integrated into building and landscape design and located to minimize impact on the pedestrian experience as follows: ☐ (A) Loading docks and service areas shall be located on façades that do not face a primary building frontage ☐ (B) Loading docks and service areas located within setback areas shall be screened by a solid fence, or wall, or dense landscaping and separated from pedestrian access to the primary building entry to avoid impeding pedestrian movement/safety. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 40     City of Palo Alto - Objective Design Standards Checklist Page 4 18.24.040 Building Orientation and Setbacks Check Standard Sheet # Applicant’s Justification (b)(1) Building Corner Elements (less than 40 feet in height) Corner buildings less than 40 feet in height and end units of townhouses or other attached housing products that face the street shall include all of the following features on their secondary building frontage: Che c k A l l ☐ (A) height and width of corner element shall have a ratio greater than 1.2:1. For townhomes, the width would be equal to the smaller side of one unit? a. Secondary building frontage height: _____ feet b. Secondary building frontage length: _____ feet c. Secondary building frontage height to width ratio: ___ ☐ (B) minimum of 15% fenestration area. a. Total secondary building frontage façade area: ___ sf b. Secondary building frontage façade fenestration area: ___ sf c. Percent of fenestration area _____ % ☐ (C) At least one facade modulation with a minimum depth of 18 inches and a minimum width of two feet. (b)(2)(A) & (B) Treatment of Buildings Corners on Corner Lots (40+ feet in height) Corner Buildings 40 feet or taller in height shall include at least one of the following special features: Che c k O n e o r M o r e w i t h i n A o r B A. Street wall is located at the minimum front yard setback or build-to line for a minimum aggregated length of 40 feet on both facades meeting at the corner and includes one or more of the following building features: ☐ i. An entry to ground floor retail or primary building entrance located within 25 feet of the corner of the building. ☐ ii. A different material application and/or fenestration pattern from the rest of the façade. ☐ iii. A change in height of at least 4 feet greater or less than the height of the adjacent/abutting primary façade. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 41     City of Palo Alto - Objective Design Standards Checklist Page 5 Che c k O n e o r Mo r e w i t h i n A o r B B. An open space with a minimum dimension of 20 feet and minimum area of 450 sf. The open space shall be at least one of the following ☐ i. A publicly accessible open space/plaza. ☐ ii. A space used for outdoor seating for public dining. ☐ iii. A residential Common Open Space adjacent to a common interior space (i.e. lobby, retail, etc.) and less than two feet above adjacent sidewalk grade. Fences and railing shall be a minimum 50% open/transparent. (b)(3) Primary Building Entry The primary building entry meets at least one of the following standards: Che c k O n e o r M o r e ☐ A. Faces a public right-of-way. ☐ B. Faces a publicly accessible pedestrian walkway. ☐ C. Is visible from a public right-of-way through a forecourt or front porch that meets the following standards: i. For residential buildings with fewer than seven units, building entry forecourts or front porch minimum dimensions of (min. 36 sf and min. dimension of 6 feet required): ___ sf and ___ ft. min. dimension ii. For commercial buildings or residential buildings with seven or more units, building entry forecourts or front porch minimum dimensions of (min. 100 sf and a min. width of 8 feet required): ___ sf and ___ ft. min. width (b)(4) Ground Floor Residential Units A. Finished Floor Height for Ground Floor Units ☐ The finished floor of ground floor residential units, when adjacent to a public right-of- way, must be within the minimum and maximum heights according to setback distance from back of walk identified in Figure 2a and 2b of the Zoning Ordinance. Calculate minimum ground floor finished floor height: Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 42     City of Palo Alto - Objective Design Standards Checklist Page 6 Che c k A l l t h a t A p p l y ☐ Setback adjacent to public right of way: ___ feet ☐ Minimum ground floor finished floor height: _____ feet 𝒚𝒚 = �−𝟒𝟒𝟏𝟏𝟏𝟏�(𝒙𝒙)+ 𝟏𝟏𝟏𝟏𝟑𝟑 where 𝑥𝑥 = setback length from back of walk, in feet and 𝑦𝑦 = ground floor finished floor height, in feet ☐ Sites with slopes greater than 2% along building façade – Average height of finished floor: _____ feet ☐ Sites located in flood zones – the minimum ground floor finished floor height shall be defined by FEMA, less flood zone elevation: _____ feet B. Setback Trees ☐ Ground floor units with a setback greater than 15 feet must have at minimum an average of one tree per 40 linear feet of facade length, within the setback area. Facade length: ______ feet Trees required: ____ tree(s) (i.e. façade length / 40) Trees provided: ____ tree(s) C and D. Front Setback Pic k O n e ☐ C. Ground floor residential entries are setback a minimum of 10 feet from the back of public sidewalk; OR ☐ D. Where no minimum building setback is required, all ground floor residential units must be set back a minimum 5 feet from back of public sidewalk. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 43     City of Palo Alto - Objective Design Standards Checklist Page 7 Check Standard Sheet # Applicant’s Justification E. Unit Entry ☐ A minimum 80% of ground floor residential units that face a public right-of-way or publicly accessible path, or open space shall have a unit entry with direct access to the sidewalk, path, or open space for minimum. a. Total number of ground floor residential units facing a public right-of-way, publicly accessible path, or open space: ____ units b. 80% of total units in (a): ____ units c. Subset of number of units in (a) that have a unit entry with direct access to the sidewalk, path, or open space: ____ entries (b)(5) Front Yard Setback Character Required setbacks provide a hardscape and/or landscaped area to create a transition between public and private space. The following standards apply, based on intended use and exclusive of areas devoted to outdoor seating, front porches, door swing of building entries, and publicly accessible open space and meet the following: Che c k A l l t h a t A p p l y ☐ (A). Ground-floor retail or retail like uses have a minimum of 10% of the required setback as landscape or planters. i. Minimum setback area (setback x frontage x 10%): ____ sf ii. Landscape or planter area in required setback: ____ sf ☐ (B). Ground-floor residential uses have a minimum of 60% landscaped area in the required setback area. i. Minimum setback area (setback x frontage x 60%): ____ sf ii. Landscape area in required setback: ____ sf (b)(6) Side Yard Setback Character ☐ (A) Each detached dwelling unit shall have at least one usable side yard, at least six feet wide, between the house and fence or other structure, to provide outdoor passage between the front and rear yards. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 44     City of Palo Alto - Objective Design Standards Checklist Page 8 18.24.050 Building Massing Check Standard Sheet # Applicant’s Justification (b)(1) Upper Floor Step Backs and Daylight Planes ☐ (A) When the height of the subject building is more than 20 feet above the average height (i.e. average of low and high roof elevations) of an adjacent building(s), an upper floor step back shall start within two vertical feet of the average height of the adjacent building. The step back shall be a minimum depth of six feet along both the façade on the primary building frontage and the façade facing the adjacent building, and the step shall occur for a minimum of 70% of each façade length. i. Proposed building height: _____ feet ii. Average building height of the adjacent building(s): _____ feet iii. Building height where upper floor step back begins: ____ feet ☐ (B) Notwithstanding, subsection (A), when adjacent to a single-story building, the upper floor step back shall occur between 33 and 37 feet in height. ☐ (C) If a project meets the following criteria, a daylight plane with an initial height of 25 feet above grade at the property line and a 45-degree angle shall be required. This daylight plane is required if all of these criteria are met: i. The project is not subject to a daylight plane requirement, pursuant to district regulations in Title 18; and ii. The project proposes a building which is more than 20 feet above the average height (i.e., average of low and high roof elevations) of an adjacent building(s); and iii. The project abuts residential units in the side or rear yard. (b)(2) Privacy and Transitions to Residential Uses When a building abuts a residential use on an interior side and/or rear property line, the building shall break down the abutting façade and maintain privacy by meeting all of the following: Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 45     City of Palo Alto - Objective Design Standards Checklist Page 9 Che c k A l l ☐ (A) Landscape Screening. A landscape screen that includes a row of trees with a minimum one tree per 25 linear feet and continuous shrubbery planting. This screening plant material shall be a minimum 72 inches (6 feet) in height when planted. Required trees shall be minimum 24” box size. ☐ (B) Façade Breaks. A minimum façade break of 4 feet in width, 2 feet in depth, and 32 sf of area (i.e. 8 ft tall minimum) for every 36 to 40 feet of façade length ☐ (C) Maximum Amount of Transparent Windows. Within 40 feet of an abutting structure, no more than 15% of the facing façade area shall be windows or other glazing. Additional windows are allowed in order to maintain light, if fixed and fully obscured (D) Windows. Within 30 feet of facing residential windows (except garage or common space windows) or private open space on an adjacent residential building, facing windows on the subject site shall meet the following: (i) Window sills at and above the 2nd floor shall be at least five feet above finished floor; or (ii) Windows shall have opaque or translucent glazing at or below five feet above finished floor; or (iii) Windows shall be angled up to 30 degrees (parallel to window) to face away from the adjacent privacy impacts; and (iv) Landscape screening shall be 24-inch box size or larger and eight+ feet height at planting; 50% evergreens; and located to align with proposed second floor windows at maturity. (E). Balconies: Within 30 feet of residential windows (except garage or common space windows) or private open space on an adjacent residential building, balconies and decks on the subject site shall be designed to prevent views: (i) No sight lines to the adjacent property window or open space are permitted within five feet above the balcony or deck flooring and a 45- degree angle downward from balcony railing. (ii) Submit section view of proposed balcony/deck and abutting residential windows and/or private open space. (iii) Provide balcony/deck design measure which may include: a. Minimum 85% solid railing b. Obscure glass railing c. Barrier with min. 18" horizontal depth from railing (e.g. planter) Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 46     City of Palo Alto - Objective Design Standards Checklist Page 10 (b)(3)(A) & (B) Maximum Façade Length - facing a street or public path Pic k O n e Cate g o r y Buildings 70 feet in length or greater and greater than 25 feet in height ☐ For building facades 70 feet in length or greater and facing a public street, right- of-way, or publicly accessible path shall not have a continuous façade plane greater than 70% of the façade length without an upper floor modulation, of at least 2 feet in depth Largest façade length featuring continuous plane: _____ feet Total Façade length: _____ feet Percent of façade length without upper floor modulation (a/b) (maximum 70%): ____ % Buildings 250 feet in length or greater ☐ (A) Buildings 250 feet in length or greater, which face a public street, right-of- way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 400 sf and a width greater than or equal to two times the depth Total Building length: _____ feet Number of vertical façade breaks: ___ area Width: ____ feet, Depth: ____ feet, Area: ____ sf Buildings between 150 feet and 250 feet in length ☐ (B) Buildings 150 to 250 feet in length, which face a public street, right-of-way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 64 sf and a minimum width of 8 feet and minimum depth of 4 feet. Total Building length: _____ feet Number of vertical façade breaks: ___ area Width: ____ feet, Depth: ____ feet, Area: ____ sf Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 47     City of Palo Alto - Objective Design Standards Checklist Page 11 Check Standard Sheet # Applicant’s Justification (b)(4) Special Conditions: Railroad Frontages All parcels with lot lines abutting railroad rights-of-way shall meet the following standards on the railroad-abutting façade(s): Che c k All ☐ (A) A minimum facade break of at least 10 feet in width and six feet in depth for every 60 feet of façade length. ☐ (B) For portions of a building 20 feet or greater in height shall not have a continuous façade length that exceeds 60 feet. (b)(5) Diversity of Housing Types ☐ A diversity of housing types (e.g. detached units, attached rowhouses/townhouses, condominiums or apartments, mixed use) are required for projects on large lots: • Less than one acre lots: minimum 1 housing types • 1 to 2-acre lots: minimum 2 housing types; or • More than 2-acre lots: minimum 3 housing types 18.24.060 Façade Design Check Two or More Standard Sheet # Applicant’s Justification (c)(1) Base-Middle-Top ☐ Buildings three stories or taller and on lots wider than 50 feet shall be designed to differentiate a defined base or ground floor, a middle or body, and a top, cornice, or parapet cap. Each of these elements shall be distinguished from one another for a minimum of 80% of the façade length through use of three or more of the following four techniques: ☐ i. Variation in Building Modulation: Building modulation shall extend for a minimum 80% of the façade length feet, and shall include one or more of the following building features. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 48     City of Palo Alto - Objective Design Standards Checklist Page 12 Che c k o n e o r m o r e i f sele c t e d ☐ a. Horizontal shifts. Changes in floor plates that protrude and/or recess with a minimum dimension of 2 feet from the primary facade. ☐ b. Upper floor step backs. A horizontal step back of upper-floor façades with a minimum 5 foot stepback from the primary façade for a minimum of 80% of the length of the façade ☐ c. Ground floor step back. A horizontal shift of the ground floor facade with a minimum depth of 2 feet for a minimum 80% of the length of the façade. Ground floor step backs shall not exceed the maximum setback, where stated ☐ ii. Variation in Façade Articulation: Façade articulation modulation shall include one or more of the following building features. Che c k o n e o r m o r e i f sele c t e d ☐ a. Horizontal and/or Vertical Recesses or Projections. Recesses or projections such as a pattern of recessed grouping of windows, recessed panels, bay windows or similar strategies. The recess or projection shall be a minimum 4 inches in depth. ☐ b. Horizontal and/or Vertical Projections. Projections such as shading, weather protection devices, decorative architectural details, or similar strategies. ☐ c. Datum Lines. Datum lines that continue the length of the building, such as parapets or cornices, with a minimum 4 inches in height or a minimum 2 inches in depth and include a change in material ☐ iii. Variation in two of the following: Che c k two if sele c t e d ☐ a. Fenestration Size ☐ b. Fenestration Proportion ☐ c. Fenestration Pattern ☐ d. Fenestration Depth or Projection ☐ iv. Variation in two of the following: Che c k two if sele c t e d ☐ a. Façade Material ☐ b. Facade Material Size ☐ c. Façade Texture and Pattern ☐ d. Façade Color Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 49     City of Palo Alto - Objective Design Standards Checklist Page 13 (c)(2) Façade Composition Building facades shall use a variety of strategies including building modulation, fenestration, and façade articulation to create visual interest and express a variety of scales through a variety of strategies. All facades shall include a minimum of three of the following façade articulation strategies to create visual interest: Che c k T h r e e o r M o r e ☐ A. Vertical and horizontal recesses such as a pattern of recessed grouping of windows or recessed panels. The recess shall be a minimum 4 inches in depth. ☐ B. Vertical and horizontal projections such as shading and weather protection devices or decorative architectural details. Projections shall be a minimum 4 inches in depth. ☐ C. Datum lines that continue the length of the building, such as cornices, with a minimum 4 inches in depth, or a minimum 2 inches in depth and include a change in material. ☐ D. Balconies, habitable projections, or Juliet balconies (every 20 to 40 feet) with a minimum 4 inches in depth. ☐ E. Screening devices such as lattices, louvers, shading devices, or perforated metal screens. ☐ F. Use of fine-grained building materials, such as brick or wood shingles, not to exceed 8 inches in either height or width. ☐ G. Incorporate a minimum of three colors, materials, and/or textures across the whole building. (c)(3) Compatible Rhythm and Pattern (A) Buildings shall express a vertical rhythm and pattern that reflects the size and scale of a housing unit and/or individual rooms and spaces. This may be achieved with building modulation to create vertically oriented façades (height greater than the width of the façade), façade articulation and fenestration repetitive vertically oriented patterns. Depending on the length of the façade, the following standards apply: ☐ i. For continuous façades less than 100 feet in length, the façade shall have vertically oriented patterns of vertical recesses or projections, façade articulation, and/or fenestration. ii. For continuous façades 100 feet or greater in length, the façade shall include either: Che c k On e ☐ a. A vertical recess or change in façade plane with a minimum 2 feet deep vertical shift modulation for a minimum 4 feet in width to establish a vertical rhythm between 20 to 50 feet in width; OR Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 50     City of Palo Alto - Objective Design Standards Checklist Page 14 ☐ b. A vertical recess or projection with a minimum depth of 2 feet that establishes the vertical rhythm between 10 to 16 feet in width (B) Residential mixed-use buildings Che c k O n e o r Mo r e ☐ i. Vertical Patterns and Modulation: Façades shall use vertical patterns of building modulation, façade articulation, and fenestration. ☐ ii. Horizontal Patterns and Modulation: Façades that use horizontal articulation and fenestration patterns shall use a vertical massing strategy with a minimum 4 feet wide and 2 feet deep vertical shift in modulation at least once every 50 feet of façade length. (C) Storefronts ☐ Storefront uses must express a vertical rhythm not to exceed 30 to 50 feet in width. (c)(4) Emphasize Building Elements & Massing (A)(i) Building Entries within Façade Design. Primary building entries shall be scaled proportionally to the number of people served (amount of floor-area or number of units accessed). Building entries shall meet the following minimum dimensions: Che c k A l l ☐ a. Individual residential entries: 5 feet in width ☐ b. Shared residential entry, such as mixed-use buildings: 8 feet in width ☐ c. Commercial building entry: 20 feet in width ☐ d. Storefront entry: 6 feet in width (ii) Primary building entries (not inclusive of individual residential entries) shall include a façade modulation that includes at least one of the following: Che c k On e o r Mo r e ☐ a. Recess or projection from the primary façade plane (minimum 2 feet). ☐ b. Weather protection that is a minimum 4 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods (c)(5) Storefront/Retail Ground Floors ☐ A. Ground floor height shall be a minimum 14 feet floor-to-floor OR shall maintain a 2nd floor datum line of an abutting building. a. Ground floor height (minimum 14 feet): _____ feet; OR b. Height of 2nd floor datum line of abutting building: _____ feet Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 51     City of Palo Alto - Objective Design Standards Checklist Page 15 ☐ B. Transparency shall include a minimum 60% transparent glazing between 2 and 10 feet in height from sidewalk, providing unobstructed views into the commercial space. a. Façade area between 2 feet and 10 feet: _____ sf b. Transparent glazing area between 2 feet and 10 feet: _____ sf c. Percentage of transparent glazing (minimum 60%): _____ % ☐ C. If provided, bulkheads and solid base walls measure between 12 and 30 inches from finished grade ☐ D. Primary entries shall include weather protection by recessing the entry, providing an awning or using a combination of these methods. a. Weather protection width (minimum 6 feet): _____ feet b. Weather protection depth (minimum 4 feet): _____ feet ☐ E. Awnings, canopies and weather protection: (i) When transom windows are above display windows, awnings, canopies and similar, weather protection elements shall be installed between transom and display windows. These elements should allow for light to enter the storefront through the transom windows and allow the weather protection feature to shade the display window. (ii) Awnings may be fixed or retractable (c)(6) Other Non-Residential Ground Floors ☐ (A) Ground floor height must be a minimum 14 feet floor-to-floor OR match the 2nd floor datum line of an abutting building Pic k On e ☐ Ground floor height (minimum 14 feet): _____ feet; OR ☐ Height of 2nd floor datum line of abutting building: _____ feet ☐ (B) Minimum of 50% transparent glazing between 4 and 10 feet in height from sidewalk or terrace grade, providing unobstructed views into the commercial space Façade area between 4 feet and 10 feet: _____ sf Transparent glazing area: _____ sf Percentage of transparent glazing (minimum 50%): _____ % ☐ (C) Primary entries include weather protection that is a minimum 6 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods. Weather protection width (minimum 6 feet): _____ feet Weather protection depth (minimum 4 feet): _____ feet Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 52     City of Palo Alto - Objective Design Standards Checklist Page 16 (c)(7) Parking/Loading/Utilities (A) Entry Size ☐ No more than 25% of the site frontage facing a street shall be devoted to garage openings, carports, surface parking, loading entries, or utilities access. On sites with less than 100 feet of frontage, no more than 25 feet. Site frontage: _____ feet Frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access: _____ feet Percent of frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access _____ % (B) Above Ground Structured Parking ☐ Above grade structured parking levels facing a public right-of-way or publicly accessible open space/path, with the exception of vehicular alleys, must be lined with commercial or habitable uses with a minimum depth of 20 feet (C)&(D) Partially Sub-Grade Structured Parking ☐ Partially sub-grade parking must not have an exposed façade that exceeds 5 feet in height above abutting grade at back of sidewalk. ☐ Partially sub-grade parking must be screened with continuous landscaping and shrubbery with minimum height of 3 feet and be located within 10 feet of the sub-grade parking. 18.24.070 Residential Entries Pick One or More (A – E) Standard Sheet # Applicant’s Justification (b)(1) Ground Floor Unit Entries Where ground floor residential unit entries are required, one or more of the following entry types shall be provided: ☐ (A) Stoop Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 53     City of Palo Alto - Objective Design Standards Checklist Page 17 Che c k A l l i f Sel e c t e d ☐ (i) Stoops provide entry access for a maximum of two ground floor units. ☐ (ii) Stoop heights are within one step of finished floor height of adjacent unit. ☐ (iii) Stoop entry landings are a minimum 5 feet in depth ☐ (iv) The maximum stoop height from the back of sidewalk grade is 5 feet. ☐ (B) Porch Che c k A l l i f Sel e c t e d ☐ (i) Porches provide entry access for a maximum of one ground floor unit. ☐ (ii) Porch heights are within one step of finished floor height of adjacent unit. ☐ (iii) Porches are large enough so a 6-foot by 6-foot square can fit inside ☐ (iv) The maximum porch height from the back of sidewalk grade is 5 feet. ☐ (C) Patio Entry Che c k A l l i f S e l e c t e d ☐ (i) Patio entries provide access for a maximum of two ground floor units. ☐ (ii) Patio entries are large enough so a 5-foot by 5-foot square can fit inside of the patio for each unit ☐ (iii) The patio shall include at least one of the following features to define the transition between public and private space: Pick O n e o r M o r e ☐ a. Row of shrubs: not exceeding 42 inches in height located between the sidewalk and the patio. One gallon size and max 3 feet on center ☐ b. Fence: not to exceed 36 inches in height located between the sidewalk and the patio with a gate or fence opening to provide access ☐ c. Metal, Wood, or Stone Wall: not to exceed 36 inches in height located between the sidewalk and the patio with gate or opening, AND a minimum 18-inch landscape strip is located between the wall and the abutting pedestrian way and entirely landscaped ☐ (D) Terrace Che c k A l l i f Sel e c t e d ☐ (i) Terraces provide entry access for multiple ground floor units. ☐ (ii) Terraces are a maximum height of 30 inches above the grade of the back of the adjacent sidewalk or accessway. ☐ (iii) Walls, fences and hedges on Terraces are a maximum of 42 inches tall and have a minimum transparency of 40%. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 54     City of Palo Alto - Objective Design Standards Checklist Page 18 ☐ (E) Frontage Court Che c k A l l i f S e l e c t e d ☐ (i) Frontage courts provide entry access for multiple ground floor units. ☐ (ii) The minimum frontage court width along a primary frontage is 25 feet. ☐ (iii) The maximum frontage court width along a primary frontage is 50% of the facade length or 80 feet, whichever is less. ☐ (iv) The minimum Frontage Court depth is 25 feet. ☐ (v) The maximum Frontage Court depth is 50 feet or a ratio not to exceed 2:1 depth to width. 18.24.080 Open Space Check Standard Sheet # Applicant’s Justification (b)(1) Private Open Space ☐ (A) Floor area includes clear space with a minimum dimension of a circle with a six- foot diameter. ☐ (B) Minimum clear height dimension of 8’-6” feet. ☐ (C) Directly accessible from a residential unit. ☐ (C) Balconies are not located within the daylight plane. (b)(1)(E) Private Open Space - Ground Floor Patios ☐ (i) RM-20 and RM-30 districts: Minimum 100 sf of area, the least dimension of which is 8 feet for at least 75% of the area. ☐ (ii) RM-40 districts: Minimum 80 sf of area, the least dimension of which is 6 feet for at least 75% of the area ☐ (iii) Street facing private open space on the ground floor shall meet the finished floor height for ground floor residential standards in section 18.24.040(b)(4) Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 55     City of Palo Alto - Objective Design Standards Checklist Page 19 (b)(2) Common Open Space ☐ (A)&(B) Minimum 200 sf of area. Area shall include a space with a minimum dimension of a circle with a 10-foot diameter. ☐ (C) A minimum of 60% of the area shall be open to the sky and free of permanent weather protection or encroachments. Trellises and similar open-air features allowed ☐ (D) Notwithstanding subsection (1), courtyards enclosed on four sides shall have a minimum dimension of 40 feet and have a minimum courtyard width to building height ratio of 1:1.25 ☐ (E) Common open space provides seating. ☐ (F) Common open space has a minimum 20% of landscaping. ☐ (G) Planting in above grade courtyards has minimum soil depth of 12 inches for ground cover, 20 inches for shrubs, and 36 inches for trees. 18.24.090 Materials Check Standard Sheet # Applicant’s Justification ☐ (b)(1) Primary, secondary, and accent materials are allowed or prohibited as in the Residential and Residential Mixed-use Material List, which may be updated from time to time by the Director of Planning with a recommendation by the ARB. See webpage for list - https://www.cityofpaloalto.org/News-Articles/Planning-and-Development- Services/Multifamily-Mixed-Use-Objective-Standards 18.24.100 Sustainability and Green Building Code Check Standard Sheet # Applicant’s Justification ☐ (b) See Chapter 16.14: California Green Building Standards additional requirements for green building and sustainable design. Notwithstanding Section 18.24.010(c), these regulations may not be modified through alternative compliance. Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 56     PLANNING & Development Services 250 Hamilton Avenue, 5th Floor Palo Alto, CA 94301 650-329-2441 www.cityofpaloalto.org HOUSING PROJECTS - Affordable Housing Plan Specifications Project Address: ____________________________________________________________________________ All housing development projects that require or include affordable residential units shall submit an Affordable Housing Plan (AHP) document in conformance with PAMC Chapter 16.65 specifying the manner in which affordable units will be provided in conformance with this chapter. The AHP shall include the project-specific details listed below and be provided at the time of application submittal. 1)Project Overview  Provide summary of overall project proposal and indicate the number of existing and proposed residential units, the BMR requirements and proposed unit mixes. Existing Units Total Proposed Unit in Project BMR Required Units 15% for ≤ 5 acres, 20% for ≥ 5 acres, and 25% for condo conversion Unit Type Number of Units Unit Square Footage Number of BMR Units Designated Income Level Plan Sheet For ownership, 66% for 80-100% AMI; 33% for 100-120% AMI. For condo conversion 25% for lower incomes as defined by HCD Studio 1 Bedroom 2 Bedroom 3 Bedroom 4+ Bedrooms TOTAL  If applicable, description of the request for Density Bonus and concessions i.e. a detailed letter detailing density bonus concessions request and how each concession relates to the affordability of the project 2)Plans  Site plan and floor plans that include location of each BMR unit clearly identified on the site plan equally distributed on the project site 3)Affordability  Detailed description and chart of each BMR unit’s: tenure, size, type, relative to total number of units 4)If Density Bonus, Financial documentation  Financial justification of each specific development concession and how it clearly demonstrates how grant will reduce the cost of the project in accordance with the findings in PAMC 18.15. 5)Relocation and Displacement  Does the project require relocation and displacement? If so, as part of Affordable Housing Plan, state how the project will mitigate, relocate and prevent displacement. 2100-2400 Geng Road N/A See Attached Affordable Housing Plan LowIncome LowIncome See Attached Affordable Housing Plan See Attached Affordable Housing Plan 0 145 0 0 0 70 75 191,660 - 1,846 2,255 - 3,050 See Sheet A.7; see also Affordable Housing Plan for information regarding requested SDBL concession regarding BMR distribution A.37, 38 A.31-36, 39 19 (13%) Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 57     6)Timeline for completion  If applicable, an alternative phasing plan may be approved as part of the approval, otherwise all BMR units to be completed with the same Under provision PAMC 16.65.075, all BMR units constructed under this condition shall be in conformance and shall be comparable in exterior appearance and overall quality of construction to market-rate units in the same housing development. Interior finishes and amenities must equal those provided in the base model market-rate units.  BMR Completion 60-Day Advance Notice or “Notice of Intent to Sell” to the Planning Department of each BMR unit(s) to provide in the development at least sixty (60) days (but no more than ninety (90) days) prior to the request for a certificate of occupancy or receipt of a DRE report for the unit, whichever is later.  Upon receipt of this Notice, the Senior Planner will inform the applicant of the current maximum BMR sales price applicable to the unit in coordination with Alta Housing, which administers the City’s BMR program.  If applicable, the applicant can propose to dedicate vacant land suitable for affordable housing or to construct affordable units on another site. Two or more applicants may also jointly propose the provision of vacant land suitable for affordable housing or the construction of off-site affordable units on a single site. ▪If so, the dedicate of qualifying land must include parcel APN(s), general plan and zoning designation, preliminary title report showing the applicant as owner, recent land survey and current environmental report(s), fair market value appraisal, schedule of transfer  Proposal to mitigate the affordable housing impacts of the non-residential and residential rental portions of the development through any of the options listed above or through on-site provision of affordable units conforming with applicable provisions of PAMC 16.15. If yes, the required Affordable Housing Plan document must list the projected unit yield as determined in the Housing Element (see Parcel Report for details) and discuss the project’s compliance with this unit yield. If yes, include in the project description details of what is proposed for the project and how the project would qualify for all requested density increases and/or concessions. When requesting concessions, clearly describe which ones are being requested for the project. Please complete following table and include in Affordable Housing Plan document. Total Units Prior to Density Bonus Proposed % Density Bonus Request Number of Restricted BMR Units Proposed Income Level of Restricted BMR Units Total Units with Density Bonus Number of Concessions Allowed Number of Concessions Requested 137 0% 137 Reserve right to Low Income 145 N/A 19 Low Income 145 3 1 (2 reserved) Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 58     2100-2400 Geng Road AAordable Housing Plan 9/26/25 This narrative document should be read in concert with the completed “AAordable Housing Plan Specification” checklist/worksheet document that precedes it. AAordable Housing Plan: The project will construct 145 for-sale residential units on a +/- 11-acre site located at 2100-2400 Geng Road. There are no existing residential units on the project site, thus no residential units will be demolished and no residential tenants or residents will be displaced. Per AB 1893, the project will provide 13% low-income BMR units, resulting in 19 total BMR units, all in Unit Plan 11, a 3- bedroom unit plan with a two car tandem garage. Tables summarizing the BMR units are below. The project may be constructed in phases. If this occurs, BMR units will be provided in proportion to market rate units through each phase. See Section III of the Project Description document for additional detail on the project’s aAordable housing and state Density Bonus Law strategy. Density Bonus: By providing 13% BMR units restricted to low-income households, the project qualifies for a density bonus, unlimited waivers, and three concessions/incentives under the state Density Bonus Law and AB 1893. The project does not seek an increase in density. Requested waivers are described in detail in the Project Description. At this time, the project requests one concession: Under PAMC 16.65.075(a)(2), aAordable units “shall be reasonably dispersed” within the residential project, with unit locations “comparable” to those of the market-rate units. Further, aAordable units must have a comparable number of bedrooms to the market rate units. PAMC 16.65.075(a)(2) also allows for the Planning Director to approve clustering of BMR units within the residential project “when this furthers aAordable housing opportunities.” The proposed site plan proposes larger, four-bedroom pull-apart townhouse units in the northern section of the site and smaller, three- and four-bedroom attached townhouse units in the balance of the site. The project’s 19 BMR units have been well distributed throughout the attached townhouse buildings and are all located within Unit Plan 11 units – a three-bedroom unit type with a two-car tandem garage. The project’s proposed BMR distribution plan is provided on Sheet A.7 of the plan sets and is intended to meet the City’s distribution standard. However, we understand that Planning staA have indicated that the BMR distribution as proposed may not meet its PAMC 16.65.075(a)(2) requirement. As a result, if staA ultimately determines that the proposed BMR distribution plan does not meet its PAMC 16.65.075(a)(2) standard, the project seeks a concession for this requirement. Additional discussion of this concession is provided in the project description. The project reserves the right to identify and utilize the two available additional incentives/ concessions as the project advances through the entitlement process. Housing Inventory Site: Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 59     The project is on two existing parcels, APNs: 008-02-035 and 008-02-036. APN 008-02-035 is listed as a Housing Inventory Site with a target yield of 175 units. The project is proposing to provide 145 units, thus it is not meeting the target yield. The rationale behind this is discussed in detail in the Project Description. The following table summarizes the BMR units by bedroom count and AMI relative to the overall project. Project Summary 3 Beds 4 Beds Total Units Number of Units by Bedroom Count 70 75 145 MR Units as % of Total Units 48.3% 51.7% BMR Units by Bedroom Count 19 0 19 BMR Units as % of Total BMR Units 100.0% 0.0% 13.1% The following table describes each BMR unit in the project. BMR Unit Number (Subject to change) Bedroom Count Square Feet AMI Tenure BMR-1 3 1,660 Low Income For Sale BMR-2 3 1,660 Low Income For Sale BMR-3 3 1,660 Low Income For Sale BMR-4 3 1,660 Low Income For Sale BMR-5 3 1,660 Low Income For Sale BMR-6 3 1,660 Low Income For Sale BMR-7 3 1,660 Low Income For Sale BMR-8 3 1,660 Low Income For Sale BMR-9 3 1,660 Low Income For Sale BMR-10 3 1,660 Low Income For Sale BMR-11 3 1,660 Low Income For Sale Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 60     BMR-12 3 1,660 Low Income For Sale BMR-13 3 1,660 Low Income For Sale BMR-14 3 1,660 Low Income For Sale BMR-15 3 1,660 Low Income For Sale BMR-16 3 1,660 Low Income For Sale BMR-17 3 1,660 Low Income For Sale BMR-18 3 1,660 Low Income For Sale BMR-19 3 1,660 Low Income For Sale Item 2 Attachment D - Applicant’s Project Description Letter     Packet Pg. 61     City of Palo Alto - Objective Design Standards Checklist Page 1 Objective Design Standards Checklist The Objective Design Standards Checklist is a tool to evaluate a project’s compliance with the Zoning Ordinance (Chapter 18.24). The Checklist is not the Zoning Ordinance. Applicants shall be responsible for meeting the standards in the Zoning Ordinance. To simplify evaluation of the Zoning Ordinance, language in the Checklist may vary from the Zoning Ordinance. (Note: sf = square feet) If a standard is not applicable to applicant’s project, please write N/A in Applicant’s Justification column. 18.24.020 Public Realm/Sidewalk Character Check Standard Sheet #Notes (b)(1) Sidewalk Widths (A) In the following districts, public sidewalk width (curb to back of walk) is at least: Commercial Mixed-Use District: CN, CS, CC, CC(2), CD-C, CD-S, CD-N, PTOD: 10 ft El Camino Real: 12 ft San Antonio Road, from Middlefield Road to East Charleston Road: 12 ft And consists of: Pedestrian clear path width of 8 foot minimum: 5 feet ☐ Landscape or furniture area width of 2 foot minimum: 7 feet ☐ If the existing public sidewalk does not meet the minimum standard, a publicly accessible extension of the sidewalk, with corresponding public access easement, shall be provided. ☐ (B) Public sidewalks or walkways connecting through a development parcel (e.g. on a through lot with a public access easement, leading to a commercial entry) must be at least 6 feet wide. Private walkways will be provided. ☒(C) The width of walkways designed to provide bicycle access (e.g. pathway to bike racks/lockers) must be at least 12 feet wide, consisting of: L1 Two of the bike racks are located immediately adjacent to the main circulation drive so 12' pedestrian access is not required. The 4 bike racks on the central green is connected Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 62     City of Palo Alto - Objective Design Standards Checklist Page 2 by a 8' wide walkway with min 2' buffers on either side. Pedestrian clear path width (8 feet min.): 8 ft Clear space/buffer – (2 feet min. on each side of path, ground cover is allowed): not dimensioned, but appears to be at least 2 ft. Check Standard Sheet #Applicant’s Justification (B)(2) Street Trees 1. One street tree provided for every 30 linear feet of public sidewalk length and located within six feet of the sidewalk. Complies a. Length of parcel frontage/public sidewalk length: 154 ft L1 b. Street Trees required (i.e. frontage/30 feet): 5 ft ☒ c. Street Trees provided: 5 (2 existing + 3 new) (B)(3) Accent Paving Parcels abutting University Avenue between Alma Street and Webster include accent paving along the project frontages, as indicated below: Brick paving at corners ☐ Brick trim mid-block ☐Parcel abutting California Avenue between El Camino Real and Park Blvd include decorative glass accent paving along project frontages (B)(4) Mobility Infrastructure ☒ (A) On-site micromobility infrastructure (e.g. bike racks/lockers) is located within 30 feet of the primary building entry and/or on a path leading to the primary building entry; OR L1.0 L1.1 Waiver requested Pic k O n e ☐Existing micromobility infrastructure (e.g. bike racks/lockers) is already located within 50 feet of project site and located in a public right-of-way. Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 63     City of Palo Alto - Objective Design Standards Checklist Page 3 ☒ (B) Primary building entries shall provide at least one seating area or bench within 30 feet of building entry and/or path leading to building entry. On arterials (see Map T-5), except Downtown, seating areas or benches shall not be located between the sidewalk and the curb; OR L1.0 L1.1 Waiver requested Pic k O n e ☐Existing seating areas or benches that are already located in the public right-of-way within 50 feet of the building entry. 18.24.030 Site Access Check Standard Sheet #Applicant’s Justification (b)(1) Through Lot Connections ☐ Through lots located more than 300 feet from an intersecting street or pedestrian walkway shall provide a publicly accessible sidewalk or pedestrian walkway (with public access easements) connecting the two streets. (b)(2) Building Entries ☒ Primary Building Entries shall be located from a public right-of-way. If there is no public right-of-way adjacent to the building, entries shall be located from a private street or Pedestrian Walkway. A.4 Complies (b)(3) Vehicle Access ☒(A) Vehicle access shall be located on alleys or side streets when they abut the property.A.4 Complies ☒ (B) Except for driveway access and short-term loading spaces (e.g. taxi), off-street parking, off-street vehicle loading (delivery trucks), and vehicular circulation areas are prohibited between the building and primary building frontage. A.4 Complies (b)(4) Loading Docks and Service Areas Loading and service areas shall be integrated into building and landscape design and located to minimize impact on the pedestrian experience as follows:No loading provided. ☒(A) Loading docks and service areas shall be located on façades that do not face a primary building frontage Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 64     City of Palo Alto - Objective Design Standards Checklist Page 4 ☒ (B) Loading docks and service areas located within setback areas shall be screened by a solid fence, or wall, or dense landscaping and separated from pedestrian access to the primary building entry to avoid impeding pedestrian movement/safety. 18.24.040 Building Orientation and Setbacks Check Standard Sheet #Applicant’s Justification (b)(1) Building Corner Elements (less than 40 feet in height) Corner buildings less than 40 feet in height and end units of townhouses or other attached housing products that face the street shall include all of the following features on their secondary building frontage: (A) height and width of corner element shall have a ratio greater than 1.2:1. For townhomes, the width would be equal to the smaller side of one unit?Buildings above 40 feet a. Secondary building frontage height: _____ feet b. Secondary building frontage length: _____ feet ☐ c. Secondary building frontage height to width ratio: ___ (B) minimum of 15% fenestration area. a. Total secondary building frontage façade area: ___ sf b. Secondary building frontage façade fenestration area: ___ sf☐ c. Percent of fenestration area _____ % Che c k A l l ☐(C) At least one facade modulation with a minimum depth of 18 inches and a minimum width of two feet. (b)(2)(A) & (B) Treatment of Buildings Corners on Corner Lots (40+ feet in height) Corner Buildings 40 feet or taller in height shall include at least one of the following special features: Che c k On e o r Mo r e wit h i n A or B A. Street wall is located at the minimum front yard setback or build-to line for a minimum aggregated length of 40 feet on both facades meeting at the corner and includes one or more of the following building features: Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 65     City of Palo Alto - Objective Design Standards Checklist Page 5 ☐i. An entry to ground floor retail or primary building entrance located within 25 feet of the corner of the building. ☒ii. A different material application and/or fenestration pattern from the rest of the façade.A.15 Complies ☐iii. A change in height of at least 4 feet greater or less than the height of the adjacent/abutting primary façade. B. An open space with a minimum dimension of 20 feet and minimum area of 450 sf. The open space shall be at least one of the following ☐i. A publicly accessible open space/plaza. ☐ii. A space used for outdoor seating for public dining. Che c k O n e o r Mo r e w i t h i n A o r B ☐ iii. A residential Common Open Space adjacent to a common interior space (i.e. lobby, retail, etc.) and less than two feet above adjacent sidewalk grade. Fences and railing shall be a minimum 50% open/transparent. (b)(3) Primary Building Entry The primary building entry meets at least one of the following standards: ☐A. Faces a public right-of-way. ☒B. Faces a publicly accessible pedestrian walkway.A.4 Complies C. Is visible from a public right-of-way through a forecourt or front porch that meets the following standards: i. For residential buildings with fewer than seven units, building entry forecourts or front porch minimum dimensions of (min. 36 sf and min. dimension of 6 feet required): ___ sf and ___ ft. min. dimension Ch e c k O n e o r M o r e ☐ii. For commercial buildings or residential buildings with seven or more units, building entry forecourts or front porch minimum dimensions of (min. 100 sf and a min. width of 8 feet required): ___ sf and ___ ft. min. width (b)(4) Ground Floor Residential Units A. Finished Floor Height for Ground Floor Units ☐The finished floor of ground floor residential units, when adjacent to a public right-of- way, must be within the minimum and maximum heights according to setback distance N/A, no ground floor units. Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 66     City of Palo Alto - Objective Design Standards Checklist Page 5 Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 67     City of Palo Alto - Objective Design Standards Checklist Page 6 from back of walk identified in Figure 2a and 2b of the Zoning Ordinance. Calculate minimum ground floor finished floor height: ☐Setback adjacent to public right of way: 20 feet ☐ Minimum ground floor finished floor height: ___0__ feet 𝒚 = ―𝟒 𝟏𝟓(𝒙)+ 𝟏𝟔 𝟑 where 𝑥 = setback length from back of walk, in feet and 𝑦 = ground floor finished floor height, in feet The site is located in a flood zone so all building ground floor heights will be raised and thus higher than the elevation of Geng Road. Proposed finished ground floor height is 11.5 feet. ☐Sites with slopes greater than 2% along building façade – Average height of finished floor: _____ feet Che c k A l l t h a t A p p l y ☒Sites located in flood zones – the minimum ground floor finished floor height shall be defined by FEMA, less flood zone elevation: _11____ feet B. Setback Trees Ground floor units with a setback greater than 15 feet must have at minimum an average of one tree per 40 linear feet of facade length, within the setback area. Ground floor units are setback greater than 15' only along Geng avenue. Facade length: 47’ 8” Trees required: 2 tree(s) (i.e. façade length / 40) ☐ Trees provided: 8 tree(s) C and D. Front Setback ☒C. Ground floor residential entries are setback a minimum of 10 feet from the back of public sidewalk; OR C2.0 Pic k O n e ☐ D. Where no minimum building setback is required, all ground floor residential units must be set back a minimum 5 feet from back of public sidewalk. Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 68     City of Palo Alto - Objective Design Standards Checklist Page 7 Check Standard Sheet #Applicant’s Justification E. Unit Entry A minimum 80% of ground floor residential units that face a public right-of-way or publicly accessible path, or open space shall have a unit entry with direct access to the sidewalk, path, or open space for minimum. A.4 See pedestrian circulation plan. a. Total number of ground floor residential units facing a public right-of-way, publicly accessible path, or open space: 145 units b. 80% of total units in (a): 116 units ☐ c. Subset of number of units in (a) that have a unit entry with direct access to the sidewalk, path, or open space: 145 entries (b)(5) Front Yard Setback Character Required setbacks provide a hardscape and/or landscaped area to create a transition between public and private space. The following standards apply, based on intended use and exclusive of areas devoted to outdoor seating, front porches, door swing of building entries, and publicly accessible open space and meet the following: (A). Ground-floor retail or retail like uses have a minimum of 10% of the required setback as landscape or planters.N/A i. Minimum setback area (setback x frontage x 10%): ____ sf☐ ii. Landscape or planter area in required setback: ____ sf Che c k A l l t h a t Ap p l y ☒(B). Ground-floor residential uses have a minimum of 60% landscaped area in the required setback area. L.1 Front Setback is only applicable along Geng Road Road. Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 69     City of Palo Alto - Objective Design Standards Checklist Page 7 Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 70     City of Palo Alto - Objective Design Standards Checklist Page 8 i. Minimum setback area (setback x frontage x 60%): 3,121 sf ii. Landscape area in required setback: 4,518 sf (b)(6) Side Yard Setback Character ☒ (A) Each detached dwelling unit shall have at least one usable side yard, at least six feet wide, between the house and fence or other structure, to provide outdoor passage between the front and rear yards. Waiver requested 18.24.050 Building Massing Check Standard Sheet #Notes (b)(1) Upper Floor Step Backs and Daylight Planes (A) When the height of the subject building is more than 20 feet above the average height (i.e. average of low and high roof elevations) of an adjacent building(s), an upper floor step back shall start within two vertical feet of the average height of the adjacent building. The step back shall be a minimum depth of six feet along both the façade on the primary building frontage and the façade facing the adjacent building, and the step shall occur for a minimum of 70% of each façade length. A310 N/A proposed buildings are no more than 20 feet above the average height of adjacent commercial buildings i. Proposed building height: 44 feet ii. Average building height of the adjacent building(s): 27 feet ☐ iii. Building height where upper floor step back begins: ☐(B) Notwithstanding, subsection (A), when adjacent to a single-story building, the upper floor step back shall occur between 33 and 37 feet in height. ☐ (C) If a project meets the following criteria, a daylight plane with an initial height of 25 feet above grade at the property line and a 45-degree angle shall be required. This daylight plane is required if all of these criteria are met: i. The project is not subject to a daylight plane requirement, pursuant to district regulations in Title 18; and ii. The project proposes a building which is more than 20 feet above the average height (i.e., average of low and high roof elevations) of an adjacent building(s); and N/A, no residential units abut this project. Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 71     City of Palo Alto - Objective Design Standards Checklist Page 9 iii. The project abuts residential units in the side or rear yard. (b)(2) Privacy and Transitions to Residential Uses When a building abuts a residential use on an interior side and/or rear property line, the building shall break down the abutting façade and maintain privacy by meeting all of the following:N/A ☐ (A) Landscape Screening. A landscape screen that includes a row of trees with a minimum one tree per 25 linear feet and continuous shrubbery planting. This screening plant material shall be a minimum 72 inches (6 feet) in height when planted. Required trees shall be minimum 24” box size. ☐(B) Façade Breaks. A minimum façade break of 4 feet in width, 2 feet in depth, and 32 sf of area (i.e. 8 ft tall minimum) for every 36 to 40 feet of façade length ☐ (C) Maximum Amount of Transparent Windows. Within 40 feet of an abutting structure, no more than 15% of the facing façade area shall be windows or other glazing. Additional windows are allowed in order to maintain light, if fixed and fully obscured (D) Windows. Within 30 feet of facing residential windows (except garage or common space windows) or private open space on an adjacent residential building, facing windows on the subject site shall meet the following: (i) Window sills at and above the 2nd floor shall be at least five feet above finished floor; or (ii) Windows shall have opaque or translucent glazing at or below five feet above finished floor; or (iii) Windows shall be angled up to 30 degrees (parallel to window) to face away from the adjacent privacy impacts; and (iv) Landscape screening shall be 24-inch box size or larger and eight+ feet height at planting; 50% evergreens; and located to align with proposed second floor windows at maturity. Che c k A l l (E). Balconies: Within 30 feet of residential windows (except garage or common space windows) or private open space on an adjacent residential building, balconies and decks on the subject site shall be designed to prevent views: (i) No sight lines to the adjacent property window or open space are permitted within five feet above the balcony or deck flooring and a 45- Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 72     City of Palo Alto - Objective Design Standards Checklist Page 10 degree angle downward from balcony railing. (ii) Submit section view of proposed balcony/deck and abutting residential windows and/or private open space. (iii) Provide balcony/deck design measure which may include: a. Minimum 85% solid railing b. Obscure glass railing c. Barrier with min. 18" horizontal depth from railing (e.g. planter) (b)(3)(A) & (B) Maximum Façade Length - facing a street or public path Buildings 70 feet in length or greater and greater than 25 feet in height For building facades 70 feet in length or greater and facing a public street, right- of-way, or publicly accessible path shall not have a continuous façade plane greater than 70% of the façade length without an upper floor modulation, of at least 2 feet in depth Largest façade length featuring continuous plane: Total Façade length: 342 feet 9 inches ☐ Percent of façade length without upper floor modulation (a/b) (maximum 70%): ____ % Buildings 250 feet in length or greater (A) Buildings 250 feet in length or greater, which face a public street, right-of- way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 400 sf and a width greater than or equal to two times the depth Total Building length: _____ feet ☐ Number of vertical façade breaks: ___ area Width: ____ feet, Depth: ____ feet, Area: ____ sf Buildings between 150 feet and 250 feet in length Pic k O n e C a t e g o r y ☐ (B) Buildings 150 to 250 feet in length, which face a public street, right-of-way, or publicly accessible path, shall have at least one vertical façade break with a minimum area greater than 64 sf and a minimum width of 8 feet and minimum depth of 4 feet. Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 73     City of Palo Alto - Objective Design Standards Checklist Page 11 Total Building length: Number of vertical façade breaks: Width: Check Standard Sheet #Applicant’s Justification (b)(4) Special Conditions: Railroad Frontages All parcels with lot lines abutting railroad rights-of-way shall meet the following standards on the railroad-abutting façade(s):N/A ☐(A) A minimum facade break of at least 10 feet in width and six feet in depth for every 60 feet of façade length. Che c k All ☐(B) For portions of a building 20 feet or greater in height shall not have a continuous façade length that exceeds 60 feet. (b)(5) Diversity of Housing Types ☒ A diversity of housing types (e.g. detached units, attached rowhouses/townhouses, condominiums or apartments, mixed use) are required for projects on large lots: Less than one acre lots: minimum 1 housing types 1 to 2-acre lots: minimum 2 housing types; or More than 2-acre lots: minimum 3 housing types A.5 Font Loaded standalone Townhomes Alley loaded standalone Townhomes Alley Loaded Row Townhomes 18.24.060 Façade Design Check Two or More Standard Sheet #Applicant’s Justification (c)(1) Base-Middle-Top ☒ Buildings three stories or taller and on lots wider than 50 feet shall be designed to differentiate a defined base or ground floor, a middle or body, and a top, cornice, or parapet cap. Each of these elements shall be distinguished from one another for a minimum of 80% of the façade length through use of three or more of the following four techniques: Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 74     City of Palo Alto - Objective Design Standards Checklist Page 11 Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 75     City of Palo Alto - Objective Design Standards Checklist Page 12 ☐i. Variation in Building Modulation: Building modulation shall extend for a minimum 80% of the façade length feet, and shall include one or more of the following building features. ☒a. Horizontal shifts. Changes in floor plates that protrude and/or recess with a minimum dimension of 2 feet from the primary facade. A.7 – A.16 Complies ☐ b. Upper floor step backs. A horizontal step back of upper-floor façades with a minimum 5 foot stepback from the primary façade for a minimum of 80% of the length of the façade Che c k o n e o r m o r e i f sel e c t e d ☐ c. Ground floor step back. A horizontal shift of the ground floor facade with a minimum depth of 2 feet for a minimum 80% of the length of the façade. Ground floor step backs shall not exceed the maximum setback, where stated ☒ii. Variation in Façade Articulation: Façade articulation modulation shall include one or more of the following building features. ☐ a. Horizontal and/or Vertical Recesses or Projections. Recesses or projections such as a pattern of recessed grouping of windows, recessed panels, bay windows or similar strategies. The recess or projection shall be a minimum 4 inches in depth. ☒ b. Horizontal and/or Vertical Projections. Projections such as shading, weather protection devices, decorative architectural details, or similar strategies. A.7 – A.16 Complies Ch e c k o n e o r m o r e i f sel e c t e d ☐ c. Datum Lines. Datum lines that continue the length of the building, such as parapets or cornices, with a minimum 4 inches in height or a minimum 2 inches in depth and include a change in material ☒iii. Variation in two of the following:A.7 – A.16 Complies ☒a. Fenestration Size ☒b. Fenestration Proportion ☒c. Fenestration Pattern Ch e c k t w o i f sel e c t e d ☐d. Fenestration Depth or Projection ☒iv. Variation in two of the following:A.7 – A.16 Complies Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 76     City of Palo Alto - Objective Design Standards Checklist Page 13 ☒a. Façade Material ☒b. Facade Material Size ☐c. Façade Texture and Pattern Che c k t w o i f sel e c t e d ☒d. Façade Color (c)(2) Façade Composition Building facades shall use a variety of strategies including building modulation, fenestration, and façade articulation to create visual interest and express a variety of scales through a variety of strategies. All facades shall include a minimum of three of the following façade articulation strategies to create visual interest: ☐A. Vertical and horizontal recesses such as a pattern of recessed grouping of windows or recessed panels. The recess shall be a minimum 4 inches in depth. ☒B. Vertical and horizontal projections such as shading and weather protection devices or decorative architectural details. Projections shall be a minimum 4 inches in depth. A.7 – A.16 Complies ☐ C. Datum lines that continue the length of the building, such as cornices, with a minimum 4 inches in depth, or a minimum 2 inches in depth and include a change in material. ☒D. Balconies, habitable projections, or Juliet balconies (every 20 to 40 feet) with a minimum 4 inches in depth. A.7 – A.16 Complies ☐E. Screening devices such as lattices, louvers, shading devices, or perforated metal screens. ☐F. Use of fine-grained building materials, such as brick or wood shingles, not to exceed 8 inches in either height or width. Che c k T h r e e o r M o r e ☒G. Incorporate a minimum of three colors, materials, and/or textures across the whole building. A.7 – A.16 Complies (c)(3) Compatible Rhythm and Pattern (A) Buildings shall express a vertical rhythm and pattern that reflects the size and scale of a housing unit and/or individual rooms and spaces. This may be achieved with building modulation to create vertically oriented façades (height greater than the width of the façade), façade articulation and fenestration repetitive vertically oriented patterns. Depending on the length of the façade, the following standards apply: Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 77     City of Palo Alto - Objective Design Standards Checklist Page 14 ☐i. For continuous façades less than 100 feet in length, the façade shall have vertically oriented patterns of vertical recesses or projections, façade articulation, and/or fenestration. ii. For continuous façades 100 feet or greater in length, the façade shall include either: ☒ a. A vertical recess or change in façade plane with a minimum 2 feet deep vertical shift modulation for a minimum 4 feet in width to establish a vertical rhythm between 20 to 50 feet in width; OR A.7 – A.16 Complies Che c k O n e ☐b. A vertical recess or projection with a minimum depth of 2 feet that establishes the vertical rhythm between 10 to 16 feet in width (B) Residential mixed-use buildings ☐i. Vertical Patterns and Modulation: Façades shall use vertical patterns of building modulation, façade articulation, and fenestration. Ch e c k O n e o r Mo r e ☐ ii. Horizontal Patterns and Modulation: Façades that use horizontal articulation and fenestration patterns shall use a vertical massing strategy with a minimum 4 feet wide and 2 feet deep vertical shift in modulation at least once every 50 feet of façade length. (C) Storefronts ☐Storefront uses must express a vertical rhythm not to exceed 30 to 50 feet in width. (c)(4) Emphasize Building Elements & Massing (A)(i) Building Entries within Façade Design. Primary building entries shall be scaled proportionally to the number of people served (amount of floor-area or number of units accessed). Building entries shall meet the following minimum dimensions: ☒a. Individual residential entries: 5 feet in width A.23 - A.29 Complies ☐b. Shared residential entry, such as mixed-use buildings: ☐c. Commercial building entry: Che c k A l l ☐d. Storefront entry: (ii) Primary building entries (not inclusive of individual residential entries) shall include a façade modulation that includes at least one of the following: C h e c k O n e o r M o r e☐a. Recess or projection from the primary façade plane (minimum 2 feet). Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 78     City of Palo Alto - Objective Design Standards Checklist Page 15 ☐b. Weather protection that is a minimum 4 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods (c)(5) Storefront/Retail Ground Floors A. Ground floor height shall be a minimum 14 feet floor-to-floor OR shall maintain a 2nd floor datum line of an abutting building. a. Ground floor height (minimum 14 feet): _____ feet; OR☐ b. Height of 2nd floor datum line of abutting building: B. Transparency shall include a minimum 60% transparent glazing between 2 and 10 feet in height from sidewalk, providing unobstructed views into the commercial space. a. Façade area between 2 feet and 10 feet: b. Transparent glazing area between 2 feet and 10 feet: ☐ c. Percentage of transparent glazing (minimum 60%): ☐C. If provided, bulkheads and solid base walls measure between 12 and 30 inches from finished grade D. Primary entries shall include weather protection by recessing the entry, providing an awning or using a combination of these methods. a. Weather protection width (minimum 6 feet): ☐ b. Weather protection depth (minimum 4 feet): ☐ E. Awnings, canopies and weather protection: (i) When transom windows are above display windows, awnings, canopies and similar, weather protection elements shall be installed between transom and display windows. These elements should allow for light to enter the storefront through the transom windows and allow the weather protection feature to shade the display window. (ii) Awnings may be fixed or retractable (c)(6) Other Non-Residential Ground Floors ☐(A) Ground floor height must be a minimum 14 feet floor-to-floor OR match the 2nd floor datum line of an abutting building ☐Ground floor height (minimum 14 feet): _____ feet; OR Pic k On e ☐Height of 2nd floor datum line of abutting building: ☐(B) Minimum of 50% transparent glazing between 4 and 10 feet in height from sidewalk or terrace grade, providing unobstructed views into the commercial space Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 79     City of Palo Alto - Objective Design Standards Checklist Page 16 Façade area between 2 feet and 10 feet: Transparent glazing area: Percentage of transparent glazing (minimum 50%): (C) Primary entries include weather protection that is a minimum 6 feet wide and 4 feet deep by recessing the entry, providing an awning or using a combination of these methods. Weather protection width (minimum 6 feet): ☐ Weather protection depth (minimum 4 feet): (c)(7) Parking/Loading/Utilities (A) Entry Size No more than 25% of the site frontage facing a street shall be devoted to garage openings, carports, surface parking, loading entries, or utilities access. On sites with less than 100 feet of frontage, no more than 25 feet. C2 Site frontage: 204 Feet Frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access: 25 feet and 26 feet driveway access into the project site ☒ Percent of frontage devoted to garage openings, carports, surface parking, loading entries, or utilities access 10.7% and 83% (B) Above Ground Structured Parking ☐ Above grade structured parking levels facing a public right-of-way or publicly accessible open space/path, with the exception of vehicular alleys, must be lined with commercial or habitable uses with a minimum depth of 20 feet (C)&(D) Partially Sub-Grade Structured Parking ☐Partially sub-grade parking must not have an exposed façade that exceeds 5 feet in height above abutting grade at back of sidewalk.N/A ☐Partially sub-grade parking must be screened with continuous landscaping and shrubbery with minimum height of 3 feet and be located within 10 feet of the sub-grade parking.N/A Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 80     City of Palo Alto - Objective Design Standards Checklist Page 17 18.24.080 Open Space Check Standard Sheet #Applicant’s Justification (b)(1) Private Open Space ☒(A) Floor area includes clear space with a minimum dimension of a circle with a six- foot diameter.A.23 – A.29 Complies ☒(B) Minimum clear height dimension of 8’-6” feet.A.23 – A.29 Complies ☒(C) Directly accessible from a residential unit.A.23 – A.29 Complies ☐(C) Balconies are not located within the daylight plane. (b)(1)(E) Private Open Space - Ground Floor Patios ☒ (i) RM-20 and RM-30 districts: Minimum 100 sf of area, the least dimension of which is 8 feet for at least 75% of the area.C2.0 Complies ☐ (ii) RM-40 districts: Minimum 80 sf of area, the least dimension of which is 6 feet for at least 75% of the area N/A ☐ (iii) Street facing private open space on the ground floor shall meet the finished floor height for ground floor residential standards in section 18.24.040(b)(4)N/A (b)(2) Common Open Space ☒(A)&(B) Minimum 200 sf of area. Area shall include a space with a minimum dimension of a circle with a 10-foot diameter.A.4 Complies ☒(C) A minimum of 60% of the area shall be open to the sky and free of permanent weather protection or encroachments. Trellises and similar open-air features allowed A.4 Complies ☐ (D) Notwithstanding subsection (1), courtyards enclosed on four sides shall have a minimum dimension of 40 feet and have a minimum courtyard width to building height ratio of 1:1.25 N/A ☒(E) Common open space provides seating. L.1 Complies ☒(F) Common open space has a minimum 20% of landscaping.L.1 Complies Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 81     City of Palo Alto - Objective Design Standards Checklist Page 18 ☐(G) Planting in above grade courtyards has minimum soil depth of 12 inches for ground cover, 20 inches for shrubs, and 36 inches for trees. 18.24.090 Materials Check Standard Sheet #Applicant’s Justification ☒ (b)(1) Primary, secondary, and accent materials are allowed or prohibited as in the Residential and Residential Mixed-use Material List, which may be updated from time to time by the Director of Planning with a recommendation by the ARB. See webpage for list - https://www.cityofpaloalto.org/News-Articles/Planning-and-Development- Services/Multifamily-Mixed-Use-Objective-Standards A.21- A.22 Complies 18.24.100 Sustainability and Green Building Code Check Standard Sheet #Applicant’s Justification ☒ (b) See Chapter 16.14: California Green Building Standards additional requirements for green building and sustainable design. Notwithstanding Section 18.24.010(c), these regulations may not be modified through alternative compliance. A.43 Complies Item 2 Attachment E - Objective Design Standards Consistency Analysis     Packet Pg. 82     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 “2100 Geng Rd” 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: https://www.paloalto.gov/Departments/Planning-Development-Services/Current-Planning/Projects/2100-Geng- Road Materials Boards: Color and material boards will be available to view in chambers during the ARB hearing. Item 2 Attachment F - Project Plans     Packet Pg. 83     Item No. 3. Page 1 of 8 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 16, 2025 Report #: 2509-5257 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 250 Hamilton Avenue [24PLN-00278] (Continued from September 18): Request by AT&T for Review of a Tier 2 Wireless Communication Facility Permit Application for a Small Wireless Facility with Modifications to the 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) complete the continued public hearing and take the following action: 1. Recommend that the Director of Planning and Development Services approve the Tier 2 Small Wireless Communications Facility (SWF) application for modifications to an existing Wireless Communications Facility (WCF) in the public right-of-way (ROW) based on the findings set forth in Attachment B and Conditions of Approval in Attachment C. EXECUTIVE SUMMARY This report provides background information on the proposed Tier 2 SWF 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. On September 18, 2025, the ARB provided comments on the project, requested additional information material to its review, and continued the hearing to a date certain of October 16, 2025. The applicant has since revised the project scope, as detailed in this report. Based on the revised plans, staff recommends the ARB recommend the project for approval by the Director of Planning and Development Services. The proposed project, as revised, meets the volume thresholds for 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 (see Ordinance 5655 in Attachment E). Item 3 Item 3 Staff Report     Packet Pg. 84     Item No. 3. Page 2 of 8 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, as detailed in the previous staff report and summarized below. This Tier 2 SWF project is subject to a 60- day shot clock expiring October 28, 2025, and the ARB hearing on October 16, 2025, will occur on day 48 of 60 days. Final action on the application must occur within the shot clock period, which for a project approval includes issuing all City required permits. If there is any appeal to Council of the Director’s decision on the project by any party in accordance with the Palo Alto Municipal Code (PAMC), it will have to be completed within the remaining 12 days, unless the applicant agrees to extend the shot clock period to allow more time for final action. PROJECT DESCRIPTION The proposed project is comprised of modifications to an existing wireless communications site on a City-owned streetlight pole in the public ROW, as shown in the aerial map on Sheet T-1 (Title Sheet) of the plans and reflected in the location map in Attachment A. The project plans are included in Attachment H. The scope of work, as revised, 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. An adjacent equipment cabinet is also proposed to be removed. New proposed equipment includes three (3) new Convection Cooled RRUs, and two (2) new antennas. 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. 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 E) 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 denial, within the Project’s shot clock period (unless applicant voluntarily redesigns the project). Under Federal law, any project denial must be issued in writing, based on substantial evidence in the written record (47 U.S.C. section 332(c)(7)(B)(iii)). BACKGROUND The subject project was previously reviewed by the ARB. An earlier staff report includes extensive background information, project analysis and evaluation under city codes and Item 3 Item 3 Staff Report     Packet Pg. 85     Item No. 3. Page 3 of 8 policies; that report is available online.1 A copy of the report without prior attachments is available in Attachment F. The purpose of this report is to summarize the comments made by the Board during the September 18 hearing, and detail the applicant’s response to those comments. The analysis section below builds upon the information contained in the earlier report and is modified to reflect recent project changes. ARB Comments/Direction Applicant Response Clarify the volume calculations in cubic feet of the proposed equipment in the application design, including the volume currently used and proposed for removal in the existing equipment cabinet, to determine the appropriate shot clock timeline and review procedure (Tier 2 SWF v. Tier 2 general). The volume calculation is now provided on Sheet A-3 of the revised plans and show that the total volume of the existing equipment, which is planned for removal, is 22.8 cubic feet and that the proposed new equipment volume is 16.39 cubic feet. Therefore, the project would continue to be processed as a Tier 2 small cell wireless facility and has a 60-day shot clock which ends on October 28, 2025. Provide alternative designs of the proposed facility that are of high aesthetic quality, with radios to be co-located to the extent feasible (e.g., within continuous shrouding or underground), or with some equipment (e.g., disconnect switch) remaining within the existing cabinet, with the intent to reduce visible equipment on the pole). For any redesign options, provide associated equipment volume calculations. The existing free-standing cabinet adjacent to the pole is now proposed to be removed and wireline equipment will be undergrounded. Accordingly, the disconnect switch has not been modified to be placed within the cabinet. No other changes are proposed to the materials, color, or equipment on the pole for reasons discussed further in the analysis below. As noted above, with the removal of the cabinet adjacent to the pole the project meets the volume requirements to remain as a Tier 2 SWF. Figure 1 provides a rendering of the difference between existing and proposed at the time of the previous review and Figure 2 provides a rendering showing the difference between existing and proposed with the proposed revisions. Specifically, the cabinet to the right of the pole will be removed. 1 A link to the September 18, 2025 ARB Staff report for this project is available online at: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16806 Item 3 Item 3 Staff Report     Packet Pg. 86     Item No. 3. Page 4 of 8 Figure 1: Existing and Proposed Conditions at Streetlight Pole #167 (from Page Mill Road looking northwest at subject site) Previous Plans Figure 2: Existing and Proposed Conditions at Streetlight Pole #167 (from Page Mill Road looking northeast at subject site) Revised Proposal Legal Framework The City has authority over the siting of WCFs. However, its authority is limited by various Federal and State laws that are listed in detail in the September 18, 2025, staff report.3 Within this legal framework, local agencies retain authority to enforce reasonable aesthetic design standards, protect community character, and ensure safe and aesthetically appropriate Item 3 Item 3 Staff Report     Packet Pg. 87     Item No. 3. Page 5 of 8 deployment of wireless infrastructure (notably, safety considerations exclude consideration of radiofrequency (RF) emissions that meet the current federal regulatory requirements). Palo Alto Regulations As detailed in the previous staff report, in May 2025, Council repealed certain objective standards set forth in the code (Resolution 9873) 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 (Ordinance 5655, Attachment E). In place of the detailed objective standards (which may still be used for guidance, see Attachment D), 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 B); 2. Confirming the project’s compliance with the development standards in PAMC Section 18.42.110(i) Generally Applicable Development Standards (see Attachment E); and 3. Confirming the project’s compliance with the conditions of approval in PAMC Section 18.42.110(j) Conditions of Approval (Attachment C). WCF Permit Tiers and Architectural Review The previous staff report, provided in Attachment F, includes a summary of wireless terminology 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). 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. Based on the project’s updated plans to remove an equipment cabinet, this Tier 2 project meets the federal definition of a SWF (no more than 28 cubic feet in volume). 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. Shot Clock Timelines WCF permit applications are subject to 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. Item 3 Item 3 Staff Report     Packet Pg. 88     Item No. 3. Page 6 of 8 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 or Tier 3 application. The applicant submitted a Tier 2 WCF application on August 7, 2025, after 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, a final decision for a Tier 2 project in the public ROW must be made within 60 days of the application submittal to fall within the presumptively reasonable period for action by City. Because this application involves a SWF, the 60-day timeline is reset upon submittal 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. The resubmitted application was received August 28, 2025, and the ARB hearing was scheduled. At the hearing the ARB requested additional information including confirmation of the equipment volume. The City’s second notice was provided September 22, 2025, following the ARB’s request for additional information and, the shot clock did not pause. The revised plans responding to the second notice were submitted on October 1, 2025 and a final revised plan set addressing utility comments were resubmitted on October 9, 2025. The 60-day period to issue a final decision and, if applicable, holding an appeal hearing and/or issuing all permits, expires on 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 and updated the wireless ordinance (Attachment E). Since July 2025, staff has received only one application categorized as a Tier 2 or 3 wireless facility subject to ARB review and applying architectural review findings. Although repealed and therefore not mandatory 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. ANALYSIS Item 3 Item 3 Staff Report     Packet Pg. 89     Item No. 3. Page 7 of 8 This application was evaluated for completion under the Tier 2 in public ROW application checklist 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, as revised, meets the required findings for approval and project standards and conditions. As summarized in the previous staff report: 1. The project complies with the Radio Frequency (RF) emissions analysis thresholds and would not expose members of the general public to hazardous levels or PF energy at ground level or in the buildings in the vicinity. 2. As designed the project would not be a source of new ambient noise since the configurations include convection cooled radius which are fan-less and utilize natural convection to dissipate heat. Response to ARB Comments Overall the applicant was responsive to ARB comments in that the project has been modified to remove the existing cabinet and to underground wireline equipment. As a result of the cabinet removal, roadway safety and aesthetics are improved, but there is no longer the opportunity to relocate some of the equipment proposed for the pole into the cabinet. The applicant has stated that relocation of all equipment underground is not feasible as the equipment would overheat if placed underground. Although each project must be reviewed individually in accordance with the findings and within the context of the location, the similar proposals have been approved in approximately 70 other locations across the City, including, but not limited to, 550 High Street, 1772 Hamilton Avenue, 179 Lincoln. The total volume of equipment to remain as well as the new proposed equipment has also been provided. Accordingly, the project will continue to be processed as a Tier 2 SWF, which requires the City to issue a decision on this project in accordance with the 60-day shot clock by October 28, 2025. The project removes existing noise producing equipment and an existing above-grade cabinet from the public ROW and results in minimal increased volume of pole equipment. Therefore, staff recommends that the ARB recommend approval of the proposed project. 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 Item 3 Item 3 Staff Report     Packet Pg. 90     Item No. 3. Page 8 of 8 The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post 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. As of the writing of this report, the City received the attached comment from United Neighbor’s, which is included in Attachment G. 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 ACTIONS 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, including applicant’s consent to 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: Architectural Review Findings for Approval Attachment C: Conditions of Approval Attachment D: (Repealed) Resolution No. 9873 Wireless Objective Standards Attachment E: Ordinance 5655 Attachment F: September 18, 2025 staff report without attachments Attachment G: Applicant’s Project Description Attachment Attachment H: Project Plans Report Author & Contact Information ARB5 Liaison & Contact Information Claire Raybould, Manager, Current Planning Steven Switzer, Senior Planner/Historic Preservation Planner (650) 329-2116 (650) 329-2321 Claire.Raybould@paloalto.gov Steven.switzer@paloalto.gov 5 Emails may be sent directly to the ARB using the following address: arb@paloalto.gov Item 3 Item 3 Staff Report     Packet Pg. 91     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 Map Streetlight Pole #167 (near 1661 Page Mill Road) 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 nkandik, 2025-09-09 16:04:33Attachment A. Location Map (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 3 Attachment A - Location Map     Packet Pg. 92     ATTACHMENT B 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 3 Attachment B - Architectural Review Findings for Approval     Packet Pg. 93     The project includes the installation of mechanical equipment, antennas and associated cabling on an existing streetlight pole in the public ROW. As revised, the project would remove an existing utility box within 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. Item 3 Attachment B - Architectural Review Findings for Approval     Packet Pg. 94     The project is consistent with Finding #5 because: 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 3 Attachment B - Architectural Review Findings for Approval     Packet Pg. 95     24PLN-00287 250 Hamilton Avenue Page 1 of 3 ATTACHMENT C 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 October 9, 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 3 Attachment C - Conditions of Approval     Packet Pg. 96     24PLN-00287 250 Hamilton Avenue Page 2 of 3 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 3 Attachment C - Conditions of Approval     Packet Pg. 97     24PLN-00287 250 Hamilton Avenue Page 3 of 3 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 3 Attachment C - Conditions of Approval     Packet Pg. 98     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 99     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 100     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 101     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 102     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 103     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 104     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 105     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 106     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 3Attachment D - (Repealed)Resolution No. 9873Wireless ObjectiveStandards    Packet Pg. 107     24 24 24 24 24 24 2424 2424 24 24 24 24 24 24 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 25 25 25 50 24 24 24 50 24 50 50 50 50 30 50 50 50 25 25 25 25 25 25 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 24 24 2424 2424 24 24 24 24 24 24 24 2424 3535 351010 24 10 53 204 418 2010351035 24 24 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 30 7 7 7 17 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 24 24 2424 4040 40 40 40 40 4040 4040 40 40 2424 24 2424 24 2424 242424242424 24 24 24 24 60 60 60 30 30 40 30 24 24 24 24 24 24 30 6060 6060 5050 40 40 24 24 24 24 242424 24 24 24 24 30 24 24 24 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 24 16 8 16 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 20 20 24 25 25 25 25 2525 252020 2525 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 24 24 24 24 2424 24 24 24 24 24 24 24 24 2424 2424 24 24 24 2424 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 P u l g a s n d H i l l R o a d J u n i p ero S e r r a B o u l e v a r d P a g e M ill Road A r a s t r a d e r o R o a d E l C a m i n o R e a l S an An t onio A v enue Cha r l e s t o n R o a d O r e g o n E x p r e s s w a y M i d d l e f i e l d R o a d University Avenue e e w a y 1 0 1 A l m a 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 s s w 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 Co yo t e 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 Ave Waverley St. Churchill Ave tPe e r Coutts Ser r a S t Ar b or e t u m Galvez P a rk Blv d Amp h i t h e a t r e Pk wy Charleston RdAlma St Los Altos Ave Hillview Ave Old Page MillRd o l 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' Exh i b i t 3 Roa 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 wit h R e s i d e n t i a l , C o m m e r c i a l , and Pub 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 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 13:00:40 (\\cc-maps\Encompass\Admin\Personal\rrivera.mdb) DocuSign Envelope ID: ECCACC0E-18AC-4D5E-9AEE-0C930810BD0A Item 3Attachment D - (Repealed) ResolutionNo. 9873 Wireless Objective Standards   Packet Pg. 108     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 109     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 3 Attachment D - (Repealed) Resolution No. 9873 Wireless Objective Standards     Packet Pg. 110     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 3 Attachment E - Ordinance 5655     Packet Pg. 111     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 3 Attachment E - Ordinance 5655     Packet Pg. 112     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 3 Attachment E - Ordinance 5655     Packet Pg. 113     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 3 Attachment E - Ordinance 5655     Packet Pg. 114     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 3 Attachment E - Ordinance 5655     Packet Pg. 115     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 3 Attachment E - Ordinance 5655     Packet Pg. 116     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 3 Attachment E - Ordinance 5655     Packet Pg. 117     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 3 Attachment E - Ordinance 5655     Packet Pg. 118     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 3 Attachment E - Ordinance 5655     Packet Pg. 119     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 3 Attachment E - Ordinance 5655     Packet Pg. 120     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 3 Attachment E - Ordinance 5655     Packet Pg. 121     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 3 Attachment E - Ordinance 5655     Packet Pg. 122     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 3 Attachment E - Ordinance 5655     Packet Pg. 123     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 3 Attachment E - Ordinance 5655     Packet Pg. 124     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 125     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 Item 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 126     Item No. 4. Page 3 of 11 inhibit service in numerous ways—not only by rendering a service provider unable to provide an existing 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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 127     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 128     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 129     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.2 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 2 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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 130     Item No. 4. Page 6 of 11 Item 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 131     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 132     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 133     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 65.3 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 3 “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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 134     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 135     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 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 136     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 ARB4 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 4 Emails may be sent directly to the ARB using the following address: arb@cityofpaloalto.org Item 3 Attachment F - September 18, 2025 staff report without attachments     Packet Pg. 137     September 25, 2025 United Neighbors Comments on AT&T Tier 2 Wireless Communication Facility, 1661 Page Mill Road (24PLN-00278) Dear Chair Chen, Vice Chair Adcock, Member Hirsch, Member Jojarth and Member Rosenberg: I am counsel to United Neighbors, a Palo Alto community group advocating for smart cell tower planning. My practice focuses on land use and telecommunication law. Thank you for your careful consideration of AT&T’s application at the hearing on September 18, 2025, listening to our concerns and issuing a decision recognizing that AT&T did not establish a need to mount radios on the side of the streetlight pole and that AT&T was required to calculate the total volume of the facility, including the utility cabinet serving the existing cell tower. As this is the first application reviewed by the Board under the City’s reinstated discretionary standards, I wish to provide additional feedback on the hearing and AT&T’s application. 1. AT&T’s assertion that the positioning of radios is restricted by GO-95 is incorrect. We are concerned by several very basic misstatements by AT&T’s representative, Justin Giarritta. One is that Mr. Giarritta asserted that the location of the radios is restricted by “GO-95.”1 GO-95 is a reference to California Public Utilities Commission General Order 95 “Rules for Overhead Electric Line Construction.” GO-95 is applicable solely to utility poles carrying energized power lines. It has no bearing on attachments to light posts. 1 See recording of September 18, 2025, ARB hearing at timestamp 3:07, https://www.youtube.com/watch?v=N0gSHnd5Vgg. ARIEL STRAUSS, Of-Counsel 2748 Adeline Street, Suite A Berkeley, CA 94703 Phone: (510) 900-9502, x 702 Email: astrauss@greenfirelaw.com www.greenfirelaw.com Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 138     2 Mr. Giarritta also incorrectly asserted that the position of the radios on opposite sides of the post is limited by required “climbing space.”2 “Climbing space” is a GO-95 pole attachment spacing rule to enable lineman to scale wooden utility poles to service the lines. But, in addition to GO-95 not applying to light posts, any work on the antenna atop this light post must be performed with a bucket boom truck; its slick surface and less robust structural standards dictate that it cannot and should not be climbed by anyone. As a matter of law, any AT&T objections predicated on inapplicable GO-95 requirements must be rejected. We also recommend that AT&T be instructed going forward to clarify whether any standards cited are mandatory or not. 2. AT&T’s assertion that the location of the disconnect switch is restricted by PG&E standards is not correct. Mr. Giarritta stated that there is “a PG&E standard that the disconnect switch is not shrouded with the radios.”3 Like GO-95, PG&E standards are not relevant to this light post. PG&E standards only apply to utility poles owned by PG&E. PG&E does not own light posts. Even utility poles in Palo Alto are not owned by PG&E. For over a hundred years, electric service has been provided by the City’s own municipal utility. It may be more convenient for AT&T to use the same standards for wireless facilities that apply in other Bay Area cities, but in Palo Alto, it has considerably more flexibility to reduce the conspicuousness of cell tower installations. Unfortunately, AT&T is hiding behind inapplicable jargon as an excuse for refusing to invest in a sleeker, more stealth designs. 3. Contrary to what AT&T stated, undergrounded of radios is required by the Palo Alto Code. Mr. Giarritta acknowledged that AT&T could underground the radios if required to do so, but claimed, as an excuse, that it is not “explicitly written in your code.”4 First, Tier 2 facilities, such as 1661 Page Mill, must be designed in a manner that enables the Board to meet all the design review findings in Code Section 18.76.020(d) and the generally applicable wireless facility standards in Code Section 18.42.110(i). AT&T is on notice of these requirements. It is obvious that undergrounding is a more appropriate approach to comply with both these provisions. Second, the wireless ordinance is explicit that AT&T does have to underground its radios. Section 2 Hearing Timestamp 3:20. 3 Hearing Timestamp 3:25. 4 Hearing Timestamp 3:30-3:31. Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 139     3 18.42.110(j)(8) states: “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.” AT&T apparently has not bothered to read the City’s Code. 4. If AT&T is allowed to install side-mounted radios on the post, inevitably AT&T will cite the decision as a precedent to gain approval for side-mounted radios on other light posts. We appreciate the statements by Board members and staff that the precedent set by a Board decision is highly contextual and necessarily narrow. Each application must be reviewed on its own merits based on the information available at that time to the Board from the applicant, staff and the public. Similarly, what is technically feasible for one application might be infeasible in another situation. And, finally, what is appropriate in one setting may not be in another. However, we also see applicants frequently asserting that the City must allow a substandard approach in a new case because of past conduct. In fact, right now, AT&T is arguing that a side- mounted radio design should be approved for 1661 Page Mill to “match” its dozens of Tier 1 projects,5 even though this is a Tier 2 project subject to ARB review. To be clear, what AT&T is citing as precedents are installations none of which ever passed muster with the ARB. Imagine how much more aggressive their assertions would be if the ARB actually did approve moving the radios that are currently hidden in an equipment cabinet at 1661 Page Mile to the side of the light pole. We applaud the Board seeking to demand the highest standards available in each instance to avoid applicants’ one-way downward ratchet. 5. As a matter of law, the standard for cell tower equipment is higher than the standard for City-owned utility equipment. I also want to respond to the point that the Board may be applying standards to Tier 2 wireless facilities, such as 1661 Page Mill, that are more restrictive than the standards that exist for city utilities and traffic control lights. In 2018, the Federal Communications Commission (FCC) issued an order dictating precisely that standards for small wireless facilities in the right of way be “no more burdensome than those applied to other types of infrastructure deployments[.]” 5 See Hearing Timestamp 2:36. Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 140     4 Many cities immediately sued the FCC to challenge this restriction and, in 2020, the court of appeals for the Ninth Circuit, the highest federal court for our region, ruled in favor of cities, expressly concluding the FCC requirement “must be vacated” as inconsistent with the federal Telecommunications Act of 1996, which protects traditional, local zoning authority. (City of Portland v. U.S., 969 F. 3d 1020, 1041 (9th Cir. 2020).) Consequently, the Board has full authority to impose the standards set in the City’s wireless ordinance and design review findings, even if they are more demanding than those applicable to other types of infrastructure in Palo Alto. Relatedly, the Ninth Circuit struck down the FCC’s restriction that regulations of small wireless facilities be “objective” as illegally “arbitrary and capricious” because it did not allow cities to address the “intangible public harm of unsightly or out-of-character deployments.” (Id. at 1042.) As a result, subjective standards are entirely lawful and the City Council specifically responded to this court decision by repealing mandatory objective standards and reinstating ARB review of Tier 2 applications. The City’s existing ordinances inform applicants of the methodology it will apply, as is the case for many discretionary permits. No additional notice to cell tower applicants is required. Cumulatively, the installation of dozens or hundreds of antennas, radios and switches protruding from poles across the City will have a negative visual impact. We hope that the Board will attempt to make all projects that come before it be of “high aesthetic quality” and harmonize with the surrounding. The Board is not required to set the lowest common denominator on account of the unideal condition of other infrastructure, but rather should incrementally improve the City where it has the power to do so. More specifically, the City’s wireless ordinance sets demands for Tier 2 facilities such as 1661 Page Mill, standards which apply regardless of the standards for other utilities. 6. The State statutory franchise does not limit ARB review. The Staff Report (p. 2) notes that AT&T has a franchise to use the public right of way under Public Utilities Code section 7901. However, it does not mention that, in 2019, the California Supreme Court specifically analyzed this section as applied to wireless providers and held that it does not limit a city’s “authority to establish aesthetic conditions for land use.” (T-Mobile West LLC v. City & County of San Francisco (2019) 6 Cal.5th 1107, 1118.) AT&T seeks to use the City’s light pole, which is in the public’s right of way. Unlike private property owners building on their land, AT&T has no creative license or design discretion for wireless facilities installed on the City’s property. AT&T’s sole right is to meet its reasonable coverage objectives with any method Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 141     5 that is technically feasible and compliant with the City’s reasonable aesthetic standards. Logic and law dictate that it must do so in a manner that minimizes clutter and visual obtrusiveness. 6 7. If the Board approved side-mounted radios for 1661 Page Mill, it would no longer be a stealth facility. This means that, if AT&T, or another carrier, decided to add equipment in the future, it could override the City’s design and zoning standards on its own, and without oversight by the ARB (i.e., it would file a Tier 1, rather than a Tier 2, application). Boardmember Rosenberg commented that she worried about the light post being “infested with these little things sticking off of it all over the place” if AT&T’s application were approved. Staff reassured the Board that approving AT&T’s application, with side-mounted radios, “here doesn’t mean we necessarily have to allow a second one to locate on the same pole.”7 I disagree. If the City is not careful, uncontrolled visual clutter is exactly what approval will mean. The only reason that the Board is reviewing this modification application for 1661 Page Mill under Tier 2 is specifically because a prior ARB required that there be no side-mounted radios. As a result, staff concluded that adding them, as AT&T now wishes to do, “defeated the concealment element” of the current permit. If this is no longer a stealth site—if the ARB allows radios to be side-mounted on the pole—the City will lose discretion over all design of future modifications to the facility. To explain further: Federal law dictates that a “local government may not deny, and shall approve, any eligible facilities request for a modification of an existing wireless tower or base station that does not substantially change the physical dimensions of such tower or base station.” (47 U.S. Code § 1455(a)(1).) FCC regulations interpret “eligible facilities request” to be one that does not defeat the concealment element of a wireless facility. Once the radios are not concealed, as a matter of right, under federal law, any wireless carrier may expand an already-permitted facility up to 10 feet horizontally and 10 feet vertically to upgrade or add as many additional attachments physically supportable by the pole, as well as add four ground cabinets, regardless of any local height restrictions or permit conditions, and without further local discretionary design 6 While not typical for other design review applications, it would be reasonable for the Board to demand that wireless facility applicants specifically provide a range of concealment options. This is similar to the common practice of cities requiring wireless applicants to demonstrate smart planning and present for consideration photo simulations of all feasible alternative locations. Providing options at the ARB hearing will make it easier for the Board to recommend the most appropriate design. 7 Hearing Timestamp 3:27. Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 142     6 review. (47 C.F.R. § 1.6100(b)(7)(i),(ii),(iii).) If the ARB now approves radios mounted on the side of the light post at 1661 Page Mill, the City will have ceded its legal authority to stop future applications and will have to rely on the good will of cell tower applicants to avoid unsightly installations. The staff presentation emphasized the need for the Board to consider wireless ordinance “generally applicable design standards” (1) through (4) but did not discuss standard (5) that “[a]n antenna, base station, or tower shall be of a ‘camouflaged’ or ‘stealth’ design[.]” (Code §18.42.110(i)(5).) Federal regulations define a “base station” to mean a “structure or equipment at a fixed location that enables Commission-licensed or authorized wireless communications [,]” which includes light posts. (47 C.F.R. § 1.6100(b)(1).) Enforcing the standard that the present facility be stealth is the only way to protect against the City permanently ceding its design review authority to future applicants. The Board should be proactively mindful of the federal co-location rights of future applicants on non-stealth facilities and demand that facilities be stealth whenever feasible. 8. Palo Alto’s ordinance demands that AT&T remove unnecessarily equipment from a cell tower facility. The wireless ordinance dictates that a facility a) be the smallest necessary to meet the applicant’s service objective, b) be downsized or undergrounded as new technology becomes available and c), within 90 days, remove any unused equipment. (See Code §18.42.110 (i)(1), (h)(8), (l).) As a result, if it is true, as asserted by Mr. Giarritta, that with the new design, the utility cabinet will be 100% used for AT&T wireline service and not serve the wireless facility at all,8 then the portion of the cabinet that currently houses the radio and other associated equipment must either be used for the new radios and switch, or the obtrusiveness of the large cabinet be downsized to only fit whatever will actually be inside of it. It should be noted, however, that the written record does not support the contention that the cabinet is irrelevant to the modified facility. First, the application does not make such a claim. Second, Street Light Single Line Diagram 3 on Sheet D-1 shows new “(N)” wires and fuses running to the AT&T cabinet, and the Electrical and Ground Diagram for the antenna shows the shut-off running to the “ground rod in AT&T cabinet” that is “to remain” per Enlarged Site Plan 8 See Hearing Timestamp 3:11. Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 143     7 on Sheet A-1.9 AT&T is routing new electrical to the cabinet in connection with this Tier 2 application, rather than only to the underground vaults, and is continuing to use the cabinet based on the submitted plans. Therefore, the cabinet is not solely for AT&T’s wireline service and its volume must be—but is not—included in the facility calculation. 9. City staff should require that AT&T either concur that the FCC shot clock is 90 days or enter into an agreement extending the shot clock; otherwise, the Director should deny the Application as incomplete. The shot clock timeline of 60 or 90 days is set based on the character of the application that is initially submitted. (47 CFR § 1.6003(c).) In this case, the application included the cabinet, and it is my opinion that this facility is too large to qualify as a “small wireless facility” as explained in the handout provided at the hearing (see attached). The application was clearly deficient for failing to include “the dimensions and volume of the antenna and the dimensions and volume of other additional equipment and the overall facility” as required by page 3 of the Tier 2 Checklist, and which is submitted under penalty of perjury. The Staff Report notes that September 18, 2025, was the 21st day of the shot clock period. The next ARB hearing will be on October 16th, which will be day 49. The Director then must make a decision within five business days, which is October 23rd, the 56th day of the period. (Code §18.77.070(d).) Because decisions are not final for 14 days to allow any residents to file an appeal (Code § 18.77.070(d)(3)), even if the Director makes a decision the same day as the ARB issues its recommendation, the permit process will not be concluded within 60 days, regardless of whether an appeal is filed. If an appeal is filed, it will also be impossible for a City Council appeal hearing to be noticed, scheduled and concluded within 60 days. My understanding of staff’s suggestion to hold a hearing on October 16th was that it reflected an implicit determination that the shot clock is in fact 90 days. While I support this conclusion, to avoid the potential for a dispute with AT&T about the shot clock, I recommend that staff request that the applicant either agree that the shot clock period is 90 days or enter into a voluntary tolling agreement, as allowed under the FCC regulations, to afford sufficient time for the City’s review process to play out. Shot clock tolling agreements are entered into routinely and 9 Diagram 8 on Sheet D-1 shows the radio shroud with the notation “supported by cabinet” and the Fiber/Coax Diagram notes “fiber jumpers to feed each 6503 dual support cabinet”. This use of “cabinet” is ambiguous and may refer to the sun-protecting shroud around the radios. Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 144     8 staff are familiar with them from past applications. In fact, applicants frequent request extensions due to their own difficulty presenting complete applications within FCC shot clock timeframes. In the unlikely event that AT&T does not cooperate, the Director should consider independently rejecting the application as incomplete prior to the continued hearing on account of the deficiencies identified by the ARB. (See ExteNet Sys. v. City of Cambridge, 481 F. Supp. 3d 41, 51 (D. Mass. 2020) (holding that a city may deny ROW wireless applications for incompleteness without waiting for end of the FCC shot clock).) This would avoid the potential for AT&T claiming the City failed to make a final decision within the shot clock period and invoking state-law deemed-approved provisions in Government Code section 5964.1(a).10 We appreciate the Board’s re-engagement in cell tower review and applying its expertise to protect the visual quality of Palo Alto public spaces. We hope that we can serve as a resource to assist the Board in this task. Sincerely, ___________________ Ariel Strauss, Of-Counsel Greenfire Law, PC Cc: Jonathan Lait, Planning Director (Jonathan.Lait@paloalto.gov) Nishita Kandikuppa, Project Planner (Nishita.Kandikuppa@paloalto.gov) City Council (City.Council@PaloAlto.gov) City Clerk (City.Clerk@paloalto.gov) Jeanne Fleming, PhD, Chair, United Neighbors 10 In the future, it may be advisable for the Board to request applicants come to hearings authorized to toll the shot clock and, in the event that the appeal process cannot be completed within the most restrictive interpretation of the deadline and the Board views the application as deficient, recommend denial to the Planning Director rather than hold a further hearing risking potential shot clock violations. Item 3 Attachment G - Applicant's Project Description Attachment     Packet Pg. 145     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 3 Attachment H - Project Plans     Packet Pg. 146     Item No. 4. Page 1 of 1 Architectural Review Board Staff Report From: Planning and Development Services Director Lead Department: Planning and Development Services Meeting Date: October 16, 2025 Report #: 2510-5300 TITLE Draft Architectural Review Board Meeting Minutes for September 4, 2025 RECOMMENDATION Staff recommends the Architectural Review Board (ARB) adopt the meeting minutes. ATTACHMENTS Attachment A: Minutes of September 4, 2025 AUTHOR/TITLE: ARB Liaison1 & Contact Information   Steven Switzer, Senior Historic Planner   (650) 329-2321   Steven.Switzer@PaloAlto.gov 1 Emails can be sent directly to the ARB at the following email: ARB@PaloAlto.gov Item 4 Item 4 Staff Report     Packet Pg. 147     Page 1 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/4/25 ARCHITECTURAL REVIEW BOARD MEETING DRAFT MINUTES: September 4, 2025 Council Chamber and Zoom 8:35 AM Call to Order / Roll Call The Architectural Review Board (ARB) of the City of Palo Alto met on September 4, 2025, in Council Chambers and virtual teleconference at 8:35 AM. Present: Chair Chen, Vice Chair Adcock, Board Member Hirsch, Board Member Rosenberg, Board Member Jojarth Absent: None Oral Communications None Agenda Changes, Additions and Deletions None City Official Reports 1. Director’s Report, Meeting Schedule, and Upcoming Agenda Items Historic Preservation Planner Steven Switzer listed the 3 items on the agenda for the September 18 meeting: the Tier 2 Wireless Facility, a study session with the Urban Land Institute for the Palo Alto Transit Center, and a San Antonio Road Area Plan update. Vice Chair Adcock asked if those items were placed in order for the next meeting. Mr. Switzer said the agenda placement was not finalized. Action Item 2. PUBLIC HEARING / QUASI-JUDICIAL. 180 El Camino Real [25PLN-00092]: Recommendation on Applicant’s Request for Major Architectural Review Approval for Exterior Storefront Revisions and Improvements, Including a New Outdoor Dining Area, Façade Revisions and New Signage for Item 4 Attachment A - Minutes of September 4, 2025     Packet Pg. 148     Page 2 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/4/25 a New Tenant, Ralph Lauren (Space #383, Building M), at the Stanford Shopping Center. CEQA Status: Exempt from CEQA per Section 15301 (Existing Facilities). Zoning District: CC (Community Commercial). Tamara Harrison, Planner for Michael Baker International, presenting on the new tenant Ralph Lauren and Ralph’s Café, located within the Stanford Shopping Center. The Stanford Shopping Center is subject to the Master Tenant Façade & Sign (MTFS) Program, which determines which tenant spaces require certain levels of City review. Storefronts above 35 feet in length require an ARB public hearing. This tenant is located at the Sandhill Road entrance. The proposed exterior façade improvements are to repaint the existing metal awnings, storefront systems, and doors; add a new entry/storefront system for the café on the south elevation; add new outdoor café seating/dining area on the south elevation; add new exterior lighting, furniture, floor tiles, and door hardware; and have new signage. Slides of the proposed changes were shown. The façade design was found to be consistent with the MTFS program and the Shopping Center’s character. All signage was determined to be consistent with the MTFS program except the primary wall sign on the southwest elevation, which exceeds the allowable wall sign height by 4 inches. Staff added a Condition of Approval (COA) to the project that the sign will be lowered to a maximum of 2 feet at the time of building permits. The key considerations and conditions are to ensure the project is in conformance with ARB findings, the MTFS program with COA, and PAMC 16.20, the City’s Sign Code. The recommended motion is to recommend approval of the proposed project’s façade changes and signage to the Director of Planning & Development Services based on findings and subject to staff’s conditions of approval. Vice Chair Adcock noted the report said the maximum height for capital letters was 18 inches and asked if the proposed sign with the COA complied. Vice Chair Adcock questioned if there was a font height limit for the primary sign. Ms. Harrison clarified the sign was considered a primary sign, so the maximum height is 24 inches. Mr. Switzer referenced a slide image showing both the primary and secondary signs. The secondary sign’s font height was about 5 inches and was detailed in the plan set. The COA was regarding the top, primary sign, for which there was no font height limit, only panel height and width restrictions. Board Member Hirsch asked if the perimeter concrete will be removed and if the new slate material will be inside or outside the building. Chair Chen asked for clarification on how primary and secondary signs were defined and if the Master Signage Program limits the number of them. Ms. Harrison confirmed the existing concrete in the walkway area will remain and the slate will be used in the entry vestibule area. Ms. Harrison clarified the Master Program allows one primary sign per tenant but with corner tenants or those who have 3 façades, primary signs are allowed on each façade to maximize advertising. Not all wall signs are considered primary signs. Jason Smith, from Landshark Development, as applicant for Ralph Lauren, said the pin-mounted letters on the primary sign were 12 inches and the background was 28 inches. Item 4 Attachment A - Minutes of September 4, 2025     Packet Pg. 149     Page 3 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/4/25 Nadir Naqvi, Director of Store Development at Ralph Lauren, wanted to retain the integrity of the building and embrace the canopies. The interior design took cues from the exterior. Mr. Naqvi explained how the on-brand color palette was chosen and highlighted the proposal to add a window to activate the side alley. PUBLIC COMMENT There were no requests to speak. Board Member Rosenberg asked about the upper windows, noting how they looked closed in the renderings. Board Member Rosenberg wondered how the sizing of the exterior café seating area was determined. Vice Chair Adcock asked what the intent was for quality and durability of the paint on the canopies and if the storefront system will be powder-coated in place. Vice Chair Adcock queried if the proposed light level was lower than existing given the reduction in the light fixture count. Mr. Smith clarified the upper windows belonged to the Stanford Medical offices and were not part of the Ralph Lauren project. The number of café seats was limited to maintain the required 8-foot clearance. Mr. Smith noted the canopies were steel structures and will be left in place, sanded, cleaned, painted, and maintained when necessary. The new portion of the storefront windows and glazing in front of the café area will be powder coated off-site and then installed. Mr. Naqvi said the existing stainless steel will be clad with powder-coated metal both inside and outside. The lighting had been reviewed and discussed with the mall. Light additions include sconces, which emit a higher light level, and street lamps that run along the alley. The lights above the windows in the white stucco are proposed to be removed and the spots will patched and painted. Board Member Hirsch asked if the façade color scheme will match what is presently on the building, what the light fixture between Ralph Lauren and Bang & Olufsen will be, and if there will be a separation between the outdoor eating area and pedestrian walkway. Vice Chair Adcock asked what color green the stucco around the café will be painted. Mr. Naqvi said the painting of the façade is not in the scope of Ralph Lauren and the last column will have a B&O light fixture. The stucco around the café will be painted an Essex green with a 10 percent black as a way to differentiate the café from the retail area. Mr. Smith noted the landlord had obtained permission to repaint Building M. The upper portion and trim have been repainted already. Mr. Smith confirmed there will be a single element of stanchions flanked by landscape planters. The color and elevation renderings did not reflect the recent façade repainting as there was not time to update them. The landlord picked lighter colors, moving away from browns to more neutral greys. Board Member Rosenberg wished the Shopping Center would remove the posts in the middle of the walkway, referencing page G-005-00, but appreciated the applicant was utilizing the alley. Vice Chair Adcock felt the drawings were hard to read and assumed the RL logo on the corner of the building did not need to meet the signage size requirements and felt it would be a nice piece. Item 4 Attachment A - Minutes of September 4, 2025     Packet Pg. 150     Page 4 of 4 Architectural Review Board Meeting Draft Summary Minutes: 9/4/25 MOTION: Board Member Rosenberg moved, seconded by Chair Chen, to approve the project as designed with the COA from staff regarding the signage included. VOTE: Motion carried 5-0. Board Member Questions, Comments, Announcements Or Future Meetings And Agendas Chair Chen announced the ad hoc committee for 975 Page Mill Road with Board Member Hirsch. Adjournment Chair Chen adjourned the meeting at 9:21 AM. Item 4 Attachment A - Minutes of September 4, 2025     Packet Pg. 151