HomeMy WebLinkAbout2023-03-08 Planning & transportation commission Agenda PacketPLANNING AND TRANSPORTATION COMMISSION
Regular Meeting
Wednesday, March 08, 2023
Council Chambers & Hybrid
6:00 PM
Pursuant to AB 361 Palo Alto City Council 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. Commissioner names, biographies, and archived agendas and
minutes are available at http://bit.ly/PaloAltoPTC.
VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/91641559499)
Meeting ID: 916 4155 9499 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
Planning.Commission@CityofPaloAlto.org and will be provided to the Cmmission 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 Planning.Commission@CityofPaloAlto.org 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.
TIME ESTIMATES
Listed times are estimates only and are subject to change at any time, including while the
meeting is in progress. The Commission reserves the right to use more or less time on any item,
to change the order of items and/or to continue items to another meeting. Particular items may
be heard before or after the time estimated on the agenda. This may occur in order to best
manage the time at a meeting or to adapt to the participation of the public.
CALL TO ORDER/ ROLL CALL
PUBLIC COMMENT
Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker.
AGENDA CHANGES, ADDITIONS AND DELETIONS
The Chair or Board majority may modify the agenda order to improve meeting management.
CITY OFFICIAL REPORTS
1.Director's Report, Meeting Schedule and Assignments
ACTION ITEMS
Public Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others:
Five (5) minutes per speaker.
2.PUBLIC HEARING/LEGISLATIVE: Recommend an Amendment to Palo Alto Municipal Code
Chapters 18.10 and 18.12, Sections 18.10.090(a) and 18.12.090(a) Related to Basements
Under Accessory and Junior Accessory Dwelling Units and a Continued Hearing and
Recommendation on Chapter 18.09 Changes. Environmental Assessment: Exempt from
the provisions of the California Environmental Quality Act (CEQA) pursuant to Public
Resources Code Section 21080.17 and CEQA Guidelines sections 15061(b)(3), 15301,
15302, and 15305. 6:10PM – 7:10PM
3.Review and Recommend City Council Adoption of the Draft 2023‐31 Housing Element,
Subject to Refinement Following Comment from the Department of Housing and
Community Development. A Draft Addendum to the City's Comprehensive Plan 2017
Environmental Impact Report has been prepared. 7:10PM – 8:10PM
4.Amendment to Title 18 Chapter 18.42 to Codify Firearms Sales Limitations Ordinance;
CEQA status—exempt under CEQA Guidelines section 15061(c)(3) 8:10PM – 9:10PM
APPROVAL OF MINUTES
Public comment is permitted. Three (3) minutes per speaker.
5.Approval of Planning & Transportation Commission Draft Verbatim Minutes of February
8, 2023
COMMISSIONER 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 m a y b e s u b m i t t e d b y e m a i l t o
planning.commission@cityofpaloalto.org.
2. Spoken public comments using a computer will be accepted through the
teleconference meeting. To address the Commission, 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 Commission, 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
Commission. 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: 916 4155 9499 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@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
PLANNING AND TRANSPORTATION COMMISSIONRegular MeetingWednesday, March 08, 2023Council Chambers & Hybrid6:00 PMPursuant to AB 361 Palo Alto City Council meetings will be held as “hybrid” meetings with theoption to attend by teleconference/video conference or in person. To maximize public safetywhile still maintaining transparency and public access, members of the public can choose toparticipate from home or attend in person. Information on how the public may observe andparticipate in the meeting is located at the end of the agenda. Masks are strongly encouraged ifattending in person. The meeting will be broadcast on Cable TV Channel 26, live onYouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen MediaCenter https://midpenmedia.org. Commissioner names, biographies, and archived agendas andminutes are available at http://bit.ly/PaloAltoPTC. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/91641559499)Meeting ID: 916 4155 9499 Phone: 1(669)900‐6833PUBLIC COMMENTSPublic comments will be accepted both in person and via Zoom for up to three minutes or anamount of time determined by the Chair. All requests to speak will be taken until 5 minutesafter the staff’s presentation. Written public comments can be submitted in advance toPlanning.Commission@CityofPaloAlto.org and will be provided to the Cmmission and availablefor inspection on the City’s website. Please clearly indicate which agenda item you arereferencing in your subject line.Spokespersons that are representing a group of five or more people who are identified aspresent at the meeting at the time of the spokesperson's presentation will be allowed up tofifteen (15) minutes at the discretion of the Chair, provided that the non‐speaking membersagree not to speak individually. The Chair may limit Public Comments to thirty (30) minutes forall combined speakers. The Chair may reduce the allowed time to speak for Study Sessions andAction 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 onlyby email to Planning.Commission@CityofPaloAlto.org at least 24 hours prior to the meeting.Once received, the Clerk will have them shared at public comment for the specified item. Touphold strong cybersecurity management practices, USB’s or other physical electronic storagedevices are not accepted.TIME ESTIMATES
Listed times are estimates only and are subject to change at any time, including while the
meeting is in progress. The Commission reserves the right to use more or less time on any item,
to change the order of items and/or to continue items to another meeting. Particular items may
be heard before or after the time estimated on the agenda. This may occur in order to best
manage the time at a meeting or to adapt to the participation of the public.
CALL TO ORDER/ ROLL CALL
PUBLIC COMMENT
Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker.
AGENDA CHANGES, ADDITIONS AND DELETIONS
The Chair or Board majority may modify the agenda order to improve meeting management.
CITY OFFICIAL REPORTS
1.Director's Report, Meeting Schedule and Assignments
ACTION ITEMS
Public Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others:
Five (5) minutes per speaker.
2.PUBLIC HEARING/LEGISLATIVE: Recommend an Amendment to Palo Alto Municipal Code
Chapters 18.10 and 18.12, Sections 18.10.090(a) and 18.12.090(a) Related to Basements
Under Accessory and Junior Accessory Dwelling Units and a Continued Hearing and
Recommendation on Chapter 18.09 Changes. Environmental Assessment: Exempt from
the provisions of the California Environmental Quality Act (CEQA) pursuant to Public
Resources Code Section 21080.17 and CEQA Guidelines sections 15061(b)(3), 15301,
15302, and 15305. 6:10PM – 7:10PM
3.Review and Recommend City Council Adoption of the Draft 2023‐31 Housing Element,
Subject to Refinement Following Comment from the Department of Housing and
Community Development. A Draft Addendum to the City's Comprehensive Plan 2017
Environmental Impact Report has been prepared. 7:10PM – 8:10PM
4.Amendment to Title 18 Chapter 18.42 to Codify Firearms Sales Limitations Ordinance;
CEQA status—exempt under CEQA Guidelines section 15061(c)(3) 8:10PM – 9:10PM
APPROVAL OF MINUTES
Public comment is permitted. Three (3) minutes per speaker.
5.Approval of Planning & Transportation Commission Draft Verbatim Minutes of February
8, 2023
COMMISSIONER 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 m a y b e s u b m i t t e d b y e m a i l t o
planning.commission@cityofpaloalto.org.
2. Spoken public comments using a computer will be accepted through the
teleconference meeting. To address the Commission, 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 Commission, 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
Commission. 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: 916 4155 9499 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@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
PLANNING AND TRANSPORTATION COMMISSIONRegular MeetingWednesday, March 08, 2023Council Chambers & Hybrid6:00 PMPursuant to AB 361 Palo Alto City Council meetings will be held as “hybrid” meetings with theoption to attend by teleconference/video conference or in person. To maximize public safetywhile still maintaining transparency and public access, members of the public can choose toparticipate from home or attend in person. Information on how the public may observe andparticipate in the meeting is located at the end of the agenda. Masks are strongly encouraged ifattending in person. The meeting will be broadcast on Cable TV Channel 26, live onYouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen MediaCenter https://midpenmedia.org. Commissioner names, biographies, and archived agendas andminutes are available at http://bit.ly/PaloAltoPTC. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/91641559499)Meeting ID: 916 4155 9499 Phone: 1(669)900‐6833PUBLIC COMMENTSPublic comments will be accepted both in person and via Zoom for up to three minutes or anamount of time determined by the Chair. All requests to speak will be taken until 5 minutesafter the staff’s presentation. Written public comments can be submitted in advance toPlanning.Commission@CityofPaloAlto.org and will be provided to the Cmmission and availablefor inspection on the City’s website. Please clearly indicate which agenda item you arereferencing in your subject line.Spokespersons that are representing a group of five or more people who are identified aspresent at the meeting at the time of the spokesperson's presentation will be allowed up tofifteen (15) minutes at the discretion of the Chair, provided that the non‐speaking membersagree not to speak individually. The Chair may limit Public Comments to thirty (30) minutes forall combined speakers. The Chair may reduce the allowed time to speak for Study Sessions andAction 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 onlyby email to Planning.Commission@CityofPaloAlto.org at least 24 hours prior to the meeting.Once received, the Clerk will have them shared at public comment for the specified item. Touphold strong cybersecurity management practices, USB’s or other physical electronic storagedevices are not accepted.TIME ESTIMATESListed times are estimates only and are subject to change at any time, including while themeeting is in progress. The Commission reserves the right to use more or less time on any item,to change the order of items and/or to continue items to another meeting. Particular items maybe heard before or after the time estimated on the agenda. This may occur in order to bestmanage the time at a meeting or to adapt to the participation of the public.CALL TO ORDER/ ROLL CALLPUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker.AGENDA CHANGES, ADDITIONS AND DELETIONSThe Chair or Board majority may modify the agenda order to improve meeting management.CITY OFFICIAL REPORTS1.Director's Report, Meeting Schedule and AssignmentsACTION ITEMSPublic Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others:Five (5) minutes per speaker.2.PUBLIC HEARING/LEGISLATIVE: Recommend an Amendment to Palo Alto Municipal CodeChapters 18.10 and 18.12, Sections 18.10.090(a) and 18.12.090(a) Related to BasementsUnder Accessory and Junior Accessory Dwelling Units and a Continued Hearing andRecommendation on Chapter 18.09 Changes. Environmental Assessment: Exempt fromthe provisions of the California Environmental Quality Act (CEQA) pursuant to PublicResources Code Section 21080.17 and CEQA Guidelines sections 15061(b)(3), 15301,15302, and 15305. 6:10PM – 7:10PM3.Review and Recommend City Council Adoption of the Draft 2023‐31 Housing Element,Subject to Refinement Following Comment from the Department of Housing andCommunity Development. A Draft Addendum to the City's Comprehensive Plan 2017Environmental Impact Report has been prepared. 7:10PM – 8:10PM4.Amendment to Title 18 Chapter 18.42 to Codify Firearms Sales Limitations Ordinance;CEQA status—exempt under CEQA Guidelines section 15061(c)(3) 8:10PM – 9:10PMAPPROVAL OF MINUTESPublic comment is permitted. Three (3) minutes per speaker.5.Approval of Planning & Transportation Commission Draft Verbatim Minutes of February8, 2023
COMMISSIONER 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 m a y b e s u b m i t t e d b y e m a i l t o
planning.commission@cityofpaloalto.org.
2. Spoken public comments using a computer will be accepted through the
teleconference meeting. To address the Commission, 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 Commission, 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
Commission. 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: 916 4155 9499 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@cityofpaloalto.org. Requests for assistance or
accommodations must be submitted at least 24 hours in advance of the meeting, program, or
service.
PLANNING AND TRANSPORTATION COMMISSIONRegular MeetingWednesday, March 08, 2023Council Chambers & Hybrid6:00 PMPursuant to AB 361 Palo Alto City Council meetings will be held as “hybrid” meetings with theoption to attend by teleconference/video conference or in person. To maximize public safetywhile still maintaining transparency and public access, members of the public can choose toparticipate from home or attend in person. Information on how the public may observe andparticipate in the meeting is located at the end of the agenda. Masks are strongly encouraged ifattending in person. The meeting will be broadcast on Cable TV Channel 26, live onYouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen MediaCenter https://midpenmedia.org. Commissioner names, biographies, and archived agendas andminutes are available at http://bit.ly/PaloAltoPTC. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/91641559499)Meeting ID: 916 4155 9499 Phone: 1(669)900‐6833PUBLIC COMMENTSPublic comments will be accepted both in person and via Zoom for up to three minutes or anamount of time determined by the Chair. All requests to speak will be taken until 5 minutesafter the staff’s presentation. Written public comments can be submitted in advance toPlanning.Commission@CityofPaloAlto.org and will be provided to the Cmmission and availablefor inspection on the City’s website. Please clearly indicate which agenda item you arereferencing in your subject line.Spokespersons that are representing a group of five or more people who are identified aspresent at the meeting at the time of the spokesperson's presentation will be allowed up tofifteen (15) minutes at the discretion of the Chair, provided that the non‐speaking membersagree not to speak individually. The Chair may limit Public Comments to thirty (30) minutes forall combined speakers. The Chair may reduce the allowed time to speak for Study Sessions andAction 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 onlyby email to Planning.Commission@CityofPaloAlto.org at least 24 hours prior to the meeting.Once received, the Clerk will have them shared at public comment for the specified item. Touphold strong cybersecurity management practices, USB’s or other physical electronic storagedevices are not accepted.TIME ESTIMATESListed times are estimates only and are subject to change at any time, including while themeeting is in progress. The Commission reserves the right to use more or less time on any item,to change the order of items and/or to continue items to another meeting. Particular items maybe heard before or after the time estimated on the agenda. This may occur in order to bestmanage the time at a meeting or to adapt to the participation of the public.CALL TO ORDER/ ROLL CALLPUBLIC COMMENT Members of the public may speak to any item NOT on the agenda. Three (3) minutes per speaker.AGENDA CHANGES, ADDITIONS AND DELETIONSThe Chair or Board majority may modify the agenda order to improve meeting management.CITY OFFICIAL REPORTS1.Director's Report, Meeting Schedule and AssignmentsACTION ITEMSPublic Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others:Five (5) minutes per speaker.2.PUBLIC HEARING/LEGISLATIVE: Recommend an Amendment to Palo Alto Municipal CodeChapters 18.10 and 18.12, Sections 18.10.090(a) and 18.12.090(a) Related to BasementsUnder Accessory and Junior Accessory Dwelling Units and a Continued Hearing andRecommendation on Chapter 18.09 Changes. Environmental Assessment: Exempt fromthe provisions of the California Environmental Quality Act (CEQA) pursuant to PublicResources Code Section 21080.17 and CEQA Guidelines sections 15061(b)(3), 15301,15302, and 15305. 6:10PM – 7:10PM3.Review and Recommend City Council Adoption of the Draft 2023‐31 Housing Element,Subject to Refinement Following Comment from the Department of Housing andCommunity Development. A Draft Addendum to the City's Comprehensive Plan 2017Environmental Impact Report has been prepared. 7:10PM – 8:10PM4.Amendment to Title 18 Chapter 18.42 to Codify Firearms Sales Limitations Ordinance;CEQA status—exempt under CEQA Guidelines section 15061(c)(3) 8:10PM – 9:10PMAPPROVAL OF MINUTESPublic comment is permitted. Three (3) minutes per speaker.5.Approval of Planning & Transportation Commission Draft Verbatim Minutes of February8, 2023COMMISSIONER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS ANDAGENDAS
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 m a y b e s u b m i t t e d b y e m a i l t o
planning.commission@cityofpaloalto.org.
2. Spoken public comments using a computer will be accepted through the
teleconference meeting. To address the Commission, 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 Commission, 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
Commission. 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: 916 4155 9499 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@cityofpaloalto.org. 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
Planning & Transportation Commission
Staff Report
From: Jonathan Lait, Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: March 8, 2023
Report #: 2302-0981
TITLE
Director's Report, Meeting Schedule and Assignments
RECOMMENDATION
Staff recommends that the Planning and Transportation Commission (PTC) review and
comment as appropriate. Also, the PTC may note the attached recruitment flyer regarding
openings on the City’s boards and commissions.
BACKGROUND
This document includes the following items:
•PTC Meeting Schedule
•PTC Representative to City Council (Rotational Assignments)
•Tentative Future Agenda
Commissioners are encouraged to contact Veronica Dao (Veronica.Dao@CityofPaloAlto.org) of
any planned absences one month in advance, if possible, to ensure the availability of a PTC
quorum.
PTC Representative to City Council is a rotational assignment where the designated
commissioner represents the PTC’s affirmative and dissenting perspectives to Council for
quasijudicial and legislative matters. Representatives are encouraged to review the City Council
agendas (https://www.cityofpaloalto.org/City-Hall/City-Council/Council-Agendas-Minutes) for
the months of their respective assignments to verify if attendance is needed or contact staff.
Prior PTC meetings are available online at
http://midpenmedia.org/category/government/cityof-palo-
alto/boardsandcommissions/planning-and-transportation-commission.
ATTACHMENTS
Attachment A: 2023 Meeting Schedule and Assignments
AUTHOR/TITLE:
Item 1
Staff Report
Packet Pg. 5
Item No. 1. Page 2 of 2
Amy French, Chief Planning Official
Item 1
Staff Report
Packet Pg. 6
Planning & Transportation Commission
2023 Meeting Schedule & Assignments
2023 Schedule
Meeting Dates Time Location Status Planned Absences
1/11/2023 6:00 PM Hybrid Cancelled
1/25/2023 6:00 PM Hybrid Cancelled
2/08/2023 6:00 PM Hybrid Regular
2/22/2023 6:00 PM Hybrid Regular
3/08/2023 6:00 PM Hybrid Regular
3/29/2023 6:00 PM Hybrid Regular
4/12/2023 6:00 PM Hybrid Regular Bryna Chang
4/26/2023 6:00 PM Hybrid Regular Bart Hechtman
5/10/2023 6:00 PM Hybrid Regular
5/31/2023 6:00 PM Hybrid Regular
6/14/2023 6:00 PM Hybrid Regular Bart Hechtman
6/28/2023 6:00 PM Hybrid Regular
7/12/2023 6:00 PM Hybrid Regular Bart Hechtman
7/26/2023 6:00 PM Hybrid Regular
8/09/2023 6:00 PM Hybrid Regular
8/30/2023 6:00 PM Hybrid Regular
9/13/2023 6:00 PM Hybrid Regular
9/27/2023 6:00 PM Hybrid Regular
10/11/2023 6:00 PM Hybrid Regular
10/25/2023 6:00 PM Hybrid Regular
11/08/2023 6:00 PM Hybrid Regular
11/29/2023 6:00 PM Hybrid Regular
12/13/2023 6:00 PM Hybrid Regular
12/27/2023 6:00 PM Hybrid Cancelled
2023 Assignments - Council Representation (primary/backup)
January February March April May June
Cari Templeton
Giselle Roohparvar
Giselle Roohparvar
Keith Reckdahl
Bart Hechtman
Doria Summa
Doria Summa
Bryna Chang
Bryna Chang
Keith Reckdahl
Keith Reckdahl
Bart Hechtman
July August September October November December
Item 1
PTC 2023 Schedule &
Assignments
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Item No. 2. Page 1 of 6
Planning & Transportation Commission
Staff Report
From: Jonathan Lait, Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: March 8, 2023
Report #: 2302-1017
TITLE
PUBLIC HEARING/LEGISLATIVE: Recommend an Amendment to Palo Alto Municipal Code
Chapters 18.10 and 18.12, Sections 18.10.090(a) and 18.12.090(a) Related to Basements Under
Accessory and Junior Accessory Dwelling Units and Amendments to Chapter 18.09 in a Continued
Hearing on Chapter 18.09 Changes. Environmental Assessment: Exempt from the provisions of
the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section
21080.17 and CEQA Guidelines sections 15061(b)(3), 15301, 15302, and 15305.
RECOMMENDATION
Staff recommends the Planning and Transportation Commission (PTC) take the following
action(s):
1. Receive public testimony on the ordinance revisions, which include responses to address
feedback received from HCD, and
2. Recommend that the City Council adopt the attached Ordinance (Attachment A)
amending Palo Alto Municipal Code (PAMC) Title 18 (Zoning) regulations for Accessory
Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs).
REPORT SUMMARY/BACKGROUND
Staff met with the PTC on February 22, 2023, to discuss changes relative to items raised by HCD’s
letter from 2022 and additional changes to the City’s local regulations regarding J/ADU
development. Links to the February 22nd PTC meeting video1 and staff report2 are provided in
footnotes below. The PTC hearing was continued to March 8, 2023, and the proposed
amendments to Chapters 18.10 and 18.12 were properly noticed. This staff report focuses on
items that the PTC did not make motions on in February, including items raised in staff’s
1 Link to 2-22-23 PTC meeting video: https://midpenmedia.org/planning-transportation-commission-63-2222023/
2 link to PTC report 2-22-23: https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-
minutes/planning-and-transportation-commission/2023/ptc-2.22-adu-hcd.pdf
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Item No. 2. Page 2 of 6
presentation. For consistency with the previous ordering of the staff report and presentation, the
items are listed below:
F. Conversion/Relocation of Uncovered Parking Stalls
G. Privacy Measures for ADUs/JADUs
I. Basements Under J/ADUs that Serve the Primary Unit
DISCUSSION
F. Conversion/Relocation of Uncovered Parking Stalls
The City’s current Zoning Code requires that single-family homes include two parking spaces on
site, both of which need to be located beyond the front yard setback, and one of which must be
a covered parking space. Over time, staff has recognized a disconnect between requirements for
single-car garages with adjacent uncovered parking spaces converted to an ADU, and two-car
garages converted to an ADU. Namely, PAMC Chapter 18.09 and state law do not require the
replacement of covered parking spaces lost through the conversion of a garage to an ADU, but
also do not provide direction on what should occur for uncovered parking spaces. Staff’s current
application of the law reflects an interpretation that there is no such relaxed replacement
allowance for uncovered parking spaces and such spaces must comply with the typical siting
requirements – i.e., that these spaces must be placed on site and beyond the front yard setback.
Below is an example to demonstrate this issue:
An owner who wants to eliminate the uncovered parking stall in the left-most example above
would first need to expand a garage within the blue area to accommodate two, 10-foot wide by
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Item No. 2. Page 3 of 6
20-foot-deep parking stalls. Once a final occupancy permit is issued for that building permit, the
owner could then file another permit to convert the new garage into an ADU. This creates a two-
step process that adds time, money, and constraints to developing an ADU whereas, under a
different existing configuration, an owner could already take advantage of the relaxed conversion
allowances. The City currently allows JADUs under PAMC 18.09.040(k) to replace parking lost
through garage conversions in the driveway as uncovered spaces.
On February 22nd, Commissioners expressed support for eliminating this two- step process. The
attached draft ordinance captures this new policy under PAMC 18.09.040(l)(2).
G. Privacy Measures for ADUs/JADUs
During the July 13, 2022 PTC meeting, two commissioners asked how to best implement the City’s
privacy measures for Table 2 units. They asked whether the City should adopt more stringent
privacy requirements for windows facing adjacent properties, based on a height standard rather
than simply requiring privacy when there is a second floor or equivalent space, as the code
currently requires. At the time, the PTC did not adopt a motion to change the existing policy,
other than to clarify that these policies only applied when a second-floor level was proposed for
an ADU.
Since then, staff have been receiving more complaints from neighbors regarding privacy impacts
from larger ADUs built close to their property lines, as State law now allows. Staff noted on
February 22nd a desire to revisit this discussion with the PTC. To illustrate the issue, the below
images are provided to illustrate the issue of views from two different floor levels:
View with standard finished floor 1.5 ft above grade View if a finished floor were 2.5 ft above grade
There are no privacy measures in place for one-story, single-family homes with taller first-floor
levels, and only building permits are required for one-story homes. However, new primary
homes in the R1 zones are generally located at least 6 to 8 feet from an interior side property
line, and at least 20 feet from a rear property line.
Privacy measures cannot be imposed on ADU or JADU buildings that are set back four feet from
an interior property line, for units that qualify under PAMC 18.09.030 (aka Table 1). This is true
also for units that do not have a second-floor level, even when the ADU height is 16 feet or more.
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Item No. 2. Page 4 of 6
The City can introduce privacy measures for ADUs and JADUs with higher first-floor levels placed
at four feet from an interior property line into Chapter 18.09; however, staff can only apply such
privacy measures to units that fall under PAMC 18.09.040 (aka Table 2 units).
During the February 22nd PTC hearing, the Commissioners supported staff’s proposal to present
additional privacy regulations for ADUs under PAMC 18.09.040(k)(2). Below are suggested
provisions staff has incorporated into the attached draft ordinance, for Table 2 units:
1. Non-egress windows on the ground floor of an ADU or JADU are not permitted to face
towards an adjacent, interior property line.
2. If the finished floor of an ADU or JADU is three (3) feet or more above grade:
a. First floor windowsill(s) shall be located five feet above the finished floor OR
b. Lower half of window(s) (minimum of five feet above finished floor) shall be
obscure glazing.
The Commission may wish to discuss whether the proposed finished floor level threshold of
three feet is sufficient for the second set of privacy measures, or whether a range is desired.
The range of finished floor levels for the PTC’s consideration could begin at 18 inches above
grade.
I. Basements Under J/ADUs that Serve the Primary Units
Basements in Palo Alto typically do not count towards the floor area, lot coverage, or maximum
house size limitations for single-family homes. Basements are only allowed to be built
underneath the footprint of the first floor. As a result, the size for a basement is inherently tied
to the primary home’s development potential. This can range from 2,550 sf (for a typical 6,000 sf
lot) or less and up to the City’s maximum house size (6,000 sf in the R1 zones). As it is currently
written, the City’s code does not distinguish between the footprint of a primary home or the
footprint of a primary home and an attached second unit for the purposes of determining the
maximum basement size. With new City and state laws, attached ADUs and JADUs can increase
the size of a primary home’s footprint by 500 sf or 800 sf, respectively. This creates a loophole
where a homeowner could build the maximum size house possible on their lot, build an attached
ADU and/or JADU, and propose a basement for the
primary home which extends underneath the
attached second unit (third image). Where a primary
unit and basement would normally be limited to a
maximum house size of 6,000 sf each, there could be
scenarios where a primary unit is 6,000 sf and a
basement that serves it is up to 6,800 sf.
Staff’s understanding of the intent behind the existing
rule is to not allow basements to expand beyond the
footprint of the primary dwelling unit, though it does
not make this distinction clear. Additionally, the
purpose of the bonus square footage for ADUs and
JADUs is to encourage the development of additional
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Item No. 2. Page 5 of 6
housing units, not to build an attached second unit and propose/expand a basement that serves
the primary home underneath it. During the February 22 PTC hearing, the Commissioners
seemed open to including language to address this issue into the draft ordinance. As a result,
staff has suggested adding language to Chapter 18.10.090(a) and 18.12.090(a) as shown under
Sections 10 and 11 in the draft ordinance.
ENVIRONMENTAL REVIEW
The adoption of the Ordinance is exempt from the provisions of the California Environmental
Quality Act (CEQA) pursuant to Public Resources Code Section 21080.17 and CEQA Guidelines
sections 15061(b)(3), 15301, 15302, and 15305, because of requirements related to accessory
dwelling units as established in Government Code Section 65852.2, and these changes are also
likely to result in few additional dwelling units dispersed throughout the City. As such, it can be
seen with certainty that the proposed action will not have the potential for causing a significant
effect on the environment.
ALTERNATIVE ACTIONS
In addition to the recommended action, the PTC may:
1. Provide direction to make further modifications to the ordinance, or
2. Continue the hearing to a date (un)certain to enable staff to perform additional study.
ATTACHMENTS
Attachment A: Draft ADU Ordinance for March 8, 2023 PTC Consideration
Attachment B: HCD Letter on ADU Ordinance (2021)
Attachment C: Staff Response to HCD (2022)
Attachment D: HCD Letter on ADU Ordinance (2022)
Attachment E: Staff Response to HCD (2023)
Attachment F: Government Code Section 65852.2
AUTHOR/TITLE:
Garrett Sauls - Planner
Item 2
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Item No. 2. Page 6 of 6
Item 2
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Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Title 18 (Zoning) of
the Palo Alto Municipal Code to Amend Requirements Relating to Accessory
Dwelling Units and Junior Accessory Dwelling Units
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Chapter 18.09 (Accessory Dwelling Units and Junior Accessory Dwelling Units) of
Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read as follows
(additions underlined and deletions struck-through):
18.09.010 Purpose
The intent of this Chapter is to provide regulations to accommodate accessory and
junior accessory dwelling units (ADU/JADU), in order to provide for variety to the city's
housing stock and additional affordable housing opportunities. These units shall be
separate, self-contained living units, with separate entrances from the main residence,
whether attached or detached. The standards below are provided to minimize the
impacts of units on nearby residents and throughout the city, and to assure that the
size and location of such dwellings is compatible with the existing or proposed
residence(s) on the site and with other structures in the area.
18.09.020 Applicable Zoning Districts
The establishment of an accessory dwelling unit is permitted in zoning districts when
single-family or multi-family residential is a permitted land use. The development of a
single-family home, ADU, and/or a JADU on a lot that allows for single-family
development shall not be considered a multifamily development pursuant to PAMC
Section 18.04.030, nor shall they require Architectural Review pursuant to other
sections of Chapter 18.
18.09.030 Units Exempt from Generally Applicable Local Regulations
(a) Government Code section 65852.2, subdivision (e) provides that certain units shall
be approved notwithstanding state or local regulations that may otherwise apply.
The following types of units shall be governed by the standards in this section. In the
event of a conflict between this section and Government Code section 65852.2,
subdivision (e), the Government Code shall prevail.
i. An ADU and JADU within the existing space of a single-family dwelling or an
ADU within the existing space of an accessory structure (i.e. conversion
without substantial addition).
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Annotated ADU
Ordinance 3-8-23
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ii. An ADU and JADU within the proposed space of a single-family dwelling.
iii. A detached, new construction ADU on a lot with a proposed or existing
single-family dwelling, provided the ADU does not exceed 800 square feet,
sixteen feet in height, or four-foot side and rear (i.e. interior) setbacks.
iv. ADUs created by conversion of portions of existing multi-family dwellings not
used as livable space.
v. Up to two detached ADUs on a lot with an existing multi-family dwelling.
(b) The Development Standards for units governed by this section are summarized in
Table 1. Regulations set forth in section 18.09.040 do not apply to units created
under 18.09.030. The minimum and maximum sizes indicated in Table 1 do not
prohibit units that are greater than 800 square feet. These sizes simply serve to
distinguish when a unit transitions from regulations set forth in Table 1 and section
18.09.030 to regulations set forth in Table 2 and section 18.09.040.
Table 1: Development Standards for Units Described in Government Code Section 65852.2(e)
Single-Family Multi-Family
Conversion of
Space Within
the Existing
Space of a
Single-Family
Home or
Accessory
Structure
Construction of
Attached ADU
Within the
Proposed Space
of a Single-
Family Home
New
Construction of
Detached ADU
Conversion of
Non-Habitable
Space Within
Existing Multi-
family Dwelling
Structure
Conversion or
Construction of
Detached(4) ADU
Number
of Units
Allowed
1 ADU and 1 JADU
25% of the
existing units
(at least one)
2
Minimum
size(1) 150 sf
Maximum
size(1) N/A2 800 sf N/A
Setbacks
N/A, if condition
is sufficient for
fire and safety
Underlying zone
standard for
Single Family
Home
(ADU must be
within
4 feet from side
and rear lot
lines;
underlying
zoning for front
setback
N/A
4 feet from side
and rear lot
lines; underlying
zoning for front
setback
Daylight N/A N/A
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Annotated ADU
Ordinance 3-8-23
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Plane allowable space
of Single-Family
Home)
Maximum
Height(3) N/A 16(5) N/A 16(5)(6)
Parking None
State Law
Reference 65852.2(e)(1)(A) 65852.2(e)(1)(A) 65852.2(e)(1)(B) 65852.2(e)(1)(C) 65852.2(e)(1)(D)
(1) Lofts where the height from the floor level to the underside of the rafter or finished roof surface
is 5' or greater shall count towards the unit’s floor area.
(2) New construction must be consistent with allowable space (e.g. FAR, Lot Coverage) of a single
family residence, except that up to 150 sf may be added for the purpose of ingress and egress
only, without regard to underlying zone standards.
(3) Units built in a flood zone are not entitled to any height extensions granted to the primary
dwelling.
(4) Units must be detached from existing primary dwellings but may be attached to each other.
(5) A height of 18 feet for a detached ADU on a lot with an existing or proposed single family or
multifamily dwelling unit that is within one-half of one mile walking distance of a major transit
stop or a high-quality transit corridor, as those terms are defined in Section 21155 of the Public
Resources Code. An additional two feet in height shall be provided to accommodate a roof pitch
on an ADU that is aligned with the roof pitch of the primary dwelling unit.
(6) A height of 18 feet for a detached ADU on a lot with an existing or proposed multifamily,
multistory dwelling.
(c) Development standards stated elsewhere in this Section or Title 18, including
standards related to FAR, lot coverage, and privacy, are not applicable to ADUs or
JADUs that qualify for approval under this section. When there is an ADU or JADU
attached to an existing or proposed primary dwelling, the shared wall between
these units shall contribute to the maximum allowable Floor Area, Lot Coverage, and
Maximum House Size of the primary unit. For a single-family home, this
measurement shall be taken to the outside stud wall in accordance with Section
18.04.030(a)(65)(D). For a multi-family dwelling, this measurement shall be taken to
the outside surface of exterior walls in accordance with Section 18.04.030(a)(65)(B)
and (C).
(d) The establishment of accessory dwelling units and junior accessory dwelling units
pursuant to this section shall not be conditioned on the correction of non-
conforming zoning conditions; provided, however, that nothing in this section shall
limit the authority of the Chief Building Official to require correction of building
standards relating to health and safety.
(e) The installation of fire sprinklers shall not be required in an accessory dwelling unit if
sprinklers are not required for the primary residence. Nothing in this section shall
preclude the Fire Marshal from accepting fire sprinklers as an alternative means of
compliance with generally applicable fire protection requirements.
Commented [YA1]: Previously recommended by PTC
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(f) Rental of any unit created pursuant to this section shall be for a term of 30 days or
more.
(g) Attached units shall have independent exterior access from a proposed or existing
single-family dwelling. Except for JADUs, attached units shall not have an interior
access point to the primary dwelling (e.g. hotel door or other similar
feature/appurtenance).
(h) Conversion of an existing accessory structure pursuant to Government Code section
65852.2(e)(1)(A) may include reconstruction in-place of a non-conforming structure,
so long as the renovation of reconstruction does not increase the degree of non-
compliance, such as increased height, envelope, or further intrusion into required
setbacks. Any portion of an ADU that exceeds the envelope of the existing accessory
structure shall be subject to Section 18.09.040.
(i) Street addresses shall be assigned to all units prior to building permit final to assist in
emergency response.
(j) The unit shall not be sold separately from the primary residence.
(k) Replacement parking is not required when a garage, carport, or covered parking
structure is converted to, or demolished in conjunction with the construction of, an
ADU.
(l) JADUs shall comply with the requirements of Section 18.09.050.
18.09.040 Units Subject to Local Standards
(a) This section shall govern applications for ADUs and JADUs that do not qualify for
approval under section 18.09.030 and for which the City may impose local standards
pursuant to Government Code section 65852.2, subdivisions (a) through (d). Nothing
in this section shall be interpreted to prohibit an ADU of up to 800 square feet, at
the heights stated in Table 2, with a four foot side and rear setbacks.
(b) The Development Standards for units governed by this section are provided in Table
2. These regulations do not limit the height of existing structures converted into
ADU/JADUs unless the envelope of the building is proposed to be modified beyond
any existing legal, non-conforming condition.
Table 2: All other Units
Attached Detached JADU
Number of Units
Allowed1 1 1
Minimum size 150 sf
Commented [YA2]: Previously recommended by PTC
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Annotated ADU
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Maximum size
900 sf (1,000 sf for two
or more bedrooms);
no more than 50% of
the size of the single-
family home
900 sf (1,000 sf for
two or more
bedrooms)
500 sf
Setbacks 4 feet from side and rear lot lines;
underlying zone standard for front setback
Daylight Plane
Underlying zone
standard per
footnote (7)
N/A Underlying zone
standard
Initial Height 8 feet at lot line
Angle 45 degrees
Maximum Height3
Underlying zone
standard
Res. Estate (RE) 30 feet
Open Space (OS) 25 feet
All other eligible
zones 16 feet(5)(6)(7)
Parking None
Square Footage
Exemption when in
conjunction with a
single family home(4)
Up to 800 sf(4) Up to 500 sf(4)
(1) An attached or detached ADU may be built in conjunction with a JADU on a lot with an existing
or proposed single family home. One attached or detached ADU may be built in conjunction
with an existing or proposed multifamily building.
(2) Lofts where the height from the floor level to the underside of the rafter or finished roof surface
is 5' or greater shall count towards the unit’s floor area.
(3) Units built in a flood zone are not entitled to any height extensions granted to the primary
dwelling.
(4) Lots with both an ADU and a JADU may exempt a maximum combined total of 800 square feet
of the ADU and JADU from FAR, Lot Coverage, and Maximum House Size calculations. Any
square footage that exceeds this exemption shall contribute to the FAR, Lot Coverage, and (if
attached) Maximum House Size calculations for the subject property. This exemption is not
afforded to lots with existing or proposed multifamily dwellings.
(5) A height of 18 feet for a detached ADU on a lot with an existing or proposed single family or
multifamily dwelling unit that is within one-half of one mile walking distance of a major transit
stop or a high-quality transit corridor, as those terms are defined in Section 21155 of the Public
Resources Code. An additional two feet in height shall be provided to accommodate a roof pitch
on an ADU that is aligned with the roof pitch of the primary dwelling unit.
(6) A height of 18 feet for a detached ADU on a lot with an existing or proposed multifamily,
multistory dwelling.
(7) A height of 25 feet or the height limitation in the underlying zone district that applies to the
primary dwelling, whichever is lower, for an ADU that is attached to a primary dwelling. These
ADUs shall not exceed two stories in height.
Commented [YA3]: Response to change in state law and
HCD direction re daylight plane
Commented [YA4]: Response to HCD direction re
daylight plane
Commented [YA5]: Response to HCD direction re JADUs
Commented [YA6]: Previously recommended by PTC
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(c) A single-family dwelling shall exist on the lot or shall be constructed on the lot in
conjunction with the construction of an ADU/JADU.
(d) ADU and/or JADU square footage shall not be included in FAR, Lot Coverage, and
Maximum House Size calculations for a lot with an existing or proposed single family
home, up to the amounts stated in Table 2. ADU and/or JADU square footage in
excess of the exemptions provided in Table 2 shall be included in FAR, Lot Coverage,
and Maximum House Size calculations for the lot.
(d)(e) When there is an ADU or JADU attached to an existing or proposed primary
dwelling, the shared wall between these units shall contribute to the maximum
allowable Floor Area, Lot Coverage, and Maximum House Size of the primary unit.
For a single-family home, this measurement shall be taken to the outside stud wall
in accordance with Section 18.04.030(a)(65)(D). For a multi-family dwelling, this
measurement shall be taken to the outside surface of exterior walls in accordance
with Section 18.04.030(a)(65)(B) and (C).
(e)(f) Attached units shall have independent exterior access from a proposed or
existing single-family dwelling. Except for JADUs, attached units shall not have an
interior access point to the primary dwelling (e.g. hotel door or other similar
feature/appurtenance).
(f)(g) No protected tree shall be removed for the purpose of establishing an accessory
dwelling unit unless the tree is dead, dangerous or constitutes a nuisance under
Section 8.04.050. Any protected tree removed pursuant to this subsection shall be
replaced in accordance with the standards in the Tree Technical Manual.
(g)(h) For properties listed in the Palo Alto Historic Inventory, the California Register of
Historical Resources, the National Register of Historic Places, or considered a historic
resource after completion of a historic resource evaluation, compliance with the
appropriate Secretary of Interior’s Standards for the Treatment of Historic
Properties shall be required.
(h)(i) Noise-producing equipment such as air conditioners, water heaters, and similar
service equipment that exclusively serves an ADU/JADU may be located anywhere
on the site, provided they maintain the underlying front yard setback requirements
of the property and, if the property is a corner lot, a 10-foot street-side setback.
shall be located outside of the setbacks for the ADU/JADU. All such equipment shall
be insulated and housed, except that the Director may permit installation without
housing and insulation, provided that a combination of technical noise
specifications, location of equipment, and/or other screening or buffering will assure
compliance with the city’s Noise Ordinance at the nearest property line. All service
Commented [YA7]: Previously recommended by PTC
Commented [YA8]: Previously recommended by PTC
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equipment must meet the city’s Noise Ordinance in Chapter 9.10 of the Municipal
Code.
(i)(j) Setbacks
(1) Detached units shall maintain a minimum three-foot distance from the
primary unit, measured from the exterior walls of structures.
(2) No A basement or other subterranean portion that serves of an ADU/JADU
shall may encroach into a setback required for the primary dwelling provided
the following conditions are met:.
(A) Newly constructed basement walls are no closer than four feet to
an adjacent interior side or rear property line.
(B) A new lightwell associated with a basement shall not be placed
closer than four feet to an adjacent property line. When visible from
the right of way, these facilities shall be screened from view with
vegetation.
(C) The new basement shall not negatively impact tree roots on the
subject property or on adjacent lots such that it would require a
protected tree to be removed or cause the tree to die.
(D) ADU/JADU basements shall contribute toward the unit’s total
allowable square footage. Any square footage in excess of the
exemptions provided in this Section shall contribute to the total
allowable limits for the site.
(3) Projections, including but not limited to windows, doors, mechanical
equipment, venting or exhaust systems, are not permitted to encroach into
the required setbacks, with the exception of a roof eave of up to 2 feet.
(3)(4) For corner lots developed as a single-family home only, when an existing
or proposed primary dwelling unit is expanded or constructed simultaneously
with the construction of a new ADU/JADU, all structures may be built to a 10-
foot street-side setback and a 16-foot front yard setback, regardless of the
presence of a special setback, unless a fire or life-safety regulation requires a
greater setback.
(4)(5) When an existing, legal, nonconforming structure is converted or
reconstructed to create an ADU/JADU, any portion of the ADU/JADU that is
in the same location and falls within the building envelope of the original
structure shall not be subject to the development standards stated in this
Section. Any portion of the ADU/JADU that is in a different location or
Commented [YA9]: Previously recommended by PTC
Commented [YA10]: Previously recommended by PTC
Commented [YA11]: Previously recommended by PTC
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exceeds the envelope of the original structure shall comply with the
development standards stated in this Section.
(5)(6) Notwithstanding the development standards stated in Table 2 and
paragraph (5) above, when an existing, legal, non-conforming structure is
converted in-place to an ADU/JADU, the envelope of the structure may be
modified to encroach further into a setback or daylight plane as follows:
(A) The height of the existing structure may be increased by no more
than one linear foot in height commensurate to the existing roofline
of the structure provided the height of the addition does not exceed
12 feet from grade. The roofline shall not be changed to a style other
than what currently exists on the structure.
(B) Each non-conforming wall may be expanded by no more than six
inches in thickness based on its existing location and configuration, as
measured to exterior surface of the material, to provide for greater
insulation and energy requirements provided that a minimum of one
foot is maintained between the addition and an adjacent property
line. An existing wall of a structure that does not currently have a
separation of one foot from a parallel property line shall not be
expanded outward.
(C) All other additions not specified here shall follow the standard
setbacks for the ADU/JADU identified in Table 2.
(j)(k) Design
(1) Except on corner lots, it shall be encouraged but not required that the unit
shall not have an entranceway facing the same lot line (property line) as the
entranceway to the main dwelling unit unless the entranceway to the
accessory unit is located in the rear half of the lot. Exterior staircases to
second floor units shall be located toward the interior side or rear yard of the
property.
(2) Privacy
(A) Second story doors and decks shall not face a neighboring dwelling
unit property line. Second story decks and balconies shall utilize
screening barriers to prevent views into adjacent properties. These
barriers shall provide a minimum five-foot, six-inch, screen wall from
the floor level of the deck or balcony and shall not include
perforations of any kind that would allow visibility between
properties.
(B) Second story w Windows on a second floor, loft, or equivalent
elevated space, excluding those required for egress, shall have a five-
Commented [YA12]: Previously recommended by PTC
Commented [YA13]: Response to HCD direction
Commented [SG14]: BH Suggested edits to retain
provision
Commented [YA15]: Previously recommended by PTC
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 21
*NOT YET APPROVED*
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foot sill height as measured from the second-finished floor level, or
utilize obscured opaque glazing on the entirety of the window when
facing any window that faces adjacent properties. Second story e
Egress windows shall utilize obscured opaque glazing on the entirety
of the windows which face that face adjacent properties.
(C) Second story w Windows on a second floor, loft, or equivalent
elevated space, shall be offset from neighbor’s windows to maximize
privacy.
(D) Egress windows on a second floor, loft, or equivalent elevated space
shall not face adjacent property lines.
(E) Non-egress windows on the ground floor of an ADU or JADU are not
permitted to face towards an adjacent interior property line.
(F) If the finished floor of an ADU or JADU is three (3) feet or more above
grade:
i. First-floor windowsill(s) shall be located five feet above the
finished floor; OR
ii. The lower half of window(s) (minimum of five feet above
finished floor) shall utilize obscured glazing.
(G) Where feasible, the use of skylights (whether operable or not) shall
be used in lieu of operable windows that face adjacent properties
(H) No exterior lighting shall be mounted above seven feet. All lighting
mounted on walls shall be directed downwards and shall not direct
light towards adjacent property lines. Any ground lighting shall not
direct light upwards to the building or sky.
(k)(l) Parking
(1) Replacement parking is not required when a garage, carport, or covered
parking structure is converted to, or demolished in conjunction with the
construction of, an ADU.
(2) Replacement parking is required when an existing attached garage, carport,
or covered parking structure is converted to a JADU or when a required,
existing, uncovered parking space is expanded into by an ADU. These
replacement spaces may be provided as uncovered spaces in any
configuration on the lot including within the front or street side yard setback
for the property.
(A) The Director shall have the authority to modify required replacement
parking spaces by up to one foot in width and length upon finding
that the reduction is necessary to accommodate parking in a location
otherwise allowed under this code and is not detrimental to public
health, safety or the general welfare.
Commented [SG16]: Response to Item G
Commented [YA17]: Previously recommended by PTC
Commented [SG18]: Suggested code for Item F
Item 2
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Ordinance 3-8-23
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(B) Existing front and street side yard driveways may be enlarged to the
minimum extent necessary to comply with the replacement parking
requirement above. Existing curb cuts shall not be altered except
when necessary to promote public health, safety or the general
welfare.
(3) When parking is provided, the unit shall have street access from a driveway
in common with the main residence in order to prevent new curb cuts,
excessive paving, and elimination of street trees, unless separate driveway
access will result in fewer environmental impacts such as paving, grading or
tree removal.
(3)(4) When a single-family dwelling unit is permitted simultaneously with the
construction of new ADU/JADUs, the primary unit’s covered parking
requirements identified in Chapter 18.10 and 18.12 do not need to be
provided. Two uncovered parking spaces shall be provided in any
configuration on the lot including within the front or street-side setback for
the property.
(4)(5) If covered parking for a unit is provided in any district, the maximum size of
the covered parking area for the accessory dwelling unit is 220 square feet.
This space shall count towards the total floor area for the site but does not
contribute to the maximum size of the unit unless attached to the unit. Any
attached garage shall not have an interior access point to the ADU/JADU (e.g.
hotel door or other similar feature/appurtenance).
(l)(m) Miscellaneous requirements
(1) Street addresses shall be assigned to all units prior to building permit final to
assist in emergency response.
(2) The unit shall not be sold separately from the primary residence.
(3) Rental of any unit created pursuant to this section shall be for a term of 30
days or more.
(4) The installation of fire sprinklers shall not be required in an accessory
dwelling unit if sprinklers are not required for the primary residence. Nothing
in this section shall preclude the Fire Marshal from accepting fire sprinklers
as an alternative means of compliance with generally applicable fire
protection requirements.
18.09.050 Additional Requirements for JADUs
Commented [YA19]: Previously recommended by PTC
Commented [YA20]: Previously recommended by PTC
Also responsive to HCD direction
Item 2
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Ordinance 3-8-23
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(a) A junior accessory dwelling unit may only be created on a lot in a single-family
residential zone with an existing or proposed single family residence. A junior
accessory dwelling unit shall be attached to or created within the walls of an existing
or proposed primary dwelling.
(b) The junior accessory dwelling unit shall include an efficiency kitchen, requiring the
following components: A cooking facility with appliances, and; food preparation
counter and storage cabinets that are of reasonable size in relation to the size of the
junior accessory dwelling unit.
i. A cooking facility with appliances shall mean, at minimum a one burner
installed range, an oven or convection microwave, a 10 cubic foot refrigerator
and freezer combination unit, and a sink that facilitates hot and cold water.
ii. A food preparation counter and storage cabinets shall be of reasonable size in
relation to a JADU if they provide counter space equal to a minimum 24-inch
depth and 36-inch length.
ii.iii. JADUs may share sanitation facilities (bathrooms, laundry facilities, etc.) with
the primary unit. In this instance, the floor area and lot coverage associated
with shared space shall count towards the primary unit’s maximum allowances
only. The combined sanitation facilities between the units shall include
shower, toilet, and sink fixtures at a minimum and shall conform to the
minimum requirements specified in the Building Code
(c) For the purposes of any fire or life protection ordinance or regulation or for the
purposes of providing service for water, sewer, or power, a junior accessory dwelling
unit shall not be considered a separate or new unit.
(d) The owner of a parcel proposed for a junior accessory dwelling unit shall occupy as a
primary residence either the primary dwelling or the junior accessory dwelling.
Owner-occupancy is not required if the owner is a governmental agency, land trust, or
housing organization.
(e) Prior to the issuance of a building permit for a junior accessory dwelling unit, the
owner shall record a deed restriction in a form approved by the city that includes a
prohibition on the sale of the junior accessory dwelling unit separate from the sale of
the single-family residence, requires owner-occupancy consistent with subsection (d)
above, does not permit short-term rentals, and restricts the size and attributes of the
junior dwelling unit to those that conform with this section.
18.09.060 Affordable ADU/JADU Pilot Program
Commented [YA21]: Previously recommended by PTC
Also responsive to HCD direction
Commented [YA22]: Previously recommended by PTC
Item 2
Attachment A -
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Ordinance 3-8-23
Packet Pg. 24
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(a) This section shall govern applications for ADUs and JADUs that will be deed restricted for
a minimum of 8 years to provide affordable rental units for households earning up to 80%
of area median income. These units shall be exempt from all development impact fees,
regardless of size, up to a maximum of $50,000 unit and a Citywide total of $400,000 per
calendar year. To participate in this program, units shall follow the development
standards in section 18.09.040 unless otherwise stated here.
(b) The City’s affordable housing administrator shall income qualify potential tenants prior to
issuing a permit for an affordable ADU/JADU. The property owner shall be responsible for
paying the City’s housing administrator to cover the cost associated with documenting a
potential tenants income level as well as annually recertifying the tenant’s income.
SECTION 2. Subsection (g) of Section 16.58.030 of Chapter 16.58 (Development Impact Fees)
of Title 16 (Building) of the Palo Alto Municipal Code (“PAMC”) is amended to read:
(f) Accessory dwelling units (ADU) less than 750 square feet in size. Any impact fees to be
charged for an accessory dwelling unit of 750 square feet or more shall be proportional
to the square footage of the primary dwelling unit. Any unit that is deed restricted to be
rented at a rate of up to 80% of AMI, in accordance with the City’s established
Affordable ADU/JADU program, shall be exempt from all impact fees, regardless of size,
up to a maximum of $50,000 per unit and a Citywide total of $400,000 per calendar
year;
SECTION 3. Subsections (a)(4) and (a)(65) of Section 18.04.030 (Definitions) of Chapter 18.04
(Definitions) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read:
[. . .]
(4) “Accessory dwelling unit” means an attached or a detached residential dwelling unit
which provides complete independent living facilities for one or more persons. It shall
include permanent provisions for living, sleeping, eating, cooking, and sanitation on the
same parcel as the single-family dwelling is situated. An ADU bathroom shall include a
shower, toilet, and sink fixture at a minimum and shall conform to the minimum
requirements specified in the Building Code. An accessory dwelling unit also includes the
following:
[. . .]
(65) “Gross Floor Area” is defined as follows:
[. . .]
(D) Low Density Residential Exclusions: In the RE and R-1 single-family residence
districts and in the R-2 and RMD two-family residence districts, “gross floor area”
Commented [YA23]: Previously recommended by PTC
Commented [SG24R23]: Removed due to prior PTC
motion
Commented [YA25]: Previously recommended by PTC
Commented [YA26]: Previously recommended by PTC
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 25
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shall not include the following:
[. . .]
(ix) Accessory structures equal to or less than one hundred and twenty square
feet in area shall not contribute to floor area provided that any attached
porches, patios, or similar features are substantially open;
(E) In all districts, gross floor area shall be calculated to the nearest 1000th decimal
point and represented and rounded on plans to the nearest 100th decimal point
(e.g. 123.456 sf shall be rounded to 123.46 sf). Standard rounding shall apply
such that a number of four or less shall be rounded down and a number of five
or more shall be rounded up.
SECTION 4. Subsections (b)(5) of Section 18.10.080 (Accessory Uses and Facilities) of Chapter
18.10 (Low-Density Residential) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is
amended to read:
[. . .]
(5) When located within a required interior yard as permitted by this section, no such
No accessory building shall have more than two plumbing fixtures. Accessory buildings
shall not be allowed to be turned into habitable space nor shall these structures be
allowed to have showers (indoor or outdoor), gas lines, washer/dryers, and/or cooking
facilities to be provided inside or attached to the structure, unless the structure is
proposed as an ADU/JADU that satisfies all requirements of the Palo Alto Municipal
Code.
[. . .]
SECTION 5. Subsections (b)(5) of Section 18.12.080 (Accessory Uses and Facilities) of Chapter
18.12 (Single-Family Residential District) of Title 18 (Zoning) of the Palo Alto Municipal Code
(“PAMC”) is amended to read:
[. . .]
(5) No such accessory building greater than 200 square feet in size shall have more than
two plumbing fixtures. Accessory buildings shall not be allowed to be turned into
habitable space nor shall these structures be allowed to have showers (indoor or
outdoor), gas lines, washer/dryers, and/or cooking facilities to be provided inside or
attached to the structure, unless the structure is proposed as an ADU/JADU that
satisfies all requirements of the Palo Alto Municipal Code.
[. . .]
Commented [YA27]: Previously recommended by PTC
Commented [YA28]: Previously recommended by PTC
Commented [YA29]: Previously recommended by PTC
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 26
*NOT YET APPROVED*
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SECTION 6. Subsection (b)(5) of 18.40.050 (Location and Use of Accessory Buildings) of
Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto
Municipal Code (“PAMC”) is amended to read:
[. . .]
(5) No such accessory building shall have more than two plumbing fixtures. Accessory
buildings shall not be allowed to be turned into habitable space nor shall these
structures be allowed to have showers (indoor or outdoor), gas lines, washer/dryers,
and/or cooking facilities to be provided inside or attached to the structure, unless the
structure is proposed as an ADU/JADU that satisfies all requirements of the Palo Alto
Municipal Code.
[. . .]
SECTION 7. Table 1 of 18.10.030 (Land Uses) of Chapter 18.10 (Low Density Residential) of
Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read:
Table 1 shows the permitted and conditionally permitted uses for the low-density residential
districts.
TABLE 1
PERMITTED AND CONDITIONALLY PERMITTED LOW-DENSITY RESIDENTIAL USES
[P = Permitted Use -- CUP = Conditional Use Permit Required]
RE R-2 RMD Subject to
Regulations in:
[. . .]
Accessory Dwelling Units P P(2) P(2) 18.42.040 18.09
Junior Accessory Dwelling
Units P P(2) P(2) 18.42.040 18.09
[. . .]
(1) Sale of Agricultural Products: No permanent commercial structures for the sale or processing of
agricultural products are permitted.
(2) Accessory Dwelling Units in R-2 and RMD Zones: An accessory dwelling unit or a Junior Accessory
Dwelling Unit associated with a single-family residence on a lot in the R-2 or RMD zones is permitted,
subject to the provisions of Section 18.42.040 Chapter 18.09, and such that no more than two units
result on the lot.
(3) [. . .]
SECTION 8. Table 1 of 18.12.030 (Land Uses) of Chapter 18.12 (Single-Family Residential
District) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read:
Commented [YA30]: Previously recommended by PTC
Commented [YA31]: Previously recommended by PTC
Commented [YA32]: Previously recommended by PTC
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 27
*NOT YET APPROVED*
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The permitted and conditionally permitted uses for the single family residential districts are
shown in Table 1:
Table 1
PERMITTED AND CONDITIONAL R-1 RESIDENTIAL USES
R-1 and all R-1
Subdistricts
Subject to
Regulations for in:
[. . .]
Accessory Dwelling Units P(1) 18.42.040 18.09
Junior Accessory Dwelling Unit P(1) 18.42.040 18.09
[. . .]
(1) An Accessory Dwelling Unit or a Junior Accessory Dwelling Unit associated with a single-family
residence on a lot is permitted, subject to the provisions of Chapter 18.09Section 18.42.040, and
such that no more than two total units result on the lot.
SECTION 9. Table 1 of 18.13.030 (Land Uses) of Chapter 18.13 (Multiple-Family Residential
Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read:
Table 1 specifies the permitted and conditionally permitted land uses in the multiple-family
residence districts.
Table 1
Multiple Family Residential Uses
[P = Permitted Use • CUP = Conditional Use Permit Required]
RM-20 RM-30 RM-40 Subject to
Regulations in:
[. . .]
Accessory Dwelling Unit when
accessory to permitted single-
family residence
P(1) & (4) P(1) & (4) P(2) & (4) 18.42.040 18.09
Junior Accessory Dwelling Unit
when accessory to permitted
single-family residence
P(1) P(1) P(2) 18.09
[. . .]
(1) Permitted use only on lots less than 8,500 square feet in size.
(2) Permitted use only on lots less than 6,000 square feet in size.
(3) Permitted use only if lot is substandard in size, e.g., less than 8,500 square feet or less than 70 feet in width, or
at the perimeter of a site in excess of one acre where used as a transition to low-density residential area.
(4) An accessory dwelling unit associated with a single-family residence on a lot is permitted if it is contained
within the existing space of a single-family residence or an existing accessory structure in accordance with and
pursuant to Section 18.42.040(a)(5), subject to the provisions of Section 18.42.040 and such that no more than two
total units result on the lot.
SECTION 10. Subsection (a) of Section 18.10.090 (Basements) of Chapter 18.10 (Low Density
Residential) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read:
Commented [YA33]: Previously recommended by PTC
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 28
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[. . .]
(a) Permitted Basement Area
Basements may not extend beyond the building footprint and basements are not allowed
below any portion of a structure that extends into required setbacks, except to the
extent that the main residence is permitted to extend into the rear yard setback by other
provisions of this code. Basements which serve the primary unit may not extend under
an attached ADU or JADU when those secondary units utilize the bonus floor area, lot
coverage, and/or maximum house size exemptions identified in Section 18.09.
[. . .]
SECTION 11. Subsection (a) of Section 18.12.090 (Basements) of Chapter 18.13 (Single-Family
Residential District) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to
read:
[. . .]
(a) Permitted Basement Area
Basements may not extend beyond the building footprint and basements are not allowed
below any portion of a structure that extends into required setbacks, except to the
extent that the main residence is permitted to extend into the rear yard setback by other
provisions of this code. Basements which serve the primary unit may not extend under
an attached ADU or JADU when those secondary units utilize the bonus floor area, lot
coverage, and/or maximum house size exemptions identified in Section 18.09.
[. . .]
SECTION 12. Any provision of the Palo Alto Municipal Code or appendices thereto inconsistent
with the provisions of this Ordinance, to the extent of such inconsistencies and no further, is
hereby repealed or modified to that extent necessary to affect the provisions of this Ordinance.
SECTION 13. If any section, subsection, sentence, clause, or phrase of this Ordinance is for
any reason held to be invalid or unconstitutional by a decision of any court of competent
jurisdiction, such decision shall not affect the validity of the remaining portions of this
Ordinance. The City Council hereby declares that it would have passed this Ordinance and
each and every section, subsection, sentence, clause, or phrase not declared invalid or
unconstitutional without regard to whether any portion of the ordinance would be
subsequently declared invalid or unconstitutional.
SECTION 14. The Council finds that the adoption of this Ordinance is exempt from the
provisions of the California Environmental Quality Act (CEQA) pursuant to Public Resources
Code Section 21080.17 and CEQA Guidelines sections 15061(b)(3), 15301, 15302 and 15305
Commented [SG34]: Response to item I in staff report
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 29
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because it constitutes minor adjustments to the City’s zoning ordinance to implement State
law requirements related to accessory dwelling units as established in Government Code
Section 65852.2, and these changes are also likely to result in few additional dwelling units
dispersed throughout the City. As such, it can be seen with certainty that the proposed action
will not have the potential for causing a significant effect on the environment.
SECTION 15. This ordinance shall be effective on the thirty-first date after the date of its
adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Planning and
Development Services
Item 2
Attachment A -
Annotated ADU
Ordinance 3-8-23
Packet Pg. 30
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
December 23, 2021
Jonathan Lait, Planning Director
Planning Department
City of Palo Alto
250 Hamilton Avenue – Fifth Floor
Palo Alto, CA 94301
Dear Jonathan Lait:
RE: Review of Palo Alto’s Accessory Dwelling Unit (ADU) Ordinance under ADU
Law (Gov. Code § 65852.2)
Thank you for submitting the City of Palo Alto (City) accessory dwelling unit (ADU)
ordinance (Ordinance No.5507) adopted September 26, 2020, to the California
Department of Housing and Community Development (HCD). The ordinance was
received on October 20, 2020. HCD has reviewed the ordinance and is submitting these
written findings pursuant to Government Code section 65852.2, subdivision (h). HCD has
determined that the ordinance does not comply with section 65852.2 in the manner
noted below. Under the statute, the City has up to 30 days to respond to these findings.
Accordingly, the City must provide a written response to these findings no later than
January 23, 2022. HCD will review and consider any written response received from the
City before that date in advance of taking further action authorized by Government Code
section 65852.2.
The adopted ADU ordinance meets many statutory requirements. However, the
ordinance must be revised to comply with State ADU Law (Gov. Code, § 65852.2), as
follows:
• Section 18.09.030(a)(3) Units Exempt from Generally Applicable Local
Regulations: The text of this Section and the applicable portion of Table 1
indicate the maximum size of a newly constructed detached ADU is 800 square
feet. Although a local agency may establish minimum and maximum size
requirements for ADUs pursuant to subdivision (c)(1) of Government Code
section 65852.2 within limits, a local agency shall not establish a maximum
square footage requirement for either attached or detached ADUs that is less
than 850 square feet and 1,000 square feet for an ADU that provides more than
one bedroom. (Gov. Code, § 65852.2, subd. (c)(2)(B).) Therefore, all relevant
Item 2
Attachment B - HCD
Letter on ADU Ordinance
(2021)
Packet Pg. 31
Jonathan Lait, Planning Director
Page 2
sections of the ordinance must be amended to comply with this mandate in State
ADU Law.
• Section 18.09.030 Units Exempt from Generally Applicable Local Regulations:
There appears to be a conflict between the text of this section and Table 1. The
number of allowable units are correctly noted in Table 1 as “1 ADU and 1
JADU.” The text of section 18.09.030(a) appears to limit allowable units to “an
ADU or JADU.” Government Code section 65852.2, subdivision (e)(1)(A),
requires an ordinance to allow “one ADU and one JADU per lot… .” The City
must amend the ordinance to correct this inconsistency, clarifying that “one
ADU and one JADU” are permitted if all the conditions of section 65852.2,
subdivision (e)(1)(A) apply.
• Section 18.09.030(b) Application of Development Standards: Local agencies
may establish standards for ADUs pursuant to Government Code section
65852.2, subdivision (a); however, these standards do not apply to ADUs
constructed pursuant to subdivision (e). Table 1 impermissibly applies
“underlying zoning” “for front setback[s]” to subdivision (e) ADUs. (Mun. Code,
§18.09.030(b).) Subdivision (e)(1) describes permitted setbacks in full. Unless
underlying zoning for all residential areas conforms to subdivision (e) limits, this
table must be amended to comply with statute. (Gov. Code, § 65852.2, subd.
(e)(1)(A).)
• Section 18.09.030(b)(1) ADU Height in Flood Zones: The City has
impermissibly restricted the height of ADUs. It appears that the City establishes
minimum elevations for the first floor of structures in the flood zone, which is
essentially the entire city to varying degrees. To account for this, the zoning
code allows most residential structures to exceed otherwise maximum
allowable heights for development. The City does not extend this
accommodation to ADUs. Currently, Table 1 states that the maximum height for
new, detached ADUs is 16 feet, but includes a caveat that “units built in a flood
zone are not entitled to any height extension.” (Mun. Code, § 18.09.030(b).) In
many instances, this would operate as an impermissible restriction on ADUs.
Under State ADU Law, the City must accommodate an ADU of at least 800
square feet and 16 feet in height. Thus, the caveat in Table 1 is potentially
confusing and could restrict the height to less than 16 feet. If it would in fact
operate to effectively limit the height of ADUs to less than 16 feet, it would
operate as an impermissible restriction on ADUs. As such, Table 1 should be
revised to clarify that this limitation does not apply where necessary to permit
an 800-square foot ADU that it at least 16 feet tall. (Gov. Code, § 65852.2,
subds. (c)(2)(C) and (e)(1)(B)(ii).)
• Section 18.09.040(b) Daylight Plane and ADU Height Standards: Table 2 states
that “daylight plane” acts as a limit on the height of ADUs. In many instances,
Item 2
Attachment B - HCD
Letter on ADU Ordinance
(2021)
Packet Pg. 32
Jonathan Lait, Planning Director
Page 3
this may not be a problem; however, daylight plane concerns cannot be used to
unduly limit the height of an ADU. ADUs are permitted up to 16 feet high. (Gov.
Code, § 65852.2, subds. (c)(2)(C), (e)(1)(B)(ii).) Therefore, in considering
restrictions that the City is imposing on ADUs for daylight planes, the ordinance
should note the 16-foot height allowable for ADUs. This Table must be
amended to clarify this point.
• Section 18.09.040(b) Units Subject to Local Standards: Table 2 sets out the
development standards for ADUs that do not qualify under section 18.09.030.
Although the City has more freedom to establish development standards for
these ADUs, that is not without limitation. This section, and Table 2, must be
amended to clarify that—notwithstanding the development standards—an ADU
of at least 800 square feet, 16 feet in height, and with four-foot rear and side-
yard setbacks is permitted as required by State ADU Law. (Gov. Code, §
65852.2, subd. (c)(2)(C).)
• Section 18.09.040(b) Floor Area and JADUs: Development standards can
account for ADUs in their measurement of the floor area restrictions or ratio
(FAR). But these standards may not account for or consider JADUs. A JADU
may not be included in this calculation, because a JADU is a unit that is
contained entirely within a single-family residence. (Gov. Code § 65852.22,
subd. (h)(1).) Footnote 4 of Table 2 impermissibly includes JADUs as part of
the FAR calculations. This footnote must be amended to clarify this point.
• Section 18.09.040(h) Noise-Producing Equipment: Local agencies may impose
development standards on ADUs; however, these standards shall not exceed
state standards. Section 18.09.040(h) states that noise-producing equipment
“shall be located outside of the setbacks.” This section must be revised to only
refer to ADUs since setbacks are not required for JADUs. In addition, this
setback for noise-producing equipment for ADUs must be revised to make clear
that this setback requirement will not impede the minimum state standards of
four-foot setbacks. (Gov. Code, § 65852.2, subd. (c)(2)(C).)
• Section 18.09.040(i)(2) Setbacks: Currently, this section states, “No basement or
other subterranean portion of an ADU/JADU shall encroach into a setback required
for the primary dwelling.” Under state law, new attached and detached ADUs have
maximum four-foot rear and side-yard setbacks. (Gov. Code, § 65852.2, subds.
(a)(1)(D)(vii), (c)(2)(C), (e)(1)(B), and (e)(1)(D).) Local agencies may impose
setback requirements if the minimum rear and side-yard setbacks established by
state law are not exceeded. This restriction is concerning on a number of grounds.
First, setbacks may not be required for JADUs as they are constructed within the
walls of the primary dwelling. Second, this requirement imposes excessive
restrictions on ADUs converted from an existing area of the primary dwelling or
accessory structure with a basement or subterranean space. Again, these
Item 2
Attachment B - HCD
Letter on ADU Ordinance
(2021)
Packet Pg. 33
Jonathan Lait, Planning Director
Page 4
structures are not subject to setback requirements. Finally, this section would
violate State ADU Law if the side or rear setback requirement for an ADU or JADU
located in a basement or other subterranean structure exceeded four feet.
Requiring ADUs and JADUs to meet the side and rear setbacks for the primary
dwellings could exceed the maximum four-foot setbacks set out in State ADU Law.
The ordinance must be revised to eliminate these concerns.
• Section 18.09.040(j) Design: This section states, “Except on corner lots, the
unit shall not have an entranceway facing the same lot line (property line) as
the entranceway to the main dwelling unit unless the entranceway to the
accessory unit is located in the rear half of the lot. Exterior staircases to second
floor units shall be located towards the interior side or rear yard of the property.”
These standards appear to apply only to the creation of ADUs and may unduly
restrict the placement of an ADU on some lots. Local development standards
provided by ordinance pursuant to subdivisions (a) through (d) of Government
Code section 65852.2 do not apply to ADUs created under subdivision (e).
Please consider eliminating this restriction or modifying it such that it applies
“when feasible.”
• Section 18.09.040(j)(2)(A) Privacy: The section states, “Second story doors and
decks shall not face a neighboring dwelling unit.” This limitation, however, may
place an impermissible constraint on an ADU. For example, excessive
constraints would be placed on the creation of a second story ADU if residential
units were located on all adjacent parcels. In addition, when operating in
conjunction with Section 18.09.040(j), noted above, this restriction may prohibit
ADUs created under subdivision (e) of Government Code section 65852.2.
Accordingly, this provision must be revised to allow for more flexibility. The City
could revise the first sentence of this section to state, “Second story doors and
decks shall not face a neighboring dwelling unit, where feasible.”
• Section 18.09.040(k)(4) Parking: The ordinance indicates if covered parking for a
unit is provided in any district, the maximum size of the covered parking area for
the accessory dwelling unit is 220 square feet. Further, under this section, the
space for the covered parking count towards the total floor area for the site and
the ADU if attached to the unit. Covered parking should not count towards the
total floor area of the site as if it would unduly limit the allowable size of an ADU
established by state law, nor should it directly count toward the area available for
the ADU. Although standards within an underlying zone may apply when noted in
the adopted ADU ordinance, they may not be more restrictive than those
contained in state statute. (See, e.g., Gov. Code, § 65852.2, subs. (a)(1)(B),
(a)(1)(D)(vii), (a)(1)(D)(x), (c), and (e).) The portion of this section stating “unit
unless attached to the unit” should be deleted, or the section should otherwise be
modified to comply with state law.
Item 2
Attachment B - HCD
Letter on ADU Ordinance
(2021)
Packet Pg. 34
Jonathan Lait, Planning Director
Page 5
In these respects, revisions are necessary to comply with statute.
HCD will consider any written response to these findings, such as a revised ordinance
or a detailed plan to bring the ordinance into compliance with law by a date certain,
before taking further action authorized pursuant to Government Code section 65852.2.
Please note that HCD may notify the Attorney General’s Office in the event that the City
fails to take appropriate and timely action under section 65852.2, subdivision (h).
HCD appreciates the City’s efforts in the preparation and adoption of the ordinance and
welcomes the opportunity to assist the City in fully complying with State ADU Law.
Please contact Lauren Lajoie of our staff, at (916) 776-7495 or at
Lauren.Lajoie@hcd.ca.gov if you have any questions or would like HCD’s technical
assistance in these matters.
Sincerely,
David Zisser
Assistant Deputy Director
Local Government Relations and Accountability
Item 2
Attachment B - HCD
Letter on ADU Ordinance
(2021)
Packet Pg. 35
PLANNING & DEVELOPMENT SERVICES
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
(650) 329-2441
February 3, 2022
Lauren Lajoie
Housing & Community Development
Division of Housing Policy Development
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
Lauren.Lajoie@hcd.ca.gov
Dear Ms. Lajoie,
This letter represents the City of Palo Alto’s response to your letter dated December 23, 2021 received by
email, and received by hard copy on January 27, 2022. The content of the Housing and Community
Development’s letter is italicized. The City of Palo Alto’s responses are bolded.
1. ADU Size - Section 18.09.030(a)(3) Units Exempt from Generally Applicable Local Regulations: The
text of this Section and the applicable portion of Table 1 indicate the maximum size of a newly
constructed detached ADU is 800 square feet. Although a local agency may establish minimum and
maximum size requirements for ADUs pursuant to subdivision (c)(1) of Government Code section
65852.2 within limits, a local agency shall not establish a maximum square footage requirement for
either attached or detached ADUs that is less than 850 square feet and 1,000 square feet for an ADU
that provides more than one bedroom. (Gov. Code, § 65852.2, subd. (c)(2)(B).) Therefore, all relevant
sections of the ordinance must be amended to comply with this mandate in State ADU Law.
PAMC Section 18.09.030 is intended to describe the requirements for ADUs built under Gov. Code
65852.2, subdivision (e). This is not intended to create any limitation on ADUs built under
subdivisions (a)-(d), which are governed by PAMC Section 18.09.040. The City will add clarifying
language to this effect at the top of PAMC Section 18.09.030.
2. ADU & JADU - Section 18.09.030 Units Exempt from Generally Applicable Local Regulations: There
appears to be a conflict between the text of this section and Table 1. The number of allowable units
are correctly noted in Table 1 as “1 ADU and 1 JADU.” The text of section 18.09.030(a) appears to
limit allowable units to “an ADU or JADU.” Government Code section 65852.2, subdivision (e)(1)(A),
requires an ordinance to allow “one ADU and one JADU per lot… .” The City must amend the ordinance
to correct this inconsistency, clarifying that “one ADU and one JADU” are permitted if all the
conditions of section 65852.2, subdivision (e)(1)(A) apply.
The City will update its ordinance to reflect the changes made by AB 3182 with respect to 1 ADU
and 1 JADU.
3. Front Setback - Section 18.09.030(b) Application of Development Standards: Local agencies may
establish standards for ADUs pursuant to Government Code section 65852.2, subdivision (a);
however, these standards do not apply to ADUs constructed pursuant to subdivision (e). Table 1
impermissibly applies “underlying zoning” “for front setback[s]” to subdivision (e) ADUs. (Mun. Code,
§18.09.030(b).) Subdivision (e)(1) describes permitted setbacks in full. Unless underlying zoning for
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
all residential areas conforms to subdivision (e) limits, this table must be amended to comply with
statute. (Gov. Code, § 65852.2, subd. (e)(1)(A).)
During our conversation on February 2, 2022, you explained that local rules may apply for front
setbacks, including ADUs built under subdivision (e), and that it is not HCD’s position that
subdivision (e) ADUs must be allowed at the front lot line. You explained that the issue with the
current City ordinance is that it does not make clear that “underlying zoning” is only for front
setbacks. The City will clarify this point in its ordinance.
4. Height - Section 18.09.030(b)(1) ADU Height in Flood Zones: The City has impermissibly restricted the
height of ADUs. It appears that the City establishes minimum elevations for the first floor of structures
in the flood zone, which is essentially the entire city to varying degrees. To account for this, the zoning
code allows most residential structures to exceed otherwise maximum allowable heights for
development. The City does not extend this accommodation to ADUs. Currently, Table 1 states that
the maximum height for new, detached ADUs is 16 feet, but includes a caveat that “units built in a
flood zone are not entitled to any height extension.” (Mun. Code, § 18.09.030(b).) In many instances,
this would operate as an impermissible restriction on ADUs. Under State ADU Law, the City must
accommodate an ADU of at least 800 square feet and 16 feet in height. Thus, the caveat in Table 1 is
potentially confusing and could restrict the height to less than 16 feet. If it would in fact operate to
effectively limit the height of ADUs to less than 16 feet, it would operate as an impermissible
restriction on ADUs. As such, Table 1 should be revised to clarify that this limitation does not apply
where necessary to permit an 800-square foot ADU that it at least 16 feet tall. (Gov. Code, § 65852.2,
subds. (c)(2)(C) and (e)(1)(B)(ii).)
For purposes of health and safety, the City of Palo Alto requires structures built in a flood zone to
have a minimum finished floor height based on FEMA regulations. For a primary residence, the City
provides an extra height allowance of 50% the minimum finished floor height. The City does not
provide this allowance for any accessory structures, including ADUs. Nevertheless, ADUs in the
flood zone can still be built to a height of 16 feet. It is unclear to the City how the failure to provide
additional height above 16 feet represents an impermissible restriction on ADUs. During our
conversation, you related that HCD prefers to have as few restrictions as possible on ADU
production. The only restriction here is on finished floor height in the flood zone, which cannot be
waived or relaxed without impacts on health and safety. Even in areas requiring the most extreme
height above the base flood elevation, an ADU remains feasible within the 16 foot height limit.
5. Daylight Plane - Section 18.09.040(b) Daylight Plane and ADU Height Standards: Table 2 states that
“daylight plane” acts as a limit on the height of ADUs. In many instances, this may not be a problem;
however, daylight plane concerns cannot be used to unduly limit the height of an ADU. ADUs are
permitted up to 16 feet high. (Gov. Code, § 65852.2, subds. (c)(2)(C), (e)(1)(B)(ii).) Therefore, in
considering restrictions that the City is imposing on ADUs for daylight planes, the ordinance should
note the 16-foot height allowable for ADUs. This Table must be amended to clarify this point.
Please note that the City’s daylight plane regulations do not apply to subdivision (e) ADUs, which
are governed by PAMC Section 18.09.030. The City will add a clarifying sentence at the top of
Section 18.09.040 explaining that none of the regulations in PAMC 18.09.040 apply to subdivision
(e) ADUs. In addition, the City will add a clarifying statement that the regulations in PAMC
18.09.040 are not intended to limit the conversion of existing structures to ADUs or JADUs.
For all other ADUs, however, the City has requested clarity on HCD’s position on daylight plane on
numerous occasions, most recently by email dated August 8, 2021. Please see this email, which is
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Attachment C - Staff
Response to HCD (2022)
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
attached, for an explanation of the City’s position. The City looks forward to continued discussion
of this topic.
6. Clarify - Section 18.09.040(b) Units Subject to Local Standards: Table 2 sets out the development
standards for ADUs that do not qualify under section 18.09.030. Although the City has more freedom
to establish development standards for these ADUs, that is not without limitation. This section, and
Table 2, must be amended to clarify that—notwithstanding the development standards—an ADU of
at least 800 square feet, 16 feet in height, and with four-foot rear and side- yard setbacks is permitted
as required by State ADU Law. (Gov. Code, § 65852.2, subd. (c)(2)(C).)
The City will add a clarifying statement to this effect.
7. Floor Area & JADUs - Section 18.09.040(b) Floor Area and JADUs: Development standards can account
for ADUs in their measurement of the floor area restrictions or ratio (FAR). But these standards may
not account for or consider JADUs. A JADU may not be included in this calculation, because a JADU is
a unit that is contained entirely within a single-family residence. (Gov. Code § 65852.22, subd. (h)(1).)
Footnote 4 of Table 2 impermissibly includes JADUs as part of the FAR calculations. This footnote
must be amended to clarify this point.
Footnote 4 of Table 2 provides additional FAR on a site for ADUs and JADUs. This is an incentive to
promote production of such units without limiting the development potential of a primary unit.
Because a JADU is contained entirely within the space of a single-family residence, it would
normally be included in the floor area of the primary unit. Footnote 4 provides an opportunity for
a property owner to exempt all JADU square footage from the calculation of floor area for the
primary unit. The removal of JADUs from footnote 4 would only serve to restrict the development
of JADUs. The City will attempt to clarify the language of this footnote.
8. Noise-Producing Equipment - Section 18.09.040(h) Noise-Producing Equipment: Local agencies may
impose development standards on ADUs; however, these standards shall not exceed state standards.
Section 18.09.040(h) states that noise-producing equipment “shall be located outside of the
setbacks.” This section must be revised to only refer to ADUs since setbacks are not required for
JADUs. In addition, this setback for noise-producing equipment for ADUs must be revised to make
clear that this setback requirement will not impede the minimum state standards of four-foot
setbacks. (Gov. Code, § 65852.2, subd. (c)(2)(C)).
As noted above, the City will add a clarifying statement that the regulations in PAMC 18.09.040 are
not intended to limit the conversion of existing structures to ADUs or JADUs. For new construction,
however, the City permits JADUs to build at a lesser setback than a single-family home normally
would. Therefore, the removal of JADUs from this section will only serve to restrict the
development of JADUs.
Additionally, the City’s ordinance states that noise producing equipment needs to be placed
outside the setback for an ADU or JADU. This means that the noise producing equipment itself
cannot be placed closer than four-feet to a property line for either type of structure; not that the
ADU or JADU cannot be placed at those locations. This is consistent with the state setback
requirements for an ADU.
9. Basements - Section 18.09.040(i)(2) Setbacks: Currently, this section states, “No basement or other
subterranean portion of an ADU/JADU shall encroach into a setback required for the primary
dwelling.” Under state law, new attached and detached ADUs have maximum four-foot rear and side-
yard setbacks. (Gov. Code, § 65852.2, subds. (a)(1)(D)(vii), (c)(2)(C), (e)(1)(B), and (e)(1)(D).) Local
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Attachment C - Staff
Response to HCD (2022)
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
agencies may impose setback requirements if the minimum rear and side-yard setbacks established
by state law are not exceeded. This restriction is concerning on a number of grounds. First, setbacks
may not be required for JADUs as they are constructed within the walls of the primary dwelling.
Second, this requirement imposes excessive restrictions on ADUs converted from an existing area of
the primary dwelling or accessory structure with a basement or subterranean space. Again, these
structures are not subject to setback requirements. Finally, this section would violate State ADU Law
if the side or rear setback requirement for an ADU or JADU located in a basement or other
subterranean structure exceeded four feet. Requiring ADUs and JADUs to meet the side and rear
setbacks for the primary dwellings could exceed the maximum four-foot setbacks set out in State ADU
Law. The ordinance must be revised to eliminate these concerns.
As noted above, the City will add a clarifying statement that the regulations in PAMC 18.09.040 are
not intended to limit the conversion of existing structures to ADUs or JADUs. In addition, as with
the previous section, the inclusion of JADUs here only serves to increase flexibility of JADU
production.
As noted above, the City will add a clarifying statement an ADU of at least 800 square feet, 16 feet
in height, and with four-foot rear and side- yard setbacks is permitted as required by State ADU
Law.
With these clarifications the City does not believe it would violate State ADU Law to require that a
newly constructed ADU limit any below-grade space to a setback greater than 4 feet. It is the City’s
understanding that it could simply state that basements are not permitted for ADUs built under
subdivisions (a)-(d), so long as it was still feasible to construct an ADU of at least 800 square feet. If
this is the case, the City should have the lesser authority to direc t the placement of below-grade
development.
The City has significant concerns about basements in general, and those concerns extend to
basements constructed as part of ADUs. Due to a high water table throughout most of Palo Alto,
the construction of basements requires dewatering (pumping water from the construction site).
While this is allowed, there are significant restrictions on timing and procedures taken during the
dewatering process.
Secondly, development of homes in Palo Alto often includes requirements for the planting and
maintenance of trees used to enhance privacy between properties. Placing ADUs with basements
as close as 4 feet from the property line may jeopardize the health of these trees on the subject
property as well as trees on adjacent properties. The trees could fail, which would both diminish
the tree canopy—important for our environment and adaptation to climate change—and diminish
the privacy between properties.
Building below ground is not required in order to achieve a unit which f ollows the requirements in
Section 65852.2 and can lead to potential impacts on adjacent lots, such as to large stature trees on
adjacent lots which is a common occurrence in Palo Alto. Building a basement in these scenarios
may cause the tree to fail which is a life, safety, and health hazard which would unduly affect both
homeowners as a result of the action by one individual. There are construction methods which can
be implemented for above ground construction to help limit root damage caused by this
construction to preserve trees but that is not possible for below ground construction and can lead
to significant impacts as noted above.
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Attachment C - Staff
Response to HCD (2022)
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
10. Corner Lots - Section 18.09.040(j) Design: This section states, “Except on corner lots, the unit shall not
have an entranceway facing the same lot line (property line) as the entranceway to the main dwelling
unit unless the entranceway to the accessory unit is located in the rear half of the lot. Exterior
staircases to second floor units shall be located towards the interior side or rear yard of the property.”
These standards appear to apply only to the creation of ADUs and may unduly restrict the placement
of an ADU on some lots. Local development standards provided by ordinance pursuant to subdivisions
(a) through (d) of Government Code section 65852.2 do not apply to ADUs created under subdivision
(e). Please consider eliminating this restriction or modifying it such that it applies “when feasible.”
As noted above, the City will add a clarifying sentence at the top of Section 18.09.040 explaining
that none of the regulations in PAMC 18.09.040 apply to subdivision (e) ADUs. The City will clarify
this is not applicable for subsection (e) ADUs. We are not aware of any evidence that this simple
design requirement creates an excessive constraint on ADU production and that has not been our
experience.
11. Privacy - Section 18.09.040(j)(2)(A) Privacy: The section states, “Second story doors and decks shall not
face a neighboring dwelling unit.” This limitation, however, may place an impermissible constraint on
an ADU. For example, excessive constraints would be placed on the creation of a second story ADU if
residential units were located on all adjacent parcels. In addition, when operating in conjunction with
Section 18.09.040(j), noted above, this restriction may prohibit ADUs created under subdivision (e) of
Government Code section 65852.2. Accordingly, this provision must be revised to allow for more
flexibility. The City could revise the first sentence of this section to state, “Second story doors and decks
shall not face a neighboring dwelling unit, where feasible.”
As noted above, the City will add a clarifying sentence at the top of Section 18.09.040 explaining
that none of the regulations in PAMC 18.09.040 apply to subdivision (e) ADUs. We are not aware of
any evidence that this simple design requirement creates an excessive constraint on ADU
production and that has not been our experience.
The City will clarify this is not applicable for subsection (e) ADUs. We are not aware of any evidence
that this creates an excessive constraint and that has not been our experience.
12. Parking - Section 18.09.040(k)(4) Parking: The ordinance indicates if covered parking for a unit is
provided in any district, the maximum size of the covered parking area for the accessory dwelling unit
is 220 square feet. Further, under this section, the space for the covered parking count towards the
total floor area for the site and the ADU if attached to the unit. Covered parking should not count
towards the total floor area of the site as if it would unduly limit the allowable size of an ADU
established by state law, nor should it directly count toward the area available for the ADU. Although
standards within an underlying zone may apply when noted in the adopted ADU ordinance, they may
not be more restrictive than those contained in state statute. (See, e.g., Gov. Code, § 65852.2, subs.
(a)(1)(B), (a)(1)(D)(vii), (a)(1)(D)(x), (c), and (e).) The portion of this section stating “unit unless
attached to the unit” should be deleted, or the section should otherwise be modified to comply with
state law.
As noted above, the City will add a clarifying sentence at the top of Section 18.09.040 explaining
that none of the regulations in PAMC 18.09.040 apply to subdivision (e) ADUs.
Currently, all covered parking in the single-family zones counts towards floor area for the site and
dwelling unit. The City does not understand how this creates a standard that is more restrictive than
that contained in state statute; none of the subsections cited in your letter speak to whether a
garage for an ADU must be exempted from the unit size for the ADU. Moreover, this provision does
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
not create a constraint on ADU production, as a property owner may always choose to provide a
detached garage, uncovered parking, or no parking at all for the ADU.
The City has concerns that allowing attached garages onto these structures will incentivize
individuals to illegally expand the unit into the garage, which would both exceed the City’s
ordinance, contain unpermitted construction, and potentially place the health and safety of the
occupants at risk.
Sincerely,
Jonathan Lait
Director of Planning and Development Services
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Certificate Of Completion
Envelope Id: 26247F48AB8146DCAE7591A87A8EE538 Status: Completed
Subject: Please DocuSign: 2022-02-02 Draft HCD ADU Letter response.docx
Source Envelope:
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250 Hamilton Ave
Palo Alto , CA 94301
Madina.Klicheva@CityofPaloAlto.org
IP Address: 199.33.32.254
Record Tracking
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Jonathan Lait
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Interim Director Planning and Community
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City of Palo Alto
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Attachment C - Staff
Response to HCD (2022)
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Attachment C - Staff
Response to HCD (2022)
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
December 21, 2022
Jonathan Lait, Director
Planning and Development Services
City of Palo Alto
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
Dear Jonathan Lait:
RE: City of Palo Alto Accessory Dwelling Unit (ADU) Ordinance – Letter of
Technical Assistance
The California Department of Housing and Community Development (HCD) thanks the
City of Palo Alto (City) for submitting accessory dwelling unit (ADU) Ordinance Number
5507 (Ordinance) and for its response to HCD’s December 23, 2021, written findings of
non-compliance. HCD appreciates the time and effort the City took in crafting its
February 3, 2022, response, and for the conversation between City staff and HCD
Analyst Lauren Lajoie on February 2, 2022. Nevertheless, HCD has concerns with the
City’s response as it fails to address identified inconsistencies between the City’s ADU
ordinance and State ADU Law, as outlined in this letter.
HCD requests that the City respond to this letter no later than January 20, 2023, with a
detailed plan of action and timeline, to bring its Ordinance into compliance pursuant to
Government Code section 65852.2, subdivision (h)(2)(B).
Background and Summary of Issues
In its December 23, 2021, findings, HCD detailed where it found the Ordinance violates
Government Code section 65852.2. In its February 3, 2022, letter, the City responded
point by point to the findings as they were presented in the HCD letter. While the
responses indicate a willingness to come into compliance with state law, HCD remains
concerned that the proposed changes to the City’s Ordinance are insufficient. This letter
will address HCD’s findings for which the City’s response and/or commitment to correct
was not satisfactory and where HCD still considers an inconsistency between the
Ordinance and State ADU Law.
1) HCD’s Original Finding
Daylight Plane - Section 18.09.040(b): Table 2 states that "daylight plane" acts as a
limit on the height of ADUs. In many instances, this may not be a problem; however,
daylight plane concerns cannot be used to unduly limit the height of an ADU. ADUs
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 44
Jonathan Lait, Director of Planning and Development Services
Page 2
are permitted up to 16 feet high. (Gov. Code, § 65852.2, subds. (c)(2)(C),
(e)(1)(B)(ii).) Therefore, in considering restrictions that the City is imposing on ADUs
for daylight planes, the ordinance should note the 16-foot height allowable for ADUs.
This Table must be amended to clarify this point.
Palo Alto’s Response
“Please note that the City’s daylight plane regulations do not apply to subdivision (e)
ADUs, which are governed by PAMC Section 18.09.030. The City will add a
clarifying sentence at the top of Section 18.09.040 explaining that none of the
regulations in PAMC 18.09.040 apply to subdivision (e) ADUs. In addition, the City
will add a clarifying statement that the regulations in PAMC 18.09.040 are not
intended to limit the conversion of existing structures to ADUs or JADUs. For all
other ADUs; however, the City has requested clarity on HCD’s position on daylight
plane on numerous occasions, most recently by email dated August 8, 2021. Please
see this email, which is attached, for an explanation of the City’s position. The City
looks forward to continued discussion of this topic.”
HCD’s Follow-up Response
On February 23, 2022, HCD received a copy of an email from Assistant City
Attorney (ACA) Albert Yang dated August 30, 2021. ACA Yang sought clarification
on behalf of the City on whether local government could enforce a development
standard that would require that any portion of an ADU fall below 16 feet in height.
The email states: ”Subdivision (c)(2)(C) provides that a local agency may not
establish “[1] any other minimum or maximum size for an accessory dwelling unit, [2]
size based upon a percentage of the proposed or existing primary dwelling, or [3]
limits on lot coverage, [4] floor area ratio, [5] open space, and [6] minimum lot size [.
. .] that does not permit at least an 800 square foot accessory dwelling unit that is at
least 16 feet in height with four-foot side and rear yard setbacks to be constructed in
compliance with all other local development standards.” ACA Yang argues that the
law is very specific regarding the development standards addressed and it (the
subdivision) specifically recognizes that the list does not encompass all development
standards. ACA Yang states, “The specific development standards addressed in
subdivision (c)(2)(C) do not include daylight plane standards.” ACA Yang impliedly
concludes that because the development standards, which ACA Yang numbered
from [1] through [6], do not list daylight plane standards, the City may impose
daylight plane standards over the minimum 16-foot height requirement.
However, the City incorrectly cited subdivision (c)(2)(C) above; thereby, creating a
list of “development standards” from portions of (c)(2)(A) and (c)(2)(B)(i) and (ii) and
conflated these with “other local development standards” found in subdivision
(c)(2)(C). Accurately cited, subdivision (c)(2)(C) states:
(C) Any other minimum or maximum size for an accessory dwelling unit, size based
upon a percentage of the proposed or existing primary dwelling, or limits on lot
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 45
Jonathan Lait, Director of Planning and Development Services
Page 3
coverage, floor area ratio, open space, and minimum lot size, for either attached or
detached dwellings that does not permit at least an 800 square foot accessory dwelling
unit that is at least 16 feet in height with four-foot side and rear yard setbacks to be
constructed in compliance with all other local development standards.
State ADU Law authorizes a local agency to establish the minimum and maximum
size requirements for ADUs in subdivision (c)(1), but any such size requirement
must allow for a minimum height of 16 feet while being constructed in compliance
with all other local development standards. This height requirement is meant to be in
harmony with local development standards. Because the subdivision has set the
minimum height, authorized by statute, local design standards set in the ordinance
cannot invalidate this provision, pursuant to Government Code section 65852.2
(a)(5). Therefore, the minimum height of all proposed ADUs is 16 feet and
cannot be limited by Daylight Plane restrictions. Table 2 must be amended to
clarify this point. Please note that SB 897 (2022), effective January 1, 2023, amends
this subdivision, and adds provisions regarding the minimum height for detached
and attached ADUs.
2) HCD’s Original Finding
Floor Area & JADUs - Section 18.09.040(b): Development standards can account for
ADUs in their measurement of the floor area restrictions or ratio (FAR). But these
standards may not account for or consider JADUs. A JADU may not be included in
this calculation, because a JADU is a unit that is contained entirely within a single-
family residence. (Gov. Code § 65852.22, subd. (h)(1).) Footnote 4 of Table 2
impermissibly includes JADUs as part of the FAR calculations. This footnote must be
amended to clarify this point.
Palo Alto’s Response
“Footnote 4 of Table 2 provides additional FAR on a site for ADUs and JADUs. This
is an incentive to promote production of such units without limiting the development
potential of a primary unit. Because a JADU is contained entirely within the space of
a single-family residence, it would normally be included in the floor area of the
primary unit. Footnote 4 provides an opportunity for a property owner to exempt all
JADU square footage from the calculation of floor area for the primary unit. The
removal of JADUs from footnote 4 would only serve to restrict the development of
JADUs. The City will attempt to clarify the language of this footnote.”
HCD’s Follow-up Response
HCD supports the City’s attempt to add clarifying language. Converting an area
within an existing home should not be counted. To clarify footnote 4 in Table 2, the
City could include, for example, "This provision applies to JADUs in proposed
single-family dwellings, or remodels that increase the square footage of a single-
family dwelling.”
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 46
Jonathan Lait, Director of Planning and Development Services
Page 4
3) HCD’s Original Finding
Noise-Producing Equipment - Section 18.09.040(h): Local agencies may impose
development standards on ADUs; however, these standards shall not exceed state
standards. Section 18.09.040(h) states that noise-producing equipment “shall be
located outside of the setbacks.” This section must be revised to only refer to ADUs
since setbacks are not required for JADUs. In addition, this setback for noise-
producing equipment for ADUs must be revised to make clear that this setback
requirement will not impede the minimum state standards of four-foot setbacks.
(Gov. Code, § 65852.2, subd. (c)(2)(C)).
Palo Alto’s Response
“As noted above, the City will add a clarifying statement that the regulations in
PAMC 18.09.040 are not intended to limit the conversion of existing structures to
ADUs or JADUs. For new construction; however, the City permits JADUs to build at
a lesser setback than a single-family home normally would. Therefore, the removal
of JADUs from this section will only serve to restrict the development of JADUs.
“Additionally, the City’s ordinance states that noise producing equipment needs to be
placed outside the setback for an ADU or JADU. This means that the noise
producing equipment itself cannot be placed closer than four feet to a property line
for either type of structure; not that the ADU or JADU cannot be placed at those
locations. This is consistent with the state setback requirements for an ADU.”
HCD’s Follow-up Response
JADUs are entirely within the walls of a proposed or existing single-family dwelling
and as such not subject to any setback requirements. Therefore, the City should
remove the reference to JADU from Section 18.09.040(h). The City writes, “For new
construction; however, the City permits JADUs to be built at a lesser setback than a
single-family home normally would.” Please clarify this statement for us. HCD
applauds the City’s intention to promote JADUs by relaxing setback requirements.
However, since setbacks do not apply to JADUs, the City would have to relax the
setback requirements for the primary single-family dwelling to achieve the desired
effect.
4) HCD’s Original Finding
Corner Lots - Section 18.09.040(j) Design: This section states, “Except on corner
lots, the unit shall not have an entranceway facing the same lot line (property line) as
the entranceway to the main dwelling unit unless the entranceway to the accessory
unit is located in the rear half of the lot. Exterior staircases to second floor units shall
be located towards the interior side or rear yard of the property.” These standards
appear to apply only to the creation of ADUs and may unduly restrict the placement
of an ADU on some lots. Local development standards provided by ordinance
pursuant to subdivisions (a) through (d) of Government Code section 65852.2 do not
apply to ADUs created under subdivision (e). Please consider eliminating this
restriction or modifying it such that it applies “when feasible.”
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 47
Jonathan Lait, Director of Planning and Development Services
Page 5
Palo Alto’s Response
“As noted above, the City will add a clarifying sentence at the top of Section
18.09.040 explaining that none of the regulations in PAMC 18.09.040 apply to
subdivision (e) ADUs. The City will clarify this is not applicable for subsection (e)
ADUs. We are not aware of any evidence that this simple design requirement
creates an excessive constraint on ADU production and that has not been our
experience.”
HCD’s Follow-Up Response
Requirements such as stipulating the facing of entranceways or the location of
stairways may unduly restrict the creation of ADUs on some lots. Statute for both
ADUs (Gov. Code, § 65852.2, subd. (e)(1)(A)(ii)) and JADUs (Gov. Code, §
65852.22, subd. (a)(5)) require independent entry into the unit, and a constraint on
the location of an entry door may prohibit the creation of an additional housing unit.
In addition, this requirement could add significant expense if entry doors must be
installed in an exterior wall instead of utilizing an existing doorway facing the same
direction as the entryway to the primary dwelling. The City must either eliminate this
restriction or modify it such that it applies “when feasible.”
5) HCD’s Original Finding
Parking - Section 18.09.040(k)(iv) Parking: The ordinance indicates if covered
parking for a unit is provided in any district, the maximum size of the covered parking
area for the accessory dwelling unit is 220 square feet. Further, under this section,
the space for the covered parking count towards the total floor area for the site and
the ADU if attached to the unit. Covered parking should not count towards the total
floor area of the site as if it would unduly limit the allowable size of an ADU
established by state law, nor should it directly count toward the area available for the
ADU. Although standards within an underlying zone may apply when noted in the
adopted ADU ordinance, they may not be more restrictive than those contained in
state statute. (See, e.g., Gov. Code, § 65852.2, subs. (a)(1)(B), (a)(1)(D)(vii),
(a)(1)(D)(x), (c), and (e).) The portion of this section stating “unit unless attached to
the unit” should be deleted, or the section should otherwise be modified to comply
with state law.
Palo Alto’s Response
“As noted above, the City will add a clarifying sentence at the top of Section
18.09.040 explaining that none of the regulations in PAMC 18.09.040 apply to
subdivision (e) ADUs.
“Currently, all covered parking in the single-family zones counts towards floor area
for the site and dwelling unit. The City does not understand how this creates a
standard that is more restrictive than that contained in state statute; none of the
subsections cited in your letter speak to whether a garage for an ADU must be
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 48
Jonathan Lait, Director of Planning and Development Services
Page 6
exempted from the unit size for the ADU. Moreover, this provision does not create a
constraint on ADU production, as a property owner may always choose to provide a
detached garage, uncovered parking, or no parking at all for the ADU.
“The City has concerns that allowing attached garages onto these structures will
incentivize individuals to illegally expand the unit into the garage, which would both
exceed the City's ordinance, contain unpermitted construction, and potentially place
the health and safety of the occupants at risk.”
HCD’s Follow-up Response
Covered parking does not count towards the total floor area of the ADU. An ADU is
defined in Government Code section 65852.2, subdivision (j)(1), as “complete
independent living facilities,” and subdivision (j)(4) further specifies that the living
area for the ADU “does not include a garage...” Thus, a covered parking space or
garage, whether or not attached to a unit, would be considered “non-livable” space.
Therefore, as stated in our original finding, covered parking should not count
towards the total floor area of the site as it would unduly limit the allowable size of an
ADU established by state law. Similarly, it should not directly count toward the area
available for the ADU, as this could also restrict the size of the ADU. The addition of
garage space to the ADUs livable space would violate ADU size requirements found
in Government Code section 65852.2, subdivisions (a)(1)(D)(iv) and (v), and (c).
While the City raises concerns of potential illegal expansion, the City may not adopt
an ordinance that would violate State ADU Law. The City may rely on its
enforcement of codes and standards to mitigate its concerns. The City should
remove the portion of this section stating “unless attached to the unit” or otherwise
modify the section to comply with State ADU Law.
Conclusion
Given the deficiencies described above and in HCD’s December 23, 2021, letter, the
City’s Ordinance is inconsistent with State ADU Law. HCD requests that the City
respond to this letter no later than January 20, 2023, with a detailed plan of action and
timeline, to bring its Ordinance into compliance pursuant to Government Code section
65852.2, subdivision (h)(2)(B). Specifically, to bring its ADU ordinance into compliance,
the City must either amend the Ordinance according to HCD’s findings to comply with
State ADU Law (Gov. Code, § 65852.2, subd. (h)(2)(B)(i)) or readopt the Ordinance
without changes. Should the City choose to readopt the Ordinance without the changes
specified by HCD, the City must include findings in its resolution that explain the
reasons the City finds that the Ordinance complies with State ADU Law despite the
findings made by HCD. (Gov. Code, § 65852.2, subd. (h)(2)(B)(ii), (h)(3)(A).)
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 49
Jonathan Lait, Director of Planning and Development Services
Page 7
HCD will review and consider any plan of action and timeline received from the City
before January 20, 2023, in advance of taking further action authorized by Government
Code section 65852.2.
HCD appreciates the City’s efforts provided in the preparation and adoption of the
Ordinance and welcomes the opportunity to assist the City in fully complying with State
ADU Law. Please feel free to contact Mike Van Gorder, of our staff, at (916) 776-7541
or at mike.vangorder@hcd.ca.gov.
Sincerely,
Shannan West
Housing Accountability Unit Chief
Item 2
Attachment D - HCD
Letter on ADU Ordinance
(2022)
Packet Pg. 50
January 13, 2023
Mike Van Gorder
Housing & Community Development
Division of Housing Policy Development
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
Mike.VanGorder@hcd.ca.gov
Dear Mr. Van Gorder,
Thank you for the telephone call today regarding HCD’s letter dated December 21, 2022, which
is attached to and referenced in this response. Staff appreciates HCD’s thorough review of the
City’s ADU ordinance and consideration of the City’s prior comments in response to HCD
compliance concerns. There are five outstanding issues referenced in the letter related to various
development standards. City staff responses to each topic area is provided below; in short, staff
will recommend that the City’s ordinance be updated in accordance with HCD’s comments.
1. Daylight Plane. Staff understands HCD’s response to mean that all portions of an ADU
must be permitted at the heights now provided Government Code section
65852.2(c)(2)(D). City staff will recommend to its legislative body updating the ordinance
to reflect that daylight plane does not limit ADU heights below the heights provided in
the Government Code.
2. Floor Area and JADUs. The City’s intention with respect to JADUs has always been that they
will not impact the development potential for single-family dwelling, whether through floor
area, lot coverage, or any other development standard. The City believes this is consistent
with HCD’s direction and will ensure that its ordinance reflects this intention in a manner that
makes sense in the context and structure of the City’s other zoning regulations.
3. Noise Producing Equipment/JADU setbacks. The City does not believe there is a
substantive disagreement in this area. Typically, in Palo Alto, new construction related to
a single-family residence requires a six-foot side yard and 20-foot rear yard setback.
However, as an incentive for JADU production, the City’s zoning regulations provide a
more lenient four-foot setback for new construction that is proposed to contain a JADU.
While, it may be technically more accurate to call this this four-foot setback a “setback
for the new construction portion of a single-family home that is dedicated to a JADU,” we
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 51
believe it is easier for applicants and staff to refer to this as a “setback for a new
construction JADU.” Nevertheless, staff will explore whether there are clearer ways to
express this in the upcoming ADU code amendment.
With respect to the topic of noise producing equipment, the City’s municipal regulations
prohibit such freestanding or attached appurtenances from being located closer to the
property line than is already allowed by state law for the ADU/JADU structure. The City is
currently working on amendments to the regulations pertaining to certain noise
producing equipment to allow greater flexibility for the primary unit in an effort to
advance the City’s carbon reduction goals.
4. Corner Lots. The City continues to be unaware of any evidence that a simple objective design
requirement related to entryways creates an excessive constraint on ADU production – that
has certainly not been our experience processing over 527 ADU permits since 2018.
Nevertheless, City staff will recommend an additional clarifying statement to the effect of
“when feasible,” or removal of this provision altogether.
5. Parking. The City was not able to find a relationship in state law between the term “living
area” and minimum or maximum sizes for an ADU. Indeed, the term “living area” is only
used in Gov. Code 65852.2(a)(1)(D)(vii) with respect to conversion of existing structures.
Nonetheless, the City understands HCD’s position that garage area should not count
toward the “size” of an ADU. City staff will recommend removal of the phrase “unless
attached to the unit”, as suggested by HCD.
City staff intends to propose amendments to the City’s ADU ordinance consistent with HCD
direction at the earliest practical opportunity. At this time, staff anticipates a hearing before the
Planning and Transportation Commission (PTC) by the end of March to discuss and address the
requested changes from HCD. Following the PTC’s recommendation, staff will then place the
ordinance on the City Council’s agenda for adoption; anticipated for May, if not sooner. If the
City deviates from this schedule, staff will contact HCD and provide relevant updates.
Thank you again for reviewing our response letters, if you have any questions, please contact me
at (650) 329-2676 or by email at jonathan.lait@cityofpaloalto.org.
Sincerely,
Jonathan Lait
Director of Planning and Development Services
Attachment: HCD Letter, dated December 21, 2022
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 52
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
December 21, 2022
Jonathan Lait, Director
Planning and Development Services
City of Palo Alto
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
Dear Jonathan Lait:
RE: City of Palo Alto Accessory Dwelling Unit (ADU) Ordinance – Letter of
Technical Assistance
The California Department of Housing and Community Development (HCD) thanks the
City of Palo Alto (City) for submitting accessory dwelling unit (ADU) Ordinance Number
5507 (Ordinance) and for its response to HCD’s December 23, 2021, written findings of
non-compliance. HCD appreciates the time and effort the City took in crafting its
February 3, 2022, response, and for the conversation between City staff and HCD
Analyst Lauren Lajoie on February 2, 2022. Nevertheless, HCD has concerns with the
City’s response as it fails to address identified inconsistencies between the City’s ADU
ordinance and State ADU Law, as outlined in this letter.
HCD requests that the City respond to this letter no later than January 20, 2023, with a
detailed plan of action and timeline, to bring its Ordinance into compliance pursuant to
Government Code section 65852.2, subdivision (h)(2)(B).
Background and Summary of Issues
In its December 23, 2021, findings, HCD detailed where it found the Ordinance violates
Government Code section 65852.2. In its February 3, 2022, letter, the City responded
point by point to the findings as they were presented in the HCD letter. While the
responses indicate a willingness to come into compliance with state law, HCD remains
concerned that the proposed changes to the City’s Ordinance are insufficient. This letter
will address HCD’s findings for which the City’s response and/or commitment to correct
was not satisfactory and where HCD still considers an inconsistency between the
Ordinance and State ADU Law.
1) HCD’s Original Finding
Daylight Plane - Section 18.09.040(b): Table 2 states that "daylight plane" acts as a
limit on the height of ADUs. In many instances, this may not be a problem; however,
daylight plane concerns cannot be used to unduly limit the height of an ADU. ADUs
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 53
Jonathan Lait, Director of Planning and Development Services
Page 2
are permitted up to 16 feet high. (Gov. Code, § 65852.2, subds. (c)(2)(C),
(e)(1)(B)(ii).) Therefore, in considering restrictions that the City is imposing on ADUs
for daylight planes, the ordinance should note the 16-foot height allowable for ADUs.
This Table must be amended to clarify this point.
Palo Alto’s Response
“Please note that the City’s daylight plane regulations do not apply to subdivision (e)
ADUs, which are governed by PAMC Section 18.09.030. The City will add a
clarifying sentence at the top of Section 18.09.040 explaining that none of the
regulations in PAMC 18.09.040 apply to subdivision (e) ADUs. In addition, the City
will add a clarifying statement that the regulations in PAMC 18.09.040 are not
intended to limit the conversion of existing structures to ADUs or JADUs. For all
other ADUs; however, the City has requested clarity on HCD’s position on daylight
plane on numerous occasions, most recently by email dated August 8, 2021. Please
see this email, which is attached, for an explanation of the City’s position. The City
looks forward to continued discussion of this topic.”
HCD’s Follow-up Response
On February 23, 2022, HCD received a copy of an email from Assistant City
Attorney (ACA) Albert Yang dated August 30, 2021. ACA Yang sought clarification
on behalf of the City on whether local government could enforce a development
standard that would require that any portion of an ADU fall below 16 feet in height.
The email states: ”Subdivision (c)(2)(C) provides that a local agency may not
establish “[1] any other minimum or maximum size for an accessory dwelling unit, [2]
size based upon a percentage of the proposed or existing primary dwelling, or [3]
limits on lot coverage, [4] floor area ratio, [5] open space, and [6] minimum lot size [.
. .] that does not permit at least an 800 square foot accessory dwelling unit that is at
least 16 feet in height with four-foot side and rear yard setbacks to be constructed in
compliance with all other local development standards.” ACA Yang argues that the
law is very specific regarding the development standards addressed and it (the
subdivision) specifically recognizes that the list does not encompass all development
standards. ACA Yang states, “The specific development standards addressed in
subdivision (c)(2)(C) do not include daylight plane standards.” ACA Yang impliedly
concludes that because the development standards, which ACA Yang numbered
from [1] through [6], do not list daylight plane standards, the City may impose
daylight plane standards over the minimum 16-foot height requirement.
However, the City incorrectly cited subdivision (c)(2)(C) above; thereby, creating a
list of “development standards” from portions of (c)(2)(A) and (c)(2)(B)(i) and (ii) and
conflated these with “other local development standards” found in subdivision
(c)(2)(C). Accurately cited, subdivision (c)(2)(C) states:
(C) Any other minimum or maximum size for an accessory dwelling unit, size based
upon a percentage of the proposed or existing primary dwelling, or limits on lot
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 54
Jonathan Lait, Director of Planning and Development Services
Page 3
coverage, floor area ratio, open space, and minimum lot size, for either attached or
detached dwellings that does not permit at least an 800 square foot accessory dwelling
unit that is at least 16 feet in height with four-foot side and rear yard setbacks to be
constructed in compliance with all other local development standards.
State ADU Law authorizes a local agency to establish the minimum and maximum
size requirements for ADUs in subdivision (c)(1), but any such size requirement
must allow for a minimum height of 16 feet while being constructed in compliance
with all other local development standards. This height requirement is meant to be in
harmony with local development standards. Because the subdivision has set the
minimum height, authorized by statute, local design standards set in the ordinance
cannot invalidate this provision, pursuant to Government Code section 65852.2
(a)(5). Therefore, the minimum height of all proposed ADUs is 16 feet and
cannot be limited by Daylight Plane restrictions. Table 2 must be amended to
clarify this point. Please note that SB 897 (2022), effective January 1, 2023, amends
this subdivision, and adds provisions regarding the minimum height for detached
and attached ADUs.
2) HCD’s Original Finding
Floor Area & JADUs - Section 18.09.040(b): Development standards can account for
ADUs in their measurement of the floor area restrictions or ratio (FAR). But these
standards may not account for or consider JADUs. A JADU may not be included in
this calculation, because a JADU is a unit that is contained entirely within a single-
family residence. (Gov. Code § 65852.22, subd. (h)(1).) Footnote 4 of Table 2
impermissibly includes JADUs as part of the FAR calculations. This footnote must be
amended to clarify this point.
Palo Alto’s Response
“Footnote 4 of Table 2 provides additional FAR on a site for ADUs and JADUs. This
is an incentive to promote production of such units without limiting the development
potential of a primary unit. Because a JADU is contained entirely within the space of
a single-family residence, it would normally be included in the floor area of the
primary unit. Footnote 4 provides an opportunity for a property owner to exempt all
JADU square footage from the calculation of floor area for the primary unit. The
removal of JADUs from footnote 4 would only serve to restrict the development of
JADUs. The City will attempt to clarify the language of this footnote.”
HCD’s Follow-up Response
HCD supports the City’s attempt to add clarifying language. Converting an area
within an existing home should not be counted. To clarify footnote 4 in Table 2, the
City could include, for example, "This provision applies to JADUs in proposed
single-family dwellings, or remodels that increase the square footage of a single-
family dwelling.”
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Attachment E - Staff
Response to HCD (2023)
Packet Pg. 55
Jonathan Lait, Director of Planning and Development Services
Page 4
3) HCD’s Original Finding
Noise-Producing Equipment - Section 18.09.040(h): Local agencies may impose
development standards on ADUs; however, these standards shall not exceed state
standards. Section 18.09.040(h) states that noise-producing equipment “shall be
located outside of the setbacks.” This section must be revised to only refer to ADUs
since setbacks are not required for JADUs. In addition, this setback for noise-
producing equipment for ADUs must be revised to make clear that this setback
requirement will not impede the minimum state standards of four-foot setbacks.
(Gov. Code, § 65852.2, subd. (c)(2)(C)).
Palo Alto’s Response
“As noted above, the City will add a clarifying statement that the regulations in
PAMC 18.09.040 are not intended to limit the conversion of existing structures to
ADUs or JADUs. For new construction; however, the City permits JADUs to build at
a lesser setback than a single-family home normally would. Therefore, the removal
of JADUs from this section will only serve to restrict the development of JADUs.
“Additionally, the City’s ordinance states that noise producing equipment needs to be
placed outside the setback for an ADU or JADU. This means that the noise
producing equipment itself cannot be placed closer than four feet to a property line
for either type of structure; not that the ADU or JADU cannot be placed at those
locations. This is consistent with the state setback requirements for an ADU.”
HCD’s Follow-up Response
JADUs are entirely within the walls of a proposed or existing single-family dwelling
and as such not subject to any setback requirements. Therefore, the City should
remove the reference to JADU from Section 18.09.040(h). The City writes, “For new
construction; however, the City permits JADUs to be built at a lesser setback than a
single-family home normally would.” Please clarify this statement for us. HCD
applauds the City’s intention to promote JADUs by relaxing setback requirements.
However, since setbacks do not apply to JADUs, the City would have to relax the
setback requirements for the primary single-family dwelling to achieve the desired
effect.
4) HCD’s Original Finding
Corner Lots - Section 18.09.040(j) Design: This section states, “Except on corner
lots, the unit shall not have an entranceway facing the same lot line (property line) as
the entranceway to the main dwelling unit unless the entranceway to the accessory
unit is located in the rear half of the lot. Exterior staircases to second floor units shall
be located towards the interior side or rear yard of the property.” These standards
appear to apply only to the creation of ADUs and may unduly restrict the placement
of an ADU on some lots. Local development standards provided by ordinance
pursuant to subdivisions (a) through (d) of Government Code section 65852.2 do not
apply to ADUs created under subdivision (e). Please consider eliminating this
restriction or modifying it such that it applies “when feasible.”
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 56
Jonathan Lait, Director of Planning and Development Services
Page 5
Palo Alto’s Response
“As noted above, the City will add a clarifying sentence at the top of Section
18.09.040 explaining that none of the regulations in PAMC 18.09.040 apply to
subdivision (e) ADUs. The City will clarify this is not applicable for subsection (e)
ADUs. We are not aware of any evidence that this simple design requirement
creates an excessive constraint on ADU production and that has not been our
experience.”
HCD’s Follow-Up Response
Requirements such as stipulating the facing of entranceways or the location of
stairways may unduly restrict the creation of ADUs on some lots. Statute for both
ADUs (Gov. Code, § 65852.2, subd. (e)(1)(A)(ii)) and JADUs (Gov. Code, §
65852.22, subd. (a)(5)) require independent entry into the unit, and a constraint on
the location of an entry door may prohibit the creation of an additional housing unit.
In addition, this requirement could add significant expense if entry doors must be
installed in an exterior wall instead of utilizing an existing doorway facing the same
direction as the entryway to the primary dwelling. The City must either eliminate this
restriction or modify it such that it applies “when feasible.”
5) HCD’s Original Finding
Parking - Section 18.09.040(k)(iv) Parking: The ordinance indicates if covered
parking for a unit is provided in any district, the maximum size of the covered parking
area for the accessory dwelling unit is 220 square feet. Further, under this section,
the space for the covered parking count towards the total floor area for the site and
the ADU if attached to the unit. Covered parking should not count towards the total
floor area of the site as if it would unduly limit the allowable size of an ADU
established by state law, nor should it directly count toward the area available for the
ADU. Although standards within an underlying zone may apply when noted in the
adopted ADU ordinance, they may not be more restrictive than those contained in
state statute. (See, e.g., Gov. Code, § 65852.2, subs. (a)(1)(B), (a)(1)(D)(vii),
(a)(1)(D)(x), (c), and (e).) The portion of this section stating “unit unless attached to
the unit” should be deleted, or the section should otherwise be modified to comply
with state law.
Palo Alto’s Response
“As noted above, the City will add a clarifying sentence at the top of Section
18.09.040 explaining that none of the regulations in PAMC 18.09.040 apply to
subdivision (e) ADUs.
“Currently, all covered parking in the single-family zones counts towards floor area
for the site and dwelling unit. The City does not understand how this creates a
standard that is more restrictive than that contained in state statute; none of the
subsections cited in your letter speak to whether a garage for an ADU must be
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 57
Jonathan Lait, Director of Planning and Development Services
Page 6
exempted from the unit size for the ADU. Moreover, this provision does not create a
constraint on ADU production, as a property owner may always choose to provide a
detached garage, uncovered parking, or no parking at all for the ADU.
“The City has concerns that allowing attached garages onto these structures will
incentivize individuals to illegally expand the unit into the garage, which would both
exceed the City's ordinance, contain unpermitted construction, and potentially place
the health and safety of the occupants at risk.”
HCD’s Follow-up Response
Covered parking does not count towards the total floor area of the ADU. An ADU is
defined in Government Code section 65852.2, subdivision (j)(1), as “complete
independent living facilities,” and subdivision (j)(4) further specifies that the living
area for the ADU “does not include a garage...” Thus, a covered parking space or
garage, whether or not attached to a unit, would be considered “non-livable” space.
Therefore, as stated in our original finding, covered parking should not count
towards the total floor area of the site as it would unduly limit the allowable size of an
ADU established by state law. Similarly, it should not directly count toward the area
available for the ADU, as this could also restrict the size of the ADU. The addition of
garage space to the ADUs livable space would violate ADU size requirements found
in Government Code section 65852.2, subdivisions (a)(1)(D)(iv) and (v), and (c).
While the City raises concerns of potential illegal expansion, the City may not adopt
an ordinance that would violate State ADU Law. The City may rely on its
enforcement of codes and standards to mitigate its concerns. The City should
remove the portion of this section stating “unless attached to the unit” or otherwise
modify the section to comply with State ADU Law.
Conclusion
Given the deficiencies described above and in HCD’s December 23, 2021, letter, the
City’s Ordinance is inconsistent with State ADU Law. HCD requests that the City
respond to this letter no later than January 20, 2023, with a detailed plan of action and
timeline, to bring its Ordinance into compliance pursuant to Government Code section
65852.2, subdivision (h)(2)(B). Specifically, to bring its ADU ordinance into compliance,
the City must either amend the Ordinance according to HCD’s findings to comply with
State ADU Law (Gov. Code, § 65852.2, subd. (h)(2)(B)(i)) or readopt the Ordinance
without changes. Should the City choose to readopt the Ordinance without the changes
specified by HCD, the City must include findings in its resolution that explain the
reasons the City finds that the Ordinance complies with State ADU Law despite the
findings made by HCD. (Gov. Code, § 65852.2, subd. (h)(2)(B)(ii), (h)(3)(A).)
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 58
Jonathan Lait, Director of Planning and Development Services
Page 7
HCD will review and consider any plan of action and timeline received from the City
before January 20, 2023, in advance of taking further action authorized by Government
Code section 65852.2.
HCD appreciates the City’s efforts provided in the preparation and adoption of the
Ordinance and welcomes the opportunity to assist the City in fully complying with State
ADU Law. Please feel free to contact Mike Van Gorder, of our staff, at (916) 776-7541
or at mike.vangorder@hcd.ca.gov.
Sincerely,
Shannan West
Housing Accountability Unit Chief
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Item 2
Attachment E - Staff
Response to HCD (2023)
Packet Pg. 59
State of California
GOVERNMENT CODE
Section 65852.2
65852.2. (a) (1) A local agency may, by ordinance, provide for the creation of
accessory dwelling units in areas zoned to allow single-family or multifamily dwelling
residential use. The ordinance shall do all of the following:
(A) Designate areas within the jurisdiction of the local agency where accessory
dwelling units may be permitted. The designation of areas may be based on the
adequacy of water and sewer services and the impact of accessory dwelling units on
traffic flow and public safety. A local agency that does not provide water or sewer
services shall consult with the local water or sewer service provider regarding the
adequacy of water and sewer services before designating an area where accessory
dwelling units may be permitted.
(B) (i) Impose objective standards on accessory dwelling units that include, but
are not limited to, parking, height, setback, landscape, architectural review, maximum
size of a unit, and standards that prevent adverse impacts on any real property that is
listed in the California Register of Historical Resources. These standards shall not
include requirements on minimum lot size.
(ii) Notwithstanding clause (i), a local agency may reduce or eliminate parking
requirements for any accessory dwelling unit located within its jurisdiction.
(C) Provide that accessory dwelling units do not exceed the allowable density for
the lot upon which the accessory dwelling unit is located, and that accessory dwelling
units are a residential use that is consistent with the existing general plan and zoning
designation for the lot.
(D) Require the accessory dwelling units to comply with all of the following:
(i) Except as provided in Section 65852.26, the accessory dwelling unit may be
rented separate from the primary residence, but may not be sold or otherwise conveyed
separate from the primary residence.
(ii) The lot is zoned to allow single-family or multifamily dwelling residential use
and includes a proposed or existing dwelling.
(iii) The accessory dwelling unit is either attached to, or located within, the proposed
or existing primary dwelling, including attached garages, storage areas or similar
uses, or an accessory structure or detached from the proposed or existing primary
dwelling and located on the same lot as the proposed or existing primary dwelling,
including detached garages.
(iv) If there is an existing primary dwelling, the total floor area of an attached
accessory dwelling unit shall not exceed 50 percent of the existing primary dwelling.
(v) The total floor area for a detached accessory dwelling unit shall not exceed
1,200 square feet.
STATE OF CALIFORNIA
AUTHENTICATED
ELECTRONIC LEGAL MATERIAL
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Attachment F -
Government Code
Section 65852.2
Packet Pg. 60
(vi) No passageway shall be required in conjunction with the construction of an
accessory dwelling unit.
(vii) No setback shall be required for an existing living area or accessory structure
or a structure constructed in the same location and to the same dimensions as an
existing structure that is converted to an accessory dwelling unit or to a portion of an
accessory dwelling unit, and a setback of no more than four feet from the side and
rear lot lines shall be required for an accessory dwelling unit that is not converted
from an existing structure or a new structure constructed in the same location and to
the same dimensions as an existing structure.
(viii) Local building code requirements that apply to detached dwellings, except
that the construction of an accessory dwelling unit shall not constitute a Group R
occupancy change under the local building code, as described in Section 310 of the
California Building Code (Title 24 of the California Code of Regulations), unless the
building official or enforcement agency of the local agency makes a written finding
based on substantial evidence in the record that the construction of the accessory
dwelling unit could have a specific, adverse impact on public health and safety.
Nothing in this clause shall be interpreted to prevent a local agency from changing
the occupancy code of a space that was unhabitable space or was only permitted for
nonresidential use and was subsequently converted for residential use pursuant to this
section.
(ix) Approval by the local health officer where a private sewage disposal system
is being used, if required.
(x) (I) Parking requirements for accessory dwelling units shall not exceed one
parking space per accessory dwelling unit or per bedroom, whichever is less. These
spaces may be provided as tandem parking on a driveway.
(II) Offstreet parking shall be permitted in setback areas in locations determined
by the local agency or through tandem parking, unless specific findings are made that
parking in setback areas or tandem parking is not feasible based upon specific site or
regional topographical or fire and life safety conditions.
(III) This clause shall not apply to an accessory dwelling unit that is described in
subdivision (d).
(xi) When a garage, carport, or covered parking structure is demolished in
conjunction with the construction of an accessory dwelling unit or converted to an
accessory dwelling unit, the local agency shall not require that those offstreet parking
spaces be replaced.
(xii) Accessory dwelling units shall not be required to provide fire sprinklers if
they are not required for the primary residence. The construction of an accessory
dwelling unit shall not trigger a requirement for fire sprinklers to be installed in the
existing primary dwelling.
(2) The ordinance shall not be considered in the application of any local ordinance,
policy, or program to limit residential growth.
(3) (A) A permit application for an accessory dwelling unit or a junior accessory
dwelling unit shall be considered and approved ministerially without discretionary
review or a hearing, notwithstanding Section 65901 or 65906 or any local ordinance
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Attachment F -
Government Code
Section 65852.2
Packet Pg. 61
regulating the issuance of variances or special use permits. The permitting agency
shall either approve or deny the application to create or serve an accessory dwelling
unit or a junior accessory dwelling unit within 60 days from the date the permitting
agency receives a completed application if there is an existing single-family or
multifamily dwelling on the lot. If the permit application to create or serve an accessory
dwelling unit or a junior accessory dwelling unit is submitted with a permit application
to create a new single-family or multifamily dwelling on the lot, the permitting agency
may delay approving or denying the permit application for the accessory dwelling
unit or the junior accessory dwelling unit until the permitting agency approves or
denies the permit application to create the new single-family or multifamily dwelling,
but the application to create or serve the accessory dwelling unit or junior accessory
dwelling unit shall be considered without discretionary review or hearing. If the
applicant requests a delay, the 60-day time period shall be tolled for the period of the
delay. If the local agency has not approved or denied the completed application within
60 days, the application shall be deemed approved. A local agency may charge a fee
to reimburse it for costs incurred to implement this paragraph, including the costs of
adopting or amending any ordinance that provides for the creation of an accessory
dwelling unit.
(B) If a permitting agency denies an application for an accessory dwelling unit or
junior accessory dwelling unit pursuant to subparagraph (A), the permitting agency
shall, within the time period described in subparagraph (A), return in writing a full
set of comments to the applicant with a list of items that are defective or deficient
and a description of how the application can be remedied by the applicant.
(4) The ordinance shall require that a demolition permit for a detached garage that
is to be replaced with an accessory dwelling unit be reviewed with the application for
the accessory dwelling unit and issued at the same time.
(5) The ordinance shall not require, and the applicant shall not be otherwise
required, to provide written notice or post a placard for the demolition of a detached
garage that is to be replaced with an accessory dwelling unit, unless the property is
located within an architecturally and historically significant historic district.
(6) An existing ordinance governing the creation of an accessory dwelling unit by
a local agency or an accessory dwelling ordinance adopted by a local agency shall
provide an approval process that includes only ministerial provisions for the approval
of accessory dwelling units and shall not include any discretionary processes,
provisions, or requirements for those units, except as otherwise provided in this
subdivision. If a local agency has an existing accessory dwelling unit ordinance that
fails to meet the requirements of this subdivision, that ordinance shall be null and
void and that agency shall thereafter apply the standards established in this subdivision
for the approval of accessory dwelling units, unless and until the agency adopts an
ordinance that complies with this section.
(7) No other local ordinance, policy, or regulation shall be the basis for the delay
or denial of a building permit or a use permit under this subdivision.
(8) (A) This subdivision establishes the maximum standards that local agencies
shall use to evaluate a proposed accessory dwelling unit on a lot that includes a
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Attachment F -
Government Code
Section 65852.2
Packet Pg. 62
proposed or existing single-family dwelling. No additional standards, other than those
provided in this subdivision, shall be used or imposed, except that, subject to
subparagraphs (B) and (C), a local agency may require an applicant for a permit issued
pursuant to this subdivision to be an owner-occupant.
(B) (i) Notwithstanding subparagraph (A), a local agency shall not impose an
owner-occupant requirement on an accessory dwelling unit before January 1, 2025.
(ii) Notwithstanding subparagraph (A), a local agency shall not impose an
owner-occupant requirement on an accessory dwelling unit that was permitted between
January 1, 2020, and January 1, 2025.
(C) Notwithstanding subparagraphs (A) and (B), a local agency may require that
an accessory dwelling unit be used for rentals of terms longer than 30 days.
(9) A local agency may amend its zoning ordinance or general plan to incorporate
the policies, procedures, or other provisions applicable to the creation of an accessory
dwelling unit if these provisions are consistent with the limitations of this subdivision.
(10) An accessory dwelling unit that conforms to this subdivision shall be deemed
to be an accessory use or an accessory building and shall not be considered to exceed
the allowable density for the lot upon which it is located, and shall be deemed to be
a residential use that is consistent with the existing general plan and zoning
designations for the lot. The accessory dwelling unit shall not be considered in the
application of any local ordinance, policy, or program to limit residential growth.
(b) (1) When a local agency that has not adopted an ordinance governing accessory
dwelling units in accordance with subdivision (a) receives an application for a permit
to create or serve an accessory dwelling unit pursuant to this subdivision, the local
agency shall approve or disapprove the application ministerially without discretionary
review pursuant to subdivision (a). The permitting agency shall either approve or
deny the application to create or serve an accessory dwelling unit or a junior accessory
dwelling unit within 60 days from the date the permitting agency receives a completed
application if there is an existing single-family or multifamily dwelling on the lot. If
the permit application to create or serve an accessory dwelling unit or a junior
accessory dwelling unit is submitted with a permit application to create or serve a
new single-family or multifamily dwelling on the lot, the permitting agency may
delay approving or denying the permit application for the accessory dwelling unit or
the junior accessory dwelling unit until the permitting agency approves or denies the
permit application to create or serve the new single-family or multifamily dwelling,
but the application to create or serve the accessory dwelling unit or junior accessory
dwelling unit shall still be considered ministerially without discretionary review or a
hearing. If the applicant requests a delay, the 60-day time period shall be tolled for
the period of the delay. If the local agency has not approved or denied the completed
application within 60 days, the application shall be deemed approved.
(2) If a permitting agency denies an application for an accessory dwelling unit or
junior accessory dwelling unit pursuant to paragraph (1), the permitting agency shall,
within the time period described in paragraph (1), return in writing a full set of
comments to the applicant with a list of items that are defective or deficient and a
description of how the application can be remedied by the applicant.
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Attachment F -
Government Code
Section 65852.2
Packet Pg. 63
(c) (1) Subject to paragraph (2), a local agency may establish minimum and
maximum unit size requirements for both attached and detached accessory dwelling
units.
(2) Notwithstanding paragraph (1), a local agency shall not establish by ordinance
any of the following:
(A) A minimum square footage requirement for either an attached or detached
accessory dwelling unit that prohibits an efficiency unit.
(B) A maximum square footage requirement for either an attached or detached
accessory dwelling unit that is less than either of the following:
(i) 850 square feet.
(ii) 1,000 square feet for an accessory dwelling unit that provides more than one
bedroom.
(C) Any requirement for a zoning clearance or separate zoning review or any other
minimum or maximum size for an accessory dwelling unit, size based upon a
percentage of the proposed or existing primary dwelling, or limits on lot coverage,
floor area ratio, open space, front setbacks, and minimum lot size, for either attached
or detached dwellings that does not permit at least an 800 square foot accessory
dwelling unit with four-foot side and rear yard setbacks to be constructed in compliance
with all other local development standards.
(D) Any height limitation that does not allow at least the following, as applicable:
(i) A height of 16 feet for a detached accessory dwelling unit on a lot with an
existing or proposed single family or multifamily dwelling unit.
(ii) A height of 18 feet for a detached accessory dwelling unit on a lot with an
existing or proposed single family or multifamily dwelling unit that is within one-half
of one mile walking distance of a major transit stop or a high-quality transit corridor,
as those terms are defined in Section 21155 of the Public Resources Code. A local
agency shall also allow an additional two feet in height to accommodate a roof pitch
on the accessory dwelling unit that is aligned with the roof pitch of the primary
dwelling unit.
(iii) A height of 18 feet for a detached accessory dwelling unit on a lot with an
existing or proposed multifamily, multistory dwelling.
(iv) A height of 25 feet or the height limitation in the local zoning ordinance that
applies to the primary dwelling, whichever is lower, for an accessory dwelling unit
that is attached to a primary dwelling. This clause shall not require a local agency to
allow an accessory dwelling unit to exceed two stories.
(d) Notwithstanding any other law, and whether or not the local agency has adopted
an ordinance governing accessory dwelling units in accordance with subdivision (a),
all of the following shall apply:
(1) The local agency shall not impose any parking standards for an accessory
dwelling unit in any of the following instances:
(A) Where the accessory dwelling unit is located within one-half mile walking
distance of public transit.
(B) Where the accessory dwelling unit is located within an architecturally and
historically significant historic district.
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Government Code
Section 65852.2
Packet Pg. 64
(C) Where the accessory dwelling unit is part of the proposed or existing primary
residence or an accessory structure.
(D) When onstreet parking permits are required but not offered to the occupant of
the accessory dwelling unit.
(E) When there is a car share vehicle located within one block of the accessory
dwelling unit.
(F) When a permit application for an accessory dwelling unit is submitted with a
permit application to create a new single-family dwelling or a new multifamily
dwelling on the same lot, provided that the accessory dwelling unit or the parcel
satisfies any other criteria listed in this paragraph.
(2) The local agency shall not deny an application for a permit to create an accessory
dwelling unit due to the correction of nonconforming zoning conditions, building
code violations, or unpermitted structures that do not present a threat to public health
and safety and are not affected by the construction of the accessory dwelling unit.
(e) (1) Notwithstanding subdivisions (a) to (d), inclusive, a local agency shall
ministerially approve an application for a building permit within a residential or
mixed-use zone to create any of the following:
(A) One accessory dwelling unit and one junior accessory dwelling unit per lot
with a proposed or existing single-family dwelling if all of the following apply:
(i) The accessory dwelling unit or junior accessory dwelling unit is within the
proposed space of a single-family dwelling or existing space of a single-family
dwelling or accessory structure and may include an expansion of not more than 150
square feet beyond the same physical dimensions as the existing accessory structure.
An expansion beyond the physical dimensions of the existing accessory structure
shall be limited to accommodating ingress and egress.
(ii) The space has exterior access from the proposed or existing single-family
dwelling.
(iii) The side and rear setbacks are sufficient for fire and safety.
(iv) The junior accessory dwelling unit complies with the requirements of Section
65852.22.
(B) One detached, new construction, accessory dwelling unit that does not exceed
four-foot side and rear yard setbacks for a lot with a proposed or existing single-family
dwelling. The accessory dwelling unit may be combined with a junior accessory
dwelling unit described in subparagraph (A). A local agency may impose the following
conditions on the accessory dwelling unit:
(i) A total floor area limitation of not more than 800 square feet.
(ii) A height limitation as provided in clause (i), (ii), or (iii) as applicable, of
subparagraph (D) of paragraph (2) of subdivision (c).
(C) (i) Multiple accessory dwelling units within the portions of existing multifamily
dwelling structures that are not used as livable space, including, but not limited to,
storage rooms, boiler rooms, passageways, attics, basements, or garages, if each unit
complies with state building standards for dwellings.
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Government Code
Section 65852.2
Packet Pg. 65
(ii) A local agency shall allow at least one accessory dwelling unit within an
existing multifamily dwelling and shall allow up to 25 percent of the existing
multifamily dwelling units.
(D) (i) Not more than two accessory dwelling units that are located on a lot that
has an existing or proposed multifamily dwelling, but are detached from that
multifamily dwelling and are subject to a height limitation in clause (i), (ii), or (iii),
as applicable, of subparagraph (D) of paragraph (2) of subdivision (c) and rear yard
and side setbacks of no more than four feet.
(ii) If the existing multifamily dwelling has a rear or side setback of less than four
feet, the local agency shall not require any modification of the existing multifamily
dwelling as a condition of approving the application to construct an accessory dwelling
unit that satisfies the requirements of this subparagraph.
(2) A local agency shall not require, as a condition for ministerial approval of a
permit application for the creation of an accessory dwelling unit or a junior accessory
dwelling unit, the correction of nonconforming zoning conditions.
(3) The installation of fire sprinklers shall not be required in an accessory dwelling
unit if sprinklers are not required for the primary residence. The construction of an
accessory dwelling unit shall not trigger a requirement for fire sprinklers to be installed
in the existing multifamily dwelling.
(4) A local agency may require owner-occupancy for either the primary dwelling
or the accessory dwelling unit on a single-family lot, subject to the requirements of
paragraph (8) of subdivision (a).
(5) A local agency shall require that a rental of the accessory dwelling unit created
pursuant to this subdivision be for a term longer than 30 days.
(6) A local agency may require, as part of the application for a permit to create an
accessory dwelling unit connected to an onsite wastewater treatment system, a
percolation test completed within the last five years, or, if the percolation test has
been recertified, within the last 10 years.
(7) Notwithstanding subdivision (c) and paragraph (1) a local agency that has
adopted an ordinance by July 1, 2018, providing for the approval of accessory dwelling
units in multifamily dwelling structures shall ministerially consider a permit application
to construct an accessory dwelling unit that is described in paragraph (1), and may
impose objective standards including, but not limited to, design, development, and
historic standards on said accessory dwelling units. These standards shall not include
requirements on minimum lot size.
(f) (1) Fees charged for the construction of accessory dwelling units shall be
determined in accordance with Chapter 5 (commencing with Section 66000) and
Chapter 7 (commencing with Section 66012).
(2) An accessory dwelling unit shall not be considered by a local agency, special
district, or water corporation to be a new residential use for purposes of calculating
connection fees or capacity charges for utilities, including water and sewer service,
unless the accessory dwelling unit was constructed with a new single-family dwelling.
(3) (A) A local agency, special district, or water corporation shall not impose any
impact fee upon the development of an accessory dwelling unit less than 750 square
Item 2
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Government Code
Section 65852.2
Packet Pg. 66
feet. Any impact fees charged for an accessory dwelling unit of 750 square feet or
more shall be charged proportionately in relation to the square footage of the primary
dwelling unit.
(B) For purposes of this paragraph, “impact fee” has the same meaning as the term
“fee” is defined in subdivision (b) of Section 66000, except that it also includes fees
specified in Section 66477. “Impact fee” does not include any connection fee or
capacity charge charged by a local agency, special district, or water corporation.
(4) For an accessory dwelling unit described in subparagraph (A) of paragraph (1)
of subdivision (e), a local agency, special district, or water corporation shall not require
the applicant to install a new or separate utility connection directly between the
accessory dwelling unit and the utility or impose a related connection fee or capacity
charge, unless the accessory dwelling unit was constructed with a new single-family
dwelling.
(5) For an accessory dwelling unit that is not described in subparagraph (A) of
paragraph (1) of subdivision (e), a local agency, special district, or water corporation
may require a new or separate utility connection directly between the accessory
dwelling unit and the utility. Consistent with Section 66013, the connection may be
subject to a connection fee or capacity charge that shall be proportionate to the burden
of the proposed accessory dwelling unit, based upon either its square feet or the
number of its drainage fixture unit (DFU) values, as defined in the Uniform Plumbing
Code adopted and published by the International Association of Plumbing and
Mechanical Officials, upon the water or sewer system. This fee or charge shall not
exceed the reasonable cost of providing this service.
(g) This section shall supersede a conflicting local ordinance. This section does
not limit the authority of local agencies to adopt less restrictive requirements for the
creation of an accessory dwelling unit.
(h) (1) A local agency shall submit a copy of the ordinance adopted pursuant to
subdivision (a) to the Department of Housing and Community Development within
60 days after adoption. After adoption of an ordinance, the department may submit
written findings to the local agency as to whether the ordinance complies with this
section.
(2) (A) If the department finds that the local agency’s ordinance does not comply
with this section, the department shall notify the local agency and shall provide the
local agency with a reasonable time, no longer than 30 days, to respond to the findings
before taking any other action authorized by this section.
(B) The local agency shall consider the findings made by the department pursuant
to subparagraph (A) and shall do one of the following:
(i) Amend the ordinance to comply with this section.
(ii) Adopt the ordinance without changes. The local agency shall include findings
in its resolution adopting the ordinance that explain the reasons the local agency
believes that the ordinance complies with this section despite the findings of the
department.
(3) (A) If the local agency does not amend its ordinance in response to the
department’s findings or does not adopt a resolution with findings explaining the
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reason the ordinance complies with this section and addressing the department’s
findings, the department shall notify the local agency and may notify the Attorney
General that the local agency is in violation of state law.
(B) Before notifying the Attorney General that the local agency is in violation of
state law, the department may consider whether a local agency adopted an ordinance
in compliance with this section between January 1, 2017, and January 1, 2020.
(i) The department may review, adopt, amend, or repeal guidelines to implement
uniform standards or criteria that supplement or clarify the terms, references, and
standards set forth in this section. The guidelines adopted pursuant to this subdivision
are not subject to Chapter 3.5 (commencing with Section 11340) of Part 1 of Division
3 of Title 2.
(j) As used in this section, the following terms mean:
(1) “Accessory dwelling unit” means an attached or a detached residential dwelling
unit that provides complete independent living facilities for one or more persons and
is located on a lot with a proposed or existing primary residence. It shall include
permanent provisions for living, sleeping, eating, cooking, and sanitation on the same
parcel as the single-family or multifamily dwelling is or will be situated. An accessory
dwelling unit also includes the following:
(A) An efficiency unit.
(B) A manufactured home, as defined in Section 18007 of the Health and Safety
Code.
(2) “Accessory structure” means a structure that is accessory and incidental to a
dwelling located on the same lot.
(3) “Efficiency unit” has the same meaning as defined in Section 17958.1 of the
Health and Safety Code.
(4) “Living area” means the interior habitable area of a dwelling unit, including
basements and attics, but does not include a garage or any accessory structure.
(5) “Local agency” means a city, county, or city and county, whether general law
or chartered.
(6) “Nonconforming zoning condition” means a physical improvement on a property
that does not conform with current zoning standards.
(7) “Objective standards” means standards that involve no personal or subjective
judgment by a public official and are uniformly verifiable by reference to an external
and uniform benchmark or criterion available and knowable by both the development
applicant or proponent and the public official prior to submittal.
(8) “Passageway” means a pathway that is unobstructed clear to the sky and extends
from a street to one entrance of the accessory dwelling unit.
(9) “Permitting agency” means any entity that is involved in the review of a permit
for an accessory dwelling unit or junior accessory dwelling unit and for which there
is no substitute, including, but not limited to, applicable planning departments, building
departments, utilities, and special districts.
(10) “Proposed dwelling” means a dwelling that is the subject of a permit
application and that meets the requirements for permitting.
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(11) “Public transit” means a location, including, but not limited to, a bus stop or
train station, where the public may access buses, trains, subways, and other forms of
transportation that charge set fares, run on fixed routes, and are available to the public.
(12) “Tandem parking” means that two or more automobiles are parked on a
driveway or in any other location on a lot, lined up behind one another.
(k) A local agency shall not issue a certificate of occupancy for an accessory
dwelling unit before the local agency issues a certificate of occupancy for the primary
dwelling.
(l) Nothing in this section shall be construed to supersede or in any way alter or
lessen the effect or application of the California Coastal Act of 1976 (Division 20
(commencing with Section 30000) of the Public Resources Code), except that the
local government shall not be required to hold public hearings for coastal development
permit applications for accessory dwelling units.
(m) A local agency may count an accessory dwelling unit for purposes of identifying
adequate sites for housing, as specified in subdivision (a) of Section 65583.1, subject
to authorization by the department and compliance with this division.
(n) In enforcing building standards pursuant to Article 1 (commencing with Section
17960) of Chapter 5 of Part 1.5 of Division 13 of the Health and Safety Code for an
accessory dwelling unit described in paragraph (1) or (2), a local agency, upon request
of an owner of an accessory dwelling unit for a delay in enforcement, shall delay
enforcement of a building standard, subject to compliance with Section 17980.12 of
the Health and Safety Code:
(1) The accessory dwelling unit was built before January 1, 2020.
(2) The accessory dwelling unit was built on or after January 1, 2020, in a local
jurisdiction that, at the time the accessory dwelling unit was built, had a noncompliant
accessory dwelling unit ordinance, but the ordinance is compliant at the time the
request is made.
(Amended (as amended by Stats. 2021, Ch. 343, Sec. 1) by Stats. 2022, Ch. 664, Sec. 2.5. (SB 897)
Effective January 1, 2023.)
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Planning & Transportation Commission
Staff Report
From: Jonathan Lait, Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: March 8, 2023
Report #: 2303-1030
TITLE
Review and Recommend City Council Adoption of the Draft 2023-31 Housing Element, Subject to
Refinement Following Comment from the Department of Housing and Community Development.
A Draft Addendum to the City's Comprehensive Plan 2017 Environmental Impact Report has been
prepared.
RECOMMENDATION
Staff recommends the Planning and Transportation Commission (PTC) take the following
action(s):
1. Consider the Draft Addendum to the 2017 Comprehensive Plan Environmental Impact
Report (Attachment A); and
2. Recommend to City Council adoption of the Draft 2023-31 Housing Element (Attachment
B).
EXECUTIVE SUMMARY
On December 23, 2022, the City submitted its Draft 2023-31 Housing Element (HE)1 for its initial
90-day review by the State Department of Housing and Community Development (HCD). This 90-
day review will end on March 23, 2023. This PTC meeting is the first of two planned hearings for
the review the Draft HE. The purpose of the first meeting is to review, comment, and recommend
to Council approval of the Draft HE submitted to HCD. The second meeting, targeted for late
April/early May 2023, is after the City receives comments from HCD. The focus of that PTC
meeting will be on the HCD comments and the prepared staff responses; PTC will be asked to
review and recommend approval of the discrete items presented at that time. It is possible,
depending on timing constraints, that this second hearing will be scheduled as a joint meeting
with the City Council.
The Draft HE submitted to HCD included minor revisions that were completed after the PTC’s
review of the Public Review Draft HE at the joint meeting with City Council on November 28,
2022. The most notable revisions are the inclusions of a summary table of City responses to public
1 Draft Housing Element, 12/23/22 can be viewed on project webpage: https://paloaltohousingelement.com/
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comments and the Council approved amendments to the public review draft. A summary of these
revisions to the Draft HE is provided in this report. To review the Public Review Draft HE, see link
in footnote for the November 28, 2022 Council report; hardcopies were recently transmitted to
the PTC.2
BACKGROUND
The Housing Element is the City’s plan to provide housing for its current and future residents. It
is the only element of the City’s Comprehensive Plan (Comp Plan) that requires certification by
the State. The Housing Element covers a period of eight years; the 5th Cycle of Housing Elements
that cover the years between 2015 through January 31, 2023 just ended. The 6th Cycle will cover
eight years between 2023 and 2031. The deadline to adopt a compliant Housing Element for the
6th Cycle Housing Element was January 31, 2023. For reference, a copy of the 5th Cycle Housing
Element is available online.3
As part of the Housing Element, the City needs to plan for its “fair share” of housing for the 6th
Cycle eight-year planning period. The City must plan for its Regional Housing Needs Allocation
(RHNA) of 6,086 units. In addition, programs must be included in the Housing Element that
support increased housing production in the City. Over the last two years, the City has evaluated
and updated its draft Housing Element for the 2023-31 planning period. To see a history of City
events and actions over the past two years, please go to www.paloaltohousingelement.com.
State law mandates that each amended element meet specific requirements and the Housing
Element update must be completed by the State mandated deadline. The deadline for Bay Area
jurisdictions was January 31, 2023. All Housing Elements must be timely submitted to and
approved by the State or jurisdictions face the possibility of funding cuts, loss of local housing
land use discretion, housing grant ineligibility, and fines.
PTC’s Role and Purview
The Planning and Transportation Commission’s role with regard to the Housing Element is to:
•Review and recommend to Council the 6th cycle Housing Element, as an amendment to
that component of the Comprehensive Plan.
•Consider the Environmental Review document prepared for the Housing Element.
PAMC Chapter 19.04, Section 19.04.010 “Duties of Planning Commission” explicitly states the
PTC’s primary duty is to prepare, adopt, and recommend to City Council adoption of the
Comprehensive General Plan. The housing element is part of the Comprehensive (general) Plan.
In addition to its responsibility to provide a recommendation to Council regarding the Housing
2 Council Staff Report 11/28/22, see Item #9: https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-
reports/agendas-minutes/city-council-agendas-minutes/2022/20221128/20221128pccsmlinked.pdf
3 5th Cycle Housing Element: https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-
services/3.-comprehensive-plan/comprehensive-plan/certified-15-23-housing-element.pdf
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Element, the PTC must consider the Addendum to the 2017 Palo Alto Comprehensive Plan
Environmental Impact Report prepared for this Housing Element.
Additionally, the Palo Alto Municipal Code (PAMC) Title 19, Chapter 19.04 describes the duties of
the PTC, and PAMC Chapter 2.20 notes that in addition to these duties, the PTC may be asked by
City Council, City Manager, or Planning Director to “provide advice on any matter pertaining to
land use planning and transportation systems affecting the city.”
Regional Housing Need Allocation
Per state law requirements, the draft Housing Element contains information about the City’s
housing needs, constraints to building housing, available housing sites, an explanation of City
resources for supporting housing construction, as well as goals, policies and programs that will
help address the city’s share of regional housing needs as identified by the Association of Bay
Area Governments (ABAG). The City’s housing needs are quantified in the RHNA, which includes
housing targets at all income levels. As part of the Housing Element, the City must proactively
identify individual sites that collectively support the total number of new units needed to meet
the RHNA. As shown in Table 1, the minimum RHNA requirement for Palo Alto in the 2023-31
planning period is 6,086 homes across four income levels.
Table 1: City of Palo Alto 2023-31 RHNA Requirement
City of Palo Alto 2023-31 RHNA
Income Level Very Low
Income
Low Income Moderate
Income
Above Moderate
Income
Total
Area Median
Income (AMI)
<50% AMI 50-80% of
AMI
80-120% AMI >120% AMI
Units 1,556 896 1,013 2,621 6,086
Table 2 shows the total inventory of sites and units to meet the RHNA. The City of Palo Alto has
assumed a 10 percent buffer which requires the site identification of an additional 609 units for
a total of 6,695. As shown in the table, with entitled and proposed development, ADUs,
underutilized sites with no rezoning required, and rezoning to meet the RHNA, a total of 6,807
units can be accommodated, which exceeds the City’s internal target of the RHNA plus 10 percent
buffer (6,695 units).
Table 2: Total Housing Element Proposed Sites and Units to Meet the RHNA
Sites Units
Entitled and Proposed Development – Credit N/A1 1,106
ADU – Credit N/A2 512
Underutilized Sites (no rezoning required) 123 1,187
Rezoning to Meet the RHNA 166 4,002
TOTAL 289 6,8074
1 The 19 project sites for existing and proposed development are not counted in the 289 RHNA sites therefore they are
not included in this table.
2 ADU development is assumed throughout the city.
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The Palo Alto 2023-31 Housing Element identifies and analyzes existing and projected housing
needs and establishes goals, policies, quantified objectives, and scheduled programs for the
preservation, improvement, and development of housing across income levels. It identifies areas
in the City where new housing may be built and estimates how many housing units could be built
on specific sites. Furthermore, it helps the City plan for future housing needs of all residents at
all income levels, including emergency shelters and special housing for the elderly, persons with
disabilities, large families, and unhoused residents.
Housing Element Document Requirements
The Housing Element contains several mandated sections including: Executive Summary;
Introduction; Housing Needs; Housing Resources; Housing Constraints; and Housing Plan
(includes Housing Element programs).
Additionally, Appendix C in the draft HE contains the City’s analysis of Affirmatively Furthering
Fair Housing (AFFH). AFFH is a new State requirement that mandates each jurisdiction take
meaningful actions to further fair housing to overcome patterns of segregation and foster
inclusive communities free from barriers that restrict access to opportunity based on protected
characteristics. The Housing Element, including the sites inventory and programs, must be
reviewed through the filter of AFFH requirements.
DISCUSSION
As noted earlier, there were limited changes to the Draft HE that was submitted to HCD
(Attachment B) in December when compared to the November Public Review Draft HE. The
primary changes to the draft HE submitted to HCD were the addition of the public comments and
related responses and several Council-directed modifications. The key document modifications
are described below.
In addition, there were a couple of errors in the HCD draft HE that staff would like to note. First,
in the sites inventory list, the proposed densities for GM/ROLM and for City parking lots were
incorrect. The maximum proposed density for the GM/ROLM sites is 65 dwelling units per acre
(du/ac), not the 81.25 du/ac density as listed. Also, the proposed density of the City parking lots
is 50 du/ac and not 62.5 du/ac as published. Second, per Council direction, the City parking lots
may also be used for workforce housing for City and Palo Alto Unified School District (PAUSD)
employees; this text was mistakenly omitted in the HCD draft. These errors will be corrected in
next revisions of the 6th Cycle Housing Element.
Public Comments
During the public review period, the City received public comment letters from individuals and
organizations. The format for responding to comments in the HE document is to group the
comments by theme and then provide a response to each of those themes. The City received 13
public comments and those were grouped into the 10 common themes noted in Table 3.
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Table 3: Summary of Public Comments and City Responses
Comment Theme Responses
1. Concerns relating to
the Site Inventory and the
future availability of
identified properties.
RHNA is a State mandate and the City must comply with State law
by planning for future residential development through the
identification of sites that can accommodate the assigned RHNA.
Development of the City’s Site Inventory is detailed more in
Chapter 4, and occurred through the identification of site
selection strategies, which were developed through input
provided by the Housing Element Working Group. Housing
Element Working Group members completed group
walking/drive by tours of the sites. Once complete, the Site
Inventory was fully vetted by the Housing Element Working
Group, the Planning and Transportation Commission and the City
Council. The City undertook a number of additional engagement
efforts related to the Site Inventory. A map of all identified sites
has been available on the City’s Housing Element website since
April 2022. The City also reached out to all property owners via a
direct mail (USPS) marketing campaign. The City honored all
requests from property owners who asked that their property(s)
be removed from the Site Inventory. Moreover, the City
communicated with various land owners whose sites were
contemplated for inclusion or placed in the site inventory,
including one prominent land owner where the City is proposing
changes to the GM/ROLM zoning district.
2. Concerns relating to
environmental and
infrastructure constraints
such as traffic,
intersection safety, and
bicycle and pedestrian
safety.
Development of the sites inventory for RHNA took into
consideration potential environmental constraints. Future
development projects may be required to assess environmental
impacts in CEQA documentation prepared for the specific project.
3. Programs should be
objective and
quantifiable.
Changes have been made to a number of programs to address this
comment. Most notably, Program 6.6 (Fair Housing) has been
significantly expanded to include more action items related to fair
housing constraints, quantified objectives, and implementation
timeframes for each.
4. City’s existing zoning
and development
standards create
constraints to housing
and do not allow for
financially feasible
projects.
Changes to the City’s Zoning Ordinance are planned to support
development of housing and to comply with recently approved
State legislation. The following are a selection of programs that
aim to reduce constraints and improve project feasibility:
•Program 1.5: Initiate discussions with Stanford University
regarding zoning modifications to support future
residential development within the Stanford Research
Park.
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Comment Theme Responses
•Program 1.6: Develop lot consolidation provisions for
affordable housing projects.
•Program 3.3: Amend the residential floor area ratios and
height requirements for projects taking advantage of the
affordable housing overlay regulations.
•Program 3.4: Revise and extend the Housing Incentive
Program.
•Program 3.6: Amend Zoning Ordinance to maintain
compliance with State legislation pertaining to ADUs.
•Program 3.7: Limit multi-family housing projects to two
hearings before the City’s ARB.
•Program 3.8: Create objective design standards for the
SOFA area to streamline future development.
•Program 3.9: Compliance with State legislation.
•Program 6.2: Explore zoning changes to support larger
units.
•Program 6.5: Encourage innovative housing structures
through zoning regulations and address State legislation
pertaining to low barrier navigation centers, emergency
shelters, supportive and transitional housing, and
employee housing.
5. Application processing
timeframes can create a
constraint to residential
development if they are
lengthy, as is the case in
Palo Alto. The City should
work to reduce
application processing
timeframes.
With the implementation of Program 3.7 the City will explore
opportunities to improve the efficiency of the development
review process, including expedited project review. This program
will also limit multi-family projects to two hearings before the
City’s ARB. Furthermore, with the recently adopted objective
design standards in 2022, the City created a streamlined review
process for compliant projects that only requires one study
session with the City’s ARB.
6. Public participation
should be fair and
equitable to all.
The City has provided a detailed summary of the public
engagement program implemented for this project in Chapter 1.
This program included a number of study sessions with PTC
and/or City Council, a dedicated website, and online survey, and
multiple community workshops that were advertised in multiple
languages. In addition, the City formed a Housing Element
Working Group, comprised of 15 members and 2 alternates.
Group members included homeowners and renters, Stanford
employees, members of Palo Alto’s young adult and minority
communities, an affordable housing developer (staff), and a
member of the unhoused community. All meetings were open to
the public (virtually) and the group took and responded to public
comments at all meetings.
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Comment Theme Responses
7. Strengthen the efforts
to enhance affordability
by providing fee waivers,
securing new funding
sources, expediting
project review, and
developing standards
supportive of higher
densities.
All these efforts are included in the Draft Housing Element.
Specific programs include: Program 2.2: Continuation and
expansion of the program to promote affordability. Program 3.1:
The City will waive staff costs associated with affordable housing
planning applications. Program 3.7: The City will explore
opportunities to improve the efficiency of the development
review process, including expedited project review. Program 3.8;
The City will create objective design standards for the SOFA area.
Program 5.1: Preservation of at-risk housing.
8. Expand support for
programs that combat
homelessness
Program 6.4 addresses the City’s efforts to combat homelessness.
Expansion of the City’s Safe Parking Program is included.
9. Accessory Dwelling
Units assumptions are too
aggressive and do not
appropriately address
affordability of these
types of units in the City.
ADU assumptions are detailed in Chapter 3 of the Housing
Element and are based on actual ADU permitting trends for the
2019-2021 time period. That said, current trends from 2022
demonstrate an increase in ADU permitting in the City. Through
these natural increases, and the implementation of Program 3.6,
the City is confident that the ADU production numbers presented
for the next 8 years can be realized. Affordability assumptions
were based on the HCD approved technical guidance prepared by
ABAG, as discussed in Chapter 3. The City does not have control
over the rental market and the affordability of non-deed
restricted units although the action items outlined in Program 3.6
support the program as a whole.
10. Tenant protection
policies should be
strengthened. The City
amended the Tenant
Relocation Assistance
requirements in January
2022.
Tenant protection strategies have been further expanded across
Program 6.6. Specifically: Program 6.6.I: Includes implementation
for additional anti-displacement measures including relocation
assistance, eviction reduction, security deposit limits and right to
counsel. Program 6.6.J: Includes consideration of a Fair Chance
Ordinance.
Council Directed Revisions to Draft HE
At its November 28, 2022 meeting, the City Council approved additional amendments to the HE
programs. The amendments (with reference to the revised program) are as follows:
1. Approve the staff proposed amendments that added a lot consolidation program,
objective standards for SOFA II, and some minor adjustments to housing sites. (Programs
1.6 & 3.8)
2. Revise Program 1.4A to require 100% affordable housing capped at 80% AMI or for
workforce housing for City and PAUSD employees on City owned parking.
3. Remove the conditional use permit requirement for residential uses in the Stanford
Research Park. (Program 1.5A)
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4. Study and research what other jurisdictions have done to provide affordable housing
preferences for historically disadvantaged populations and report back to Council.
(Program 6.7D)
Consequences for Non-compliance
As mentioned, all Housing Elements must be timely submitted to the State for review and
adopted by the local jurisdiction. The deadline for adoption of a compliant Housing Element was
January 31, 2023. As of February 28, 2023, 38 of the region’s 109 cities and counties had adopted
a 6th Cycle Housing Element. And only six of those plans — from San Francisco, Emeryville, San
Leandro, Oakland, San Ramon and the City of Alameda — had received final approval from the
State. Consequences for noncompliance include jurisdictions facing the possibility of loss of local
housing land use discretion, housing grant ineligibility, and fines.
More recently, there has been statewide discussions about a “builder’s remedy” in the Housing
Accountability Act (HAA) and jurisdictions with non-compliant Housing Elements. In short, the
builder’s remedy refers to a provision of the Housing Accountability Act (HAA) that obligates a
jurisdiction that does not have a compliant housing element to approve certain affordable
housing projects even if the projects are inconsistent with local zoning or general plan
regulations. Staff previously provided a discussion of the builder’s remedy as a supplemental
memo to Item #12 on the Council’s November 7, 2022 agenda.4
FISCAL/RESOURCE IMPACT
The implementation of the Housing Element will require staff resources to complete rezones,
program implementation, and prepare studies. Generally, all tasks will need to be completed
within the first few years of Housing Element adoption. This will involve greater staff resources
and the use of consultants for the studies and potential environmental review. Budget requests
related to these activities will be reflected in the annual budget development process.
TIMELINE
The Housing Element update process has been underway for over two years. Table 3 shows the
significant milestones that have been achieved up to the present.
Table 3: 2023-31 Housing Element Progress Milestones
MILESTONE DATE
Formation of HE Working Group (HEWG)Feb. 2021
1st Meeting of HEWG April 2021
PTC consideration of HE sites February 2022
Council approval of HE sites April 2022
PTC consideration of HE programs August 2022
Council approval of HE programs October 2022
4 https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/city-council-
agendas-minutes/2022/20221107/20221107pccsm-amended-linked-q.a-2.pdf#page=229
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Public Review HE draft released for 30-day comment period November 2022
Draft HE submitted to HCD for 90-day review December 2022
The City is currently waiting for HCD to complete its initial 90-day review, with formal comments
expected by March 23, 2023. The PTC will have the opportunity to review the HCD letter along
with the proposed staff response at one of its regularly scheduled meetings or a possible joint
session with the City Council.
The following key tasks reflect next steps for the HE update process:
1. Revise Draft Housing Element per HCD Comments.
After receiving HCD’s comment letter, staff will prepare a summary of the comments and
proposed staff responses for PTC’s review and recommendation to the City Council.
2. City May Choose to Adopt Housing Element or Resubmit to HCD.
For the Council action, the City may choose to either (1) submit the additional revisions as a
draft for review by HCD, or (2) adopt the Housing Element with or without changes. If the City
elects to adopt a Housing Element without all changes suggested by HCD, the City must also
adopt written findings explaining why the Housing Element substantially complies with state
law despite HCD’s findings to the contrary.
If Council adopts the Housing Element with the HCD suggested changes, the City is still
required to submit the adopted document to HCD within 30 days for their review. HCD may
take 60-90 days to review the adopted Housing Element and may issue findings regarding
further changes it believes are needed to substantially comply with state law. At this stage,
the City would then have no more than 30 days to provide a response, which may include a
plan to adopt further revisions. Please note that if the City adopts its Housing Element making
findings for substantial compliance, staff recommend that the City still seek official
compliance from HCD.
3. Submit Revised Draft/Adopted Housing Element to HCD.
If the City elects to propose further revisions to its HE, either before or after initial adoption,
the City must first post the proposed revisions on its website and email a link to all individuals
and organizations that have previously requested notices relating to the housing element at
least seven days prior to submission. The City must then submit the revisions to HCD, which
has up to 60 days to review the revised draft.
If HCD determines the City’s revisions address and meet all the comments in the HCD review
letter, HCD may issue a “substantial compliance” letter to the City. This compliance letter
would state that if the jurisdiction adopts the Housing Element as outlined in the responses,
the Housing Element substantially complies with the State Housing Element requirements.
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Generally, however, because of the new HE requirements, many jurisdictions have not
received certification even after the second review. Because of this, HCD recommends that
jurisdictions plan for a third review.
STAKEHOLDER ENGAGEMENT
The Housing Element update process included substantial public outreach and engagement
opportunities. The City formed the Housing Element Working Group (Working Group), a 17-
member group that advised the City Council with the Housing element update. The Working
Group represented a demographic cross-section of the City. The Working Group included renters,
affordable housing residents, seniors, persons of color, a representative from the unhoused
community, and an affordable housing developer.
There were other outreach efforts to educate the community about the HE update effort and to
receive community input. In addition to the project’s webpage,
(www.paloaltohousingelement.com), the City conducted an online survey with 430 respondents,
hosted three community workshops and held over 30 public meetings (includes Working Group,
Council Ad-hoc, PTC, and City Council). Additionally, staff had numerous presentations with civic
groups, meetings and calls with members of the public and developers to address questions and
provide information. See Appendix B of Attachment B for more details. The draft HE Introduction
also provides a more detailed breakdown of each of the public meetings as well as summaries of
other community engagement efforts.
The Palo Alto Municipal Code requires notice of this public hearing to be published in a local
paper. Notice of a public hearing for this project was published in the Daily Post on February 24,
2022, which is 12 days in advance of the meeting. Interested parties were sent the public notice
via electronic mail. Notice of the public hearing was also posted on the City’s Housing Element
website at www.paloaltohousingelement.com.
ENVIRONMENTAL REVIEW
The subject project has been 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, acting as the lead agency, has
prepared an Addendum to the 2017 Palo Alto Comprehensive Plan Environmental Impact Report5
(Comp Plan EIR) for the draft HE.
The CEQA analysis for the HE is focused on the resulting physical changes on the identified RHNA
sites that would take place as a result of the implementation of the required rezonings to meet
RHNA and implementing those programs which help increase housing production. For CEQA
purposes, the review assessed a higher density on some of the identified RHNA sites than strictly
required to meet RHNA as well as other sites that may be developed from the proposed
incentives (i.e. expansion of the HIP program). For example, the City parking lots were assigned
5 https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Long-Range-Planning/2030-
Comprehensive-Plan. Please see “Additional Comprehensive Plan Resources”.
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a maximum density of 50 du/ac for RHNA purposes however it was assigned a density of
100du/ac for the CEQA analysis. This is considered the “reasonable maximum development
scenario,” to fully analyze potential impacts if development occurs at a rate higher than it has
historically. This reasonable maximum development scenario assumes that the entire housing
sites inventory would develop as housing and does not account for existing development
(primarily low-rise commercial uses) that would be demolished to allow for housing. As a result,
the impact analysis represents a conservative approach of potential impacts.
Table 4 shows the final CEQA unit count applying increased densities and assuming program
implementation, primarily the expansion of the City’s Housing Incentive Program (HIP).
Table 4 Total Housing Element Buildout for CEQA Analysis
Sites Units
RHNA Sites Inventory + Additional Density Assumption1 289 6,936
Sites removed from CEQA review2 (123) (1,387)
Increase in allowable density in ROLM/GM zones (Housing Element Program 1.1B) 3 13 294
HIP Standards Enhanced Citywide (Housing Element Program 3.4C) 4 0 294
HIP Expanded to All RM Zones (Housing Element Program 3.4D) 5 69 528
Total 248 6,665
( ) denotes subtraction
1 The CEQA unit yield is higher than the RHNA sites yield because of an assumed higher density development assigned to the sites.
2 123 sites do not involve changes in development density; therefore, they have been excluded from the CEQA buildout because the
development density is already permitted
3 Additional sites added due to higher feasibility of development due to proposed upzoning.
4 HIP allows for greater density and more relaxed development standards thus some developers will take advantage of the incentives.
5 Extending the HIP to the RM zones will allow property owners to take advantage of the development incentives.
The projected HE buildout of 6,665 units is slightly above the assumed 6,000 unit buildout of
Scenario 6 of the 2030 Comp Plan Supplement to the draft Environmental Review (EIR). Therefore
the Addendum focused on the impact of the 665 more residential units assumed in the HE
buildout. The Addendum focused on the potential impacts to circulation and air quality of the
additional units. In the review, the new State metric of Vehicle Miles Traveled (VMT) instead of
Level of Service (LOS) was used and the review concluded there would not be a significant impact
in citywide circulation patterns.
Air quality was also analyzed based on the greenhouse gas emissions generated from the
calculated VMT. It was determined that the air quality impacts did not exceed the CEQA
thresholds.
ALTERNATIVE ACTIONS
1. Continue the item and have staff return with a revised draft for review and
recommendation.
2. Request participation to have a joint meeting with the City Council to review and
recommend on the adoption.
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Report Author & Contact Information PTC6 Liaison & Contact Information
Tim Wong, Senior Planner Amy French, Chief Planning Official
(650) 329-2493 (650) 329-2441
tim.wong@cityofpaloalto.org amy.french@cityofpaloalto.org
ATTACHMENTS
Attachment A: Draft Addendum to the 2017 Palo Alto Comprehensive Plan Environmental
Impact Report
Attachment B: Draft 2023-31 Housing Element, December 2022 (viewable online and broken
down into five documents):
•DRAFT Housing Element 2023-2031 (https://paloaltohousingelement.com/wp-
content/uploads/2022/12/Palo-Alto-Housing-Element-2023-2031.pdf)
•Appendix A - Past Accomplishments (https://paloaltohousingelement.com/wp-
content/uploads/2022/12/Appendix-A-Past-Accomplishments.pdf)
•Appendix B - Public Outreach (https://paloaltohousingelement.com/wp-
content/uploads/2022/12/Appendix-B-Public-Outreach.pdf)
•Appendix C - Assessment of Fair Housing (https://paloaltohousingelement.com/wp-
content/uploads/2022/12/Appendix-C-Assessment-of-Fair-Housing.pdf)
•Appendix D - Site Inventory (https://paloaltohousingelement.com/wp-
content/uploads/2022/12/Appendix-D-Site-Inventory.pdf)
6 Emails may be sent directly to the PTC using the following address: planning.commission@cityofpaloalto.org
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DRAFT ADDENDUM TO THE 2030 COMPREHENSIVE PLAN
ENVIRONMENTAL IMPACT REPORT
(SCH #2014052101)
City of Palo Alto 2023-2031 Housing Element
PREPARED BY: City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Contact: Tim Wong, Senior Planner
PREPARED WITH THE ASSISTANCE OF: Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
REPORT DATE: March 2023
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TABLE OF CONTENTS
Introduction .................................................................................................................................................. 1
Project Description........................................................................................................................................ 5
Impact Analysis ........................................................................................................................................... 23
1 Aesthetics ................................................................................................................................ 25
2 Agriculture and Forestry Resources ........................................................................................ 31
3 Air Quality ................................................................................................................................ 35
4 Biological Resources ................................................................................................................ 53
5 Cultural Resources ................................................................................................................... 59
6 Energy ...................................................................................................................................... 63
7 Geology and Soils .................................................................................................................... 71
8 Greenhouse Gas Emissions ..................................................................................................... 77
9 Hazards and Hazardous Materials ........................................................................................... 87
10 Hydrology and Water Quality .................................................................................................. 93
11 Land Use and Planning .......................................................................................................... 101
12 Mineral Resources ................................................................................................................. 109
13 Noise ...................................................................................................................................... 111
14 Population and Housing ........................................................................................................ 121
15 Public Services ....................................................................................................................... 125
16 Recreation ............................................................................................................................. 129
17 Transportation ....................................................................................................................... 131
18 Tribal Cultural Resources ....................................................................................................... 139
19 Utilities and Service Systems ................................................................................................. 143
20 Wildfire .................................................................................................................................. 153
21 Cumulative Impacts ............................................................................................................... 157
22 Other CEQA Required Discussions ........................................................................................ 159
Conclusion ................................................................................................................................................. 161
References ................................................................................................................................................ 163
FIGURES
Figure 1 Regional Location ........................................................................................................................ 6
Figure 2 City of Palo Alto Location ............................................................................................................ 7
Figure 3 Housing Element Update Sites Inventory Locations ................................................................. 12
Figure 4 GM and ROLM Zones ................................................................................................................ 16
Figure 5 Existing and Proposed HIP Sites ................................................................................................ 18
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TABLES
Table 1 RHNA Allocation and Percentage of Income Distribution for Palo Alto ................................... 10
Table 2 Total Housing Element Proposed Sites and Units to Meet the RHNA ...................................... 15
Table 3 Total Housing Element Buildout for CEQA Analysis .................................................................. 20
Table 4 Total Development Evaluated in the Comprehensive Plan EIR Compared to the
Housing Element Update .......................................................................................................... 20
Table 5 2017 EIR Mitigation Measures: Aesthetics ............................................................................... 26
Table 6 2017 EIR Mitigation Measures: Air Quality ............................................................................... 36
Table 7 BAAQMD Criteria Air Pollutant Screening Levels ...................................................................... 39
Table 8 BAAQMD Criteria Air Pollutant Significance Thresholds .......................................................... 40
Table 9 BAAQMD Odor Source Thresholds ........................................................................................... 42
Table 10 Project Consistency with Applicable 2017 Clean Air Plan Control Measures ........................... 44
Table 11 Increase in Population Compared to VMT Under Project ........................................................ 45
Table 12 2017 EIR Mitigation Measures: Cultural Resources .................................................................. 60
Table 13 2017 EIR Mitigation Measures: Energy ..................................................................................... 64
Table 14 Consistency with State Renewable Energy and Energy Efficiency Plans .................................. 67
Table 15 Project Consistency with Applicable 2030 Comprehensive Plan policies ................................. 69
Table 16 2017 EIR Mitigation Measures: Greenhouse Gas Emissions..................................................... 78
Table 17 Operational GHG Emissions ...................................................................................................... 82
Table 18 Proposed Project Compliance with Applicable S/CAP Actions ................................................. 83
Table 19 2017 EIR Mitigation Measures: Hydrology and Water Quality ................................................. 95
Table 20 2017 EIR Mitigation Measures: Land Use and Planning ......................................................... 102
Table 21 Project Consistency with Plan Bay Area 2050 ......................................................................... 104
Table 22 Project Consistency with Relevant 2030 Comprehensive Plan Goals and Policies ................. 105
Table 23 2017 EIR Mitigation Measures: Noise ..................................................................................... 113
Table 24 2017 EIR Mitigation Measures: Public Services and Recreation ............................................. 126
Table 25 2017 EIR Mitigation Measures: Transportation and Traffic .................................................... 132
Table 26 Vehicle Miles Traveled Analysis Summary .............................................................................. 135
Table 27 2017 EIR Mitigation Measures: Utilities and Service Systems ................................................ 145
Table 28 Estimated Water Use for the Proposed HEU .......................................................................... 148
Table 29 Estimated Solid Waste Generation ......................................................................................... 150
APPENDICES
Appendix A Vehicle Miles Traveled Analysis
Appendix B Greenhouse Gas Emissions Modeling Results
Appendix C Native American Tribal Correspondence
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INTRODUCTION
This document is an addendum to the Environmental Impact Report (EIR) (State Clearinghouse
[SCH] #2014052101) certified in 2017 (“2017 EIR”) for the 2030 Comprehensive Plan. This
addendum is being prepared for the City’s 2023-2031 Housing Element Update (HEU),
henceforth known as the “proposed project” or “proposed HEU.” The City of Palo Alto was the
lead agency for the certified EIR and is the lead agency for this addendum. The addendum
analyzes the environmental effects of proposed revisions to the previously approved project
analyzed in the 2017 EIR to address the proposed HEU and has been prepared in accordance
with relevant provisions of the California Environmental Quality Act (CEQA) of 1970 (as
amended) and the CEQA Guidelines.
According to CEQA Guidelines Section 15164, an addendum to a previously certified EIR or
negative declaration is the appropriate environmental document in instances when “only minor
technical changes or additions are necessary” and when the new information does not involve
new significant environmental effects or a substantial increase in the severity of a significant
effect beyond those identified in the previous EIR. CEQA Guidelines Section 15164 states that:
a. The lead agency or responsible agency shall prepare an addendum to a previously certified
EIR if some changes or additions are necessary but none of the conditions described in
Section 15162 calling for preparation of a subsequent EIR have occurred [these are listed
below in Section 1.2].
b. [Omitted – applies to Negative Declarations]
c. An addendum need not be circulated for public review but can be included in or attached to
the final EIR or adopted negative declaration.
d. The decision-making body shall consider the addendum with the final EIR or adopted
negative declaration prior to making a decision on the project.
e. A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section
15162 should be included in an addendum to an EIR, the lead agency’s findings on the
project, or elsewhere in the record.
BACKGROUND AND PURPOSE OF THE EIR ADDENDUM
2017 EIR BACKGROUND
The City of Palo Alto prepared and certified the Comprehensive Plan Update EIR (State
Clearinghouse #2014052101) on February 5, 2016. The EIR analyzed four scenarios (scenarios 1,
2, 3, and 4) and their environmental impacts. The City then prepared and certified the
Comprehensive Plan Update Supplement to the Draft EIR (State Clearinghouse #2014052101)
on February 10, 2017, which analyzed two more scenarios (scenarios 5 and 6) with higher
buildouts compared to scenarios 1 through 4. This addendum analyzes the proposed HEU’s
impacts in relation to the 2017 EIR, which analyzed a maximum buildout of 6,000 new housing
units and 14,080 new residents in Scenario 6. The City also prepared and adopted a Mitigation,
Monitoring and Reporting Program (MMRP); CEQA findings; and a Statement of Overriding
Considerations in 2017.
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BASIS FOR THE ADDENDUM
As discussed in the CEQA Guidelines, between the date an environmental document for a
project is completed and the date that project is implemented fully, one or more of the
following changes may occur: 1) the project may change; 2) the environmental setting of the
project may change; or 3) previously unknown information can arise. Before proceeding with a
project, CEQA requires the lead agency to evaluate these changes to determine whether they
affect the conclusions in the prior environmental document. When an EIR has been adopted
and a project is modified or otherwise changed after adoption, additional CEQA review may be
necessary. The key considerations in determining the need for the appropriate type of
additional CEQA review are outlined in Public Resources Code Section 21166 (CEQA) and CEQA
Guidelines Sections 15162 and 15164.
CEQA Guidelines Section 15162(a) provides that a Subsequent EIR is not required unless the
following occurs:
1) Substantial changes are proposed in the project which will require major revisions of the
previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of identified significant
effects;
2) Substantial changes occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR or Negative Declaration
due to the involvement of new significant environmental effects or a substantial increase in
the severity of identified significant effects; or
3) New information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified
as complete or the Negative Declaration was adopted, shows any of the following:
A) The project will have one or more significant effects not discussed in the previous EIR or
negative declaration;
B) Significant effects previously examined will be substantially more severe than shown in
the previous EIR;
C) Mitigation measures or alternatives previously found not to be feasible would in fact be
feasible, and would substantially reduce one or more significant effects of the project,
but the project proponents decline to adopt the mitigation measure or alternative; or
D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant effects
on the environment, but the project proponents decline to adopt the mitigation
measure or alternative.
Pursuant to CEQA Guidelines Section 15164(a), an addendum to a previously certified EIR may
be prepared if some changes or additions are necessary but none of the conditions described in
Section 15162 have occurred that require preparation of a Subsequent EIR. An addendum must
include a brief explanation of the agency’s decision not to prepare a Subsequent EIR and must
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be supported by substantial evidence in the record as a whole (Section 15164[e]). The decision-
making body must consider the addendum prior to approving the project (Section 15164[d]).
An addendum to the 2017 EIR is appropriate to address the proposed project, because the
proposed modifications to the 2030 Comprehensive Plan project do not meet the conditions of
Section 15162(a) for preparation of a Subsequent EIR as described herein.
This addendum presents an analysis of the environmental topics identified in Appendix G of the
State CEQA Guidelines using a modified checklist that determines for each topic whether the
circumstances set forth in Public Resources Code Section 21166 and its implementing State
CEQA Guidelines sections 15162 and 15163 are present with respect to the proposed project or
the circumstances surrounding the project.
The 2017 EIR and this addendum serve as documents to inform decision-makers and the public
of the potential environmental consequences of approving the proposed project. This
addendum neither controls nor determines the ultimate decision for approval of the proposed
project. The information presented in this addendum to the certified EIR will be considered by
the City of Palo Alto alongside the certified EIR prior to deciding whether to approve the
proposed project.
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PROJECT DESCRIPTION
The proposed project, herein referred to as the “Housing Element Update,” “proposed Housing
Element Update,” or “HEU,” would amend the City of Palo Alto’s 2030 Comprehensive Plan
(hereinafter referred to as the “2030 Comprehensive Plan”) by replacing the current Housing
Element with the proposed 2023-2031 Housing Element and amending the 2030
Comprehensive Plan and Palo Alto Municipal Code (PAMC) as needed for consistency and HEU
implementation.
The proposed HEU establishes programs, policies, and actions to further the goal of
accommodating projected housing demand, as mandated by the State; increasing housing
production to meet this demand; improving housing affordability; preserving existing
affordable housing; improving the safety, quality and condition of existing housing; facilitating
the development of housing for all income levels and household types, including special needs
populations; improving the livability and economic prosperity of all Palo Alto residents; and
promoting fair housing choice for all.
This section describes the proposed project, including the project location, major project
characteristics, project objectives, and discretionary actions needed for approval.
LEAD AGENCY NAME, ADDRESS, AND CONTACT
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Contact: Tim Wong, Senior Planner, Tim.Wong@cityofpaloalto.org, 650-329-2493
PROJECT LOCATION
The study area considered in this analysis includes the entire city of Palo Alto (hereinafter
referred to as “City” or “Palo Alto”). Palo Alto is located 35 miles south of San Francisco and 14
miles north of San Jose. Palo Alto encompasses an area of approximately 26 square miles,
about a third of which is open space, including 34 city-owned parks, and 1,700 acres of
protected Baylands. The regional location of Palo Alto is shown in Figure 1 and the city limits
are show in Figure 2.
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Figure 1 Regional Location
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Figure 2 City of Palo Alto Location
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EXISTING SETTING
Palo Alto includes primarily single-family residential uses (approximately 61 percent of Palo
Alto) as well as schools, civic buildings, parks and open space, and commercial uses. The
developable area within Palo Alto, located between Junipero Serra Boulevard and the Bayshore
Freeway (US 101), is largely built out. Less than 0.5 percent of the developable land area is
vacant. A large percentage of Palo Alto’s land area is also undeveloped Baylands and hillsides.
The housing stock of Palo Alto in 2022 was made up of 16,403 single-family detached
residences, 1,218 single-family attached residences, 1,958 multi-family residences with 2 to 4
units, 9,489 multi-family residences with 5 or more units, and 97 mobile homes (California
Department of Finance [DOF] 2022 1).
PROJECT CHARACTERISTICS
The proposed project consists of a complete update to the Comprehensive Plan Housing
Element. The updates are intended to enable Palo Alto to accommodate housing in accordance
with State law while continuing to provide services, parks, schools, and environmental setting,
and offering new programs that support the city’s diversity and housing affordability.
HOUSING ELEMENT UPDATE
The Housing Element is one of the State-mandated elements of the Comprehensive Plan. The
current Housing Element was adopted in 2014 and is in effect through January 31, 2023. The
Housing Element identifies Palo Alto’s housing conditions and needs, and establishes the goals,
objectives, and policies that comprise the City’s housing strategy to accommodate projected
housing needs, including the provision of adequate housing for low-income households and for
special-needs populations (e.g., unhoused people, seniors, single-parent households, large
families, and persons with disabilities).
The proposed HEU would bring the element into compliance with State legislation passed since
adoption of the 2015-2023 Housing Element and with the current Regional Housing Needs
Allocation (RHNA). In December 2021, the Association of Bay Area Governments (ABAG)
Executive Board adopted the 6th Cycle Final RHNA, which includes a “fair share” allocation for
meeting regional housing needs for each community in the ABAG region.
The proposed HEU includes the following components, as required by State law:
Evaluation of the 2015-2023 Housing Element: An evaluation of the results of the goals,
policies, and programs adopted in the 2015-2023 Housing Element that compares projected
outcomes with actual achieved results.
1 California Department of Finance (DOF). 2022. E-5 Population and Housing Estimates.
https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-counties-and-the-
state-2020-2022/
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Demographics and Housing Needs Assessment: An analysis of the existing and projected
housing needs of the community. It provides a profile of socio-demographic information,
such as population characteristics, household information, housing stock, tenure, and
housing affordability. The assessment also considers local special housing needs, such as
seniors, farmworkers, unhoused persons, large households, and female-headed households.
Housing Capacity Analysis and Methodology: An inventory listing adequate sites that are
suitably zoned and available within the planning period to meet the city’s fair share of
regional housing needs across all income levels.
Housing Resources: An identification of resources to support the development,
preservation, and rehabilitation of housing.
Constraints to Housing Production: An assessment of impediments to housing production
across all income levels covering both governmental (e.g., zoning, fees, etc.) and
nongovernmental (e.g., market, environmental, etc.) impediments.
Housing Plan: This section provides a statement of the community’s goals, policies and
quantified objectives to maintain, preserve, improve, and develop housing, as well as a
schedule of implementable actions to be taken during the planning period. Quantified
objectives are included to make sure that both the existing and the projected housing needs
are met, consistent with the city’s share of the RHNA.
The draft Housing Element is available on the City’s website:
https://paloaltohousingelement.com/
REGIONAL HOUSING NEEDS ALLOCATION
The Housing Element must address the City's fair share of the regional housing need and
specific State statutory requirements and must reflect the vision and priorities of the local
community. ABAG has allocated the region’s 441,176 housing unit growth needs among each
city and county in its region through a process called the Regional Housing Needs
Determination. From the determination, ABAG assigns each jurisdictions Regional Housing
Needs Allocation (RHNA). The RHNA represents the minimum number of housing units that the
City is required to plan for in its Housing Element by providing adequate sites through the
Comprehensive Plan and zoning.
As shown in Table 1, Palo Alto’s RHNA for the 2023-2031 planning period is 6,086 units, which is
distributed among four income categories (a fifth category for extremely low-income
households is added in Table 1).
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Table 1 RHNA Allocation and Percentage of Income Distribution for Palo Alto
Income Level Percent of Area Median Income (AMI) Units Percent
Extremely Low <30% 778 12.7%
Very Low <50% 778 12.7%
Low 50-80% 896 14.7%
Moderate 80-120% 1,013 16.6%
Above Moderate >120% 2,621 43.0%
Total – 6,086 100%
Source: Association of Bay Area Governments Methodology and numbers were approved by ABAG’s Executive board on January 21, 2021
(Resolution No. 02-2021).
MEETING THE RHNA
To meet the RHNA and provide sufficient capacity to accommodate future housing
development, the HEU specifies sites suitable for residential development, identifies sites to
increase permitted residential densities to meet affordability requirements, and includes other
goals, policies, and programs to encourage housing. However, the Housing Element in and of
itself does not develop housing – it is a plan. This housing plan would be supported by new and
revised zoning standards. Not all of the housing anticipated by the RHNA will necessarily be
built, as housing development is mainly accomplished by the private sector and dependent on
factors independent of City control, such as financial resources. The sections below introduce
the Sites Inventory, sites proposed to meet the RHNA, and then a subset of the inventory
describing sites that require rezoning to meet the RHNA.
The Department of Housing and Community Development (HCD) guidance is to identify enough
housing sites inventory to not only cover the jurisdiction’s RHNA, but to also provide for an
additional buffer capacity to accommodate realistic production rates of affordable housing
units. Having a surplus or buffer can also allow for instances when a smaller residential unit
count may have to be considered for a given property. The “No Net Loss” Law (Government
Code Section 65863) requires maintenance of sufficient sites to meet the RHNA for all income
levels throughout the planning period.
SITES INVENTORY
The City assessed capacity in entitled and proposed development, accessory dwelling units
(ADU) and underutilized sites to meet the RHNA. Some of the underutilized sites are already
zoned to accommodate multifamily housing at appropriate densities. However, other sites
require rezoning to increase densities to allow multifamily housing and meet the remaining
shortfall in accommodating the RHNA. These categories are further explained below. The City
has identified 289 sites that could provide housing to meet the City’s RHNA and buffer. These
sites are shown on Figure 3.
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ENTITLED AND PROPOSED DEVELOPMENT
Approved and permitted residential developments can be credited towards the City’s RHNA for
the 6th cycle Housing Element provided it can be demonstrated that the units will be built
during the planning period. The city has identified 19 projects that are entitled or under review.
Entitled and proposed development would generate 1,016 new units within the city.
ACCESSORY DWELLING UNITS
The City anticipates that it will permit an average of 64 accessory dwelling units (ADU) per year
or 512 units during the planning period. ADUs, also referred to as granny flats or secondary
units, provide an affordable housing option and are an important tool to help meet the housing
needs in communities. The ADUs can also be credited towards RHNA. The proposed HEU
includes programs for the City to incentivize and promote ADUs, such as by new incentives for
rent-restriction ADUs that are affordable to low and very low income households and by
allowing the construction of an ADU or Junior ADU with the construction of a new residence,
whether on vacant property or on any property that is proposed to be redeveloped. The 64-unit
annual projection is based on the City’s average ADU production from 2019-2021.
IDENTIFYING UNDERUTILIZED SITES
After crediting the entitled or under review 1,106 units and the 512 projected ADUs towards
total RHNA (and buffer) of 6,695 units, there is a shortfall of 5,077 units. The proposed HEU
identifies 289 sites that could accommodate 5,189 units2 to meet the RHNA allocation during
the 2023-2031 period plus an additional buffer. Most of the parcels are developed but
underutilized. Parcels that were considered during this phase included:
Underutilized sites such as lots with uses that are no longer needed or need rehabilitation
Locations where housing could be denser
Locations near public transit and services
Locations where housing could be added near commercial buildings or in business parks to
create “live-work” neighborhoods
2 Note that the identified sites’ yield of 5,189 exceeds the calculated shortfall of 5,077 units by 112 units; the revised total unit
yield to meet RHNA is 6,807 units.
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Due to a lack of vacant available parcels, the City relies on non-vacant and underutilized sites to
accommodate nearly all of its RHNA.
SITES REQUIRING ZONING CHANGES
Of the 289 sites identified to meet RHNA, the majority (166 sites) would need to be rezoned to
a higher density to meet the estimated unit yields. The sites that do not require rezoning
already allow for the development density to reach the estimated unit yields.
STRATEGIES TO MEET RHNA
The City identified nine strategies to identify additional housing opportunity sites to
accommodate for the remaining total shortfall of 5,077 residential units. These strategies
include:
1. General up-zone of sites that allow for multi-family residential use;
2. Sites located within ½ mile of a Caltrain station;
3. Sites within ½ mile of high-frequency bus transit corridors;
4. Parking lots owned by the City;
5. Surface parking surrounding local faith-based institutions;
6. Sites within the General Manufacturing (GM) zone;
7. Sites within Research, Office, and Limited Manufacturing (ROLM) zone;
8. Sites owned by Stanford University; and,
9. Additional sites identified by City staff.
Overall, it is estimated that 166 sites would be rezoned and these rezoned sites would have a
capacity for an estimated 4,000 residential units distributed among all income categories. These
sites are also shown on Figure 3.
GENERAL UP-ZONING STRATEGIES
The City would allow more residential development by increasing the maximum allowable
density on sites where multi-family development is currently allowed. Medium to high density
residential zones, or commercial zones that currently allow a maximum density of 20 dwelling
units per acre would be up-zoned to allow a maximum of 30 dwelling units per acre. Similarly,
areas zoned for a density of 30 dwelling units per acre would be up-zoned to allow up to 40
dwelling units per acre. Those identified parcels within 0.25 mile of Caltrain stations would
receive an up-zone to 50 dwelling units per acre while those sites within a quarter to half a mile
would be up-zoned to 40 units per acre.
This strategy would increase the capacity of the city’s RM-20, RM-30, CN, CC, and CS zones on
99 sites. These sites are generally spread throughout the city but are predominately located
within the CS zone along El Camino Real with additional sites in the Downtown and North
Ventura Coordinated Area Plan (NVCAP) areas, and along Colorado Avenue and San Antonio
Road.
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SITES WITHIN 0.5 MILE OF A CALTRAIN STATION
This strategy focuses on facilitating transit-oriented residential development within a 0.5-mile
buffer of the three Caltrain stations that serve Palo Alto, which includes the Downtown,
California Avenue, and San Antonio Stations. Twenty-seven sites located within 0.25 mile of one
of these stations were identified to be re-zoned to allow multi-family development at densities
up to 50 dwelling units per acre, while 21 sites within 0.25 to 0.5 mile of one of these stations
were identified to be re-zoned to allow up to 40 dwelling units per acre. These sites are
primarily located in proximity to the Downtown and California Avenue Stations.
SITES WITHIN 0.5 MILE OF FREQUENT BUS ROUTES
This strategy would increase residential densities in areas located within walking distance of
frequent bus and shuttle service stops, specifically VTA route 22, 522-El Camino Real and VTA
route 21 – San Antonio Avenue, Middlefield Road, and University Avenue. These sites are
primarily located along El Camino Real.
CITY-OWNED PARKING LOTS
Several city-owned surface parking lots can be redeveloped to include affordable housing, if
appropriate. Four of these sites are located in the University Avenue Downtown area and two
additional sites are located near California Avenue, within the California Avenue Business
District.
SURFACE PARKING AND VACANT LAND ON SITES WITH FAITH-BASED INSTITUTIONS
Underutilized areas on sites occupied by faith-based institutions, such as excess parking lots
and vacant segments of properties, could accommodate additional residential units.
GM AND ROLM ZONES
Nearly all sites in GM and ROLM zones are currently occupied by, or reserved for, office uses.
This strategy would rezone these sites to allow for high-density multi-family residential uses
and would accommodate approximately 35 percent of the city’s overall remaining need.
Program 1.1 of the proposed HEU would rezone ROLM and GM zoned properties to allow multi-
family residential housing as a permitted use with a base density of 65 dwelling units per acre
for those properties nearest Bayshore Freeway and generally bounded by East Charleston Road
and Loma Verde Avenue.
STANFORD SITES
Stanford University owns multiple properties within city limits that could be used as sites for
potential housing. Two sites were identified for use as residential development under the
proposed HEU, which would be available for Stanford University affiliated employees and not
for students.
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ADDITIONAL SITES IDENTIFIED BY CITY STAFF
Nineteen additional sites were included in the Sites Inventory. These are sites where
development interest has been expressed, sites that have been pre-screened by developers for
residential projects, or the sites adequate for Palo Alto’s Housing Incentives Program (HIP).
TOTAL SITES INVENTORY
Table 2 shows the total inventory of sites and units to meet the RHNA. The City of Palo Alto has
assumed a 10 percent buffer which requires the site identification of an additional 609 units for
a total of 6,695. As shown in the table, with entitled and proposed development, ADUs,
underutilized sites with no rezoning required, and rezoning to meet the RHNA, a total of 6,807
units can be accommodated, which is more than the RHNA plus 10 percent buffer of 6,695
units.
Table 2 Total Housing Element Proposed Sites and Units to Meet the RHNA
Sites Units
Entitled and Proposed Development – Credit N/A1 1,1,06
ADU – Credit N/A2 512
Underutilized Sites (no rezoning required) 123 1,187
Rezoning to Meet the RHNA 166 4,002
Total 289 6,8074
1 The 19 project sites for entitled and proposed development are not counted in the 289 RHNA sites therefore they are not
included in this table.
2 ADU development is assumed throughout the city.
OTHER ZONING CHANGES NOT REQUIRED TO MEET THE RHNA
The HEU includes additional programs to support housing development production and/or
affordability throughout the city, some of which require zoning changes. Although these zoning
changes are not required to meet the RHNA, they facilitate the goals of the Housing Element.
These programs identified in the proposed HEU could modify zoning standards as follows:
Rezone ROLM and GM zoned properties to increase densities for multi-family residential
housing beyond 65 dwelling units per acre, for those properties nearest Bayshore Freeway
and generally bounded by East Charleston Road and Loma Verde Avenue. The GM and
ROLM zones are shown in Figure 4.
Extend the Affordable Housing Incentive Program (AHIP) to all housing opportunity sites.
Modify AHIP development standards to expand housing feasibility and affordability,
including allowing more residential floor area, taller building heights, and align the City’s
parking requirements to be consistent with State Density Bonus law.
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Figure 4 GM and ROLM Zones
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Modify the Housing Incentive Program (HIP) to amend development standards including
floor area, building height, aligning the City’s parking requirements to be consistent with
State Density Bonus law; and modifying retail preservation requirements to allow more
flexibility in redevelopment outside of essential retail locations (i.e., ground floor (GF) and
retail (R) combining districts and strategic locations generally depicted in the draft South El
Camino Real Design Guidelines). These revisions will promote greater housing production
and affordability.
Extend the HIP to multi-family residential districts and the ROLM and GM districts in
northeast portion of the City nearest the Bayshore Freeway and generally bounded by East
Charleston Road to the east and Loma Verde Avenue. The existing and proposed HIP
expanded HIP areas are shown in Figure 5.
Assess the existing Pedestrian and Transit Oriented Development (PTOD) Combining District
development standards and the review process to identify modifications needed to support
higher density housing production.
Amend the City's seismic hazards identification program to strengthen regulations and
require seismic upgrades of vulnerable housing stock through a combination mandatory
provisions and voluntary incentives.
Explore development incentives to encourage larger units, such as floor area ratio
exemptions for three or more bedroom units to encourage a mix of different bedroom units
in each development.
Amend the Palo Alto Municipal Code (PAMC) to reduce commercial floor area allowances or
other commercial incentives at strategic locations to shift the economic benefit of
redevelopment toward home building.
Assess the City's Workforce Housing Overlay regulations and consider amendments to
better align the target housing population with a housing typology that provides clear
reduced rents compared to market rate rents for a comparable unit.
Adopt incentives to encourage lot consolidation to encourage high density housing with
additional incentives for 100 percent affordable housing developments.
The zoning changes resulting from the implementation of these Housing Element programs may
stimulate development on housing opportunity sites identified in the Housing Element to meet
the RHNA or on other sites not identified in the Housing Element. This CEQA document
evaluates implementation of this broader set of zoning tools and housing development on sites
beyond the Housing Element sites inventory that may take advantage of these incentives. In
this way, the analysis accounts for a scenario in which development occurs at a rate higher than
it has historically or that is likely to occur.
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Figure 5 Existing and Proposed HIP Sites
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HOUSING ELEMENT UPDATE CEQA ASSUMPTIONS
CEQA BUILDOUT ASSUMPTIONS
For the purposes of the California Environmental Quality Act (CEQA) analysis, this document
assesses a higher range of development potential, considered the “reasonable maximum
development scenario,” to fully analyze potential impacts if development occurs at a rate
higher than it has historically. This reasonable maximum development scenario assumes that
the entire housing sites inventory would develop as housing and does not account for removal
of existing development (primarily low-rise commercial uses) that would be demolished to
allow for housing. As a result, the impact analysis represents a conservative approach of
potential impacts.
The CEQA analysis for the HEU is focused on the resulting physical changes that would take
place as a result of the implementation of the required rezonings to meet RHNA as explained in
Section 2.3.3 and program implementation as outlined in Section 2.3.4.
As shown on Table 2, there are 289 sites identified to meet RHNA; 123 of those do not require a
zone change. Therefore, while they are identified sites for the purpose of meeting RHNA they
are not assessed for the purposes of the CEQA analysis because they could be built to the
projected Housing Element buildout with or without adoption of the Housing Element.
Further, although Table 2 shows a total 6,807 units associated with the 289 RHNA sites, the
CEQA analysis assumes a higher unit yield because of an assumed higher density assigned to
these sites. While the assumed yield count is lower for the purposes of demonstrating capacity
to meet the RHNA, for the CEQA analysis the assumed yield is higher to allow for a reasonable
maximum development scenario to account for potential environmental impacts.
Lastly, because HEU programs 1.1B, 3.4C, and 3.4C involve increased residential density, the
CEQA buildout assumptions include an additional 82 sites and 1,116 units.
Table 3 shows the total buildout assumed with implementation of the Housing Element for the
purposes of the CEQA analysis, which is 248 sites with a yield of 6,665 units.
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Table 3 Total Housing Element Buildout for CEQA Analysis
Sites Units
RHNA Sites Inventory + Additional Density Assumption1 289 6,936
Sites removed from CEQA review2 (123) (1,387)
Increase in allowable density in ROLM/GM zones (Housing Element Program 1.1B) 3 13 294
HIP Standards Enhanced Citywide (Housing Element Program 3.4C) 4 0 294
HIP Expanded to All RM Zones (Housing Element Program 3.4D) 5 69 528
Total 248 6,665
( ) denotes subtraction
1 The CEQA unit yield is higher than the RHNA sites yield because of an assumed higher density development assigned to the sites.
2 123 sites do not involve changes in development density; therefore, they have been excluded from the CEQA buildout because the
development density is already permitted
3 Additional sites added due to higher feasibility of development due to proposed upzoning.
4 HIP allows for greater density and more relaxed development standards thus some developers will take advantage of the incentives.
5 Extending the HIP to the RM zones will allow property owners to take advantage of the development incentives.
CEQA BASELINE AND COMPARISON TO THE 2017 EIR
The CEQA baseline for this analysis is the maximum allowable development for residential uses
under the City’s 2030 Comprehensive Plan Environmental Impact Report (EIR). The
Comprehensive Plan Supplement to the Draft EIR analyzed six scenarios for development under
the 2030 Comprehensive Plan. Scenario 6 of the 2030 Comprehensive Plan Supplement to the
Draft EIR assumed a buildout of 6,000 residential units and 14,080 residents, similar to the
residential buildout of the HEU. Table 4 compares the potential buildout under the proposed
HEU to the buildout contemplated in Scenario 6 of the Comprehensive Plan EIR.
As shown on Table 4, buildout under the proposed HEU would result in 665 more residential
units and 2,650 more residents compared to Scenario 6 as studied in the Comprehensive Plan
EIR. Additionally, the construction of these units could result in an overall reduction in office
uses, but this document utilizes a conservative approach of simply analyzing the additional
impacts of the residential units, without assuming a reduction in the commercial buildout that
was analyzed for the Comprehensive Plan EIR.
Table 4 Total Development Evaluated in the Comprehensive Plan EIR Compared to the
Housing Element Update
Buildout under
Comprehensive Plan EIR
Buildout under
Proposed Housing
Element Update Change in Buildout
New Housing Units (# of units) 6,000 6,665 +665
New Population (# of people) 14,080 16,7301 +2,650
1 Based on Palo Alto persons per household of 2.51 (DOF 2022)
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PROJECT OBJECTIVES
The purpose of the project is to address the housing and safety needs of the City, to support
City programs to increase diversity and housing affordability, and to update the Comprehensive
Plan to meet the requirements of current State law. The proposed Housing Element includes
the following objectives:
Accommodating projected housing demand, as mandated by the State;
Increasing housing production to meet this demand;
Improving housing affordability;
Preserving existing affordable housing;
Improving the safety, quality and condition of existing housing;
Facilitating the development of housing for all income levels and household types, including
special needs population;
Improving the livability and economic prosperity of all City residents; and
Promoting fair housing choice and affirmatively furthering fair housing for all.
REQUIRED APPROVALS
With recommendations from the Planning and Transportation Commission, the City Council
would need to take the following discretionary actions in conjunction with the proposed HEU:
Adoption of the 2023-2031 Housing Element of the Comprehensive Plan
Amendments to the City’s Zoning Ordinance
Amendments to the Comprehensive Plan to ensure internal consistency between the
Housing Element and other chapters. This would include changes to land use designations in
the Land Use Element and changes to the Safety Element to meet current State law
requirements.
CALIFORNIA NATIVE AMERICAN TRIBAL CONSULTATION
On September 29, 2022, the City of Palo Alto contacted California Native American Tribal
governments by sending an Assembly Bill (AB) 52 and Senate Bill (SB) 18 notification letter via
email to tribes with an affiliation with the project area based on a list provided by the Native
American Heritage Commission (NAHC). Under AB 52, Native American tribes have 30 days to
respond and request further project information and request formal consultation. Under SB 18,
Native American tribes have 90 days to respond and request further project information and
request formal consultation. The City did not receive a request for formal consultation under
AB 52 or SB 18. Therefore, no California Native American Tribes traditionally or culturally
affiliated with the project area have requested consultation pursuant to Public Resources Code
Section 21080.3.1.
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IMPACT ANALYSIS
A comparative analysis has been prepared of the potential impacts associated with the
proposed project and the potential impacts of the scenarios analyzed in the 2017 EIR, using the
CEQA Guidelines Appendix G checklist as a guide. The checklist considers the full range of
environmental issues subject to analysis under CEQA (in rows), and then poses a series of
questions (in columns) aimed at identifying the degree to which the issue was analyzed in the
EIR. The checklist also includes a column identifying whether the proposed changes to the
Comprehensive Plan meet any of the criteria of CEQA Guidelines Section 15162 requiring a
subsequent EIR relative to each environmental issue. The questions posed in each column are
described below:
Where was impact analyzed? This column provides a cross-reference to the portions of the
2017 EIR where information and analyses may be found relative to the environmental issue
listed under each topic. The cross-references identified in this column correspond with page
numbers and section numbers of the 2017 EIR.
Could proposed changes involve new or substantially more severe impacts? In accordance
with the CEQA Guidelines Section 15162(a)(1), this column indicates whether the proposed
project would involve new significant environmental impacts or a substantial increase in the
severity of identified significant impacts that, in turn, would require major revisions of the 2017
EIR.
Are there new circumstances resulting in new or substantially more severe impacts? In
accordance with CEQA Guidelines Section 15162(a)(2), this column indicates whether changes
to the circumstances under which the proposed project is undertaken or implemented have
occurred that would involve new significant environmental impacts or a substantial increase in
the severity of identified significant impacts that, in turn, would require major revisions of the
2017 EIR.
Is there new information resulting in new or substantially more severe significant impacts? In
accordance with CEQA Guidelines Sections 15162(a)(3)(A) and 15162(a)(3)(B), this column
indicates whether new information of substantial importance, which was not known and could
not have been known with the exercise of reasonable diligence at the time the EIR was
certified, shows additional or substantially more severe significant impacts not discussed in the
2017 EIR.
Do mitigation measures included in the certified EIR address and/or resolve impacts? In
accordance with CEQA Guidelines Sections 15162(a)(3)(C) and 15162(a)(3)(D), this column
indicates whether new mitigation measures or alternatives previously found not to be feasible
in the 2017 EIR would in fact be feasible and would substantially reduce one or more significant
effects of the project, or whether such mitigation measures or alternatives which are
considerably different from those analyzed in the 2017 EIR would substantially reduce one or
more significant effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
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If impacts have been adequately analyzed in the 2017 EIR or would be less than significant,
major revisions of the 2017 EIR would not be required and no further environmental review
under CEQA would be required.
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1 Aesthetics
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Except as provided in Public Resources Code Section 21099, would the project:
a. Have a substantial
adverse effect on a
scenic vista?
EIR Page 4.1-5
through 4.1-7
No No No N/A
b. Substantially damage
scenic resources,
including but not limited
to, trees, rock
outcroppings, and
historic buildings within
a state scenic highway?
EIR Page 4.1-5
through 4.1-7
No No No N/A
c. In non-urbanized areas,
substantially degrade the
existing visual character
or quality of public views
of the site and its
surroundings? (Public
views are those that are
experienced from a
publicly accessible
vantage point). If the
project is in an urbanized
area, would the project
conflict with applicable
zoning and other
regulations governing
scenic quality?
EIR Pages 4.1-2
through 4.1-5
No No No N/A
d. Create a new source of
substantial light or glare
that would adversely
affect daytime or
nighttime views in the
area?
EIR Pages 4.1-7
through 4.1-8
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENT
Section 4.1, Aesthetics, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts
related to aesthetics. The 2017 EIR determined that the 2030 Comprehensive Plan would have
significant but mitigable impacts related to aesthetics. The 2017 EIR states that the project
could potentially substantially degrade the existing visual character or quality of the affected
areas of the city and their surroundings since it would introduce housing on sites previously
used for non-residential purposes and increase the scale of development on existing housing
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sites. Therefore, Mitigation Measure AES-1 would be required and would reduce impacts to a
less than significant level.
The 2017 EIR found that the 2030 Comprehensive Plan would not significantly alter public
viewsheds, view corridors, or scenic resources, and would not create a new source of
substantial light or glare which would adversely affect day or nighttime views in the area. These
impacts were found to be less than significant.
Table 5 lists the mitigation measure from the 2017 EIR related to aesthetics.
Table 5 2017 EIR Mitigation Measures: Aesthetics
Mitigation
Measure # Mitigation Text
Impact AES-1: Implementation of the proposed Plan would have the potential to substantially degrade the existing visual
character or quality of the area and its surroundings. (Potentially Significant and Mitigable)
AES-1 To ensure that increased residential densities would not degrade the visual character or quality of the area,
the proposed Plan shall include policies that address the following topics:
High-quality building and site design.
Compatibility with surrounding development and public spaces.
Enhancement of existing commercial centers.
Requirements for landscaping and street trees.
Preservation and creation of a safe and inviting pedestrian environment.
Appropriate building form, massing, and setbacks.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project have a substantial adverse effect on a scenic vista?
An adverse effect would occur if a proposed plan or project would block or otherwise damage
the scenic vista upon implementation. The City does not contain designated scenic views or
scenic vistas. However, Palo Alto identifies the backdrop of forested hills to the southwest and
San Francisco Bay to the northeast as views that are character-defining features of the city,
including the East Bay hills and the Santa Cruz Mountains (City of Palo Alto 2016).
The proposed HEU involves policies or programs that could increase allowed height (an
estimated additional 10 to 35 feet of height in some zoning districts) and floor area of
development in the city. The proposed HEU involves numerous programs and policies to
facilitate the development of housing in Palo Alto. However, areas proposed for development
were also analyzed for development in the 2017 EIR. Overall, the proposed HEU would result in
665 more residential units compared to what was analyzed in the 2017 EIR. As discussed in the
2017 EIR, future development facilitated by the 2030 Comprehensive Plan would be required to
comply with design guidelines such as the El Camino Real Design Guidelines which address site,
building, and landscaping design issues; South of Forest Avenue Coordinated Area Plan
guidelines which provides planning policies, development regulations, and design guidelines for
the South Forest Area; and the Downtown Urban Design Plan which includes conceptual
designs for specific locations and offers examples of desirable architectural and landscape
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treatments. These guidelines and standards would also generally apply to development under
the HEU. Furthermore, future multi-family development would be subject to the City’s
Architectural Review Board and/or designed in accordance with objective multi-family design
standards, to ensure that visual resources in Palo Alto are protected through compliance with
applicable development standards. However, consistent with what was analyzed in the 2017
EIR, the proposed HEU would introduce housing on sites previously used for non-residential
purposes, such as in ROLM and GM zones, and would increase the scale of development on
some existing housing sites, leading to newer and larger structures.
Nonetheless, even with potentially increased allowed height limits, development facilitated
under the proposed HEU compared to what is currently allowed would not substantially block
views, as most views are already fully or intermittently impeded by urban development,
including mature trees and existing buildings, and urbanized areas do not offer near or far field
views of scenic vistas. Therefore, an increase in height would not directly or substantially block
views. This impact would be less than significant and would be generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project substantially damage scenic resources, including but not limited to, trees,
rock outcroppings, and historic buildings within a state scenic highway?
While there are no officially designated State scenic highways in Palo Alto, the City identifies
several scenic routes, including Sand Hill Road, University Avenue, Embarcadero Road, Page Mill
Road, Oregon Expressway, I-280, Arastradero Road (west of Foothill Expressway), Junipero
Serra Boulevard/Foothill Expressway, and Skyline Boulevard as having high scenic value (City of
Palo Alto 2016). The proposed rezoning that would occur under the proposed HEU would allow
for increased residential density in RM-20, RM-30, CN, CC, and CS zones, and would allow for
residential uses in non-residential zones such as ROLM and GM zones. Overall, the proposed
HEU would result in 665 more units compared to what was analyzed in the 2017 EIR, which
could affect scenic views toward scenic routes. However, the housing inventory sites are all
located in areas that are already developed, and development would occur on underutilized or
non-vacant sites. Furthermore, development within the urbanized areas of the town such as
the Downtown area has already been planned to reinforce the existing development pattern.
Since there are no State-designated scenic highways in Palo Alto, the HEU would not facilitate
development that would substantially damage scenic resources within a state scenic highway.
Future multi-family development would be subject to the city’s Major Architectural Review,
which would help ensure that development complies with the applicable design guidelines and
development standards, including protection of scenic resources. Or, if projects qualify for
streamlined review, multifamily projects would be subject to objective design standards that
aim to create high-quality design and compatibility with surrounding uses and character.
Therefore, this impact would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
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c. In non-urbanized areas, substantially degrade the existing visual character or quality of
public views of the site and its surroundings? (Public views are those that are experienced
from a publicly accessible vantage point). If the project is in an urbanized area, would the
project conflict with applicable zoning and other regulations governing scenic quality?
The proposed HEU includes goals, policies, and programs to encourage housing in Palo Alto.
The proposed rezoning that would occur under the proposed HEU would allow for increased
residential density in RM-20, RM-30, CN, CC, and CS zones, and would allow for residential uses
in non-residential zones such as ROLM and GM zones. Overall, the proposed HEU would result
in 665 more units compared to what was analyzed in the 2017 EIR. Additional residential
development could result on other sites in urbanized areas of the city as a result of new
incentives in the HIP. However, future development would be subject to the city’s Major
Architectural Review which includes a hearing and recommendation by the Architectural
Review Board on whether the individual project is consistent with the findings for Architectural
Review outlined in PAMC Section 18.76.020. Or, if projects qualify for streamlined review,
multifamily projects would be subject to objective design standards that aim to create high-
quality design and compatibility with surrounding uses and character. This process aims to
promote orderly and harmonious development in the city and promote visual environments
that are of high aesthetic quality and variety and which, at the same time, are considerate of
each other. Additionally, future development in locations within specific area plans would be
required to adhere to development guidelines outlined within the respective area plans.
Although the proposed HEU would introduce housing on sites previously used for non-
residential purposes and increase the height and scale of development on existing underutilized
sites, as with the 2017 EIR, future development would be required to comply with policies L-1.1,
L-6.1, L-4.2, and N-2.1 of the 2030 Comprehensive Plan, adopted in compliance with Mitigation
Measure AES-1 of the 2017 EIR, which would ensure that increased residential densities would
not degrade the visual character or quality of the area. Therefore, this impact would be less
than significant with mitigation, and would be generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
d. Would the project create a new source of substantial light or glare that would adversely
affect daytime or nighttime views in the area?
Palo Alto is an urbanized city with commensurate level of light and glare. Development
facilitated by the project would, in large part, occur as infill on already developed parcels within
existing neighborhoods. New lighting could occur on buildings for safety and in pedestrian
walkways, and light could be emitted from interior sources through windows on upper stories
of tall buildings. The main source of glare would likely be from the sun shining on reflective or
light-colored building materials and glazing.
Development facilitated by the proposed HEU would occur as redevelopment of existing built
and underutilized sites. When facilities such as parking lots are replaced with buildings, these
replacements may reduce nighttime sources of light, because parking lots are often more
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brightly lit during the nighttime than most buildings. Development of underutilized parcels may
result in new light sources, but they would likely be congruous with nearby light sources (e.g.,
lighting from residential windows). Furthermore, as the development facilitated by the project
would be residential units, light from windows would be mostly filtered or obscured by window
coverings. Light spillover from exterior residential lighting is typically blocked by adjacent
structures or trees.
Furthermore, future development would be required to comply with PAMC Section 18.40.250,
which outlines guidelines for building exterior lighting and downward illumination; interior
lighting; unnecessary continued illumination; and timing devices and dimmers. Additionally,
future commercial and multi-family development would be subject to the city’s Major
Architectural Review which would ensure that all development comply with the applicable
design guidelines and development standards, including lighting and glare.
Overall, new residential development would be in existing residential neighborhoods or along
commercial corridors where sources of light and glare already exist. Development under the
proposed HEU would not create new sources of substantial light or glare that would adversely
affect daytime or nighttime views in the area and the impact therefore would be less than
significant. Therefore, this impact would be less than significant, and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
The project would have less than significant impacts on aesthetic resources, the same as those
identified in the 2017 EIR, with compliance with policies adopted in compliance with Mitigation
Measure AES-1. Therefore, the project would not result in new significant effects not addressed
in the prior EIR, and no new mitigation measures are warranted. This issue does not require
further study in an EIR.
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2 Agriculture and Forestry Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Convert Prime Farmland,
Unique Farmland, Farmland
of Statewide Importance
(Farmland), as shown on
maps prepared pursuant to
the Farmland Mapping and
Monitoring Program of the
California Resources Agency,
to non-agricultural use?
EIR Pages 7-1
through 7-2
No No No N/A
b. Conflict with existing zoning
for agricultural use or a
Williamson Act contract?
EIR Pages 7-1
through 7-2
No No No N/A
c. Conflict with existing zoning
for, or cause rezoning of,
forest land (as defined in
Public Resources Code
Section 12220(g));
timberland (as defined by
Public Resources Code
Section 4526); or timberland
zoned Timberland
Production (as defined by
Government Code Section
51104(g))?
EIR Pages 7-1
through 7-2
No No No N/A
d. Result in the loss of forest
land or conversion of forest
land to non-forest use?
EIR Pages 7-1
through 7-2
No No No N/A
e. Involve other changes in the
existing environment which,
due to their location or
nature, could result in
conversion of Farmland to
non-agricultural use or
conversion of forest land to
non-forest use?
EIR Pages 7-1
through 7-2
No No No N/A
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AGRICULTURE AND FORESTRY RESOURCES
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ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR addresses agricultural and forestry resources in Chapter 7, CEQA-Mandated
Sections. The 2017 EIR found that the implementation of the 2030 Comprehensive Plan would
have no impacts related to agricultural and forestry resources.
PROJECT-SPECIFIC IMPACTS
a. Would the project convert Prime Farmland, Unique Farmland, Farmland of Statewide
Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping
and Monitoring Program of the California Resources Agency, to non-agricultural use?
Although there are approximately nine acres of Prime Farmland and 11 acres of Unique
Farmland within Palo Alto, none of the sites in the Sites Inventory or areas proposed to be
rezoned are located on agricultural land. The proposed HEU would facilitate increased housing
on non-vacant and underutilized sites that are in urbanized areas. Therefore, the project would
not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-
agricultural use, and there would be no impact, generally the same as the impact analyzed in
the 2017 EIR for the 2030 Comprehensive Plan. Because would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
b. Would the project conflict with existing zoning for agricultural use, or a Williamson Act
contract?
According to the 2017 EIR, there are a total of 24 properties under the Williamson Act Contract.
The proposed HEU would facilitate increased housing on non-vacant and underutilized sites
that are in urbanized areas and would not involve changes to existing agricultural land or
conflict with a Williamson Act Contract. Therefore, there would be no impact, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as
defined in Public Resources Code Section 12220(g)), timberland (as defined by Public
Resources Code Section 4526), or timberland zoned Timberland Production (as defined by
Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest
use?
e. Would the project involve other changes in the existing environment, which, due to their
location or nature, could result in conversion of Farmland to non-agricultural use?
According to the 2017 EIR and the California Department of Forestry and Fire Protection (CAL
FIRE), forest lands are primarily located in the southern foothills. CAL FIRE also shows scattered,
isolated forestland within urbanized areas of the city. However, these areas are contained
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within parks, creek corridors, and built-out residential neighborhoods. No forest land,
timberland, or timberland zoned Timberland Production are proposed for redevelopment,
rezoning, or land use changes by the proposed HEU. The proposed HEU would facilitate
increased housing only on non-vacant and underutilized sites that are in urbanized areas.
Therefore, there would be no impact, generally the same as the impact analyzed in the 2017
EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
CONCLUSION
The project would have less than significant impacts on agriculture or forestry resources, the
same as those identified in the 2017 EIR. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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3 Air Quality
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Conflict with or obstruct
implementation of the
applicable air quality
plan?
EIR Pages 4.2-2
through 4.2-13
No No No No
b. Result in a cumulatively
considerable net
increase of any criteria
pollutant for which the
project region is non-
attainment under an
applicable federal or
state ambient air quality
standard?
EIR Pages 4.2-13
through 4.2-21
No No No No
c. Expose sensitive
receptors to substantial
pollutant
concentrations?
EIR Pages 4.2-22
through 4.2-29
No No No No
d. Result in other emissions
(such as those leading to
odors) adversely
affecting a substantial
number of people?
EIR Pages 4.2-29
through 4.2-31
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.2, Air Quality, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts
related to air quality. The 2017 EIR found that implementation of the 2030 Comprehensive Plan
could conflict with or obstruct the implementation of the 2010 Bay Area Clean Air Plan.
Although Scenario 6 was found to result in a lower vehicle miles traveled (VMT) per capita and
a lower VMT per service population than under existing conditions at the time, it could not be
verified whether the 2030 Comprehensive Plan would aid or hinder implementation of control
measures outlined in the 2010 Bay Area Clean Air Plan. Therefore, Mitigation Measure AIR-1
would be required to reduce impacts to a less than significant level.
The 2017 EIR also found that the 2030 Comprehensive Plan could violate an air quality
standard; contribute substantially to an existing or project air quality violation; and/or result in
a cumulatively considerable net increase of any criteria pollutant for which the project region is
nonattainment under an applicable federal or State ambient air quality standard, resulting in
significant and unavoidable impacts. Even with implementation of mitigation measures AIR-2a
through 2d, impacts would be significant since future development projects would contribute
to increases in concentrations of air pollutants.
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The 2017 EIR found that implementation of the 2030 Comprehensive Plan could expose
sensitive receptors to substantial concentrations of Toxic Air Contaminants (TACs), and
mitigation measures AIR-3a through 3d would be required to reduce impacts to a less than
significant level. Additionally, the implementation of the 2030 Comprehensive Plan could
expose a substantial number of people to objectionable odors. Therefore, mitigation measure
AIR-4 would be required to reduce odor impacts to a less than significant level.
Table 6 lists the mitigation measures from the 2017 EIR related to air quality.
Table 6 2017 EIR Mitigation Measures: Air Quality
Mitigation
Measure # Mitigation Text
Impact AIR-1: Without inclusion of air quality policies, implementation of the proposed Plan could conflict with or
obstruct implementation of the applicable air quality plan. (Significant and Mitigable)
AIR-1 To ensure consistency with the 2010 Bay Area Clean Air Plan, the proposed Plan shall include policies
that address the following topics:
Reduction in emissions of particulates from automobiles, manufacturing, construction activity, and
other sources (e.g. dry cleaning, wood burning, landscape maintenance).
Support for regional, State, and federal programs that improve air quality.
Support for transit, bicycling, and walking.
Mix of uses (e.g. housing near employment centers) and development types (e.g. infill) to reduce the
need to drive.
Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard; contribute substantially to an
existing or project air quality violation; and/or result in a cumulatively considerable net increase of any criteria pollutant
for which the Project region is nonattainment under an applicable federal or State ambient air quality standard (including
releasing emissions which exceed quantitative thresholds for ozone precursors). (Significant and Unavoidable)
AIR-2a As part of the City’s development approval process, the City shall require applicants for future
development projects to comply with the current BAAQMD basic control measures for reducing
construction emissions of PM10 (Table 8-1, Basic Construction Mitigation Measures Recommended for
All Proposed Projects, of the BAAQMD CEQA Guidelines).
AIR-2b Prior to issuance of construction permits, development project applicants that are subject to CEQA and
have the potential to exceed the BAAQMD screening-criteria listed in the BAAQMD CEQA Guidelines
shall prepare and submit to the City of Palo Alto a technical assessment evaluating potential project
construction-related air quality impacts. The evaluation shall be prepared in conformance with BAAQMD
methodology in assessing air quality impacts. If construction related criteria air pollutants are
determined to have the potential to exceed the BAAQMD thresholds of significance, as identified in the
BAAQMD CEQA Guidelines, the City of Palo Alto shall require that applicants for new development
projects incorporate mitigation measures (Table 8-2, Additional Construction Mitigation Measures
Recommended for Projects with Construction Emissions Above the Threshold, of the BAAQMD CEQA
Guidelines or applicable construction mitigation measures subsequently approved by BAAQMD) to
reduce air pollutant emissions during construction activities to below these thresholds. These identified
measures shall be incorporated into all appropriate construction documents (e.g., construction
management plans) submitted to the City and shall be verified by the City’s Planning and Community
Environment Department.
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Mitigation
Measure # Mitigation Text
AIR-2c To ensure that development projects that have the potential to exceed the BAAQMD screening criteria
air pollutants listed in the BAAQMD CEQA Guidelines reduce regional air pollutant emissions below the
BAAQMD thresholds of significance, the proposed Plan shall include policies that address the following
topic:
Require compliance with BAAQMD requirements, including BAAQMD CEQA Guidelines
AIR-2d Implement Mitigation Measure TRANS-1a. In addition, to reduce long-term air quality impacts by
emphasizing walkable neighborhoods and supporting alternative modes of transportation., the
proposed Plan shall include policies that address the following topic:
Enhanced pedestrian and bicycle connections between commercial and mixed-use centers.
Impact AIR-3: Implementation of the proposed Plan would expose sensitive receptors to substantial concentrations of air
pollution. (Significant and Mitigable)
AIR-3a The City of Palo Alto shall update its CEQA Procedures to require that future non-residential projects
within the city that: 1) have the potential to generate 100 or more diesel truck trips per day or have 40
or more trucks with operating diesel powered TRUs, and 2) are within 1,000 feet of a sensitive land use
(e.g., residential, schools, hospitals, nursing homes), as measured from the property line of a proposed
project to the property line of the nearest sensitive use, shall submit a health risk assessment (HRA) to
the City of Palo Alto prior to future discretionary Project approval or shall comply with best practices
recommended for implementation by the BAAQMD. The HRA shall be prepared in accordance with
policies and procedures of the State Office of Environmental Health Hazard Assessment and the Bay
Area Air Quality Management District. If the HRA shows that the incremental cancer risk exceeds the
BAAQMD significance thresholds, the applicant will be required to identify and demonstrate that
mitigation measures are capable of reducing potential cancer and noncancer risks to an acceptable
level, including appropriate enforcement mechanisms.
Mitigation measures and best practices may include but are not limited to:
Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible.
Electrifying warehousing docks.
Requiring use of newer equipment and/or vehicles.
Restricting off-site truck travel through the creation of truck routes.
Mitigation measures identified in the project-specific HRA shall be identified as mitigation measures in
the environmental document and/or incorporated into the site development plan as a component of a
proposed project.
AIR-3b To ensure that new industrial and warehousing projects with the potential to generate new stationary
and mobile sources of air toxics that exceed the BAAQMD project level and/or cumulative significance
thresholds for toxic air contaminants and PM2.5 listed in the BAAQMD CEQA Guidelines reduce
emissions below the BAAQMD thresholds of significance, the proposed Plan shall include policies that
address the following topic:
Require compliance with BAAQMD requirements, including BAAQMD CEQA Guidelines.
AIR-3c The City of Palo Alto shall update its CEQA Procedures to require that residential and other sensitive
land use projects (e.g., hospitals, nursing homes, and day care centers) that are subject to CEQA and are
not classified as exempt within 1,000 feet of a major sources of TACs (e.g., warehouses, industrial areas,
freeways, and roadways with traffic volumes over 10,000 vehicle per day), as measured from the
property line of the project to the property line of the source/edge of the nearest travel lane, shall
submit a health risk assessment (HRA) to the City of Palo Alto prior to future discretionary Project
approval or shall comply with best practices recommended by the BAAQMD.
The HRA shall be prepared in accordance with policies and procedures of the State Office of
Environmental Health Hazard Assessment (OEHHA) and the BAAQMD. The latest OEHHA guidelines shall
be used for the analysis, including age sensitivity factors, breathing rates, and body weights appropriate
for children age zero to 16 years. If the HRA exceeds the BAAQMD significance thresholds, the applicant
will be required to identify and demonstrate that mitigation measures are capable of reducing potential
cancer and non-cancer risks to an acceptable level (i.e., below 10 in one million or a hazard index of 1.0),
including appropriate enforcement mechanisms.
Measures and/or best practices to reduce risk may include but are not limited to:
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Mitigation
Measure # Mitigation Text
Air intakes located away from high volume roadways and/or truck loading zones.
Heating, ventilation, and air conditioning systems of the buildings provided with appropriately sized
Maximum Efficiency Rating Value (MERV) filters.
Mitigation measures identified in the HRA and best practices shall be incorporated into the site
development plan as a condition of approval. The air intake design and MERV filter requirements shall
be noted and/or reflected on all building plans submitted to the City and shall be verified by the City.
AIR-3d Amend the Palo Alto Municipal Code to require applicants for new ministerial projects, or new
discretionary projects that are exempt from CEQA, within 1,000 feet of a major sources of TACs (e.g.,
warehouses, industrial areas, freeways, and roadways with traffic volumes over 10,000 vehicle per day),
as measured from the property line of the project to the property line of the source/edge of the nearest
travel lane, to either submit an HRA showing that BAAQMD significance thresholds would not be
exceeded, or provide a filtration system capable of filtering out 90 percent of fine inhalable particulates
and diesel particulate matter.
Impact AIR-4: Implementation of the proposed Plan could create or expose a substantial number of people to
objectionable odors unless policies are integrated into the proposed Plan. (Significant and Mitigable)
AIR-4 To reduce odor impacts, the proposed Plan shall include policies that address the following topic:
Buffers and other mitigation methods to avoid human health impacts from sources of odor and/or
toxic air contaminants.
Source: City of Palo Alto 2016
BAAQMD SIGNIFICANCE THRESHOLDS
This analysis uses the Bay Area Air Quality Management District’s (BAAQMD’s) May 2017 CEQA
Air Quality Guidelines to evaluate air quality. The plan-level thresholds specified in the May
2017 BAAQMD CEQA Air Quality Guidelines were used to determine whether the proposed
HEU’s impacts would exceed the thresholds identified in CEQA Guidelines Appendix G.
CONSISTENCY WITH AIR QUALITY PLAN
Under BAAQMD’s methodology, a determination of consistency with CEQA Guidelines
thresholds should demonstrate that a project:
1. Supports the primary goals of the 2017 Clean Air Plan
2. Includes applicable control measures from the 2017 Clean Air Plan
3. Does not disrupt or hinder implementation of any 2017 Clean Air Plan control measures
CONSTRUCTION EMISSIONS THRESHOLDS
The BAAQMD’s May 2017 CEQA Air Quality Guidelines have no plan-level significance
thresholds for construction air pollutants emissions. However, they do include project-level
screening and emissions thresholds for temporary construction-related emissions of air
pollutants. These thresholds represent the levels at which a project’s individual emissions of
criteria air pollutants or precursors would result in a cumulatively considerable contribution to
the San Francisco Bay Area Air Basin’s (SFBAAB) existing air quality conditions and are discussed
in detail below (BAAQMD 2017a). Construction emissions associated with plan implementation
are discussed qualitatively to evaluate potential air quality impacts.
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The BAAQMD developed screening criteria in the 2017 CEQA Air Quality Guidelines to provide
lead agencies and project applicants with a conservative indication of whether a project could
result in potentially significant air quality impacts. The screening criteria for residential land
uses are shown in Table 7.
Table 7 BAAQMD Criteria Air Pollutant Screening Levels
Land Use Type
Operational Criteria
Pollutant Screening Size (du)
Construction Criteria
Pollutant Screening Size (du)
Single-family 325 (NOX) 114 (ROG)
Apartment, low-rise 451 (ROG) 240 (ROG)
Apartment, mid-rise 494 (ROG) 240 (ROG)
Apartment, high-rise 510 (ROG) 249 (ROG)
Condo/townhouse, general 451 (ROG) 240 (ROG)
Condo/townhouse, high-rise 511 (ROG) 252 (ROG)
Mobile home park 450 (ROG) 114 (ROG)
Retirement community 487 (ROG) 114 (ROG)
Congregate care facility 657 (ROG) 240 (ROG)
du = dwelling unit; NOX = oxides of nitrogen; ROG = reactive organic gases
Source: BAAQMD 2017a
If a project meets the screening criteria, then the lead agency or applicant would not need to
perform a detailed air quality assessment of their project’s air pollutant emissions. These
screening levels are generally representative of new development on greenfield sites without
any form of mitigation measures taken into consideration (BAAQMD 2017a).
In addition to the screening levels above, several additional factors are outlined in the 2017
CEQA Air Quality Guidelines that construction activities must satisfy for a project to meet the
construction screening criteria:
All basic construction measures from the 2017 CEQA Guidelines must be included in project
design and implemented during construction
Construction-related activities would not include any of the following:
Demolition
Simultaneous occurrence of more than two construction phases (e.g., paving and
building construction would occur simultaneously)
Simultaneous construction of more than one land use type (e.g., project would develop
residential and commercial uses on the same site) (not applicable to high density infill
development)
Extensive material transport (e.g., greater than 10,000 cubic yards of soil import/export)
requiring a considerable amount of haul truck activity
For projects that do not meet the screening criteria above, the BAAQMD construction
significance thresholds for criteria air pollutants, shown in Table 8, are used to evaluate a
project’s potential air quality impacts.
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Table 8 BAAQMD Criteria Air Pollutant Significance Thresholds
Pollutant
Construction Thresholds
Average Daily Emissions (lbs/day)
Operational Threshold
Average Daily Emissions (lbs/day)
Operational Threshold
Maximum Annual
Emissions (tons/year)
ROG 54 54 10
NOX 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
Fugitive Dust Construction Dust Ordinance or other
Best Management Practices
Not Applicable Not Applicable
lbs = pounds; NOX = oxides of nitrogen; ROG = reactive organic gases; PM2.5 = particulate matter with an aerodynamic diameter equal to or
less than 2.5 microns
Source: BAAQMD 2017a
For all projects in the SFBAAB, the BAAQMD 2017 CEQA Air Quality Guidelines recommends
implementation of the Basic Construction Mitigation Measures listed in Table 8-2 of the
Guidelines (BAAQMD 2017a). For projects that exceed the thresholds in Table 8, the BAAQMD
2017 CEQA Air Quality Guidelines recommends implementation of the Additional Construction
mitigation measures listed in Table 8-3 of the Guidelines (BAAQMD 2017a).
OPERATIONAL EMISSIONS THRESHOLDS
The BAAQMD’s 2017 CEQA Air Quality Guidelines contain specific operational plan-level
significance thresholds for criteria air pollutants. Plans must show the following over the
planning period:
Consistency with current air quality plan control measures, and
VMT or vehicle trips increase is less than or equal to the plan’s projected population
increase.
The current air quality plan is the 2017 Clean Air Plan. If a plan can demonstrate consistency
with both criteria, then impacts would be less than significant.
For project-level thresholds, the screening criteria for operational emissions are shown in
Table 7. For projects that do not meet the screening criteria, the BAAQMD operational
significance thresholds for criteria air pollutants, shown in Table 8, are used to evaluate a
project’s potential air quality impacts.
CARBON MONOXIDE HOTSPOTS
BAAQMD provides a preliminary screening methodology to conservatively determine whether a
proposed project would exceed carbon monoxide (CO) thresholds. If the following criteria are
met, a project would result in a less than significant impact related to local CO concentrations:
The project is consistent with an applicable congestion management program established
by the county congestion management agency for designated roads or highways, regional
transportation plan, and local congestion management agency plans.
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Project traffic would not increase traffic volumes at affected intersections to more than
44,000 vehicles per hour.
Project traffic would not increase traffic volumes at affected intersections to more than
24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited
(e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade
roadway).
A CO hotspot is a localized concentration of CO that is above a CO ambient air quality standard.
The entire Basin is in conformance with state and federal CO standards (BAAQMD 2017c). There
are no current exceedances of CO standards within the BAAQMD jurisdiction and have not had
a CO exceedance in the Bay Area since before 1994.3 For 2019 the Bay Area’s reported
maximum 1-hour and average daily concentrations of CO were 5.6 ppm and 1.7 ppm
respectively (BAAQMD 2019).4 These are well below the respective 1-hour and 8-hour
standards of 20 ppm and 9 ppm. Given the ambient concentrations, which include mobile as
well as stationary sources, a project in the Bay Area would need to emit concentrations three
times the hourly maximum ambient emissions for all sources before project emissions would
exceed the 1-hour standard. Additionally, the project would need to emit seven times the daily
average for ambient concentrations to exceed the 8-hour standards. Typical development
projects, even plan level growth, would not emit the levels of CO necessary to result in a
localized hot spot.
TOXIC AIR CONTAMINANTS
For health risks associated with TAC and PM2.5 emissions, the BAAQMD May 2017 CEQA Air
Quality Guidelines state a project would result in a significant impact if the any of the following
thresholds are exceeded (BAAQMD 2017b):
Non-compliance with Qualified Community Risk Reduction Plan;
Increased cancer risk of > 10.0 in a million;
Increased non-cancer risk of > 1.0 Hazard Index (Chronic or Acute); or
Ambient PM2.5 increase of > 0.3 µg/m3 annual average
ODORS
The BAAQMD provides minimum distances for siting of new odor sources shown in Table 9. A
significant impact would occur if the project would result in other emissions (such as odors)
affecting substantial numbers of people or would site a new odor source as shown in Table 9
within the specified distances of existing receptors.
3 BAAQMD only has records for annual air quality summaries dating back to 1994.
4 Data for 2019 was used as the data for 2020 and 2021 are not currently available.
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Table 9 BAAQMD Odor Source Thresholds
Odor Source Minimum Distance for Less than Significant Odor Impacts (in miles)
Wastewater treatment plant 2
Wastewater pumping facilities 1
Sanitary Landfill 2
Transfer Station 1
Composting Facility 1
Petroleum Refinery 2
Asphalt Batch Plant 2
Chemical Manufacturing 2
Fiberglass Manufacturing 1
Painting/Coating Operations 1
Rendering Plant 2
Source: BAAQMD 2017a
METHODOLOGY
CONSTRUCTION EMISSIONS
Construction-related emissions are temporary but may still result in adverse air quality impacts.
Construction of development facilitated by the project would generate temporary emissions
from three primary sources: the operation of construction vehicles (e.g., scrapers, loaders,
dump trucks, etc.); ground disturbance during site preparation and grading, which creates
fugitive dust; and the application of asphalt, paint, or other oil-based substances.
At this time, there is not sufficient detail to provide analysis of individual construction projects
that would be facilitated by the project, and thus it would be speculative to analyze project-
level impacts. Rather, consistent with the programmatic nature of the project, construction
impacts for the project are discussed qualitatively and emissions are not compared to the
project-level thresholds.
OPERATION EMISSIONS
Based on plan-level guidance from the BAAQMD 2017 CEQA Air Quality Guidelines, long-term
operational emissions associated with implementation of the proposed project are discussed
qualitatively by comparing the proposed project to the 2017 Clean Air Plan goals, policies, and
control measures. In addition, comparing the rate of increase of plan VMT and population is
recommended by BAAQMD for determining significance of criteria pollutants. If the proposed
project does not meet either criterion then impacts would be potentially significant.
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PROJECT-SPECIFIC IMPACT ANALYSIS
a. Would the project conflict with or obstruct implementation of the applicable air quality
plan?
The most current clean air plan, Spare the Air, Cool the Climate: A Blueprint for Clean Air and
Climate Protection in the Bay Area (2017 Clean Air Plan) was adopted by BAAQMD April 2017
(BAAQMD 2017b). The legal impetus for the 2017 Clean Air Plan was to update the previous
2010 Clean Air Plan to comply with State air quality planning requirements as codified in the
California Health & Safety Code. The 2017 Clean Air Plan either has updated or replaced the air
quality plans that were discussed in the 2017 EIR.
The California Clean Air Act requires that air districts create a Clean Air Plan that describes how
the jurisdiction will meet air quality standards. To fulfill State ozone planning requirements, the
2017 Clean Air Plan control strategy includes all feasible measures to reduce emissions of ozone
precursors—ROG and NOX—and reduce transport of ozone and its precursors to neighboring air
basins. The Clean Air Plan builds upon and enhances the BAAQMD’s efforts to reduce emissions
of fine particulate matter and TACs. The 2017 Clean Air Plan does not include control measures
that apply directly to individual development projects. Instead, the control strategy includes
control measures related to stationary sources, transportation, energy, buildings, agriculture,
natural and working lands, waste management, water, and super-GHG pollutants.
The 2017 Clean Air Plan focuses on two paramount goals, both consistent with the mission of
BAAQMD:
Protect air quality and health at the regional and local scale by attaining all national and
state air quality standards and eliminating disparities among Bay Area communities in
cancer health risk from TACs; and
Protect the climate by reducing Bay Area GHG emissions to 40 percent below 1990 levels by
2030, and 80 percent below 1990 levels by 2050
Under BAAQMD’s methodology, a determination of consistency with the 2017 Plan should
demonstrate that a project:
Supports the primary goals of the air quality plan
Includes applicable control measures from the air quality plan
Does not disrupt or hinder implementation of any air quality plan control measures
A project that would not support the 2017 Clean Air Plan’s goals would not be considered
consistent with the 2017 Clean Air Plan. Table 10 shows project consistency with applicable
control measures from the 2017 Clean Air Plan.
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Table 10 Project Consistency with Applicable 2017 Clean Air Plan Control Measures
Control Measures Consistency
Transportation
TR9: Bicycle and Pedestrian Access and
Facilities. Encourage planning for bicycle and
pedestrian facilities in local plans, e.g., general
and specific plans, fund bike lanes, routes, paths
and bicycle parking facilities.
Consistent: The proposed HEU would facilitate development of
increased housing compared to the 2030 Comprehensive Plan within
urbanized sites and in areas such as along El Camino Real, the California
Avenue area, the Downtown area, near Bayshore Road, and in
underutilized commercial areas. These areas are mostly near or adjacent
to transportation corridors currently served by Class I, II, and III bicycle
lanes such as University Avenue, Bryant Street, California Avenue, and
Bayshore Road, which would encourage the use of bicycles and reduce
reliance on single-occupancy vehicles. Future residents would also be
able to utilize bicycle parking facilities around the city which would
encourage residents to bicycle and walk to transit and services (City of
Palo Alto 2012).
Energy
EN2: Decrease Electricity Demand. Work with
local governments to adopt additional energy-
efficiency policies and programs. Support local
government energy efficiency program via best
practices, model ordinances, and technical
support. Work with partners to develop
messaging to decrease electricity demand during
peak times.
Consistent. Development facilitated by the project would be required to
comply with the PAMC Chapters 16.14 (California Green Building
Standards Code) and 16.17 (California Energy Code), which mandates
the implementation of the City’s sustainability and energy efficiency
measures. Newly constructed buildings would be required to comply
with the City’s All-Electric Mandate which requires an all-electric
building design for single-family, low-rise multi-family, and non-
residential development (City of Palo Alto 2022a). Although the
inclusion of all-electric construction would increase electricity demand,
electricity would be provided by City of Palo Alto Utilities (CPAU), which
has provided 100 percent carbon neutral electricity since 2013 (City of
Palo Alto 2022b).
Buildings
BL1: Green Buildings. Collaborate with partners
such as KyotoUSA to identify energy-related
improvements and opportunities for on-site
renewable energy systems in school districts;
investigate funding strategies to implement
upgrades. Identify barriers to effective local
implementation of the CALGreen (Title 24)
statewide building energy code; develop
solutions to improve
implementation/enforcement. Work with
ABAG’s BayREN program to make additional
funding available for energy-related projects in
the buildings sector. Engage with additional
partners to target reducing emissions from
specific types of buildings.
Consistent: Development facilitated by the project would be required to
comply with the energy and sustainability standards of Title 24
(including the California Energy Code and CALGreen) and the City’s
associated amendments that are in effect at that time. For example, the
current 2022 CALGreen standards require a minimum of 65 percent
diversion of construction and demolition debris while the City’s
Construction and Demolition Debris Diversion Ordinance (PAMC Section
16.14.260) requires a minimum of 80 percent diversion for projects with
a valuation of $25,000 or greater. Future development would be
required to comply with the most recent Title 24 standards, which are
updated every three years and become increasingly more stringent over
time. Future development would also be subject to the Reach Code
which would requires all-electric building design for single-family, low-
rise multi-family, and non-residential development. Pursuant to Section
16.14.420 of the PAMC, new multi-family residences would be required
to provide at least one Electric Vehicle Supply Equipment (EVSE) Ready
outlet or EVSE installed for each residential unit in the structure for
residential parking, and would be required to provide Conduit Only,
EVSE Ready Outlet, or EVSE installed for at least 25 percent of guest
parking spaces, among which at least 5 percent shall be EVSE installed.
Future development facilitated by the project would be required to
comply with the most updated EV requirements in both the City’s Reach
Code and Title 24 at the time of construction.
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Control Measures Consistency
Water
WR2: Support Water Conservation. Develop a
list of best practices that reduce water
consumption and increase on-site water
recycling in new and existing buildings;
incorporate into local planning guidance.
Consistent: Future development that needs new or expanded water
service would be required to comply with the San Francisco Public
Utilities Commission’s (SFPUC) and CALGreen’s water efficiency
regulations, and the State’s Model Water Efficiency Landscape
Ordinance to reduce indoor and outdoor water use.
Source: BAAQMD 2017b
As shown in Table 10, the project would be consistent with the applicable measures as
development facilitated by the project would be required to comply with the latest Title 24
regulations and would increase density along transportation corridors and in the downtown
area, allowing for greater use of alternative modes of transportation. Development facilitated
by the project would not contain elements that would disrupt or hinder implementation of a
2017 Clean Air Plan control measures. Therefore, the project would be consistent with the 2017
Clean Air Plan.
PROJECT VMT AND POPULATION GROWTH
According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air
pollutants and precursors includes an assessment of the rate of increase of plan VMT versus
population growth. As discussed above under Environmental Setting, to result in a less than
significant impact, the analysis must show that the project’s projected VMT increase would be
less than or equal to its projected population increase. Put another way, the project’s projected
VMT per resident must be less than what would occur without the project. As shown in
Table 11, VMT associated with project buildout would increase by approximately 23.2 percent
over baseline 2015 conditions and would not exceed the rate of increase from the forecast
population of approximately 24.1 percent over baseline 2015 conditions. The resulting VMT per
resident (9.13 VMT per resident) would be less than baseline 2015 conditions (9.19 VMT per
resident). Therefore, the project’s VMT increase would not conflict with the BAAQMD’s 2017
CEQA Air Quality Guidelines operational plan-level significance thresholds for criteria air
pollutants and would be consistent with the 2017 Clean Air Plan. Accordingly, impacts would be
less than significant, and would be generally the same as the impact analyzed in the 3017 EIR
for the 2030 Comprehensive Plan.
Table 11 Increase in Population Compared to VMT Under Project
Scenario Baseline (2015)
2023-2031 Housing
Element Update
(Proposed Project) Net Increase Percent Change
Population 69,537 86,277 16,740 24.1%
Vehicle Miles Traveled 638,838 787,447 148,262 23.2%
Source: Data provided by Hexagon Transportation Consultants, Inc 2022 (Appendix A)
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b. Would the project violate any air quality standard or contribute substantially to an existing
or projected air quality violation?
CONSTRUCTION
Development facilitated by the proposed HEU would involve activities that result in air
pollutant emissions. Construction activities such as demolition, grading, construction worker
travel, delivery and hauling of construction supplies and debris, and fuel combustion by on-site
construction equipment would generate pollutant emissions. These construction activities
would temporarily create emissions of dust, fumes, equipment exhaust, and other air
contaminants, particularly during site preparation and grading. The extent of daily emissions,
particularly ROGs and NOX emissions, generated by construction equipment, would depend on
the quantity of equipment used and the hours of operation for each project. The extent of
PM2.5 and PM10 emissions would depend upon the following factors: 1) the amount of disturbed
soils; 2) the length of disturbance time; 3) whether existing structures are demolished; 4)
whether excavation is involved; and 5) whether transporting excavated materials offsite is
necessary. Dust emissions can lead to both nuisance and health impacts. According to the 2017
BAAQMD CEQA Air Quality Guidelines, PM10 is the greatest pollutant of concern during
construction (BAAQMD 2017a).
As discussed above under BAAQMD Significance Thresholds, BAAQMD’s 2017 CEQA Air Quality
Guidelines have no plan-level significance thresholds for construction air pollutant emissions
that would apply to the project. However, the guidelines include project-level thresholds for
construction emissions. If an individual project’s construction emissions fall below the project-
level thresholds, the project’s impacts on regional air quality would be individually and
cumulatively less than significant. Mitigation Measure AIR-2b of the 2017 EIR would require
future development that does not meet the BAAQMD construction screening criteria under
Table 7 to conduct individual air quality analysis and compare emissions to BAAQMD
significance thresholds as detailed under Table 8, and to implement mitigation measures to
reduce emissions.
Construction of development envisioned under the project would temporarily increase air
pollutant emissions, possibly creating localized areas of unhealthy air pollution concentrations
or air quality nuisances. Therefore, construction air quality impacts would be potentially
significant. Furthermore, site preparation and grading during construction activities facilitated
by development under the proposed project may cause wind-blown dust that could contribute
particulate matter into the local atmosphere. The BAAQMD has not established a quantitative
threshold for fugitive dust emissions but rather states that projects that incorporate best
management practices (BMPs) for fugitive dust control during construction would have a less-
than-significant impact related to fugitive dust emissions. The BAAQMD has identified feasible
fugitive dust control measures for construction activities. These Basic Construction Mitigation
Measures are recommended for all projects (BAAQMD 2017a). In addition, the BAAQMD and
CARB have regulations that address the handling of hazardous air pollutants such as lead and
asbestos, which could be aerially disbursed during demolition activities. BAAQMD rules and
regulations address both the handling and transport of these contaminants. Mitigation
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Measure AIR-2a of the 2017 EIR would require future development to comply with the
BAAQMD Basic Construction Mitigation Measures to reduce fugitive dust emissions. However,
as discussed in the 2017 EIR, construction impacts would still remain significant and
unavoidable due to the programmatic nature of the project, similar to the 2030 Comprehensive
Plan as analyzed in the 2017 EIR. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
OPERATION
According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air
pollutants and precursors includes an assessment of the rate of increase of plan VMT versus
population growth. As discussed above under Environmental Setting, to result in a less than
significant impact, the analysis must show that the project’s projected VMT increase would be
less than or equal to its projected population increase. Table 11 under Checklist Question (a)
summarizes the net increase in population versus VMT based on VMT modeling performed by
Hexagon Transportation Consultants, Inc (Appendix A). Because the VMT associated with
project buildout would increase by approximately 23.2 percent over baseline 2015 conditions, it
would not exceed the rate of increase from the forecast population growth of approximately
24.1 percent over baseline 2015 conditions. VMT increases at a lower percentage because the
proposed project would concentrate increased residential units in proximity to jobs and
services to reduce singular vehicle trips and encourage alternative models of travel. The
resulting VMT per resident (9.13 VMT per resident) would be less than baseline 2015 conditions
(9.19 VMT per resident). Therefore, impacts concerning criteria pollutants generated from
operation of the project would be less than significant and would be generally the same as for
the 2030 Comprehensive Plan as analyzed in the 2017 EIR.
Future development would continue to be required to implement policies N-5.1, N-5.5, T-1.9,
and L-2.2 of the 2030 Comprehensive Plan, adopted in compliance with mitigation measures
AIR-2c and 2d of the 2017 EIR, which would require compliance with BAAQMD requirements
and support for alternative modes of transportation. However, as analyzed in the 2017 EIR,
Scenario 6 would cumulatively contribute to the nonattainment designations (ozone, PM10, and
PM2.5) of the Basin and would have a significant and unavoidable impact by contributing to the
regional air quality problem. Therefore, since the proposed HEU would increase the number of
residential units by 665 units compared to Scenario 6, operational impacts for the proposed
HEU would be slightly increased compared to those identified in the 2017 EIR and would remain
significant and unavoidable. However, similar to the 2017 EIR, development facilitated by the
proposed HEU would place residents in urbanized areas in proximity to services, jobs, and
transit, which would reduce VMT by reducing reliance on single-occupancy vehicles.
Additionally, the prohibition of natural gas and inclusion of all-electric new construction would
reduce the amount of criteria air pollutants, and the required inclusion of EVSE in new multi-
family dwelling units would also further reduce emissions due to increased vehicle efficiency.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
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c. Would the project result in a cumulatively considerable net increase of any criteria pollutant
for which the project region is non-attainment under an applicable federal or state ambient
air quality standard (including releasing emissions that exceed quantitative thresholds for
ozone precursors)?
CARBON MONOXIDE HOTSPOTS
As discussed above under BAAQMD Significance Thresholds, typical development projects, even
plan level growth, would not emit the levels of CO necessary to result in a localized hotspot.
Therefore, CO hotspots are not discussed further in this analysis. Impacts to CO hotspots would
be less than significant and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
TOXIC AIR CONTAMINANTS
CONSTRUCTION
Construction-related activities would result in short-term emissions of diesel particulate matter
(DPM) exhaust emissions from off-road, heavy-duty diesel equipment for site preparation (e.g.,
excavation, grading, and clearing), building construction, and other miscellaneous activities.
DPM was identified as a TAC by CARB in 1998. The potential cancer risk from the inhalation of
DPM, as discussed below, outweighs the potential non-cancer5 health impacts (CARB 2021).
Generation of DPM from construction typically occurs in a single area for a short period.
Construction of development facilitated by the project would occur over approximately a
decade, but use of diesel-powered construction equipment in any one area would likely occur
for no more than a few years for an individual project and would cease when construction is
completed in that area. It is impossible to quantify risk without identified specific project
details, timelines, and locations.
Projects developed under the proposed HEU would be required to comply with applicable
BAAQMD regulatory requirements and control strategies and the CARB In-Use Off-Road Diesel
Vehicle Regulation, which are intended to reduce emissions from construction equipment and
activities. Additionally, future development facilitated by the proposed HEU would be required
to comply with Mitigation Measure AQ-2a of the 2017 EIR, requiring implementation of
construction emission measures that would reduce construction-related TACs. According to the
OEHHA, construction of individual projects lasting longer than two months or placed within
1,000 feet of sensitive receptors could potentially expose nearby sensitive receptors to
substantial pollutant concentrations and therefore could result in potentially significant risk
impacts (OEHHA 2015). These projects could exceed BAAQMD’s thresholds of an increased
cancer risk of greater than 10.0 in a million and an increased non-cancer risk of greater than 1.0
Hazard Index (Chronic or Acute). Therefore, construction impacts from TAC emissions would be
5 Non-cancer risks include premature death, hospitalizations and emergency department visits for exacerbated chronic heart
and lung disease, including asthma, increased respiratory symptoms, and decreased lung function (CARB 2021a).
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potentially significant. However, future development would be required to comply with
Mitigation Measure AIR-3a of the 2017 EIR, which outlines requirements for the preparation of
health risk assessments (HRA) and the inclusion of best practices, as well as Policy N-5.6 of the
2030 Comprehensive Plan, adopted in compliance with Mitigation Measure AIR-3b of the 2017
EIR, which would ensure compliance with BAAQMD requirements. Therefore, this impact would
be less than significant with mitigation, and would be generally the same as for the 2030
Comprehensive Plan as analyzed in the 2017 EIR. There would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, and further analysis is not
warranted.
OPERATION
In the Bay Area, there are several urban or industrialized communities where the exposure to
TACs is relatively high in comparison to others. The City of Palo Alto is not located in an
impacted community according to BAAQMD CEQA Guidelines. Sources of TACs include, but are
not limited to, land uses such as freeways and high-volume roadways, truck distribution
centers, ports, rail yards, refineries, chrome plating facilities, dry cleaners using
perchloroethylene, and gasoline dispensing facilities (BAAQMD 2017a). Operation of
development facilitated by the project would not involve these uses, and therefore, would not
be considered a source of TACs. In addition, residences do not typically include new stationary
sources onsite, such as emergency diesel generators. However, if a residential project did
include a new stationary source onsite, it would be subject to BAAQMD Regulation 2, Rule 2
(New Source Review) and require permitting. This process would ensure that the stationary
source does not exceed applicable BAAQMD health risk thresholds. Development facilitated by
the project would be required to comply with the residential indoor air quality requirements in
the Title 24 Building Energy Efficiency Standards, which currently require Minimum Efficiency
Reporting Value 13 (or equivalent) filters for heating/cooling systems and ventilation systems in
residences (Section 150.0[m])). Therefore, this impact would be less than significant, and would
be generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
There would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, and further analysis is not warranted.
PROJECT SITING
Development facilitated by the project would occur under the jurisdiction of BAAQMD. CARB
screening methodology for project siting is used in this analysis. In 2005, CARB issued
recommendations to avoid siting new residences within 500 feet of a freeway, urban roads with
100,000 vehicles/day, or rural roads with 50,000 vehicles/day or close to known stationary TAC
sources (CARB 2005). BAAQMD’s average daily traffic (ADT) threshold is lower, at 10,000
vehicles per day (BAAQMD 2017a).
Development facilitated by the project could place sensitive receptors living in housing within
approximately 500 to 1,000 feet of roadways with more than 10,000 annual average daily
traffic (AADT), and highways or freeways. Examples of roadways with over 10,000 vehicles per
day include US 101, SR 82/El Camino Real, I-280, Middlefield Road, Alma Street, Foothill
Expressway/Junipero Serra Boulevard, University Avenue, Embarcadero Road, Oregon
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Expressway/Page Mill Road, Charleston Road/ Arastradero Road, and San Antonio Road. In
addition, portions of Lytton Avenue, Manhattan Avenue, Arboretum Road, Quarry Road,
Pasteur Drive, California Avenue, Fabian Way, and California Street are also identified as high-
volume roadways (City of Palo Alto 2017a). Additionally, development facilitated by the project
could also place sensitive receptors living in housing in proximity to stationary sources of TACs
such as dry cleaners and gasoline-dispensing facilities. The proposed project would facilitate
increased housing compared to the 2017 EIR which could potentially expose an increased
number of residents to sources of TACs and PM2.5. However, future development would be
required to comply with mitigation measures AIR-3c and 3d identified in the 2017 EIR, which
would require the preparation of HRAs for residential and sensitive land use projects or new
ministerial projects located within 1,000 feet of a major source of TAC. Therefore, this impact
would be less than significant with mitigation, generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because here would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
d. Would the project expose sensitive receptors to substantial pollutant concentrations?
During construction activities, heavy equipment and vehicles would emit odors associated with
vehicle and engine exhaust both during normal use and when idling. However, these odors
would be temporary and transitory and would cease upon completion. Therefore, development
facilitated by the project would not generate objectionable odors affecting a substantial
number of people.
BAAQMD includes odor screening distances for land uses with the potential to generate
substantial odor complaints. Those uses include wastewater treatment plants, landfills or
transfer stations, refineries, composting facilities, confined animal facilities, food
manufacturing, smelting plants, and chemical plants. The proposed HEU includes residential
uses which do not typically generate odors. The 2017 EIR included mitigation to address
impacts associated with placing new residential uses in proximity to odor sources. Although the
proposed project would increase the number of residential units compared to the 2017 EIR,
future development would be required to comply with Policy N-5.4 of the 2030 Comprehensive
Plan, adopted in compliance with Mitigation Measure AIR-4 of the 2017 EIR, which would
reduce the potential for residents to be exposed to odors through buffers and other mitigation
methods. Therefore, this impact would be less than significant with mitigation and would be
generally the same as for the 2030 Comprehensive Plan as analyzed in the 2017 EIR. Because
there would be no new or substantially more severe significant impacts than what was analyzed
in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2030 Comprehensive Plan, future development would continue to
implement Mitigation Measures 2a and 2b, 3a and 3c, as well as policies adopted in compliance
with Mitigation Measures AIR-2c and 2d, 3b, and 4, which would reduce air quality impacts to a
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less than significant level. However, similar to the 2017 EIR, the proposed project could
cumulatively contribute to the nonattainment designations (ozone, PM10, and PM2.5) of the
Basin and would have a significant and unavoidable impact by contributing to the regional air
quality problem. Therefore, the project would not result in new or substantially more severe
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted, but impacts would remain significant and unavoidable. This issue does not require
further study in an EIR.
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4 Biological Resources
Where was
Impact
Analyzed in the
EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Have a substantial
adverse effect, either
directly or through
habitat modifications, on
any species identified as
a candidate, sensitive, or
special status species in
local or regional plans,
policies, or regulations,
or by the California
Department of Fish and
Wildlife or U.S. Fish and
Wildlife Service?
EIR Pages 4.3-6
through 4.3-8
No No No Yes
b. Have a substantial
adverse effect on any
riparian habitat or other
sensitive natural
community identified in
local or regional plans,
policies, or regulations,
or by the California
Department of Fish and
Wildlife or U.S. Fish and
Wildlife Service?
EIR Pages 4.3-8
through 4.3-9
No No No N/A
c. Have a substantial
adverse effect on state
or federally protected
wetlands (including, but
not limited to, marsh,
vernal pool, coastal, etc.)
through direct removal,
filling, hydrological
interruption, or other
means?
EIR Pages 4.3-8
through 4.3-9
No No No N/A
d. Interfere substantially
with the movement of
any native resident or
migratory fish or wildlife
species or with
established native
resident or migratory
wildlife corridors, or
impede the use of native
wildlife nursery sites?
EIR Page 4.3-9 No No No Yes
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Where was
Impact
Analyzed in the
EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
e. Conflict with any local
policies or ordinances
protecting biological
resources, such as a tree
preservation policy or
ordinance?
EIR Pages 4.3-10
through 4.3-12
No No No Yes
f. Conflict with the
provisions of an adopted
Habitat Conservation
Plan, Natural Community
Conservation Plan, or
other approved local,
regional, or state habitat
conservation plan?
EIR Page 4.3-12
through 4.3-13;
4.9-15 through
4.9-16
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.3, Biological Resources, of the 2017 EIR found that the 2030 Comprehensive Plan
would not have a substantial adverse effect on special-status species; riparian habitats;
sensitive natural communities identified in local or regional plans, policies, or regulations;
federally protected wetlands; or the movement of any native resident or migratory fish or
wildlife species. Additionally, the 2030 Comprehensive Plan would not conflict with local
policies or ordinances protecting biological resources, such as a tree preservation policy, or an
adopted Habitat Conservation Plan or Natural Community Conservation Plan.
PROJECT-SPECIFIC IMPACTS
a. Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as candidate, sensitive, or special status in local or
regional plans, policies, or regulations, or by the California Department of Fish and Wildlife
or the U.S. Fish and Wildlife Service?
The proposed HEU would substantially affect special-status species if it would allow
development that would remove their habitat such as wetlands or riparian vegetation along
non-channelized creeks. Although the proposed HEU would facilitate 665 more residential units
compared to what was analyzed in the 2017 EIR, the proposed HEU would only increase
residential density on non-vacant and underutilized sites in urbanized areas of the city generally
away from open space preserves and non-channelized creeks and would not directly or
indirectly impact the habitat of special-status species. Additionally, implementation of the
proposed HEU would involve disturbance in the same areas as analyzed in the 2017 EIR
(citywide) and the citywide conditions have not substantially changed since the time of the EIR.
Therefore, this impact would be less than significant, and would be generally the same as the
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impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted .
b. Would the project have a substantial adverse effect on any riparian habitat or other
sensitive natural community identified in local or regional plans, policies, or regulations, or
by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
c. Would the project have a substantial adverse effect on federally protected wetlands as
defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal
pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Similar to what was analyzed in the 2017 EIR, the proposed HEU does not propose development
of open space areas, creeks, or wetlands that would result in impacts to these resources. The
proposed HEU would only increase density on non-vacant and underutilized sites in urbanized
areas of the city. Riparian resources are protected by the City’s tree preservation and
management regulations, the Urban Forest Master Plan, and California Fish and Game Code.
Future projects that affect the bed, bank, or channel of a creek or stream where riparian
vegetation is located would require authorization to do so. Wetlands are protected by the
federal Clean Water Act, and impacts to wetlands as a result of future development facilitated
by the proposed HEU would require a permit from the United States Army Corps of Engineers
(USACE) and the Regional Water Quality Control Board (RWQCB). In addition, implementation
of the proposed HEU would involve disturbance in the same areas as analyzed in the 2017 EIR
(citywide) and the citywide conditions have not substantially changed since the time of the EIR.
Therefore, although the proposed HEU would increase the number of residential units by 665
units compared to what was analyzed in the 2017 EIR, with compliance with existing federal,
State, and local regulations, impacts would be less than significant and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive. Because there would
be no new or substantially more severe impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
d. Would the project interfere substantially with the movement of any native resident or
migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
Although the proposed HEU would increase the number of residential units by 665 units
compared to what was analyzed in the 2017 EIR, it would facilitate development only on non-
vacant and underutilized sites in urbanized areas of the city and would not block or remove
wildlife corridors or interfere with fish or wildlife migration or rearing sites. The proposed HEU
does not envision development in open space areas or within the Baylands area of Palo Alto.
Future projects requiring discretionary approval and with the potential to affect wildlife
corridors in Palo Alto would be assessed and mitigated during project-specific review under the
California Environmental Quality Act (CEQA). In addition, future projects that impact creek bed,
bank, or channel would require authorization from federal and State agencies, including the
USACE, United States Fish and Wildlife Service (USFWS), National Oceanic and Atmospheric
Administration (NOAA) Fisheries, California Department of Fish and Wildlife (CDFW), and
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BIOLOGICAL RESOURCES
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RWQCB, as applicable (City of Palo Alto 2017a). Implementation of the proposed HEU would
also involve disturbance in the same areas as analyzed in the 2017 EIR (citywide) and the
citywide conditions have not substantially changed since the time of the EIR. Therefore, this
impact would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
e. Would the project conflict with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or as defined by the City of Palo Alto’s Tree
Preservation Ordinance (Municipal Code Section 8.10)?
Although the proposed HEU does not explicitly propose the removal of trees, development
facilitated under the proposed HEU could result in the removal of existing trees on private or
public properties. Although the proposed HEU would increase the number of residential units
by 665 units compared to buildout assumed in the 2017 EIR, future development would be
required to comply with the City’s Urban Forest Master Plan; Street Tree Management Plan;
Line Clearing Program; Right Tree, Right Place Program; Tree Protection Ordinance Update
adopted on June 6, 2022; and Chapter 8.10 of the PAMC which outlines requirements for tree
and landscape preservation and management. Therefore, this impact would be less than
significant and would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe impacts
than what was analyzed in the 2017 EIR, further analysis is not warranted.
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
As discussed in the 2017 EIR, although Palo Alto is not in the Santa Clara Valley Habitat
Conservation Plan (HCP)/Natural Community Conservation Plan (NCCP), lands in the Baylands
area of Palo Alto have been identified in the Santa Clara Valley HCP/NCCP as suitable mitigation
lands for impacts to the western burrowing owl caused by development in the Santa Clara
Valley HCP/NCCP Plan Area. Additionally, the Stanford HCP identifies four management zones
according to habitat value for Covered Species. However, the proposed HEU does not include
housing sites within the Baylands area of Palo Alto or within the Stanford HCP limits. The
proposed HEU would also facilitate development on non-vacant and underutilized sites in
urbanized areas where species are not present. Therefore, the proposed HEU would not conflict
with the Santa Clara Valley HCP/NCCP or the Stanford HCP. This impact would be less than
significant and would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
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CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to biological resources which would reduce
impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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5 Cultural Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Cause a substantial adverse
change in the significance
of a historical resource
pursuant to §15064.5?
EIR Pages
4.4-2 through
4.4-6
No No No Yes
b. Cause a substantial adverse
change in the significance
of an archaeological
resource pursuant to
§15064.5?
EIR Pages
4.4-7 through
4.4-9
No No No Yes
c. Disturb any human
remains, including those
interred outside of formal
cemeteries?
EIR Pages
4.4-9 through
4.4-10
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.4, Cultural Resources, of the 2017 EIR analyzes the 2030 Comprehensive Plan’s
impacts related to cultural resources. The 2017 EIR found that the 2030 Comprehensive Plan
could adversely affect a historic resource listed or eligible for listing on the National and/or
California Register, or listed on the City’s Historic Inventory, since the City’s historical resource
inventory is out of date, and the City’s ordinance does not explicitly prohibit demolition of
historic resources. Therefore, mitigation measure CULT-1 was required and was found to
reduce impacts to a less than significant level.
The 2017 EIR also found that the 2030 Comprehensive Plan could eliminate important examples
of major periods of California history or prehistory since it could result in the demolition or
modification of an historical resource; permittance of inappropriate new construction adjacent
to an historical resource; or result in the demolition, relocation, or alteration of an
archaeological or paleontological resource. Therefore, mitigation measure CULT-2 was required
and was found to reduce impacts to a less than significant level.
The 2017 EIR also found that buildout in accordance with the 2030 Comprehensive Plan could
cause damage to an important archaeological resource as defined in Section 15064.5 of the
CEQA Guidelines without mitigation to address unknown resources that could be uncovered.
Mitigation Measure CULT-3 was required and was found to reduce impacts to a less than
significant level.
The 2017 EIR found that the 2030 Comprehensive Plan would not disturb any human remains,
including those interred outside of formal cemeteries.
Table 12 lists the mitigation measures from the 2017 EIR related to cultural resources.
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Table 12 2017 EIR Mitigation Measures: Cultural Resources
Mitigation
Measure # Mitigation Text
Impact CULT-1: Implementation of the proposed Plan could adversely affect a historic resource listed or eligible for listing
on the National and/or California Register, or listed on the City’s Historic Inventory. (Significant and Mitigable)
CULT-1 To ensure the protection of historic resources listed on the National and/or California Register or the
City’s Historic Resource Inventory, the proposed Plan shall include policies that address the following
topics:
The effectiveness of the Historic Preservation Ordinance in preserving historic resources. Periodic
updates to and maintenance of the City’s Historic Resource Inventory.
Process for including potential historic resources in the City’s Historic Resources Inventory.
Protection of archaeological resources.
Impact CULT-2: Implementation of the proposed Plan could eliminate important examples of major periods of California
history or prehistory. (Significant and Mitigable)
CULT-2 Implement Mitigation Measure CULT-1.
Impact CULT-3: Implementation of the proposed Plan could cause damage to an important archaeological resource as
defined in Section 15064.5 of the CEQA Guidelines. (Significant and Mitigable)
CULT-3 Implement Mitigation Measure CULT-1. In addition, to ensure that future development would not
damage archaeological resources, the proposed Plan shall include policies that address the following
topics:
Archaeological surveys and mitigation plans for future development projects.
Developer compliance with applicable regulations regarding the identification and protection of
archaeological and paleontological deposits.
Adequate tribal consultation and consideration of tribal concerns.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project cause a substantial adverse change in the significance of a historical
resource pursuant to §15064.5?
As discussed in the 2017 EIR, there are over 850 structures/sites in Palo Alto that are identified
as historical resources, including four districts (Green Gables, Greenmeadow Units 1 and 2,
Professorville, and Ramona Street). The proposed HEU includes sites in the Professorville
district and the Ramona Street District, as well as along University Avenue, a historic
thoroughfare as described in the 2017 EIR. However, disturbance would occur in the same
areas as analyzed in the 2017 EIR (citywide) and the citywide conditions have not substantially
changed since the time of the EIR. The proposed HEU does not propose any specific
development. It envisions development including the proposed rezoning of sites for the
potential development of additional housing units to meet the City’s RHNA needs on parcels
that may contain buildings that meet the age threshold for potential historical resources
pursuant to CEQA. Development on these parcels could be proposed by a property owner or
project applicant with or without the City’s adoption of the HEU; still, development associated
with the proposed HEU, similar to development under the 2030 Comprehensive Plan on the
same sites, could result in the material impairment of historical resources, which CEQA
Guidelines Section 15064.5(b)(2)(A) defines as the demolition or alteration in an adverse
manner of those characteristics of a historical resource that convey its historical significance
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and that justify its inclusion in, or eligibility for inclusion in, the CRHR or a local register. Future
development requiring discretionary approval would be subject to separate project-level CEQA
review in order to identify potential impacts to a specific historical resource and incorporate
mitigation measures as needed, including City Council consideration of the potential benefits of
the proposed project and potential significant, unavoidable impacts. Modifications to Inventory
resources Downtown and in Professorville historic districts would be subject to PAMC Chapter
16.49. Future development would also be required to implement policies L-7.1 and L-7.15 of
the 2030 Comprehensive Plan EIR, adopted in compliance with Mitigation Measure CULT-1 of
the 2017 EIR, which would ensure the protection of historic resources listed on the National
and/or California Register or the City’s Historic Resource Inventory, as well as applicable
federal, State, and local laws. Therefore, impacts would be less than significant with mitigation,
and would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, and further analysis is not warranted.
b. Would the project cause a substantial adverse change in the significance of an
archaeological resource pursuant to §15064.5?
Similar to what was assumed in the 2017 EIR, although development under the proposed HEU
would occur on non-vacant and underutilized sites in previously disturbed areas, ground-
disturbing activities such as earthmoving and excavation could still potentially damage and/or
destroy unrecorded archaeological resources in subsurface soils within the housing sites.
Implementation of the proposed HEU would involve disturbance in the same areas as analyzed
in the 2017 EIR (citywide) and the citywide conditions have not substantially changed since the
time of the EIR. Further, future development requiring discretionary approval would be subject
to separate project-level CEQA review in order to identify potential impacts to archaeological
resources and incorporate mitigation measures as needed. Future development would also be
required to implement policies L-7.16 through 7.18 of the 2030 Comprehensive Plan EIR,
adopted in compliance with Mitigation Measure CULT-3 of the 2017 EIR, which would ensure
the protection of archaeological, paleontological, and tribal cultural resources. Therefore,
impacts would be less than significant with mitigation, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
c. Would the project disturb any human remains, including those interred outside of formal
cemeteries?
Similar to what was assumed in the 2017 EIR, although development under the proposed HEU
would occur on non-vacant and underutilized sites in previously disturbed areas, ground-
disturbing activities such as earthmoving and excavation could still potentially disturb human
remains. However, implementation of the proposed HEU would involve disturbance in the
same areas as analyzed in the 2017 EIR (citywide) and the citywide conditions have not
substantially changed since the time of the EIR. Future development would be subject to
federal and State regulations, such as the California Health and Safety Code Section 7050.5,
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Public Resources Code Section 5097.98, and the California Code of Regulations Section
15064.5(e) (CEQA), which state the mandated procedures of conduct following the discovery of
human remains. Therefore, compliance with the mandatory regulatory procedures would
ensure that potential impacts related to the potential discovery or disturbance of any human
remains accidentally unearthed during construction activities would be less than significant and
would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, development would occur in the same areas as those
analyzed in the 2017 EIR. Further, future development would be required to comply with
federal, State, and local regulations pertaining to cultural resources as well as policies adopted
in compliance with Mitigation Measures CULT-1 and CULT-3 from the 2017 EIR, which would
reduce impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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6 Energy
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New or
Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Result in a potentially
significant
environmental impact
due to wasteful,
inefficient, or
unnecessary
consumption of energy
resources, during
project construction or
operation?
EIR Pages
4.14-33
through
4.14-38
No No No N/A
b. Conflict with or obstruct
a state or local plan for
renewable energy or
energy efficiency?
EIR Pages
4.14-33
through
4.14-38
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.14, Utilities and Service Systems, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to energy. At the time the 2017 EIR was prepared, there were no
separate adopted thresholds for energy use under CEQA, although Guidelines Section 15126.4
required that an “EIR shall describe feasible mitigation measures which could minimize
significant adverse impacts, including where relevant, inefficient and unnecessary consumption
of energy,” and Appendix F provided criteria for consideration of energy conservation.
Checklist questions (a) and (b) in this section are now included in CEQA Guidelines Appendix G.
Lead agencies that use Appendix G as a basis for environmental analysis, including the City of
Palo Alto, now consider energy impacts more explicitly during the initial study of a project.
Changes to the CEQA thresholds subsequent to certification of an EIR do not in themselves
constitute a substantial change or new information of substantial importance that requires
major revisions to the EIR unless new significant impacts or a substantial increase in the
severity of a significant impact would occur.
The 2017 EIR concluded that the 2030 Comprehensive Plan would not substantially increase
electrical or natural gas demands to the extent that new local electrical and natural gas supply
facilities would be required. Additionally, future development would be required to comply
with the California Building Standards Code, Chapters 16.14 and 16.17 of the PAMC, and utilize
modern appliances and equipment, in accordance with the 2012 Appliance Efficiency
Regulations, which would conserve energy. Nonetheless, mitigation measure UTIL-17 would be
required to reduce impacts to a less than significant level.
Table 13 lists the mitigation measures from the 2017 EIR related to energy.
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Table 13 2017 EIR Mitigation Measures: Energy
Mitigation
Measure # Mitigation Text
Impact UTIL-17: The proposed Plan would not result in a substantial increase in natural gas and electrical service demands
that would require the new construction of energy supply facilities and distribution infrastructure or capacity enhancing
alterations to existing facilities. However, without the adoption of policies in support of energy efficiency and
conservation, the proposed Plan would result in a potentially significant impact, requiring mitigation. (Potentially
Significant and Mitigable)
UTIL-17 To ensure that future development would maximize energy efficiency and conservation the proposed
Plan shall include policies that address the following topics:
Maximized conservation and efficient use of energy.
Continued procurement of carbon-neutral energy.
Investment in cost-effective energy efficiency and energy conservation programs.
Provision of public education programs addressing energy conservation and efficiency.
Use of cost-effective energy conservation measures in City projects and practices.
Adherence to State and federal energy efficiency standards and policies.
Consideration of a transition to a carbon-neutral natural gas supply.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACT ANALYSIS
a. Would the project result in a potentially significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
Energy consumption is directly related to environmental quality in that the consumption of
nonrenewable energy resources releases criteria air pollutant and GHG emissions into the
atmosphere. The environmental impacts of air pollutant and GHG emissions associated with the
project’s energy consumption are discussed in detail in Section 3, Air Quality, and Section 8,
Greenhouse Gas Emissions, respectively.
Palo Alto demonstrates its commitment to energy efficiency and renewable energy via
implementation of CALGreen and State-mandated Energy Efficiency Requirements for new
development and retrofits. The proposed HEU would facilitate development of projects to
encourage housing on non-vacant and underutilized sites in urbanized areas. When proposed,
individual projects would be required, pursuant to the requirements of CALGreen, to comply
with the zero-net energy requirements, where new development combines energy efficiency
and renewable energy generation to consume only as much energy as can be produced on-site
through renewable resources over a specified period. However, development under the
proposed HEU would consume energy during construction and operation, using petroleum fuel,
natural gas, and electricity, as discussed below.
CONSTRUCTION
Energy use during construction associated with future development under the proposed HEU
would be in the form of fuel consumption (e.g., gasoline and diesel fuel) to operate heavy
equipment, light-duty vehicles, machinery, and generators for lighting. Temporary grid power
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may also be provided to construction trailers or electric construction equipment. Energy use
during the construction of individual projects would be temporary in nature, and equipment
used would be typical of construction projects in the region. Construction contractors would be
required to demonstrate compliance with applicable CARB regulations that restrict the idling of
heavy-duty diesel motor vehicles and govern the accelerated retrofitting, repowering, or
replacement of heavy-duty diesel on- and off-road equipment. Construction activities
associated with reasonably foreseeable development under the proposed HEU would be
required to utilize fuel-efficient equipment consistent with federal and State regulations and
would comply with State measures to reduce the inefficient, wasteful, or unnecessary
consumption of energy. In addition, individual projects would be required to comply with
construction waste management practices to divert at least 80 percent of construction and
demolition debris pursuant to PAMC Section 16.14.260. These practices would result in efficient
use of energy during construction of future development under the proposed HEU.
Furthermore, in the interest of both environmental awareness and cost efficiency, construction
contractors would not utilize fuel in a manner that is wasteful or unnecessary. Therefore, future
construction activities associated with development under the proposed HEU would not result
in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary
consumption of energy, and impacts would be less than significant.
OPERATIONAL
Long-term operation of future development under the proposed HEU would require permanent
grid connections for electricity to power internal and exterior building lighting, and heating and
cooling systems. Electricity in Palo Alto is supplied by the City of Palo Alto Utilities (CPAU). As
discussed in the 2017 EIR, forecasting and planning by the CPAU will be able to accommodate
expected net annual average increase in electrical service demand of less than one percent with
the implementation of policies N-7.1 and N-7.4 of the 2030 Comprehensive Plan EIR, adopted in
compliance with Mitigation Measure UTIL-17. Although the proposed HEU would facilitate the
development of 665 more residential units, CPAU’s 10-year electric savings increased from 4.8
percent between 2014 and 2023 to 5.7 percent between 2018 and 2027 showing increased
energy efficiency. Additionally, future development would be required to comply with the City’s
most updated Reach Code and All-Electric Mandate which requires all-electric building design
for single-family, low-rise multi-family, and non-residential development (City of Palo Alto
2022a). This would increase demand for electricity but would decrease demand for natural gas.
Electricity provided by CPAU is 100 percent carbon neutral (City of Palo Alto 2022b).
Development facilitated by the proposed HEU would be subject to the energy conservation
requirements of the California Energy Code (Title 24, Part 6 of the California Code of
Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential
Buildings), the California Green Building Standards Code (CALGreen, Title 24, Part 11 of the
California Code of Regulations). The California Energy Code provides energy conservation
standards for all new and renovated commercial and residential buildings constructed in
California. This code applies to the building envelope, space-conditioning systems, and water-
heating and lighting systems of buildings and appliances and provides guidance on construction
techniques to maximize energy conservation. Minimum efficiency standards are given for a
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variety of building elements, including appliances; water and space heating and cooling
equipment; and insulation for doors, pipes, walls, and ceilings. The code emphasizes saving
energy at peak periods and seasons and improving the quality of installation of energy
efficiency measures. Furthermore, future development would be required to comply with the
PAMC Chapter 16.17, which mandates the implementation of the Building Energy Efficiency
Standards (California Code of Regulations, Title 24, Part 6). Compliance would include
complying with the most updated rooftop solar requirements at the time of construction.
CALGreen sets targets for energy efficiency, water consumption, dual plumbing systems for
potable and recyclable water, diversion of construction waste from landfills, and use of
environmentally sensitive materials in construction and design, including ecofriendly flooring,
carpeting, paint, coatings, thermal insulation, and acoustical wall and ceiling panels. These
standards for new buildings are designed for energy efficient performance, using clean
electricity, so that the buildings do not result in wasteful, inefficient, or unnecessary
consumption of energy.
The housing inventory sites are located within the city’s urbanized and underutilized sites.
These areas are near or adjacent to transportation corridors as well as Class I, II, and III bicycle
lanes, which would reduce trip distances and encourage the use of alternative modes of
transportation such as bicycling and walking, thereby reducing fuel consumption. These factors
would minimize the potential of the proposed project to result in the wasteful or unnecessary
consumption of vehicle fuels.
Future development would also be required to continue to implement policies N-7.1 and N-7.4
of the 2030 Comprehensive Plan EIR, adopted in compliance with Mitigation Measure UTIL-17
to reduce energy impacts to a less than significant level. As a result, operation of development
projects under the proposed HEU would not result in potentially significant environmental
effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts
would be less than significant with mitigation, and generally the same as the impact analyzed in
the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy
efficiency?
Several State plans as well as the City’s adopted 2030 Comprehensive Plan include energy
conservation and energy efficiency strategies intended to enable the State and the city to
achieve GHG reduction and energy conservation goals. A full discussion of the proposed
project’s consistency with GHG reduction plans is included in Section 8, Greenhouse Gas
Emissions. As shown in Table 14, the project would be consistent with applicable State
renewable energy and energy efficiency plans.
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Table 14 Consistency with State Renewable Energy and Energy Efficiency Plans
Renewable Energy or Energy Efficiency Plan Proposed Project Consistency
Assembly Bill 2076: Reducing Dependence on
Petroleum. Pursuant to AB 2076, the CEC and CARB
prepared and adopted a joint-agency report, Reducing
California’s Petroleum Dependence, in 2003. Included
in this report are recommendations to increase the use
of alternative fuels to 20 percent of on-road
transportation fuel use by 2020 and 30 percent by
2030, significantly increase the efficiency of motor
vehicles, and reduce per capita VMT. One of the
performance-based goals of AB 2076 is to reduce
petroleum demand to 15 percent below 2003 demand.
Consistent. Many of the proposed housing inventory sites located
in areas served by transit, are in proximity to jobs and services, or
are near or adjacent to corridors currently served by Class I, II,
and III bicycle lanes such as University Avenue, Bryant Street,
California Avenue, and Bayshore Road. This which would
encourage the use of alternative modes of transportation such as
walking, transit, and bicycling, thereby reducing VMT and
reducing reliance on single-occupancy vehicles. Further, future
development under the proposed HEU would be subject to the
requirements of the most recent iteration of CALGreen and
locally adopted amendments, which include provisions for
electric vehicle charging infrastructure, reducing dependence on
gasoline powered vehicles.
2019 Integrated Energy Policy Report. The 2019 report
highlights the implementation of California’s innovative
policies and the role they have played in establishing a
clean energy economy, as well as provides more detail
on several key energy policies, including decarbonizing
buildings, increasing energy efficiency savings, and
integrating more renewable energy into the electricity
system.
Consistent. Development facilitated by the project would be
required to comply with PAMC Chapter 16.17, which mandates
the implementation of Title 24. Compliance would include
complying with the most updated rooftop solar requirements at
the time of construction. Future development would also be
required to comply with the City’s most updated Reach Code and
All-Electric Mandate which requires all-electric building design for
single-family, low-rise multi-family, and non-residential
development (City of Palo Alto 2022a). Electricity would be
provided by CPAU, which has provided 100 percent carbon
neutral electricity since 2013 (City of Palo Alto 2022b).
California Renewable Portfolio Standard. California’s
RPS obligates investor-owned utilities, energy service
providers, and community choice aggregators to
procure 33 percent total retail sales of electricity from
renewable energy sources by 2020, 60 percent by 2030,
and 100 percent by 2045.
Consistent. Electricity for future development would be provided
by CPAU which has provided 100 percent carbon neutral
electricity since 2013 (City of Palo Alto 2022b).
Energy Action Plan. In the October 2005, the CEC and
CPUC updated their energy policy vision by adding
some important dimensions to the policy areas
included in the original EAP, such as the emerging
importance of climate change, transportation-related
energy issues, and research and development activities.
The CEC adopted an update to the EAP II in February
2008 that supplements the earlier EAPs and examines
the State’s ongoing actions in the context of global
climate change. The nine major action areas in the EAP
include energy efficiency, demand response, renewable
energy, electricity adequacy/reliability/infrastructure,
electricity market structure, natural gas
supply/demand/infrastructure, transportation fuels
supply/demand/infrastructure,
research/development/demonstration, and climate
change.
Consistent. Future development facilitated by the proposed
project would be required to be constructed in accordance with
the latest iteration of CALGreen, the California Energy Code, and
any locally adopted amendments, which include requirements for
the use of energy-efficient design and technologies as well as
provisions for incorporating renewable energy resources into
building design. Electricity for future development would be
provided by CPAU which has provided 100 percent carbon neutral
electricity since 2013 (City of Palo Alto 2022b). Given these
features, the project would facilitate implementation of the nine
major action areas in the EAP.
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Renewable Energy or Energy Efficiency Plan Proposed Project Consistency
AB 1007: State Alternative Fuels Plans. The State
Alternative Fuels Plan assessed various alternative fuels
and developed fuel portfolios to meet California’s goals
to reduce petroleum consumption, increase alternative
fuels use, reduce GHG emissions, and increase in-State
production of biofuels without causing a significant
degradation of public health and environmental quality.
Bioenergy Action Plan, EO S-06-06. The EO establishes
the following targets to increase the production and
use of bioenergy, including ethanol and biodiesel fuels
made from renewable resources: produce a minimum
of 20 percent of its biofuels in California by 2010, 40
percent by 2020, and 75 percent by 2050.
Consistent. The project would not interfere with or obstruct the
production of biofuels in California. Vehicles used by future
residents would be fueled by gasoline and diesel fuels blended
with ethanol and biodiesel fuels as required by CARB regulations.
Pursuant to Section 16.14.420 of the PAMC, new multi-family
residences would be required to provide at least one EVSE Ready
outlet or EVSE installed for each residential unit in the structure
for residential parking, and would be required to provide Conduit
Only, EVSE Ready Outlet, or EVSE installed for at least 25 percent
of guest parking spaces, among which at least 5 percent shall be
EVSE installed. Future development facilitated by the project
would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at the
time of construction.
Title 24, CCR – Part 6 (Building Energy Efficiency
Standards) and Part 11 (CALGreen). The 2019 Building
Energy Efficiency Standards move toward cutting
energy use in new homes by more than 50 percent and
will require installation of solar photovoltaic systems
for single-family homes and multi-family buildings of
three stories and less. The CALGreen Standards
establish green building criteria for residential and
nonresidential projects. The 2019 Standards include the
following: increasing the number of parking spaces that
must be prewired for electric vehicle chargers in
residential development; requiring all residential
development to adhere to the Model Water Efficient
Landscape Ordinance; and requiring more appropriate
sizing of HVAC ducts.
Consistent. Development facilitated by the project would be
required to comply with PAMC Chapter 16.17, which mandates
the implementation of Title 24.
Furthermore, the City’s 2030 Comprehensive Plan and Sustainability and Climate Action Plan
(S/CAP) also contains goals and policies related to energy efficiency and renewable energy. As
discussed under Table 18 in Section 8, Greenhouse Gas Emissions, the proposed project would
be consistent with recommended goals, policies, and actions in the City’s S/CAP related to
energy efficiency and renewable energy. Table 15 summarizes the project’s consistency with
the applicable 2030 Comprehensive Plan policies. As shown therein, the proposed project
would be consistent with the applicable 2030 Comprehensive Plan policies and therefore would
not conflict with or obstruct a State or local plan for renewable energy or energy efficiency, and
impacts would be less than significant and generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
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Table 15 Project Consistency with Applicable 2030 Comprehensive Plan policies
Policies Project Consistency
Natural Environment Element
Policy N-7.4: Maximize the conservation and
efficient use of energy in new and existing
residences and other buildings in Palo Alto.
Consistent: Future development facilitated by the proposed HEU would
be required to be constructed in accordance with the latest iteration of
CALGreen, the California Energy Code, and any locally adopted
amendments, which include green building practices. Future
development would also be required to comply with the City’s most
updated Reach Code and All-Electric Mandate which requires all-electric
building design for single-family, low-rise multi-family, and non-
residential development (City of Palo Alto 2022a).
Policy N-7.5: Encourage energy efficient lighting
that protects dark skies and promotes energy
conservation by minimizing light and glare from
development while ensuring public health and
safety
Consistent: Future development facilitated by the proposed HEU would
be required to incorporate sustainability considerations into project
design such as energy efficient lighting pursuant to PAMC Section
18.24.100(a). Future development would also be subject to PAMC
Section 18.40.250 which outlines requirements for minimizing light
spillover and glare.
Policy N-7.6: Support the maximum economic
use of solar electric (photovoltaic) and solar
thermal energy, both as renewable supply
resources for the Electric Utility Portfolio and as
alternative forms of local power generation.
Consistent: Development facilitated by the proposed HEU would be
required to comply with the PAMC Chapter 16.17, which mandates the
implementation of Title 24. Compliance would include complying with
the most updated rooftop solar requirements at the time of
construction.
Policy N-7.7: Explore a variety of cost-effective
ways to reduce natural gas usage in existing and
new buildings in Palo Alto in order to reduce
associated greenhouse gas emissions.
Consistent: Future development facilitated by the proposed HEU would
also be required to comply with the City’s most updated Reach Code and
All-Electric Mandate which requires all-electric building design for single-
family, low-rise multi-family, and non-residential development (City of
Palo Alto 2022a). Electricity would be provided by City of Palo Alto
Utilities (CPAU), which has provided 100 percent carbon neutral
electricity since 2013 (City of Palo Alto 2022b).
Policy N-7.8: Support opportunities to maximize
energy recovery from organic materials such as
food scraps, yard trimmings and residual solids
from sewage treatment.
Consistent: Future development facilitated by the proposed HEU would
be required to comply with SB 1383 and recycle organic wastes.
Source: City of Palo Alto 2017b
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations as well as policies adopted in compliance with Mitigation
Measure UTIL-17 pertaining to energy, which would reduce impacts to a less than significant
level. Therefore, the project would not result in new significant effects not addressed in the
prior EIR, and no new mitigation measures are warranted. This issue does not require further
study in an EIR.
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7 Geology and Soils
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New or
Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Directly or indirectly cause
potential substantial
adverse effects, including
the risk of loss, injury, or
death involving:
1. Rupture of a known
earthquake fault, as
delineated on the most
recent Alquist-Priolo
Earthquake Fault
Zoning Map issued by
the State Geologist for
the area or based on
other substantial
evidence of a known
fault?
EIR Pages 4.5-4
through 4.5-6
No No No N/A
2. Strong seismic ground
shaking?
EIR Pages 4.5-4
through 4.5-6
No No No N/A
3. Seismic-related ground
failure, including
liquefaction?
EIR Pages 4.5-4
through 4.5-6
No No No N/A
4. Landslides? EIR Pages 4.5-4
through 4.5-6
No No No N/A
b. Result in substantial soil
erosion or the loss of
topsoil?
EIR Pages 4.5-8
through 4.5-9
No No No Yes
c. Be located on a geologic
unit or soil that is made
unstable as a result of the
project, and potentially
result in on or offsite
landslide, lateral
spreading, subsidence,
liquefaction, or collapse?
EIR Pages 4.5-7
through 4.5-8
No No No N/A
d. Be located on expansive
soil, as defined in Table
18-1-B of the Uniform
Building Code (1994),
creating substantial risks
to life or property?
EIR Pages 4.5-4
through 4.5-6
No No No Yes
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Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New or
Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
e. Have soils incapable of
adequately supporting the
use of septic tanks or
alternative wastewater
disposal systems where
sewers are not available
for the disposal of
wastewater?
N/A No No No N/A
f. Directly or indirectly
destroy a unique
paleontological resource
or site or unique geologic
feature?
EIR Pages 4.4-7
through 4.4-9
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.5, Geology, Soils, and Seismicity, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to geology and soils. The 2017 EIR found that implementation of the
2030 Comprehensive Plan would result in less than significant impacts associated with risk of
loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground
shaking, seismic-related ground failure (including liquefaction), landslides, and expansive soils.
The 2017 EIR also found that implementation of the 2030 Comprehensive Plan would not result
in development located on a geologic unit or on soil that is unstable, or that would become
unstable as a result of the project and potentially result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction, or collapse. The 2030 Comprehensive Plan also determined
that there would be less than significant impacts related to erosion or siltation.
PROJECT-SPECIFIC IMPACTS
a1. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other substantial evidence of a known fault?
The Alquist-Priolo Earthquake Fault Zone associated with the San Andreas Fault is located near
the crest of the Santa Cruz Mountains and just east of the intersection of Page Mill Road and
State Route 35. Similar to what was analyzed in the 2017 EIR, no housing inventory sites are
located near the Alquist-Priolo Earthquake Fault Zone associated with the San Andreas Fault
(City of Palo Alto 2016). The closest active fault is the San Andreas Fault, located approximately
2.5 miles from the southern portion of the city. As a result, the likelihood of surface rupture
occurring from active faulting that would affect future development under the proposed HEU is
remote. This impact would be less than significant and would be generally the same as the
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impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
a2. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving strong seismic ground shaking?
As with any site in the Bay Area region, development under the proposed HEU is susceptible to
strong seismic ground shaking in the event of a major earthquake. Nearby faults include the San
Andreas Fault, the Monte Vista Fault, the Hayward Fault and the Calaveras Fault. These faults
are capable of producing strong seismic ground shaking in the city.
Although nothing can ensure that residences and infrastructure do not fail under seismic stress,
proper engineering can minimize the risk to life and property. Accordingly, building standards
have been developed for construction in areas subject to seismic ground-shaking. Development
facilitated by the proposed HEU would be required to comply with standards established by
PAMC Chapter 16.04 and 16.06, which adopt the California Building Code (CBC) and the
California Residential Code, respectively. The requirements of the California Building Code
ensure that new habitable structures are engineered to withstand the expected ground
acceleration at a given location. Further, CBC Chapter 18 requires that actions recommended in
a site-specific soil investigation are incorporated into the construction of each structure. Future
development would also be required to comply with PAMC Section 16.28.150, which would
require detailed engineering geology reports in areas of suspected geological hazards and
implementation of recommendations and mitigations to reduce hazards from ground shaking
or rupture. Additionally, the project would promote infill development, which may involve
replacing older buildings subject to seismic damage with newer structures built to current
seismic standards that could better withstand the adverse effects of strong ground shaking.
Although the proposed HEU would facilitate development of 665 more housing units compared
to what was analyzed in the 2017 EIR, continued compliance with applicable provisions of the
CBC and the PAMC would ensure that potential impacts from ground-shaking would be
minimized. This impact would be less than significant and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
a3. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving seismic-related ground failure, including
liquefaction?
As shown in Map S-3 of the Safety Element of the 2030 Comprehensive Plan, the northern and
eastern portion of the city lies within a high-liquefaction zone. Although the proposed HEU
would facilitate some development in a high-liquefaction zone adjacent to US 101, future
development would be required to comply with requirements of the CBC pursuant to PAMC
Chapter 16.04, as well as requirements for soils engineering reports and engineering geology
reports pursuant to PAMC Sections 16.28.140 and 16.28.150. Additionally, PAMC Section
18.40.120 imposes requirements in areas that have been identified as having moderate or high
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risk due to seismic activity hazards, including liquefaction, and requires the preparation of
detailed geologic, soils, and engineering studies prior to development. Such reports typically
include recommendations for project design and construction, such as site grading/soil
preparation, and foundation design, as well as quantitative evaluations of liquefaction
susceptibility. The final grading, drainage, and foundation plans are reviewed before
construction to confirm incorporation of the report recommendations. Although the proposed
HEU would facilitate development of 665 more housing units compared to what was analyzed
in the 2017 EIR, continued compliance with all applicable provisions of the California Building
Code and the PAMC would minimize impacts associated with liquefaction to a less than
significant level and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
a4. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving landslides?
c. Would the project be located on a geologic unit or soil that is unstable, or that would
become unstable as a result of the project, and potentially result in on- or off-site landslide,
lateral spreading, subsidence, liquefaction, or collapse?
Earthquakes can trigger landslides that may cause injuries and structural damage. Landslides
are typically a hazard on or near slopes or hillside areas, rather than generally level areas where
HEU housing development is anticipated. The 2017 EIR characterizes most of Palo Alto as
having low topographic relief where the probability of landslides is very low, with the exception
of hilly slopes west of Interstate 280. Similar to what was analyzed in the 2017 EIR, no
development would be facilitated in landslide zones within the city. Furthermore, future
development would be required to comply with PAMC Sections 16.28.140 and 16.28.150, which
outline requirements for soils engineering reports and engineering geology reports, as well as
PAMC Section 18.40.120, which imposes requirements in areas that have been identified as
having moderate or high risk due to seismic activity hazards. Although the proposed HEU would
facilitate development of 665 more housing units compared to what was analyzed in the 2017
EIR, continued compliance with all applicable provisions of the California Building Code and the
PAMC would ensure that potential impacts from landslides would be minimized to a less than
significant level and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
b. Would the project result in substantial soil erosion or the loss of topsoil?
The proposed HEU would include infill development in non-vacant and underutilized sites in
urbanized areas. Demolition and construction activities would be required to comply with CBC,
Appendix Section J110, Erosion Control Standards, pursuant to Chapter 16.04 of the PAMC,
which ensures appropriate erosion and stormwater pollution control during grading and
construction activities.
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Construction activities that occur on more than one acre are required to obtain a National
Pollutant Discharge Elimination System (NPDES) Construction General Permit. NPDES requires
the development of a storm water pollution prevention plan (SWPPP), which includes BMPs to
reduce erosion and topsoil loss from stormwater runoff. BMP examples generally include an
effective combination of erosion and sediment controls, which include barriers such as silt
fences, hay bales, drain inlet protection, or gravel bags.
Future development would also be required to comply with PAMC Chapter 16.28, which
outlines requirements for grading and erosion and sediment control. Examples include
preparation of an interim and a final erosion and sediment control and SWPPP, as well as soils
engineering reports, which would prevent excessive erosion and runoff. Although the proposed
HEU would facilitate development of 665 more housing units compared to what was analyzed
in the 2017 EIR, continued compliance with all applicable federal, State, and local regulations
and the PAMC would ensure that potential impacts from soil erosion would be minimized. This
impact would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform
Building Code (1994), creating substantial direct or indirect risks to life or property?
As discussed in the 2017 EIR, shrink-swell potential in the western and central parts of the city
are generally lower than the northeastern parts, where clay-rich soils and “Bay Mud” sediments
are widespread (City of Palo Alto 2016). The proposed HEU would facilitate some housing
development in the northeastern part of the city, and therefore could potentially locate
housing inventory sites on areas with expansive soils. However, future development would be
required to comply with PAMC Sections 16.28.140 and 16.28.150, which outline requirements
for soils engineering reports and engineering geology reports, as well as PAMC Section
18.40.120, which imposes requirements in areas that have been identified as having moderate
or high risk due to seismic activity hazards. The CBC also includes requirements to address soil-
related hazards. Typical measures to treat hazardous soil conditions involve removal of soil or
fill materials, proper fill selection, and compaction. In cases where soil remediation is not
feasible, the CBC requires structural reinforcement of foundations to resist the forces of
expansive soils. This would ensure that the potential for projects to occur on expansive soils
such that substantial direct or indirect risks to life or property to occur would be reduced.
Although the proposed HEU would facilitate development of 665 more housing units compared
to buildout analyzed in the 2017 EIR, continued compliance with all applicable provisions of the
California Building Code and the PAMC would ensure that potential impacts from soil erosion
would be minimized. This impact would be less than significant and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
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e. Would the project have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
Palo Alto is served by the City’s established wastewater system. The proposed HEU would
facilitate development on non-vacant and underutilized sites which are and would continue to
be served by the City’s wastewater system. The project would not include the use of septic
tanks or alternative wastewater disposal systems. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
f. Would the project directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature?
As discussed in the Geological Setting above, there are known paleontological resource sites
within the city, and the presence of these sites indicates that there are likely undiscovered
paleontological resources. Although the proposed HEU would facilitate development on non-
vacant and already disturbed sites, similar to what was analyzed in the Comprehensive Plan EIR,
development facilitated by the proposed HEU could still potentially impact a unique
paleontological resource or site, or unique geologic feature. However, future development
would be required to comply with applicable federal and State regulations that protect
paleontological resources, as well as implement Mitigation Measure CULT-5 which would
reduce impacts on paleontological resources to a less than significant level. Therefore, this
impact would be less than significant with mitigation, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to geological resources which would reduce
impacts to a less than significant level. Future development would also be required to comply
with applicable federal and State regulations that protect paleontological resources, as well as
implement Mitigation Measure CULT-5 which would reduce impacts on paleontological
resources to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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8 Greenhouse Gas Emissions
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Generate greenhouse
gas emissions, either
directly or indirectly,
that may have a
significant impact on
the environment?
EIR Pages 4.6-10
through 4.6-16
No No No N/A
b. Conflict with any
applicable plan, policy,
or regulation adopted
for the purposes of
reducing the emissions
of greenhouse gases?
EIR Pages 4.6-16
through 4.6-21
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.6, Greenhouse Gas Emissions and Climate Change, of the 2017 EIR analyzed the 2030
Comprehensive Plan’s impacts related to greenhouse gas emissions. The 2017 EIR concluded
that the 2030 Comprehensive Plan would not directly or indirectly generate GHG emissions that
may have a significant impact on the environment since Scenario 6 would result in a decrease in
emissions from existing conditions and would achieve the 2030 performance criteria that would
ensure the City is on a trajectory to achieve the GHG reductions targets of SB 32 for year 2030.
Additionally, the 2030 Comprehensive Plan would not conflict with CARB’s Scoping Plan or
Association of Bay Area Governments (ABAG)/Metropolitan Transportation Commission’s
(MTC) Plan Bay Area. However, the 2017 EIR found that the 2030 Comprehensive Plan would
expose people or structures to the physical effects of climate change, including but not limited
to flooding, extreme temperatures, public health, wildfire risk, or other impacts resulting from
climate change, and mitigation measure GHG-3 would be required to reduce impacts to a less
than significant level.
Table 16 lists the mitigation measures from the 2017 EIR related to greenhouse gas emissions.
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Table 16 2017 EIR Mitigation Measures: Greenhouse Gas Emissions
Mitigation
Measure # Mitigation Text
Impact GHG-3: The proposed Plan would expose people or structures to the physical effects of climate change, including
but not limited to flooding, extreme temperatures, public health, wildfire risk, or other impacts resulting from climate
change, requiring mitigation. (Significant and Mitigable)
GHG-3 To address the potential impacts associated with exposing additional people or structures to the effects
of climate change, the proposed Plan shall include policies that address the following topics:
Flooding risks caused by climate change-related changes to precipitation patterns, groundwater
levels, sea level rise, tides, and storm surges.
Cooperative planning with federal, State, regional, and local public agencies on issues related to
climate change (including sea level rise and extreme storms).
Preparation of response strategies to address sea level rise, increased flooding, landslides, soil
erosion, storm events, and other events related to climate change.
Impacts of sea level rise on Palo Alto’s levee system.
Source: City of Palo Alto 2016
THRESHOLDS
In response to climate change, California implemented AB 32, the “California Global Warming
Solutions Act of 2006.” AB 32 requires the reduction of statewide GHG emissions to 1990
emissions levels (essentially a 15 percent reduction below 2005 emission levels) by 2020 and
the adoption of rules and regulations to achieve the maximum technologically feasible and
cost-effective GHG emissions reductions. On September 8, 2016, the Governor signed SB 32
into law, extending AB 32 by requiring the State to further reduce GHG emissions to 40 percent
below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On September
10, 2018, the Governor signed Executive Order (EO) B-55-18, which identifies a new goal of
carbon neutrality by 2045 and supersedes the goal established by EO S-3-05.6 CARB adopted
the 2022 Scoping Plan on November 16, 2022, which provides a framework for achieving
carbon neutrality by 2045 or earlier. The 2022 Scoping Plan extends and expands upon the
three earlier versions of scoping plans with a target of reducing anthropogenic emissions to 85
percent below 1990 levels by 2045.
According to the CEQA Guidelines, projects can tier from a qualified GHG reduction plan, which
allows for project-level evaluation of GHG emissions through the comparison of the project’s
consistency with the GHG reduction policies included in a qualified GHG reduction plan. This
approach is considered by the Association of Environmental Professionals (AEP) in their white
paper, Beyond Newhall and 2020, to be the most defensible approach presently available under
CEQA to determine the significance of a project’s GHG emissions (AEP 2016). Palo Alto does not
currently have a qualified GHG reduction plan and thus this approach is not currently feasible.
6 Executive Order (EO) S-3-05, signed by Governor Arnold Schwarzenegger in 2005, proclaims that California is vulnerable to the
impacts of climate change. It declares that increased temperatures could reduce the Sierra Nevada snowpack, further
exacerbate California’s air quality problems, and potentially cause a rise in sea levels. To combat those concerns, the EO
established total GHG emission targets for the state. Specifically, emissions are to be reduced to the 2000 level by 2010, the
1990 level by 2020, and to 80 percent below the 1990 level by 2050.
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To evaluate whether a project may generate a quantity of GHG emissions that may have a
significant impact on the environment, state agencies have developed a number of operational
bright-line significance thresholds. Significance thresholds are numeric mass emissions
thresholds that identify the level at which additional analysis of project GHG emissions is
necessary. Projects that attain the significance target, with or without mitigation, would result
in less than significant GHG emissions. Since the proposed project would tier from the 2017 EIR,
the BAAQMD GHG 2030 efficiency target applied in the 2017 EIR would be used to inform the
threshold for this analysis. However, to take into account the new State goal of carbon
neutrality by 2045 and the project buildout year of 2031, the BAAQMD GHG 2030 efficiency
target was interpolated to get an adjusted 2031 threshold of 3.74 MTCO2e per service
population per year.7 Therefore, the proposed project’s GHG emissions would be significant if
they would exceed the 2031 interpolated threshold of 3.74 MTCO2e per service population per
year, consistent with EO B-55-18.
PALO ALTO SUSTAINABILITY AND CLIMATE ACTION PLAN
The City of Palo Alto launched its S/CAP in August 2014. In 2020, the city launched an update to
the S/CAP to develop strategies needed to meet their goal of reducing GHG emissions 80
percent below 1990 levels by 2030 (the “80 x 30” goal). In October 2022, the Palo Alto City
Council approved the updated S/CAP Goals and Key Actions that will serve as the City's
roadmap to meeting the "80 x 30" goal and most recent Carbon Neutral by 2030 goal. The
S/CAP Goals and Key Actions includes goals and actions in seven areas: Energy, Mobility,
Electric Vehicles, Water, Climate Adaptation and Sea Level Rise, Natural Environment, and Zero
Waste. The S/CAP is not a qualified CAP under CEQA Guidelines 15183.5(b)(1) since it has not
yet been adopted in a public process following environmental review.
METHODOLOGY
OPERATIONAL EMISSIONS
Long-term emissions relate to area sources, energy use, solid waste, water use, and
transportation. Operational emissions for the proposed HEU were modeled using the California
Emissions Estimator Model (CalEEMod) version 2022.1 and compared to the adjusted BAAQMD
efficiency thresholds used in the 2017 EIR. CalEEMod default settings were used to estimate
emissions associated with the proposed project to apply a high-level and conservative analysis.
AREA SOURCE EMISSIONS
Emissions associated with area sources, including consumer products, landscape maintenance,
and architectural coating were calculated in CalEEMod and utilized default standard emission
rates from CARB, U.S. EPA, and emission factor values provided by the local air district (CAPCOA
2017). Architectural coatings were calculated pursuant to BAAQMD Regulation 8 Rule 3.
7 4.0 MTCO2e (2030 Comprehensive Plan EIR threshold) / 15 years (2030 to 2045 for carbon neutrality) = 0.26 MTCO2e. To find
the 2031 interpolated threshold, 4.0 MTCO2e - 0.26 MTCO2e = 3.74 MTCO2e.
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ENERGY USE EMISSIONS
CalEEMod provides operational emissions of CO2, N2O, and CH4. Emissions from energy use
include electricity and natural gas use. The emissions factors for natural gas combustion are
based on EPA’s AP-42 (Compilation of Air Pollutant Emissions Factors) and CCAR. Electricity
emissions are calculated by multiplying the energy use times the carbon intensity of the utility
district per kilowatt hour (CAPCOA 2017). Since the City’s All-Electric Ordinance requires all-
electric construction for future residential uses, it was assumed that the natural gas demand
estimated for the project would instead be supplied by electricity to account for increased
electricity usage. Total annual consumption for natural gas (kBTU/year) was converted to
electricity (kWh/year) and added to the total annual consumption for electricity. CalEEMod
incorporates 2019 Title 24 CALGreen Building Standards.
SOLID WASTE EMISSIONS
Emissions from solid waste generation were also calculated in CalEEMod and are based on the
IPCC’s methods for quantifying GHG emissions from solid waste using the degradable organic
content of waste (CAPCOA 2017). Waste disposal rates by land use and overall composition of
municipal solid waste in California was primarily based on data provided by the California
Department of Resources Recycling and Recovery [CalRecycle] 2019).
WATER AND WASTEWATER USE EMISSIONS
Emissions from water and wastewater usage calculated in CalEEMod were based on the default
electricity intensity from the California Energy Commission’s 2006 Refining Estimates of Water-
Related Energy Use in California using the average values for Northern and Southern California.
The Palo Alto RWQCP was assumed to be 100 percent aerobic since it does not contain
facultative lagoons or septic tanks.
MOBILE SOURCE EMISSIONS
For mobile sources, CO2, CH4, and N2O emissions were quantified in CalEEMod.
REFRIGERANT EMISSIONS
Refrigerants are substances used in equipment for cooling and heating purposes and are mostly
comprised of hydrofluorocarbons (HFC). HFCs are potent GHGs that have high global warming
potential (GWP) values. CalEEMod calculates refrigerant emissions according to equipment
charge sizes and leak rates that have been determined for relevant land uses and equipment
types.
CONSTRUCTION EMISSIONS
Construction of the proposed HEU would generate temporary GHG emissions primarily due to
the operation of construction equipment and truck trips. Site preparation and grading typically
generate the greatest amount of emissions due to the use of grading equipment and soil
hauling. Although construction activity is addressed in this analysis, CAPCOA does not discuss
whether any of the suggested threshold approaches adequately address impacts from
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temporary construction activity. As stated in the CEQA and Climate Change white paper, “more
study is needed to make this assessment or to develop separate thresholds for construction
activity” (CAPCOA 2008). Additionally, the BAAQMD does not have specific quantitative
thresholds for construction activity. Therefore, although estimated in CalEEMod and provided
for informational purposes, construction activity is not included in the total emissions
calculations.
PROJECT-SPECIFIC IMPACTS
a. Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
Proposed construction activities, energy use, daily operational activities, and mobile sources
(traffic) associated with the proposed project would generate GHG emissions. CalEEMod was
used to calculate emissions resulting from construction and long-term operation (see Appendix
B for model output).
CONSTRUCTION EMISSIONS
Emissions generated from construction of full buildout under the proposed HEU are estimated
to be 5,433 MT of CO2e per year.8 However, as the BAAQMD does not have a recommended
threshold for construction-related GHG emissions, emissions associated with construction are
not included in Table 17 and compared to BAAQMD significance thresholds.
OPERATIONAL INDIRECT AND STATIONARY DIRECT EMISSIONS
Long-term emissions relate to area sources, energy use, solid waste, water use, and
transportation. Each of the operational sources of emissions is discussed further below.
MOBILE EMISSIONS
As shown in Table 17 below, the additional 665 units facilitated by the proposed project would
generate approximately 2,921 MTCO2e per year.
AREA SOURCE EMISSIONS
CalEEMod was used to calculate direct sources of air emissions associated with the proposed
project. These include consumer product use and landscape maintenance equipment. Area
emissions are estimated at 42 MTCO2e per year.
ENERGY USE EMISSIONS
Operation of the proposed project would consume both electricity and natural gas. The
generation of electricity through combustion of fossil fuels emits CO2, and to a smaller extent,
N2O and CH4. As discussed under the Methodology section, pursuant to the City’s All-Electric
8 Construction emissions were determined assuming the 1,308 units were built as one continuous project using CalEEMod
defaults. Construction emissions for future projects would be based on the timing and size of individual projects.
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Ordinance, natural gas was converted to electricity to account for increased electricity usage.
Since CPAU provides electricity to the city, and has supplied 100 percent carbon neutral
electricity since 2013, GHG emissions from energy use are estimated at 0 MTCO2e per year.
WATER USE EMISSIONS
Based on the amount of electricity generated to supply and convey water for the project, the
proposed project would generate an estimated 29 MTCO2e per year.
SOLID WASTE EMISSIONS
Based on the estimate of GHG emissions from project-generated solid waste as it decomposes,
solid waste associated with the proposed project would generate approximately 129 MTCO2e
per year.
REFRIGERANT EMISSIONS
Based on the estimate of GHG emissions from refrigerants used for the project, the proposed
project would generate an estimated 1 MTCO2e per year.
The annual emissions associated with the additional development under the proposed HEU
would total approximately 3,122 MTCO2e per year. As discussed in Section 14, Population and
Housing, the service population from the project would be 1,670 new residents. Therefore, the
MTCO2e per service population for the proposed HEU would be 1.9. These emissions would not
exceed the 2017 EIR’s BAAQMD 2030 efficiency target of 3.74. Therefore, this impact would be
less than significant, and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
Table 17 Operational GHG Emissions
Emissions Source Annual Emissions (MT of CO2e/year)
Mobile 2,921
Area 42
Energy 0
Water 29
Waste 129
Refrigerants 1
Total 3,122
Service Population 1,670
MTCO2e/Service Population 1.9
2017 EIR BAAQMD 2030 Efficiency Target (Adjusted for SB 32) 3.74
Exceeds Threshold? No
See Table 2.5 “Operations Emissions by Sector, Unmitigated” emissions. CalEEMod worksheets in Appendix B.
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b. Would the project conflict with any applicable plan, policy, or regulation adopted for the
purpose of reducing the emissions of greenhouse gases?
The City of Palo Alto has adopted the Sustainability and Climate Action Plan (S/CAP) in 2020 to
develop strategies to meet their goal of reducing GHG emissions 80 percent below 1990 levels
by 2030. The California Air Resources Board (CARB) also updated its Climate Change Scoping
Plan in November 2022. Table 18 shows the proposed project’s compliance with the City’s
S/CAP and CARB Scoping Plan measures.
Table 18 Proposed Project Compliance with Applicable S/CAP Actions
GHG Reduction Goal or Policy Project Consistency
City of Palo Alto S/CAP
Action C3: Complete study to identify any additional Energy,
EV, or Mobility key actions needed to achieve 80% reduction
in greenhouse gas emissions from 1990 levels by 2030, such
as electrification of additional multifamily or commercial end
uses, greater electrification of vehicles, or other emissions
reduction actions not already identified in this Plan.
Consistent. Development facilitated by the project would be
required to comply with the PAMC Chapter 16.17, which
mandates the implementation of Title 24. Compliance would
include complying with the most updated rooftop solar
requirements at the time of construction. Future
development would also be required to comply with the
City’s most updated Reach Code and All-Electric Mandate
which requires all-electric building design for single-family,
low-rise multi-family, and non-residential development (City
of Palo Alto 2022a). Electricity would be provided by CPAU,
which has provided 100 percent carbon neutral electricity
since 2013 (City of Palo Alto 2022b).
Pursuant to Section 16.14.420 of the PAMC, new multi-
family residences would be required to provide at least one
EVSE Ready outlet or EVSE installed for each residential unit
in the structure for residential parking, and would be
required to provide Conduit Only, EVSE Ready Outlet, or
EVSE installed for at least 25 percent of guest parking
spaces, among which at least 5 percent shall be EVSE
installed. Future development facilitated by the project
would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at
the time of construction.
Action E1: Reduce all or nearly all greenhouse gas emissions
in single-family appliances and equipment, including water
heating, space heating, cooking, clothes drying, and other
appliances that use natural gas.
Consistent. Future development would be required to
comply with the City’s most updated Reach Code and All-
Electric Mandate which requires all-electric building design
for single-family, low-rise multi-family, and non-residential
development (City of Palo Alto 2022a).
Action E7: Use codes and ordinances - such as the energy
reach code, green building ordinance, zoning code, or other
mandates - to facilitate electrification in both existing
buildings and new construction projects where feasible.
Consistent. Development facilitated by the project would be
required to comply with the PAMC Chapter 16.17, which
mandates the implementation of Title 24. Compliance would
include complying with the most updated rooftop solar
requirements at the time of construction. Future
development would also be required to comply with the
City’s most updated Reach Code and All-Electric Mandate
which requires all-electric building design for single-family,
low-rise multi-family, and non-residential development (City
of Palo Alto 2022a). Electricity would be provided by CPAU,
which has provided 100 percent carbon neutral electricity
since 2013 (City of Palo Alto 2022b).
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GHG Reduction Goal or Policy Project Consistency
Action EV6: Expand access to on-site EV charging for multi-
family residents.
Consistent. Pursuant to Section 16.14.420 of the PAMC, new
multi-family residences would be required to provide at
least one EVSE Ready outlet or EVSE installed for each
residential unit in the structure for residential parking, and
would be required to provide Conduit Only, EVSE Ready
Outlet, or EVSE installed for at least 25 percent of guest
parking spaces, among which at least 5 percent shall be EVSE
installed. Future development facilitated by the project
would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at
the time of construction.
Action M7: Continue to implement the City’s Housing
Element of the Comprehensive Plan to improve jobs -
housing balance and reduce vehicle miles traveled (VMT).
Consistent. The proposed project would implement the
2023-2031 Housing Element Update which would facilitate
development within the city’s urbanized and underutilized
sites. These areas are near or adjacent to transportation
corridors currently served by transit or Class I, II, and III
bicycle lanes such as University Avenue, Bryant Street,
California Avenue, and Bayshore Road, which would
encourage the use of bicycles and reduce reliance on single-
occupancy vehicles and VMT.
Action N2: Ensure No Net Tree Canopy Loss for all projects. Consistent. Future development would be required to
comply with the City’s Tree Ordinance pursuant to Title 8 of
the PAMC, which also ensures no net loss of canopy across
all tree removal types.
Action N8: Expand the requirements of the Water Efficient
Landscape Ordinance (WELO) to increase native and
drought-tolerant species composition.
Consistent. Future development would be required to
comply with the most updated requirements of WELO
pursuant to Section 12.32.040 of the PAMC.
Action N9: Phase out gas-powered lawn and garden
equipment, in compliance with California’s AB 1346
Consistent. Future development would be required to
comply with AB 1346 and would be prohibited from using
gas-powered lawn and garden equipment.
Action ZW2: Promote residential food waste reduction. Consistent: Future development facilitated by the proposed
HEU would be required to comply with SB 1383 and recycle
organic wastes.
CARB Scoping Plan Measures
Consider enhanced energy efficiency (high efficiency air
conditioners, light-emitting diode lamps, efficiency
improvements in industrial process cooling and
refrigeration, efficient street lighting).
Consistent. Future development would be required to
comply with the latest CALGreen standards and Building
Energy Efficiency Standards, which would require
implementation of energy-efficient light fixtures and
building materials into the project design, and would ensure
energy efficient performance for new buildings.
Source: City of Palo Alto 2022c, CARB 2017
As shown in Table 18, the project would be consistent with applicable actions from the City’s
S/CAP. Therefore, impacts would be less than significant, and would be generally the same as
for the 2030 Comprehensive Plan as analyzed in the 2017 EIR. There would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, and
further analysis is not warranted.
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PROJECT CONSISTENCY WITH 2022 SCOPING PLAN
The principal State plans and policies for reducing GHG emissions are AB 32, SB 32, and AB
1279. The quantitative goal of AB 32 is to reduce GHG emissions to 1990 levels by 2020; the
goal of SB 32 is to reduce GHG emissions to 40 percent below 1990 levels by 2030; and the goal
of AB 1279 is to achieve net zero greenhouse gas emissions no later than 2045, and reduce GHG
emissions by 85 percent below 1990 levels no later than 2045. The 2022 Scoping Plan expands
upon earlier plans to include the AB 1279 targets. The 2022 Scoping Plan’s strategies that are
applicable to the proposed project include reducing fossil fuel use and vehicle miles traveled;
decarbonizing the electricity sector, maximizing recycling and diversion from landfills; and
increasing water conservation. The project would be consistent with these goals since future
development would be required to comply with the latest Title 24 Green Building Code and
Building Efficiency Energy Standards, as well as the AB 341 waste diversion goal of 75 percent
and recycle organic wastes pursuant to SB 1383. Future development facilitated by the project
would also be largely located in areas served by transit, such as along El Camino Real, the
California Avenue area, and the Downtown area, and would be near or adjacent to
transportation corridors currently served by transit or Class I, II, and III bicycle lanes such as
University Avenue, Bryant Street, California Avenue, and Bayshore Road. This would reduce
reliance on single-occupancy vehicles and VMT and promote bicycling and walking. Future
development would also be required to comply with the City’s most updated Reach Code and
All-Electric Mandate which requires all-electric building design for single-family, low-rise multi-
family, and non-residential development (City of Palo Alto 2022a). Additionally, future
development would receive electricity from CPAU, which sources 100 percent GHG free
electricity. Therefore, the project would not conflict with the 2022 Scoping Plan and this impact
would be less than significant, generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in emissions exceeding
the 2031 interpolated thresholds, and would be consistent with the City’s S/CAP and CARB
Scoping Plan measures, resulting in less than significant GHG impacts. Therefore, the project
would not result in new significant effects not addressed in the prior EIR, and no new mitigation
measures are warranted. This issue does not require further study in an EIR.
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9 Hazards and Hazardous Materials
Where
was
Impact
Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or
Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Create a significant hazard to the
public or the environment
through the routine transport,
use, or disposal of hazardous
materials?
EIR Pages
4.7-2
through
4.7-3
No No No N/A
b. Create a significant hazard to the
public or the environment
through reasonably foreseeable
upset and accident conditions
involving the release of
hazardous materials into the
environment?
EIR Pages
4.7-3
through
4.7-5
No No No Yes
c. Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within 0.25 mile of an
existing or proposed school?
EIR Pages
4.7-5
through
4.7-6
No No No Yes
d. Be located on a site that is
included on a list of hazardous
material sites compiled pursuant
to Government Code Section
65962.5 and, as a result, would it
create a significant hazard to the
public or the environment?
EIR Pages
4.7-6
through
4.7-8
No No No N/A
e. For a project located within an
airport land use plan or, where
such a plan has not been
adopted, within two miles of a
public airport or public use
airport, would the project result
in a safety hazard or excessive
noise for people residing or
working in the project area?
EIR Pages
4.7-9
through
4.7-10;
4.7-11
No No No N/A
f. Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
EIR Pages
4.7-10
through
4.7-11
No No No N/A
g. Expose people or structures,
either directly or indirectly, to a
significant risk of loss, injury, or
death involving wildland fires?
EIR Pages
4.7-8
through
4.7-9
No No No N/A
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ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.7, Hazards and Hazardous Materials, of the 2017 EIR analyzed the 2030
Comprehensive Plan’s impacts related to hazards and hazardous materials. The 2017 EIR found
that the 2030 Comprehensive Plan would not create a significant hazard to the public or
environment as a result of the routine transport, use, or disposal of hazardous materials, and
would not involve the release of hazardous materials into the environment through upset and
accident conditions. The 2017 EIR concluded that with compliance with applicable federal,
State, and local regulations regarding the storage, use, and handling of hazardous materials, the
2030 Comprehensive Plan would not result in hazardous emissions or the handling of
hazardous wastes within 0.25 mile of an existing or proposed school, and would not expose
future occupants to contaminated soil and groundwater. The 2017 EIR also found that the 2030
Comprehensive Plan would not impair implementation or interfere with an adopted emergency
response or evacuation plan, or result in a safety hazard from a public airport or private airstrip
for people residing or working within the plan area.
PROJECT-SPECIFIC IMPACTS
a. Would the project create a significant hazard to the public or the environment through the
routine transport, use, or disposal of hazardous materials?
The proposed HEU would include 665 more housing units compared to buildout assumed in the
2017 EIR and therefore would potentially transport, use, or dispose of more hazardous
materials than what was analyzed. However, hazardous materials would be required to be
transported under the United States Department of Transportation (DOT) regulations. Future
development facilitated by the proposed HEU would be subject to regulatory programs such as
those overseen by the RWQCB and the Department of Toxic Substances Control (DTSC). These
agencies require applicants for development of potentially contaminated properties to perform
investigation and cleanup if the site is found to be contaminated with hazardous substances. In
addition, Santa Clara County has substantial regulations concerning hazardous materials under
its Certified Unified Program Agencies (CUPA) jurisdiction and related Unified Programs. This is
further enforced by Palo Alto Fire Department Programs.
The proposed HEU is intended to expand housing capacity and would not facilitate the
establishment of uses that would sell, use, store, transport, or release substantial quantities of
hazardous materials such as industrial, warehouse, auto-service, or manufacturing uses.
Residential uses do not typically use hazardous materials other than small amounts for cleaning
and landscaping. These materials would not be different from household chemicals and
solvents already in wide use throughout Palo Alto. Residents are anticipated to use limited
quantities of products routinely for periodic cleaning, repair, and maintenance or for landscape
maintenance/pest control that could contain hazardous materials. Those using such products
would be required to comply with all applicable regulations regarding the disposal of household
waste.
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Compliance with all applicable federal, State, and local regulations would reduce impacts from
the routine transport, use, or disposal of hazardous materials to a less than significant level,.
Therefore, this impact would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
b. Would the project create a significant hazard to the public or the environment through
reasonably foreseeable upset and accident conditions involving the release of hazardous
materials into the environment?
Development under the proposed HEU would facilitate development on sites that are possibly
contaminated and inactive, undergoing evaluation, and/or undergoing corrective action, and
grading or excavation may result in the transport, disposal, and release of hazardous materials
if they are unearthed and removed from the site. However, the amount and type of soil
disturbance would be similar to what was analyzed under the 2017 EIR as development would
be facilitated on previously disturbed soils, and future development under the project would be
subject to regulatory programs such as those overseen by the RWQCB and the DTSC. These
agencies require applicants for development of potentially contaminated properties to perform
investigation and cleanup if the properties are contaminated with hazardous substances above
the applicable environmental screening levels for the site. Future development would also be
required to comply with Chapter 17.16 of the PAMC which requires the preparation of a
hazardous materials management plan (HMMP) demonstrating the suitable storage of
hazardous materials, as well as Chapter 16.11 which requires the implementation of a SWPPP
and stormwater pollution prevention measures. Although the proposed HEU would include 665
more housing units compared to buildout assumed in the 2017 EIR, compliance with all
applicable federal, State, and local regulations would reduce impacts from the release of
hazardous materials to a less than significant level. Therefore, this impact would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within 0.25 mile of an existing or proposed school?
Several housing inventory sites are located within 0.25 mile of a school, such as Palo Verde
Elementary School, Fairmeadow Elementary School, Herbert Hoover Elementary School, and
Palo Alto High School. The proposed HEU would not involve new industrial or manufacturing
uses, or involve the use, storage, disposal, or transportation of significant quantities of
hazardous materials. The proposed project is designed to facilitate residential development.
Residential uses may involve use and storage of some materials considered hazardous, though
primarily these would be limited to solvents, paints, chemicals used for cleaning and building
maintenance, and landscaping supplies. These materials would not be different from household
chemicals and solvents already in general and wide use throughout the city. Development
accommodated under the project therefore would not pose a health risk to nearby schools or
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childcare facilities. Additionally, as discussed above under Impacts (a) and (b), future
development would be required to comply with existing applicable federal, State, and local
regulations which govern the routine use, transport, handling, storage, disposal, and release of
hazardous materials. Oversight by the appropriate federal, State, and local agencies and
compliance by new development with applicable regulations related to the handling and
storage of hazardous materials would minimize the risk of the public’s potential exposure to
these substances to a less than significant level. Therefore, this impact would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
d. Would the project be located on a site that is included on a list of hazardous material sites
compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment?
As discussed in the 2017 EIR, a number of hazardous materials sites are listed on databases
compiled pursuant to Government Code Section 65962.5. Most of the sites are listed as closed
and have been remediated to the satisfaction of the lead responsible agency (i.e., RWQCB,
DTSC, Santa Clara County Department of Environmental Health (SCCDEH)) based on land use at
the time of closure. Additionally, several groundwater contaminant plumes underlie certain
areas of the city, which could potentially expose future residents to contamination of soil and
groundwater. The proposed HEU would facilitate 665 more housing units compared to buildout
analyzed in the 2017 EIR, and therefore could potentially facilitate more development on sites
containing hazardous materials in underlying groundwater or soils. However, the amount and
type of soil disturbance would be similar to what was analyzed under the 2017 EIR as
development would be facilitated on previously disturbed soils and on underutilized and non-
vacant sites. Future development would be required to adhere to all applicable federal, State,
and local regulations regarding cleanup and reuse of a site with hazardous materials, as well as
policies within the Safety Element of the 2030 Comprehensive Plan, which would reduce
impacts to a less than significant level. Therefore, this impact would be less than significant, and
would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
e. For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project result
in a safety hazard or excessive noise for people residing or working in the project area?
As discussed in the 2017 EIR, the Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport
was adopted in November 2008 by the Santa Clara County Airport Land Use Commission (ALUC)
and the city amended the Comprehensive Plan in 2009 to incorporate the CLUP (Santa Clara
County Airport Land Use Commission 2016). The CLUP includes policies intended to safeguard
the general welfare of the inhabitants within the vicinity of the airport and ensure that new
surrounding uses do not affect the airport’s continued safe operation (City of Palo Alto 2017a).
Unlike Scenario 6 of the 2017 EIR, the proposed HEU would allow residential uses in the ROLM
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zone south of US 101. This area is within the Palo Alto Airport’s Airport Influence Area (AIA);
however, this area is not located in the airport’s inner or outer safety zone and is outside of the
aircraft noise contours. Future development in the height restricted areas surrounding the
airport would be subject to Federal Aviation Regulations (FAR) Part 77, Objects Affecting
Navigable Airspace, which establishes imaginary surfaces for airports and runways as a means
to identify objects that are obstructions to air navigation. Any penetrations of the FAR Part 77
surface are subject to review on a case-by-case basis. If a safety problem is found to exist, the
Federal Aviation Administration (FAA) may issue a determination of a hazard to air navigation
(Santa Clara County Airport Land Use Commission 2016). The City of Palo Alto establishes and
enforces height restrictions in these areas.
Therefore, with compliance with existing regulations, the proposed HEU would not interfere
with an airport land use plan or create an airport-related safety hazard, and impacts would be
less than significant. This impact would be less than significant and would be generally the same
as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would
be no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
f. Would the project impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan?
As discussed in the 2017 EIR, the Palo Alto Office of Emergency Services (OES) is responsible for
coordinating agency response to disaster or other large-scale emergencies in Palo Alto with
assistance from the Santa Clara County Operational Area in accordance with the State of
California Standardized Emergency Management System. The Palo Alto Emergency Operations
Plan (EOP) establishes policy direction for emergency planning, mitigation, response, and
recovery activities within the city. The Palo Alto EOP addresses interagency coordination,
procedures to maintain communication with County and State emergency response teams, and
methods to assess the extent of damage and management of volunteers. With participation
from the City of Palo Alto and other local agencies, ABAG created an umbrella Hazard
Mitigation Plan entitled “Taming Natural Disasters.” In addition, the city participated in
development of and has since adopted the Regional Catastrophic Earthquake Mass
Transportation Plan, which is an annex to the San Francisco Bay Area Regional Emergency
Coordination Plan and addresses mass transportation/evacuation issues in response to a major
earthquake (City of Palo Alto 2017a). As discussed in Section 4.13, Public Services and
Recreation, future development in Palo Alto would be required to conform to the latest fire
code requirements, including provisions for emergency access. With adherence to existing
Comprehensive Plan policies and other regulations, implementation of the proposed HEU
would not impair or interfere with an emergency response or evacuation plan. Therefore, this
impact would be less than significant, and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
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g. Would the project expose people or structures, either directly or indirectly, to a significant
risk of loss, injury, or death involving wildland fires?
As shown in Map S-8 of the 2017 EIR, much of the area surrounding Palo Alto west of I-280 is
considered to have a moderate and high risk of wildland fire, whereas all of the urbanized areas
do not have any wildland fire hazards. Since the proposed HEU would facilitate development in
non-vacant and underutilized sites in urbanized areas, wildfire risk to future residents would be
low. Future development would be subject to the CAL FIRE Strategic Plan and the California Fire
Code (CFC), pursuant to Chapter 15.04 of the PAMC. The CFC requires the clearance of debris
and vegetation within a prescribed distance from structures in wildlife hazard areas.
Additionally, future development would be located in proximity to Palo Alto Fire Stations 1, 2,
3, and 4. Cooperative fire service agreements with the Central County Fire Department (CCFD),
City of Menlo Park, City of Mountain View, Woodside Fire Protection District, and Stanford
University would further assist the city in protecting people and structures from potential
wildland fires. Therefore, this impact would be less than significant, and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to hazards and hazardous materials which would
reduce impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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10 Hydrology and Water Quality
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface
or ground water quality?
EIR Pages
4.8-11
through
4.8-13
No No No Yes
b. Substantially decrease
groundwater supplies or
interfere substantially with
groundwater recharge such
that the project may impede
sustainable groundwater
management of the basin?
EIR Page
4.8-13
through
4.8-16; 4.8-
20 through
4.8-22
No No No N/A
c. Substantially alter the existing
drainage pattern of the site or
area, including through the
alteration of the course of a
stream or river or through the
addition of impervious
surfaces, in a manner which
would:
(i) Result in substantial
erosion or siltation on- or
off-site;
EIR Pages
4.8-16
through
4.8-17
No No No Yes
(ii) Substantially increase the
rate or amount of surface
runoff in a manner which
would result in flooding on-
or off-site;
EIR Pages
4.8-19
through
4.8-20
No No No Yes
(iii) Create or contribute runoff
water which would exceed
the capacity of existing or
planned stormwater
drainage systems or
provide substantial
additional sources of
polluted runoff; or
EIR Pages
4.8-19
through
4.8-20
No No No Yes
(iv) Impede or redirect flood
flows?
EIR Pages
4.8-22
through
4.8-23
No No No Yes
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Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
d. In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
EIR Pages
4.8-23
through
4.8-26
No No No N/A
e. Conflict with or obstruct
implementation of a water
quality control plan or
sustainable groundwater
management plan?
N/A No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.8 of the 2017 EIR analyzes impacts to hydrology and water quality. The 2017 EIR
determined that the 2030 Comprehensive Plan could substantially degrade or deplete
groundwater resources or interfere substantially with groundwater recharge since there is a
potential for localized lowering of the shallow aquifer during construction dewatering activities.
However, implementation of mitigation measure HYD-2 would reduce impacts to a less than
significant level. The 2017 EIR found that the 2030 Comprehensive Plan would not violate any
water quality standards or waste discharge requirements with compliance with the NPDES
General Construction Permit (GCP), SWPPP requiring incorporation of BMPs, and Low Impact
Development (LID) treatment measures. The 2017 EIR also states that the 2030 Comprehensive
Plan would not increase the rate of stormwater runoff or alter the existing drainage pattern;
result in stream bank instability; result in new or increased flooding on-or off-site or exceed the
capacity of stormwater drainage systems in local streams; or provide substantial additional
sources of pollutants associated with urban runoff or otherwise substantially degrade surface
or ground water quality. The 2017 EIR determined that the 2030 Comprehensive Plan would
not substantially impede or redirect flood flows through placement of structures within the
100-year flood hazard area with compliance with the National Flood Insurance Program (NFIP)
and Flood Hazard Regulations in the PAMC. Additionally, the 2030 Comprehensive Plan would
not expose people or structures to a significant risk or loss, injury or death involving flooding by
placing housing or other development within a 100-year flood hazard area or a levee or dam
failure inundation area and would not result in impacts from inundation by seiche, tsunami, or
mudflow.
Table 19 lists the mitigation measures from the 2017 EIR related to Hydrology and Water
Quality.
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Table 19 2017 EIR Mitigation Measures: Hydrology and Water Quality
Mitigation
Measure # Mitigation Text
Impact HYD-2: The proposed Plan could substantially degrade or deplete ground water resources or interfere substantially
with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local
groundwater table level. (Significant and Mitigable)
HYD-2 To reduce potential impacts associated with construction dewatering the proposed Plan shall include
policies that address the following topics:
Impacts of basement construction for single-family homes on adjacent properties, public resources,
and the natural environment.
Conservation of subsurface water resources.
Reduced residential basement dewatering and other excavation activities.
Construction techniques and recharge strategies to reduce subsurface and surface water impacts.
Monitoring of dewatering and excavation projects.
Cooperation with other jurisdictions and regional agencies to protect groundwater.
Protection of groundwater from the adverse impacts of urban use.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project violate any water quality standards or waste discharge requirements?
Similar to what was assumed in the 2017 EIR, although development under the proposed HEU
would occur on non-vacant and underutilized sites in previously disturbed areas, ground-
disturbing activities would still have the potential to cause soil erosion from exposed soil, an
accidental release of hazardous materials used for equipment such as vehicle fuels and
lubricant, or temporary siltation from storm water runoff. If uncontrolled during construction,
soil erosion and water pollutants could have adverse offsite effects on water quality. However,
future development that would disturb one or more acre of land would be required to comply
with the NPDES GCP as well as prepare a SWPPP that requires the incorporation of BMPs to
control sedimentation, erosion, and hazardous materials contamination of runoff during
construction. Additionally, projects that apply for a grading permit must also comply with the
City of Palo Alto’s grading and erosion and sediment control requirements pursuant to PAMC
Chapter 16.28, which require project applicants to submit an erosion and sediment control plan
for review by the City prior to the issuance of grading permits. Pursuant to Chapter 16.11 of the
PAMC, permanent stormwater pollution prevention measures must also be incorporated into
future projects. These may include but are not limited to minimization of impervious surfaces;
construction of sidewalks, walkways, and/or patios with permeable surfaces; and minimization
of disturbances to natural drainages. Furthermore, all new and redevelopment projects that
create or replace 10,000 square feet or more of impervious surface must incorporate site
design, source control, and Low Impact Development (LID) treatment measures to the
maximum extent practicable. Also, all development or redevelopment projects that create or
replace one acre or more of impervious surface and are located in a hydromodification area
must implement hydromodification management measures (i.e., post-project runoff rates shall
not exceed estimated pre-project rates and durations) (City of Palo Alto 2017a).
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If groundwater is encountered, future development would be required to comply with the
City’s Construction Dewatering System Policy and Plan Preparation Guidelines, which require
excavation activities that may encounter groundwater to submit a Construction Dewatering
Plan to the City’s Public Works Department (City of Palo Alto 2020). The Public Works
Department would review and permit the dewatering plan prior to commencement of
dewatering as part of the Street Work Permit process. The Construction Dewatering Plan must
comply with the City’s Guidelines that require that water be tested for contaminants prior to
initial discharge and at intervals during dewatering. In the dewatering plan, the applicant must
include provisions for keeping sediment and contaminated groundwater out of the storm drain
system (City of Palo Alto 2017a).
Therefore, with compliance with the NPDES GCP, the Municipal Regional Permit (MRP),
preparation of a SWPPP, and implementation of site design, source control, and LID treatment
control measures for new development would reduce impacts to a less than significant level.
This impact would be less than significant and would be generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project substantially decrease groundwater supplies or interfere substantially
with groundwater recharge such that the project may impede sustainable groundwater
management of the basin?
The proposed HEU would substantially degrade or deplete groundwater resources or interfere
substantially with groundwater recharge if future development would use significant amounts
of groundwater for water supply or would significantly increase impervious surfaces or
construction dewatering. Since the City receives 100 percent of its potable water from the San
Francisco Public Utilities Commission (SFPUC), which obtains its supply from surface water
sources, the proposed HEU would not substantially degrade or deplete groundwater resources.
Implementation of LID measures, which prioritize the use of on-site infiltration, would also
result in some level of groundwater recharge. Although the proposed HEU could potentially
increase impervious surfaces within the city more than what was analyzed under the 2017 EIR,
future development would be facilitated on non-vacant and underutilized sites that are already
built-out. Additionally, future development would be required to comply with Section
18.40.130(f) of the PAMC which lists guidelines for landscaping and pervious paving to
accommodate filtration of stormwater runoff from impervious areas.
As shown in the Palo Alto groundwater dewatering map, construction dewatering sites in 2020
to 2022 were located primarily along the west of Oregon Expressway and Evergreen Park (City
of Palo Alto 2022d). Under the proposed HEU, a few housing sites would be located east of
Oregon Expressway and near the Evergreen Park area. Therefore, impacts would be potentially
significant. However, with compliance with the City’s Construction Dewatering System Policy
and Plan Preparation Guidelines and implementation of policies L-3.5 and N-4.8 of the 2030
Comprehensive Plan EIR, adopted in compliance with Mitigation Measure HYD-2 outlined in the
2017 EIR, impacts associated with construction dewatering would be less than significant.
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Therefore, this impact would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
c.(i) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner which would result in substantial erosion or siltation
on- or off-site?
c.(ii) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner which would substantially increase the rate or amount
of surface runoff in a manner which would result in flooding on- or off-site?
c.(iii) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner that would create or contribute runoff water which
would exceed the capacity of existing or planned stormwater drainage systems or provide
substantial additional sources of polluted runoff?
c.(iv) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner which would impede or redirect flood flows?
Similar to Scenario 6 of the 2017 EIR, the proposed HEU would not convert open space areas,
creeks, or wetlands to impervious surfaces or require the alteration of the course of an existing
stream or river. The proposed HEU would facilitate development on non-vacant and
underutilized sites in urbanized areas. Future development would be required to implement
construction phase BMPs as well as post-construction site design measures, source control
measures, and stormwater LID treatment measures. Additionally, future development that
disturbs one or more acre of land would be required to prepare and submit a SWPPP to the
State Water Resources Control Board (SWRCB) that describes the measures to control
discharges from construction sites. Pursuant to PAMC Chapter 16.28, projects that apply for a
grading permit must also comply with the City of Palo Alto’s grading and erosion and sediment
control requirements, which require project applicants to submit an erosion and sediment
control plan for review by the city prior to the issuance of grading permits. Furthermore,
pursuant to Chapter 16.11 of the PAMC, permanent stormwater pollution prevention measures
must also be incorporated into future projects.
MRP-regulated projects would be required to treat 80 percent or more of the volume of annual
runoff for volume-based treatment measures. Projects that create or replace 2,500 square feet
or more, but less than 10,000 square feet, of impervious surface must implement site design
measures to reduce stormwater runoff. All future development that satisfies Provision C.3 of
the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) would be
required to implement post-construction stormwater controls into the design of the project.
New on-site storm drain systems in the city must be designed to convey the stormwater runoff
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from a 10-year storm and project applicants must demonstrate that the runoff discharged from
the site to the City’s storm drain system will not exceed its carrying capacity. In addition, the
City’s Department of Public Works requires new development to provide storm drain flow and
detention calculations that compare pre- and post-project flow rates and volumes. The
calculations must be signed and stamped by a registered civil engineer. On-site stormwater
detention may also be required to lessen the project’s impact on the City’s storm drain system.
A final grading and drainage plan must be prepared by a licensed professional that shows the
existing and proposed on-site drainage layout, locations, and elevations and shows the
conveyance of stormwater to the nearest City storm drain system. Existing drainage patterns,
including the accommodation of off-site runoff, must be maintained (City of Palo Alto 2017a).
Therefore, facilitation of development on already built-out sites and compliance with existing
State and local regulations related to stormwater would reduce impacts to a less than
significant level. Therefore, this impact would be less than significant, and would be generally
the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because
there would be no new or substantially more severe significant impacts than what was analyzed
in the 2017 EIR, further analysis is not warranted.
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to
project inundation?
As discussed in the 2017 EIR, only the Baylands area of Palo Alto is within a tsunami inundation
zone and this is a large area of undisturbed marshlands open for recreational access. None of
the housing inventory sites facilitated by the proposed HEU would be located in the Baylands
area. Additionally, mud and debris flows can occur in the southern, mountainous area of Palo
Alto. These areas are maintained as open space and none of the housing inventory sites are
located within areas susceptible to mud or debris flows. The proposed HEU would facilitate
development on flat and urbanized sites away from crests and steep ridges. Therefore, impacts
would be less than significant, and would be generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
e. Would the project conflict with or obstruct implementation of a water quality control plan
or sustainable groundwater management plan?
As discussed under Impact (a), the proposed HEU would not violate water quality or degrade
water quality during construction or operation.
The City of Palo Alto is under the jurisdiction of the San Francisco Bay RWQCB. The San
Francisco Bay RWQCB provides permits for projects that may affect surface waters and
groundwater locally and is responsible for preparing the Water Quality Control Plan for the San
Francisco Bay Basin (Basin Plan). The Basin Plan designates beneficial uses of water in the
region and establishes narrative and numerical water quality objectives. The Basin Plan serves
as the basis for the San Francisco Bay RWQCB’s regulatory programs and incorporates an
implementation plan for achieving water quality objectives (California Water Board 2017). The
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proposed project would not interfere with the objectives and goals in the Basin Plan. This
impact would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations as well as policies adopted in compliance with Mitigation
Measure HYD-2 pertaining to hydrology and water quality which would reduce impacts to a less
than significant level. Therefore, the project would not result in new significant effects not
addressed in the prior EIR, and no new mitigation measures are warranted. This issue does not
require further study in an EIR.
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11 Land Use and Planning
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Physically divide an
established community?
EIR Page 4.9-13
through 4.9-15
No No No N/A
b. Cause a significant
environmental impact
due to a conflict with any
land use plan, policy, or
regulation adopted for
the purpose of avoiding
or mitigating an
environmental effect?
EIR Pages 4.9-3
through 4.9-13
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.9, Land Use and Planning, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s
impacts related to land use. The 2017 EIR found that the 2030 Comprehensive Plan could
adversely change the type or intensity of existing or planned land use patterns in the area, and
therefore mitigation measure LAND-1 would be required to guide the change in density and
character in order to avoid or minimize potential impacts to a less than significant level.
Additionally, the 2030 Comprehensive Plan would allow development that could be
incompatible with adjacent land uses or with the general character of the surrounding area,
including density and building height. Therefore, implementation of mitigation measures LAND-
2 would be required to ensure development is compatible with adjacent land uses and that the
general character in Palo Alto is maintained. The 2030 Comprehensive Plan states that the 2030
Comprehensive Plan would not allow development that could conflict with established
residential, recreational, educational, religious, or scientific uses of an area; would not allow
new development that could conflict with any applicable City land use plan, policy or regulation
adopted for the purpose of avoiding or mitigating an environmental effect; and would not
conflict with an applicable habitat conservation plan or natural community plan. However,
Scenario 6 of the 2030 Comprehensive Plan would include transportation improvements at
existing roadways and rail corridors that could potentially physically divide existing
communities. As a result, Mitigation Measure LAND-5 would be required to promote
connectivity and context-sensitive design of infrastructure improvements and to reduce
impacts to a less than significant level.
Table 20 lists mitigation measures related to land use and planning in the 2017 EIR.
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Table 20 2017 EIR Mitigation Measures: Land Use and Planning
Mitigation
Measure # Mitigation Text
Impact LAND-1: The proposed Plan could adversely change the type or intensity of existing or planned land use patterns in
the area. (Potentially Significant and Mitigable)
LAND-1 To ensure that the intensity of future development would not adversely change the land use patterns or
affect the livability of Palo Alto neighborhoods, the proposed Plan shall include policies that address the
following topics:
Strengthening of residential neighborhoods.
Vitality of commercial areas and public facilities.
High-quality building and site design.
Architectural compatibility of new development.
Promotion of appropriate infill development.
Gradual transitions in the scale of development where residential districts abut more intense uses.
Impact LAND-2: The proposed Plan would allow development that could be incompatible with adjacent land uses or with
the general character of the surrounding area, including density and building height. (Potentially Significant and
Mitigable)
LAND-2 Implement Mitigation Measure LAND-1. In addition, to further reduce potential impacts to visual
character and ensure compatibility with adjacent land uses, the proposed Plan shall include policies that
address the following topic:
Architectural standards that address land use transitions.
Impact LAND-5: The proposed Plan could physically divide an established community. (Potentially Significant and
Mitigable)
LAND-5 To avoid potential impacts from physically dividing an established community, the proposed Plan shall
include policies that address the following topics:
Enhanced connections to and from parks, schools, and community facilities for all users.
Safe and convenient pedestrian, bicycle, and transit connections between residential areas and
commercial centers.
Cooperation with other agencies to improve circulation connections.
Grade separation of rail crossings.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project physically divide an established community?
The proposed HEU would not divide a community; rather, it is designed to meet the City’s
RHNA and includes implementation programs that would promote the development of existing
non-vacant, underdeveloped, or underutilized sites, thereby locating people closer to existing
employment, goods and services within an established community. Unlike Scenario 6 of the
2017 EIR, which included changes to transportation infrastructure, the proposed HEU would
not involve the construction of barriers, such as new roads or other linear development or
infrastructure, that would divide the existing communities or neighborhoods. Existing roadways
would not be permanently blocked, and temporary construction would not limit access to a
community or restrict movement within a community. Nonetheless, future development would
continue to implement policies T-1.17 and T-1.19 of the 2030 Comprehensive Plan EIR, adopted
in compliance with Mitigation Measure LAND-5 from the 2017 EIR, which would further reduce
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impacts to a less than significant level. Therefore, this impact would be less than significant
with mitigation, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
b. Would the project conflict with any applicable land use plan, policy, or regulation of an
agency with jurisdiction over the project (including but not limited to the general plan,
specific plan, local coastal program, or zoning ordinance) adopted for the purpose of
avoiding or mitigating an environmental effect?
The proposed HEU would provide a framework for introducing new housing at all levels of
affordability that is within access to transit, jobs, services, and open spaces. Through its
identification of sites for future development and implementation of housing programs, the
project would encourage development of up to 6,695 new residential units, which would
address the City’s fair share housing needs as quantified in the RHNA plus buffer. As shown in
Table 2, with entitled and proposed development, ADUs, underutilized sites with no rezoning
required, and rezoning to meet the RHNA, a total of 6,807 units can be accommodated, which is
more than the RHNA plus 10 percent buffer of 6,695 units.
The proposed HEU would also include zoning ordinance and zoning map amendments to
increase permitted density, floor area, and height in the RM-20, RM-30, CN, CC, and CS zones,
and permit residential development in the ROLM and GM zones. Although the proposed HEU
would allow residential development in the ROLM and GM zones, the corresponding
Research/Office Park Comprehensive Plan land use designations for these zones already permit
multi-family residential uses and mixed use.
The following analysis discusses the project’s consistency with relevant and applicable plans
and regulations, including Plan Bay Area 2050 and the 2030 Comprehensive Plan. Consistency
with Plan Bay Area is presented in Table 21, and consistency with the Comprehensive Plan is
presented in Table 22. The project is determined to be either “consistent” or “inconsistent”
with the identified goals and policies.
PLAN BAY AREA 2050
As shown in Table 21, the project would be consistent with the key goals and strategies of Plan
Bay Area 2050. Therefore, the project would not conflict with Plan Bay Area 2050 and impacts
would be less than significant.
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Table 21 Project Consistency with Plan Bay Area 2050
Measure Proposed HEU Project Consistency
Housing. Spur Housing Production for Residents of all Income Levels
H1. Further strengthen renter protections
beyond state law. Building upon recent tenant
protection laws, limit annual rent increases to the
rate of inflation, while exempting units less than
10 years old.
Consistent. The HEU analyzes housing needs for present and future
residents. The City’s Regional Housing Needs Assessment (RHNA)
allocation is 6,086 units, which are distributed across over four income
levels. The units would be distributed as is over the four income levels:
1,556 extremely low and very low units, 896 low units, 1,013 moderate
units, and 2,621 above moderate units. The allocation described would
be protected and not altered. Furthermore, Policy 4.3 of the proposed
HEU encourages new high-quality rental housing and Program 6.6
ensures fair housing by instituting tenant protections to prevent anti-
displacement and requiring a 90-day notice for rent increases of 6
percent instead of the State’s 10 percent threshold for noticing.
H2. Preserve existing affordable housing. Acquire
homes currently affordable to low and middle-
income residents for preservation as permanently
deed-restricted affordable housing.
H4. Build adequate affordable housing to ensure
homes for all. Construct enough deed-restricted
affordable homes to fill the existing gap in housing
for the unhoused community and to meet the
needs of low-income households.
Consistent. As described above, the Housing Element Update is
required to provide 1,556 extremely low and very low units, 896 low
units, and 1,013 moderate units. Affordable housing would be
preserved for these income levels. HEU Goal 2.0 Affordable Housing
and policies and programs under this goal would ensure housing
affordability in Palo Alto especially for people at the lowest income
levels.
H3. Allow a greater mix of housing densities and
types in Growth Geographies. Allow a variety of
housing types at a range of densities to be built in
Priority Development Areas, select Transit-Rich
Areas and Select High-Resource Areas.
Consistent. As shown in Figure 2-3 of the Project Description (Housing
Element Update Sites Inventory Locations), many of the housing
inventory sites are generally located in areas near major transportation
corridors such as along El Camino Real or in transit-accessible Priority
Development Areas (PDAs) such as the California Avenue area and the
Downtown area, as well as near existing residential and commercial
development. HEU Policies 3.1, 3.3, and 4.4 also aim to promote
transit-oriented new construction and encourage construction of new
high-density housing on major transit corridors in proximity to transit
stations.
H5. Integrate affordable housing into all major
housing projects. Require a baseline of 10-20% of
new market-rate housing developments of five
units or more to be affordable to low-income
households.
Consistent. Pursuant to the City’s Below Market Rate (BMR) Housing
Purchase Program, the city requires that developers for new
development with three or more residential units to contribute at least
15 percent of those units at below market rates, and projects with
seven or more units are required to provide one or more BMR units
within the development (City of Palo Alto 2023). Additionally, HEU Goal
2.0 Affordable Housing aims to ensure Palo Alto residents have access
to quality housing at a range of housing options and prices.
EN4. Maintain urban growth boundaries. Using
urban growth boundaries and other existing
environmental protections, focus new
development within the existing urban footprint
or areas otherwise suitable for growth, as
established by local jurisdictions.
Consistent. The proposed HEU would facilitate development of
housing on underutilized sites in urbanized areas of the city, which
would reduce pressure to develop open space areas. By placing
residents close to jobs, commercial services, and alternative methods
of transportation, the project would reduce greenhouse gas emissions
and other criteria pollutants associated with vehicle use to help
communities stay healthy and safe.
Source: ABAG 2021
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CITY OF PALO ALTO 2030 COMPREHENSIVE PLAN
As shown in Table 22, the project would be consistent with the goals, policies, and actions
within the 2030 Comprehensive Plan. As noted under Government Code Section 65589.5(a),
the Legislature has concluded that “the lack of housing, including emergency shelters, is a
critical problem that threatens the economic, environmental, and social quality of life in
California.” More specifically, the Legislature’s stated intent is “to assure that counties and
cities recognize their responsibilities in contributing to the attainment of the state housing
goal…to assure that counties and cities will prepare and implement housing elements
which…will move toward attainment of the state housing goal” (Government Code Section
65581). The project would help meet the city’s RHNA allocation, as well as efficiently utilize
non-vacant, underutilized, and underdeveloped lots within the city to increase the supply of
housing. The project would encourage development of housing, which is supportive of the city’s
goal and policies.
Table 22 Project Consistency with Relevant 2030 Comprehensive Plan Goals and Policies
Comprehensive Plan Policy Proposed HEU Project Consistency
Land Use Element
Policy L-1.2: Limit future urban development to
currently developed lands within the urban service
area. The boundary of the urban service area is
otherwise known as the urban growth boundary.
Retain undeveloped land west of Foothill Expressway
and Junipero Serra as open space, with allowances
made for very low-intensity development consistent
with the open space character of the area. Retain
undeveloped land northeast of Highway 101 as open
space.
Consistent. Most of the housing inventory sites are located in
areas near major transportation and commercial corridors such as
along El Camino Real or in transit-accessible PDAs such as the
California Avenue area and the Downtown area, or are located in
commercial areas such as GM/ROLM zones. None of the housing
inventory sites are located in areas designated as open space.
Policy L-2.4: Use a variety of strategies to stimulate
housing, near retail, employment, and transit, in a
way that connects to and enhances existing
neighborhoods.
Consistent. As shown in Figure 3of the Project Description
(Housing Element Update Sites Inventory Locations), most of the
housing inventory sites are located in areas near major
transportation and commercial corridors such as along El Camino
Real or in transit-accessible PDAs such the California Avenue area
and the Downtown area, as well as near existing residential and
commercial development. The proposed HEU would also
encourage residential uses in areas shown on Figure 4 and
Figure 5. These areas are located near existing services. The
addition of housing in the GM/ROLM zones shown on Figure 4
would place housing near services (including those in Mountain
View) and on underutilized commercial parcels. Overall, the
proposed HEU would create walkable neighborhoods and increase
transit ridership.
Policy L-2.8: When considering infill redevelopment,
work to minimize displacement of existing residents.
Consistent. The proposed HEU would facilitate development on
non-vacant and underutilized sites. Program 6.6 of the HEU
ensures tenant protections and prevents anti-displacement.
Policy L-2.9: Facilitate reuse of existing buildings. Consistent. The proposed HEU would not hinder reuse of existing
buildings by facilitating development on non-vacant and
underutilized sites in urbanized areas.
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Comprehensive Plan Policy Proposed HEU Project Consistency
Policy L-1.3: Infill development in the urban service
area should be compatible with its surroundings and
the overall scale and character of the city to ensure a
compact, efficient development pattern.
Policy L-3.1: Ensure that new or remodeled structures
are compatible with the neighborhood and adjacent
structures.
Policy L-6.1: Promote high-quality design and site
planning that is compatible with surrounding
development and public spaces.
Policy L-6.2: Use the Zoning Ordinance, design review
process, design guidelines and Coordinated Area
Plans to ensure high quality residential and
commercial design and architectural compatibility.
Consistent. Development facilitated by the proposed HEU would
be subject to the City’s Major Architectural Review which includes
a hearing and recommendation by the Architectural Review Board
on whether the individual project is consistent with the findings for
Architectural Review outlined in PAMC Section 18.76.020. This
process aims to promote orderly and harmonious development in
the city and promote visual environments that are of high
aesthetic quality and variety and which, at the same time, are
considerate of each other. Additionally, future development in
locations within specific area plans would be required to adhere to
development guidelines outlined within the respective
coordinated area plans, such as the North Ventura Coordinated
Area Plan following its adoption. If projects qualify for streamlined
review, multifamily projects would be subject to objective design
standards that aim to create high-quality design and compatibility
with surrounding uses and character.
Transportation Element
Policy T-1.3: Reduce GHG and pollutant emissions
associated with transportation by reducing VMT and
per-mile emissions through increasing transit options,
supporting biking and walking, and the use of zero-
emission vehicle technologies to meet City and State
goals for GHG reductions by 2030.
Consistent. As shown in Figure 3 (Housing Element Update Sites
Inventory Locations), most of the housing inventory sites are
located in areas near major transportation corridors such as along
El Camino Real, or in transit-accessible PDAs such as the California
Avenue area and the Downtown area, as well as near existing
residential and commercial development. HEU Policies 3.1, 3.3, and
4.4 also aim to promote transit-oriented new construction and
encourage construction of new high-density housing on major
transit corridors in proximity to transit stations. The addition of
housing in the GM/ROLM zones shown on Figure 4 would place
housing near services (including those in Mountain View) and on
underutilized commercial parcels. Pursuant to Section 16.14.420 of
the PAMC, new multi-family residences would be required to
provide at least one EVSE Ready outlet or EVSE installed for each
residential unit in the structure for residential parking, and would
be required to provide Conduit Only, EVSE Ready Outlet, or EVSE
installed for at least 25 percent of guest parking spaces, among
which at least 5 percent shall be EVSE installed. Future
development facilitated by the project would be required to
comply with the most updated EV requirements in both the City’s
Reach Code and Title 24 at the time of construction.
Source: City of Palo Alto 2017b
As shown in Table 21 and Table 22, the proposed HEU would not conflict with applicable goals
and policies in Plan Bay Area 2050 or the 2030 Comprehensive Plan. Therefore, impacts would
be less than significant, and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not physically divide an
established community or conflict with any applicable land use plan, policy, or regulation, and
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impacts would be less than significant with mitigation. Therefore, the project would not result
in new significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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12 Mineral Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Result in the loss of
availability of a known
mineral resource that would
be of value to the region and
the residents of the state?
EIR Pages 7-2
through 7-3
No No No N/A
b. Result in the loss of
availability of a locally
important mineral resource
recovery site delineated on a
local general plan, specific
plan, or other land use plan?
EIR Pages 7-2
through 7-3
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The City’s Comprehensive Plan EIR analyzes mineral resources in Chapter 7, CEQA-Mandated
Sections, and found that no impacts related to mineral resources would occur.
PROJECT-SPECIFIC IMPACTS
a. Would the project result in the loss of availability of a known mineral resource that would be
of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource
recovery site delineated on a local general plan, specific plan, or other land use plan?
According to the 2017 EIR, most of the city is classified as MRZ-19, MRZ-3 10, or MRZ-4 11,
meaning that no significant mineral deposits are present or data does not exist to identify the
significance of mineral deposits (City of Palo Alto 2017a). Therefore, there would be no impacts
regarding mineral resources, generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because here would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
9 MRZ-1: Adequate information indicates that no significant mineral deposits are present or likely to be present.
10 MRZ-3: The significance of mineral deposits cannot be determined from the available data.
11 MRZ-4: There is insufficient data to assign any other MRZ designation.
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CONCLUSION
As with what was analyzed under the 2017 EIR, there would be no impacts related to mineral
resources. Therefore, the project would not result in new significant effects not addressed in
the prior EIR, and no new mitigation measures are warranted. This issue does not require
further study in an EIR.
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13 Noise
Where was
Impact
Analyzed
in the EIR?
Could
Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project result in:
a. Generation of a substantial
temporary or permanent
increase in ambient noise levels
in the vicinity of the project in
excess of standards established
in the local general plan or
noise ordinance, or applicable
standards of other agencies?
EIR Pages
4.10-2
through
4.10-18;
4.10-21
through
4.10-26
No No No Yes
b. Generation of excessive
ground-borne vibration or
groundborne noise levels?
EIR Pages
4.10-18
through
4.10-21
No No No N/A
c. For a project located within the
vicinity of a private airstrip or
an airport land use plan or,
where such a plan has not been
adopted, within two miles of a
public airport or public use
airport, would the project
expose people residing or
working in the project area to
excessive noise levels?
EIR Pages
4.10-26
through
4.10-28
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.10, Noise, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts related to
on-site operational noise, traffic noise, and construction noise. The 2017 EIR found that impacts
related to long-term non-transportation, operational noise would be potentially significant due
to zoning changes for commercial and residential uses, and mitigation measure NOISE-1a would
be required to reduce impacts to a less than significant level. The 2017 EIR also found that
transportation noise impacts related to aircraft and railway noise sources would be potentially
significant due to encroachment of land uses near aircraft facilities, along with unknown future
operations patterns, which could potentially result in unacceptable aircraft-related noise
environments from one or both of these Palo Alto-based facilities (Stanford University Hospital
helipad and the Palo Alto Airport). Therefore, mitigation measures NOISE-1b and NOISE-1c
would be required to reduce impacts to a less than significant level. Additionally, the 2030
Comprehensive Plan would have the potential to result in noise level increases such that Ldn
would increase by three dB, causing the Ldn in existing residential areas to exceed 60 dBA.
Implementation of mitigation measures NOISE-2 and NOISE-3 would be required to reduce
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impacts from long-term operational noise as well as transportation noise related to aircraft and
railway noise to a less than significant level.
The 2017 EIR determined that the 2030 Comprehensive Plan would have the potential to result
in indoor noise levels for residential development to exceed 45 dB Ldn, and mitigation measures
NOISE-4a and NOISE-4b would be required to reduce indoor noise impacts to a less than
significant level. Furthermore, the 2030 Comprehensive Plan would have the potential to
expose persons to or generate excessive ground-borne vibration or ground-borne noise levels,
and therefore impacts related to temporary construction-related vibration, long-term
operational vibration, and railway-related vibration could be potentially significant, requiring
implementation of mitigation measures NOISE-5a and NOISE-5b to reduce vibration impacts to
a less than significant level. The 2017 EIR also concluded that the 2030 Comprehensive Plan
would have the potential to expose people to noise levels in excess of established State
standards and standards established in the local General Plan or noise ordinance since previous
Comprehensive Plan policies do not require acoustical analyses to demonstrate compliance
with applicable interior or exterior noise compatibility standards. Therefore, implementation of
mitigation measures NOISE-6 and NOISE-7 would be required to ensure that pertinent exterior
and interior noise environments would comply with City guidelines and State standards.
Additionally, the 2030 Comprehensive Plan could result in a potentially substantial temporary
or periodic increase in ambient noise levels in the project vicinity above levels existing without
the project since certain construction activities may lead to substantial temporary or periodic
increases to ambient noise levels. Mitigation measure NOISE-8 would be required to reduce
impacts to a less than significant level.
The 2017 EIR found that the 2030 Comprehensive Plan would not expose people residing or
working within an airport land use plan or within two miles of a public airport to excessive noise
levels since all areas of Palo Alto are miles outside of the pertinent 65 dBA CNEL noise contour
of medium or large airports including the Moffett Federal Airfield (KNUQ), San Carlos Airport
(KSQL), San Jose International Airport (SJC), San Francisco International Airport (SFO), and
Oakland International Airport (OAK). Additionally, since only airport property and the golf
course – neither of which are noise-sensitive land uses – are within the Palo Alto Airport’s 60
dBA CNEL noise contours, within-city public airport noise impacts would also be less than
significant.
Table 23 lists mitigation measures related to noise in the 2017 EIR.
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Table 23 2017 EIR Mitigation Measures: Noise
Mitigation
Measure # Mitigation Text
Impact NOISE-1: Implementation of the proposed Plan would have the potential to cause the average 24-hour noise level
(Ldn) to increase by 5.0 decibels (dB) or more in an existing residential area, even if the Ldn would remain below 60 dB.
(Potentially Significant and Mitigable)
NOISE-1a To ensure that average 24-hour noise levels associated with long term operational noise would not
increase by 5.0 decibels (dB) or more in an existing residential area, the proposed Plan shall include
policies that address the following topics:
Location of land uses in areas with compatible noise environments.
Use of the guidelines in the “Land Use Compatibility for Community Noise Environment” table to
evaluate the compatibility of proposed land uses with existing noise environments.
Clear guidelines for maximum outdoor noise levels in residential areas.
Adherence to the interior noise requirements of the State of California Building Standards Code (Title
24) and the Noise Insulation Standards (Title 25).
Inclusion of a noise contour map in the proposed Plan.
Reduction of noise impacts of development on adjacent properties.
Updating for clarity the Noise Ordinance to make enforcement easier.
NOISE-1b To ensure that aircraft noise would not increase average 24-hour noise levels by 5.0 decibels (dB) or more
in an existing residential area, the proposed Plan shall include policies that address the following topics:
Compliance with the airport-related land use compatibility standards for community noise
environments.
Prohibition of incompatible land use development within the 60 dBA CNEL noise contours of the Palo
Alto airport, as established in the adopted County of Santa Clara Airport Land Use Commission
Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport.
NOISE-1c To ensure that railway noise would not increase average 24-hour noise levels by 5.0 decibels (dB) or more
in an existing residential area, the proposed Plan shall include policies that address the following topics:
Noise spillover from rail-related activities into adjacent noise-sensitive areas.
Reduction of impacts from noise and ground borne vibrations associated with rail operations.
Guidelines for interior noise levels.
Requirements for vibration impact analysis for future development projects.
Impact NOISE-2: Implementation of the proposed Plan would not cause the Ldn to increase by three dB or more in an
existing residential area, thereby causing the Ldn in the area to exceed 60 dB. (Significant and Mitigable)
NOISE-2 Implement Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
Impact NOISE-3: Implementation of the proposed Plan would have the potential to cause an increase of three dB or more
in an existing residential area where the Ldn currently exceeds 60 dB. (Potentially Significant and Mitigable)
NOISE-3 Implement Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
Impact NOISE-4: Implementation of the proposed Plan would have the potential to result in indoor noise levels for
residential development to exceed an Ldn of 45 dB. (Potentially Significant and Mitigable)
NOISE- 4a Implement Mitigation Measure NOISE-1a.
NOISE-4b The Land Use Noise Compatibility Guidelines established in the current Comprehensive Plan shall be
maintained under all six scenarios.
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Mitigation
Measure # Mitigation Text
Impact NOISE-5: Implementation of the proposed Plan would have the potential to expose persons to or generate
excessive ground-borne vibration or ground-borne noise levels.(Potentially Significant and Mitigable)
NOISE-5a To ensure that future development would not result in significant construction-related vibration impacts,
the proposed Plan shall include policies that address the following topics:
Requirements for construction and operations vibration impact analysis, to be prepared by a qualified
acoustical consultant for development projects.
Requirements for vibration mitigation plans to ensure compliance with the pertinent industry
standards and City guidelines for projects that would experience vibration impacts during construction
or operations.
Limits for construction and operations vibration around vibration-sensitive receptors.
NOISE-5b Implement Mitigation Measure NOISE-1c.
Impact NOISE-6: Implementation of the proposed Plan would have the potential to expose people to noise levels in excess
of established State standards. (Potentially Significant and Mitigable)
NOISE-6 Implement Mitigation Measures NOISE-4a and NOISE-4b
Impact NOISE-7: Implementation of the proposed Plan would have the potential to result in the exposure of persons to or
generation of noise levels in excess of standards established in the local General Plan or noise ordinance, or applicable
standards of other agencies. (Potentially Significant and Mitigable)
NOISE-7 Implement Mitigation Measures NOISE-1a, NOISE-1b, NOISE-1c, NOISE-4a, and NOISE-4b.
Impact NOISE-8: Implementation of the proposed Plan could result in a potentially substantial temporary or periodic
increase in ambient noise levels in the project vicinity above levels existing without the project. (Potentially Significant
and Mitigable)
NOISE-8 To ensure that future development would not result in significant impacts to sensitive receptors from
construction noise, the proposed Plan shall include policies that address the following topics:
Construction noise limits around sensitive receptors.
Monitoring and reporting plans for construction noise levels of larger development projects.
Noise control measures to ensure compliance with the noise ordinance.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project result in generation of a substantial temporary or permanent increase in
ambient noise levels in the vicinity of the project in excess of standards established in the
local general plan or noise ordinance, or applicable standards of other agencies?
Standards for interior noise in Palo Alto are currently determined primarily through the Land
Use Noise Compatibility Guidelines and interior noise standards set by Title 24 of the State
Building Code, while standards for exterior noise are currently determined primarily through
the City’s Noise Ordinance, or PAMC Chapter 9.10, and PAMC Section 18.42.190 which outlines
requirements for noise and vibration. Although the proposed HEU would include 665 more
residential units compared to buildout analyzed in the 2017 EIR and could therefore result in an
increased amount of noise in excess of established standards, future development requiring
discretionary approval would be required to conduct project-level acoustical analysis pursuant
to Section 18.42.190 of the PAMC to demonstrate consistency with applicable land use
compatibility requirements and noise standards.
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CONSTRUCTION NOISE IMPACTS
Noise from increased construction could also temporarily or periodically increase ambient noise
levels within the city. Engine noise reduction technology, including silencers, continues to
improve, but heavy construction equipment still generates noise exceeding ambient levels that
could cause intermittent annoyance to nearby receivers. Even with adherence to the city’s
allowed construction hours of 8 a.m. through 6 p.m. on Monday to Friday and 9 a.m. through 6
p.m. on Saturday, as well as maximum construction noise levels of 110 dBA at a distance of 25
feet pursuant to PAMC Section 9.10.060, it is likely that in certain cases these and other
available methods to reduce noise would be inadequate to prevent a significant impact.
Therefore, future development would also be required to comply with Policy N-6.11 of the
2030 Comprehensive Plan, adopted in compliance with Mitigation Measure NOISE-8 of the
2017 EIR which would reduce noise impacts to a less than significant level. Therefore, this
impact would be less than significant with mitigation, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
TRANSPORTATION-RELATED NOISE IMPACTS
AIRPORT/HELIPORT NOISE
As discussed in the 2017 EIR, because Palo Alto has only one heliport at Stanford University
Hospital, and one airport, the Palo Alto Airport, notable increases in ambient noise levels from
air traffic are not anticipated. However, encroachment of land uses near these aircraft facilities,
along with unknown future operations patterns, could potentially result in unacceptable
aircraft-related noise environments from one or both of these Palo Alto-based facilities. Aircraft
operations may cause the Ldn to increase by five DB or more in an existing residential area. The
proposed HEU does not envision housing inventory sites in proximity to the Stanford University
Hospital helipad, and the closest housing inventory site from the Palo Alto Airport would be
located approximately three miles southeast. As with the 2017 EIR, future development would
be required to comply with policies L-10.3 and N-6.12 of the 2030 Comprehensive Plan, adopted
in compliance with Mitigation Measure NOISE-1b, which would reduce impacts from airport or
heliport noise to a less than significant level, generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
RAILWAY NOISE
As discussed in the 2017 EIR, with only one single railway alignment through the city, railway
operations (primarily Caltrain pass-bys) are not anticipated to notably increase community
noise levels, except in the immediate vicinity of the rail lines. However, the 2017 EIR
determined that since a definitive assessment of operations increases cannot be determined,
future railway operations could potentially cause the Ldn to increase by five dB or more in an
existing residential area. Since the proposed HEU would facilitate an increased number of units
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NOISE
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along Alma Street where Caltrain runs parallel, impacts could potentially be significant.
However, future development would be required to comply with policies N-6.11 and N-6.14 of
the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measure NOISE-1c,
which would reduce impacts from railway noise to a less than significant level, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive. Because there would
be no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
OPERATIONAL NOISE IMPACTS
As discussed in the 2017 EIR, development would have the potential to receive noise from both
highways and major arterials, and certain areas would require special noise-insulating features
or construction techniques. Project-level acoustical analyses, at a minimum, would need to
examine portions of individual housing sites nearest to major transportation corridors to
measure current, 24-hour ambient noise levels and determine appropriate site design and/or
construction techniques for noise attenuation. Future development facilitated by the proposed
HEU would be required to conduct project-level acoustical analysis pursuant to Section
18.42.190 of the PAMC, and would be required to comply with policies N-6.1, 6.2, and 6.6 of
the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measure NOISE-1a of the
2017 EIR, which would reduce impacts on interior noise to a less than significant level, generally
the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
The project allows for higher density/intensity land uses in some areas of Palo Alto than
currently permitted, leading to additional vehicle trips on area roadways. Under full buildout of
the project, an estimated 665 new units compared to buildout in the 2030 Comprehensive Plan
would be added to Palo Alto. By generating new vehicle trips, new development would
incrementally increase the exposure of land uses along roadways to traffic noise. Development
facilitated by the project would increase vehicle trips and VMT in Palo Alto, depending on the
location and intensity of individual projects. As discussed under Section 3, Air Quality, the
proposed HEU would increase residential VMT from 2015 conditions by 26 percent (though the
VMT per resident would be expected to decrease). It is unlikely that a VMT growth of 26
percent would result in a 100 percent increase in traffic volumes on a given roadway segment.
When analyzing roadway vehicle trips, a three dBA increase in noise is considered noticeable. A
40 percent increase in trips equates to a noise increase of less than 1.5 decibels. A 1.5 dBA
increase in noise would not be perceptible, and the increase in traffic volumes on any given
roadway segment is expected to be below 40 percent. A doubling of traffic volumes would be
required to reach the threshold of noticeability (a 3-dba increase in noise levels). A doubling of
traffic volumes on a roadway (i.e., a 100 percent increase) is not anticipated under the project,
considering VMT is only anticipated to increase by 26 percent. Traffic volumes on streets would
not increase by 40 percent on average, and therefore increases in traffic noise would be less
than perceptible. Increases in roadway noise would be less than significant generally the same
as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would
be no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
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LONG-TERM OPERATIONAL NOISE IMPACTS
As discussed in the 2017 EIR, zoning changes could result in noise level increases such that Ldn
would increase by three dB, causing the Ldn in a residential area to exceed 60 dBA Ldn. The
proposed rezoning that would occur under the proposed HEU would allow for increased
residential density in RM-20, RM-30, CN, CC, and CS zones, and would allow for residential uses
in non-residential zones such as ROLM and GM zones. Therefore, as with the 2017 EIR, impacts
would be potentially significant. However, future development would be required to comply
with policies N-6.1, 6.2, and 6.6 of the 2030 Comprehensive Plan, adopted in compliance with
Mitigation Measures NOISE-2 and NOISE-3 of the 2017 EIR, which would reduce impacts from
long-term operational noise to a less than significant level, generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project result in generation of excessive groundborne vibration or groundborne
noise levels?
As discussed in the 2017 EIR, groundborne vibration can be related to short-term impacts from
construction activities, on-going impacts related to operation, or on-going impacts related to
rail pass-bys.
CONSTRUCTION VIBRATION IMPACTS
Since the proposed HEU would include 665 more residential units compared to Scenario 6 of
the 2017 EIR, vibration resulting from construction activities could occur more frequently;
however, the intensity of vibration would be similar as analyzed previously as the type of
equipment anticipated would be similar. Overall, vibration impacts related to construction
would be short-term, temporary, and generally restricted to the areas in the immediate vicinity
of active construction equipment. Methods to reduce vibration during construction would
include the use of smaller equipment, use of well-maintained equipment, use of static rollers
instead of vibratory rollers, and drilling of piles as opposed to pile driving. Methods to reduce
human impacts of vibration from construction include limitations on construction hours and/or
guidelines for the positioning of vibration-generating construction equipment. Construction
would be localized and would occur intermittently for varying periods of time. Because specific,
project-level information is not available at this time, it is not possible to quantify construction-
related vibration impacts at specific sensitive receptors. Future development requiring
discretionary approval would be required to undergo individual review to ensure construction
vibration impacts are reduced. Nonetheless, vibration impacts could be potentially significant
and construction of future development would be required to comply with policies N-6.3, 6.11,
and 6.14 of the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measures
NOISE-5a and NOISE-5b of the 2017 EIR, which would reduce construction-related vibration
impacts to a less than significant level, generally the same as the impact analyzed in the 2017
EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
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NOISE
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OPERATIONAL VIBRATION IMPACTS
Future development would have a significant environmental effect involving operational
vibration if it would increase the risk of harm to surrounding properties from such vibrational
hazards. Since operation of residential housing development would not involve activities that
would result in substantial vibration levels, such as use of heavy equipment or machinery, the
project would not have any known environmental impact involving operational vibration.
Additionally, future development would be required to comply with Section 18.42.190 of the
PAMC which contains restrictions regarding the generation of vibration that is perceptible
without instruments at the lot line of the receiving property. Therefore, impacts would be
generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
RAILWAY PASS-BY VIBRATION IMPACTS
CEQA is concerned with the impacts of a project on the environment, and not the impacts of
the environment on a project. A project would not have a significant environmental effect
involving railway pass-by vibration, unless the project would increase the risk of harm to
surrounding properties from such vibrational hazards. Therefore, the project would not have
any known environmental impact involving railway pass-by vibration.
Even if CEQA were concerned with impacts of the environment on projects, the impact would
be less than significant. The 2017 EIR states that Scenario 6 may result in long-term vibration
impacts if sensitive land uses were allowed to be developed in proximity to existing railways.
Since the proposed HEU would include 665 more residential units compared to Scenario 6 of
the 2017 EIR, it would place more sensitive receptors in proximity to existing railways. These
additional receptors would be exposed to similar vibration levels as considered in the 2017 EIR.
While vibration impacts related to rail pass-bys would be short-term, temporary, and generally
restricted to the areas in the immediate vicinity of a railway, vibration effects from on-going rail
pass-bys could be objectionable. These vibration effects can range from no perceptible effects
at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate
levels, to slight structural damage at the highest levels. Vibration from rail pass-bys rarely
reaches the levels that can damage structures, but groundborne vibration and groundborne
noise can reach perceptible and audible levels in buildings that are close to railways. As such,
appropriate setbacks, buffers, and/or other measures can largely eliminate these impacts since
these basic techniques are particularly effective approaches to avoid vibration impacts.
However, individual project review would still be needed to ensure appropriately reduced
vibration impacts arising from rail pass-bys. Future development would also be required to
comply with policies N-6.3, 6.11, and 6.14 of the 2030 Comprehensive Plan, adopted in
compliance with Mitigation Measures NOISE-5a and NOISE-5b of the 2017 EIR, which would
reduce railway pass-by vibration impacts to a less than significant level, generally the same as
the impact for the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new
or substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
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c. For a project located within the vicinity of a private airstrip or an airport land use plan or,
where such a plan has not been adopted, within two miles of a public airport or public use
airport, would the project expose people residing or working in the project area to excessive
noise levels?
As discussed in the 2017 EIR, the City of Palo Alto owns and operates the Palo Alto Airport
(KPAO), a relatively small public air facility which primarily serves single-engine, general aviation
(GA) aircraft. At the nearest points within city limits, Palo Alto is located approximately 2.6
miles to the west of Moffett Federal Airfield (KNUQ), 6 miles to the southeast of San Carlos
Airport (KSQL), 10 miles to the northwest of the San Jose International Airport (SJC), 15 miles to
the southeast of San Francisco International Airport (SFO), and 17 miles to the south of Oakland
International Airport (OAK) (City of Palo Alto 2017a). As shown in Figure 5 of the Palo Alto
Airport CLUP, none of the housing inventory sites are located within the airport’s 55 to 70 CNEL
noise contours, and therefore would not exceed the “Normally Acceptable” noise levels for
compatibility for those land uses. Nonetheless, as with the 2017 EIR, future development would
be required to comply with policies L-10.3 and N-6.12 of the 2030 Comprehensive Plan,
adopted in compliance with Mitigation Measure NOISE-1b, which would reduce impacts from
airport or heliport noise to a less than significant level. Therefore, impacts would be less than
significant with mitigation, and would be generally the same as the impact for the 2017 EIR for
the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would result in less than significant
impacts regarding noise and vibration with implementation of policies adopted in compliance
with Mitigation Measures NOISE-1a through NOISE-1c, NOISE-2, NOISE-3, NOISE-4a and NOISE-
4b, and 5a and 5b of the 2017 EIR. Therefore, the project would not result in new significant
effects not addressed in the prior EIR, and no new mitigation measures are warranted. This
issue does not require further study in an EIR.
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NOISE
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14 Population and Housing
Where was
Impact
Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Induce substantial unplanned
population growth in an area,
either directly (e.g., by
proposing new homes and
businesses) or indirectly (e.g.,
through extension of roads or
other infrastructure)?
EIR Pages
4.11-5
through
4.11-10
No No No Yes
b. Displace substantial numbers
of existing people or housing,
necessitating the construction
of replacement housing
elsewhere?
EIR Pages
4.11-10
through
4.11-13
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.11, Population and Housing, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s
impacts related to population and housing growth. The 2017 EIR found that Scenario 6 of the
2030 Comprehensive Plan could increase the total population from 65,685 persons in 2014 to
79,765 persons in 2030, resulting in an addition of 2,665 persons or a 3.34 percent increase
from ABAG projections. However, the 2017 EIR concluded that the exceedance of ABAG
projections is intended to help to lower the jobs-to employed-resident ratio by providing more
local housing opportunities, thereby helping to alleviate the need for workers to commute to
Palo Alto from other areas of the region. Therefore, the 2030 Comprehensive Plan would not
directly or indirectly induce substantial population growth and impacts would be less than
significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would not displace a substantial
number of existing housing or people or necessitate the construction of replacement housing
elsewhere since the 2015-2023 Housing Element included policies and programs that protect
existing residents, neighborhoods, and housing. Additionally, the 2030 Comprehensive Plan
would not create a substantial imbalance between employed residents and jobs, and impacts
would be less than significant.
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IMPACT ANALYSIS
POPULATION AND HOUSING
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PROJECT-SPECIFIC IMPACTS
a. Would the project induce substantial unplanned population growth in an area, either
directly (for example, by proposing new homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)?
For the purposes of this analysis, buildout under the proposed HEU would add up to 6,665 new
residential units in the city by the year 2031, or approximately 665 residential units more than
what was analyzed under Scenario 6 of the Comprehensive Plan EIR. Based on the estimated
number of 2.51 residents per household, the additional 665 units compared to Scenario 6
would lead to an increase of approximately 1,670 new residents during the housing element
cycle 2023 to 2031 assuming all of the estimated 665 units are built (DOF 2022).
Although the proposed HEU would increase residential units compared to Scenario 6, the State
requires that all local governments adequately plan to meet the housing needs of their
communities. Given that the State is currently in an ongoing housing crisis due to an insufficient
housing supply, the additional units under the proposed project would further assist in
addressing the existing crisis and meeting the housing needs of the City’s communities.
Furthermore, the proposed HEU would first be submitted to the HCD for review and approval
to ensure that it would adequately address the housing needs and demands of the city.
Approval by the HCD would ensure that population and housing growth under the proposed
HEU would not be substantial or unplanned.
Additionally, growth under the proposed HEU would be concentrated in locations where such
development is encouraged by adopted plans due to their proximity to transit and
transportation corridors as well as located near commercial uses and services and on
underutilized sites. The proposed HEU would facilitate infill growth, promote housing in close
proximity to employment opportunities, and support regional planning efforts.
Lastly, this analysis is conservative because it assumes a maximum buildout scenario. The
project’s actual contribution to population growth may be less than estimated. In addition, the
project would not involve the extension of roads or other infrastructure that could indirectly
lead to population growth. The city is mostly developed and is supported by existing public
services and infrastructure which are sufficient to serve the additional housing units. Therefore,
the project would not result in substantial unplanned population growth, either directly or
indirectly, and impacts would be less than significant, generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project displace substantial numbers of existing people or housing, necessitating
the construction of replacement housing elsewhere?
“Substantial” displacement would occur if the proposed project would displace more
residences than would be accommodated through growth facilitated by the project. The goal of
the proposed project is to accommodate and encourage new residential development in Palo
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Alto. A portion of the housing units would be developed at a density range that could
accommodate low and very low-income housing as required to meet the 6th Cycle RHNA.
Development under the proposed HEU would result in 665 more residential units compared to
Scenario 6 of the 2017 EIR. The proposed buildout, in addition to existing and planned housing
projects, would result in an overall increase in available housing which exceeds the City’s RHNA
requirements. Therefore, overall, the proposed HEU would add to the City’s housing stock to
meet housing goals.
On an individual site basis, it is possible that some redevelopment projects could result in
displacement of current residents. However, the proposed HEU includes policies and programs
to reduce displacement impacts. For example, Program 2.2 addresses the potential loss of
rental housing and displacement of lower- and moderate-income households due to new
development and ensures the retainment of a stock of affordable housing through a Below
Market Rate (BMR) Program, while Program 6.6 of the proposed HEU aims to provide fair
housing and Implementing Objective 6 serves to institute tenant protections to prevent anti-
displacement.
Therefore, although the proposed HEU would provide additional housing in excess of RHNA
requirements and Scenario 6, there are policies and programs in place to reduce displacement
resulting from the proposed project, and impacts would be less than significant, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not induce substantial unplanned
population growth or displace substantial numbers of existing people and housing, and impacts
would be less than significant. Therefore, the project would not result in new significant effects
not addressed in the prior EIR, and no new mitigation measures are warranted. This issue does
not require further study in an EIR.
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15 Public Services
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes Involve
New or
Substantially More
Severe Impacts?
Do New
Circumstances
Result in New or
Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address and/or
Resolve
Impacts?
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered
governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could
cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for any of the public services:
a. Fire protection? EIR Page
4.12-9
through
4.12-11
No No No N/A
b. Police protection? EIR Page
4.12-13
through
4.12-14
No No No N/A
c. Schools? EIR Page
4.12-2
through
4.12-7
No No No N/A
d. Parks? EIR Pages
4.12-17
through
4.12-20
No No No N/A
e. Other public
facilities?
EIR Pages
4.12-22
through
4.12-24
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.12, Public Services and Recreation, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to public services. The 2017 EIR states that the 2030 Comprehensive Plan
would not result in an adverse physical impact associated with the construction of additional
school facilities, fire protection facilities, police facilities, and libraries. Impacts would be less
than significant. However, the 2017 EIR found that the 2030 Comprehensive Plan could result in
an adverse physical impact from the construction of additional parks and recreation facilities
since Scenario 6 would require new parkland to accommodate new development and meet the
City’s parkland standard. Therefore, implementation of mitigation measure PS-7 would be
required to reduce impacts to a less than significant level.
Table 24 lists mitigation measures related to public services and recreation in the 2017 EIR.
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Table 24 2017 EIR Mitigation Measures: Public Services and Recreation
Mitigation
Measure # Mitigation Text
Impact PS-7: Implementation of the proposed Plan would result in an adverse physical impact from the construction of
additional parks and recreation facilities in order to maintain acceptable performance standards. (Significant and
Mitigable)
PS-7 To address the potential physical impacts of park construction/improvement, the Comprehensive Plan
Update and/or the Parks, Trails, Natural Open Space and Recreation Master Plan shall incorporate policies
addressing the following topic:
Evaluation and mitigation of construction impacts associated with park and recreational facility
creation and expansion.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered fire protection facilities, or the need for new or
physically altered fire protection facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times or
other performance objectives?
To meet increased demand under the 2030 Comprehensive Plan, the 2017 EIR found that the
City of Palo Alto Fire Department (PAFD) would likely increase staffing for EMS delivery and new
apparatus and fire station improvements or expansions, but would not anticipate the need to
construct a new station, as development would be located in existing urbanized areas already
served by existing PAFD stations. Furthermore, the city’s approved infrastructure plan includes
the replacement of two fire stations (City of Palo Alto 2017a). Fire Station 3 was replaced in
March 2020 to meet the most current California Building Codes (CBC), Essential Services
Building Seismic Safety Act, American with Disabilities Act (ADA), National Fire Protection
Association (NFPA), and OSHA standards, and Fire Station 4 is currently underway and will be
completed in December 31, 2025 (City of Palo Alto 2022e).
Although the proposed HEU would increase the number of residential units by 665 compared to
Scenario 6 of the 2017 EIR, future development would be facilitated on non-vacant and
underutilized sites in urbanized areas such as along El Camino Real, the California Avenue area,
the Downtown area, and in the GM/ROLM zones which are already served by existing fire
stations. Future remodeling or expansion of PAFD facilities to accommodate new equipment
would not be needed to specifically to serve the additional residential units, which would be
added incrementally in various locations in the city and served by more than one fire station.
Therefore, impacts would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
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b. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered police protection facilities, or the need for new or
physically altered police protection facilities, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios, response
times or other performance objectives?
Police protection in the city is provided by the Palo Alto Police Department (PAPD). As discussed
under Impact (a), although the proposed HEU would increase the number of residential units by
665 compared to Scenario 6 of the 2017 EIR, future development would be facilitated on non-
vacant and underutilized sites in urbanized areas such as El Camino Real, the California Avenue
area, the Downtown area, and in the GM/ROLM zones, which are already served by an existing
police station. The PAPD has already indicated that the existing police station is inadequate to
accommodate current and future needs, and the city is currently constructing a new Public
Safety Building (PSB) at 250 Sherman Avenue which will serve as the new headquarters of the
Police Department, the Fire Department and the Office of Emergency Services and house the
city's dispatch operation. Future construction or expansion of the PAPD facility would not be a
result specifically of the additional residential units and would be subject to separate project-
level CEQA review in order to identify potential environmental impacts and mitigation
measures as needed. As such, with the new police station, police services would be adequate to
accommodate current and future needs of the city. Therefore, impacts would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
c. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered schools, or the need for new or physically altered
schools, the construction of which could cause significant environmental impacts, in order
to maintain acceptable service ratios or other performance objectives?
Palo Alto is served by the Palo Alto Unified School District (PAUSD), which consists of 12
primary schools, three middle schools, two high schools, and an adult school. In general,
kindergarten enrollment has been increasing within PAUSD, however, projections forecast a
decline in enrollment district-wide across a 10-year period based upon historical enrollment
trends and projected new development (DecisionInsite 2021).
As discussed in the 2017 EIR, Scenario 6 would result in enrollment that would exceed the
capacity of existing PAUSD elementary schools, middle schools, and high schools. Since the
proposed HEU would include 665 more units compared to Scenario 6, the proposed HEU would
also result in enrollment that would exceed the capacity of existing PAUSD schools. Although
the increased enrollment would add stress to schools in PAUSD, this growth would occur over a
period of approximately 8 years from 2023 to 2031, resulting in a gradual increase in demand
for school service in PAUSD. Additionally, in order to offset a project’s potential impact to
schools, Government Code 65995 (b) establishes the base amount of allowable developer fees
a school district can collect from development projects located within its boundaries. The fees
obtained by school districts that serve Palo Alto are used for construction or reconstruction of
school facilities. Future development facilitated by the proposed project would be required to
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pay school impact fees which, pursuant to Section 65995 (3) (h) of the California Government
Code (Senate Bill 50, chaptered August 27, 1998), are “deemed to be full and complete
mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not
limited to, the planning, use, or development of real property, or any change in governmental
organization or reorganization.”
Facility expansions in the PAUSD would require project-specific environmental analysis under
CEQA to address site-specific environmental concerns. Therefore, existing laws and regulations
that require funding for the provision or expansion of new school facilities would offset impacts
from new residential development, and impacts would be less than significant, and would be
generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
d. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered parks, or the need for new or physically altered parks,
the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios or other performance objectives?
Refer to Section 16, Recreation.
e. Would the project result in substantial adverse physical impacts associated with the
provision of other new or physically altered public facilities, or the need for other new or
physically altered public facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times or
other performance objectives?
The 2017 EIR states that while an overall increase in residents is expected, the growth would
occur incrementally throughout the 15-year time horizon; therefore, potential impacts from
increased demand from library services would not occur in the immediate future. Similarly,
growth induced from the proposed HEU would occur incrementally over eight years from 2023
to 2031. Pursuant to Chapter 16.58 of the PAMC, future development would be required to
contribute impact fees to offset potential impacts from increased demand in library facilities
and to ensure library facilities remain adequate. Therefore, impacts would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in the construction of
new or physically altered public facilities, and impacts would be less than significant. Therefore,
the project would not result in new significant effects not addressed in the prior EIR, and no
new mitigation measures are warranted. This issue does not require further study in an EIR.
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16 Recreation
Where was
Impact
Analyzed
in the EIR?
Could
Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Increase the use of existing
neighborhood and regional
parks or other recreational
facilities such that substantial
physical deterioration of the
facility would occur or be
accelerated?
EIR Page
4.12-17
through
4.12-20
No No No Yes
b. Include recreational facilities or
require the construction or
expansion of recreational
facilities which might have an
adverse physical effect on the
environment?
EIR Page
4.12-17
through
4.12-20
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR analyzes recreation in Section 4.12, Public Services and Recreation, and impacts
are summarized above under Section 14, Public Services. The Comprehensive Plan EIR
concludes that impacts regarding public services would be significant but mitigable with
incorporation of mitigation measure PS-7, which would include new policies and programs
addressing funding, community input, and environmental review for property acquisition and
park construction/improvement.
PROJECT-SPECIFIC IMPACTS
a. Would the project increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical deterioration of the facility would occur
or be accelerated?
b. Does the project include recreational facilities or require the construction or expansion of
recreational facilities which might have an adverse physical effect on the environment?
The City of Palo Alto has adopted a policy of 4 acres of neighborhood and district parkland for
every 1,000 residents and a parkland dedication standard of 5 acres of parkland (including open
space) for every 1,000 residents. Based on the existing 2022 population of 67,473 and the
adopted parkland standard, Palo Alto should currently provide 269.9 acres of neighborhood
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and district parkland.12 There is an existing total of 173.4 acres of neighborhood and district
parkland, 96.5 acres below the adopted policy.
The proposed HEU would increase the number of residential units by 665 compared to Scenario
6 of the 2017 EIR, and would therefore increase the demand for parks and recreational facilities
and would require more acres of new parkland to meet the city’s requirement that new
residential development provide 5 acres of parkland per 1,000 residents. As noted above, the
city currently provides less parkland than required to meet its adopted policy for neighborhood
and district parkland. Nonetheless, future development would be required to comply with
Chapter 21.50 of the PAMC which outlines requirements for parkland dedication or in lieu fees
payment, and the ongoing master planning effort for the parks, trails, and open space system
would develop strategies for the addition and improvement of park land. Because the exact
locations of future residential or parkland development are not known at this time, it would be
speculative to assess the physical environmental impacts associated with the construction of
future park facilities. However, given the need to new parkland under the proposed HEU,
construction or expansion of new parks or recreation facilities would be expected and the
impact would be potentially significant. However, future development would be required to
comply with Policy N-1.13 of the 2030 Comprehensive Plan, adopted in compliance with
Mitigation Measure PS-7 of the 2017 EIR, which would address the potential physical impacts of
park construction and improvement and reduce impacts to a less than significant level,
generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in the substantial
deterioration of existing neighborhood and regional parks. The proposed HEU could result in
the construction or expansion of new parks or recreational facilities and this impact could be
potentially significant. However, Policy N-1.13 adopted in compliance with Mitigation Measure
PS-7 would reduce impacts to a less than significant level. Therefore, the project would not
result in new significant effects not addressed in the prior EIR, and no new mitigation measures
are warranted. This issue does not require further study in an EIR.
12 67,473 (existing population) / 1,000 = 67.473 x 4 (number of acres per 1,000 residents of parkland) = 269.89
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17 Transportation
Where was
Impact
Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Conflict with a program, plan,
ordinance or policy addressing
the circulation system,
including transit, roadway,
bicycle and pedestrian
facilities?
EIR Pages
4.13-38
through
4.13-48
No No No No
b. Conflict or be inconsistent with
CEQA Guidelines section
15064.3, subdivision (b)?
EIR Pages
4.13-18
through
4.13-30
No No No No
c. Substantially increase hazards
due to a geometric design
feature (e.g., sharp curves or
dangerous intersections) or
incompatible use (e.g., farm
equipment)?
EIR Pages
4.13-49
through
4.13-51
No No No No
d. Result in inadequate
emergency access?
EIR Pages
4.13-51
through
4.13-52
No No No No
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.13, Transportation and Traffic, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to traffic and the circulation system. The 2017 EIR analyzes
transportation impacts using the level of service (LOS) methodology and found that impacts
would be significant and unavoidable since there would be six intersections with a substandard
LOS and there would be a significant impact during at least one of the peak hours. Although
implementation of mitigation measures TRANS-1a through 1e would mitigate the projected
impact to a less than significant level, Scenario 6 would still result in some impacted
intersections, both because of growth in Palo Alto and regional growth. Therefore, the
mitigation measures would reduce, but not eliminate, impacts at five of the six study
intersections analyzed in the 2017 EIR. Additionally, the 2030 Comprehensive Plan was found to
cause a freeway segment or ramp to drop below its level of service standard, or deteriorate
operations that already operate at a substandard level of service since mitigation measures
TRANS-1a and TRANS-3b would reduce but not eliminate the impact under Scenario 6 on four
freeway segments. Although mitigation measures TRANS-3a and 3b would be required, impacts
would remain significant and unavoidable. The 2017 EIR found that the 2030 Comprehensive
Plan would not cause a roadway segment to drop below its level of service standard or
deteriorate operations that already operate at a substandard level of service.
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The 2017 EIR concluded that the 2030 Comprehensive Plan would not impede the function of
planned bicycle or pedestrian facilities since compliance with existing City regulations and
procedures would maintain existing and may improve the function of planned bicycle and
pedestrian facilities. Furthermore, the 2030 Comprehensive Plan would not increase demand
for pedestrian and bicycle facilities as well as transit services that cannot be met by existing or
planned facilities or services. The 2030 Comprehensive Plan would also not result in inadequate
emergency access and impacts would be less than significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would create the potential
demand for through traffic to use local residential streets and would create an operational
safety hazard since growth under Scenario 6 could result in increased congestion, increasing the
potential for drivers to divert onto local streets and therefore causing a potential for increase in
accidents onto local streets. Therefore, mitigation measures TRANS-8 and TRANS-9 would be
required to reduce impacts to a less than significant level.
Table 25 lists the 2017 EIR’s mitigation measures related to transportation. Pursuant to Public
Resource Code, Section 21099 (b)(2), traffic congestion, while potentially an inconvenience to
drivers, is not itself an environmental impact. Therefore, issues related solely to traffic
congestion are outside the scope of CEQA analysis.
Table 25 2017 EIR Mitigation Measures: Transportation and Traffic
Mitigation
Measure # Mitigation Measure Text
Impact TRANS-1: Implementation of the project would cause an intersection to drop below its motor vehicle level of
service standard, or deteriorate operations at representative intersections that already operate at a substandard level of
service. (Significant and Unavoidable)
TRANS-1a Adopt a programmatic approach to reducing traffic with the goal of achieving no net increase in peak
period motor vehicle trips from new development, with an exception for uses that directly contribute to
the neighborhood character and diversity of Palo Alto (such as ground floor retail and below market rate
housing). The program should, at a minimum:
Require new development projects to prepare and implement a Transportation Demand Management
(TDM) Plan to achieve the following reduction in peak period motor vehicle trips from the rates
included in the Institute of Transportation Engineers’ Trip Generation Manual for the appropriate land
use category. These reductions are deemed aggressive, yet feasible, for the districts indicated.
45 percent reduction in the Downtown district
35 percent reduction in the California Avenue area
30 percent reduction in the Stanford Research Park
30 percent reduction in the El Camino Real Corridor
20 percent reduction in other areas of the city.
TDM Plans must be approved by the City and monitored by the property owner on an annual basis.
The Plans must contain enforcement mechanisms or penalties that accrue if targets are not met.
Require new development projects to pay a Transportation Impact Fee which will be partially used to
reduce peak period motor vehicle trips citywide.
TRANS-1b Study the feasibility of unbundled parking for office, commercial and multi-family residential
development (including senior housing developments) that are well-served by transit and demonstrated
walking and biking connections, including senior housing developments.
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Mitigation
Measure # Mitigation Measure Text
TRANS-1c Include policies in the Comprehensive Plan to ensure collaboration with regional agencies and
neighboring jurisdictions, and identification and pursuit of funding for rail corridor improvements and
grade separation. Policies shall support grade separation of rail crossings along the rail corridor as a City
priority and encourage studies and outreach necessary to advance grade separation of Caltrain to
become a “shovel ready” project.
TRANS-1d Engage in regional transportation planning and advocate for specific transit improvements and
investments, such as Caltrain service enhancements and grade separations, Dumbarton Express service,
enhanced bus service on El Camino Real with queue jumping and curbside platforms, and additional VTA
bus service.
TRANS-1e Encourage the PAUSD to analyze decisions regarding school assignments to reduce peak period motor
vehicle trips to and from school sites.
Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to drop below its level of service
standard, or deteriorate operations that already operate at a substandard level of service. (Significant and Unavoidable)
TRANS-3a The City shall require new development projects to prepare and implement TDM programs, as described
in TRANS-1a. TDM programs for worksites may include measures such as private bus services and free
shuttle services to transit stations geared towards commuters.
TRANS-3b Include policies in the Comprehensive Plan that advocate for efforts by Caltrans and the Valley
Transportation Authority to reduce congestion and improve traffic flow on existing area freeway facilities
consistent with Statewide GHG emissions reduction initiatives.
Policies shall support the application of emerging freeway information, monitoring, and control systems
that provide non-intrusive driver assistance and reduce congestion.
Policies shall support, where appropriate, the conversion of existing traffic lanes to exclusive bus and
high-occupancy vehicle (HOV) lanes on freeways and expressways, including the Dumbarton Bridge, and
the continuation of an HOV lane from Redwood City to San Francisco.
Impact TRANS-8: Implementation of the project would create the potential demand for through traffic to use local
residential streets. (Significant and Mitigable)
TRANS-8 Include policies in the Comprehensive Plan to identify specific improvements that can be used to
discourage non-local drivers from using local, neighborhood streets to bypass traffic congestion on
arterials.
Impact TRANS-9: Implementation of the project would create an operational safety hazard. (Significant and Mitigable)
TRANS-9 Implement Mitigation Measure TRANS-8.
Source: City of Palo Alto 2016
REGULATORY SETTING
SENATE BILL 743 AND VEHICLE MILES TRAVELED
Senate Bill (SB) 743 was signed into law by Governor Brown in 2013 and directed the State
Office of Planning and Research (OPR) to establish new criteria for determining the significance
of transportation impacts under the California Environmental Quality Act (CEQA). SB 743
requires the new criteria to “promote the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses.” It also states
that alternative measures of transportation impacts may include “vehicle miles traveled, vehicle
miles traveled per capita, automobile trip generation rates, or automobile trips generated.”
In January 2018, OPR transmitted its proposed CEQA Guidelines implementing SB 743 to the
California Natural Resources Agency for adoption, and in January 2019 the Natural Resources
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Agency finalized SB 743 updates to the CEQA Guidelines. SB 743 changed the way that public
agencies evaluate the transportation impacts of projects under CEQA, recognizing that roadway
congestion, while an inconvenience to drivers, is not itself an environmental impact (Public
Resource Code, § 21099 (b)(2)). In addition to new exemptions for projects consistent with
specific plans, the CEQA Guidelines replaced congestion-based metrics, such as auto delay and
level of service (LOS), with VMT as the basis for determining significant impacts, unless the
Guidelines provide specific exceptions.
The 2017 EIR examined program-level transportation impacts using the level of service (LOS)
methodology and found that all such impacts would be significant and unavoidable. Although
the 2017 EIR analyzes VMT, VMT was not the basis for a standard of significance used and no
impact finding regarding VMT was made. Nonetheless, Scenario 6 was found to result in the
lowest VMT per capita (including employment and residential VMT) of 30.8 compared to other
scenarios.
PROJECT-SPECIFIC IMPACTS
This analysis is based upon the VMT Analysis prepared for the HEU by Hexagon Transportation
Consultants, Inc. (Hexagon) in January 2023 (Appendix A).
IMPACT ANALYSIS
a. Would the project conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities?
The 2017 EIR used level of service (LOS) as its performance criteria while analyzing the city’s
roadway system. However, to implement SB 743, the CEQA Guidelines have been updated to
change the criteria for determining what constitutes a significant traffic related environmental
impact to rely upon quantification of VMT instead of LOS. The proposed HEU would be
consistent with the Transportation Element of the 2030 Comprehensive Plan since it would
place housing near transit, services, and jobs, which would reduce the usage of single-
occupancy vehicles and encourage walking, bicycling, and using alternative modes of
transportation.
Bicycling would be encouraged through the Bicycle and Pedestrian Transportation Plan which
aims to improve bicycling and pedestrian conditions and increase bicycling and walking rates
within Palo Alto (City of Palo Alto 2012). Future residents would be able to benefit from goals,
policies, and improvements associated with the Bicycle and Pedestrian Transportation Plan
which would reduce VMT and reliance on single-occupancy vehicles.
Future development proposals for individual projects would be subject to adopted
development guidelines, including standards that govern VMT, transportation, GHG, and
associated issues. Impacts identified for development facilitated by the plan would be
addressed through the project approval process, including Planning and Transportation
Commission (PTC) review as well as design review specific to potential impacts of that project.
Because the proposed HEU does not include modifications to the existing transportation
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network and individual future developments must be designed consistent with applicable
bicycle and pedestrian facility requirements, the proposed HEU would not conflict with the
City’s existing circulation, bicycle, or pedestrian plans. Impacts to transit, roadway, bicycle, and
pedestrian facilities would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3,
subdivision (b)?
CEQA Guidelines Section 15064.3(b) requires specific consideration of a plan or project’s
transportation impacts based on VMT. This implements SB 743, which eliminates level of
service as a basis for determining significant transportation impacts under CEQA and requires a
different performance metric: VMT. With this change, the State shifted the focus from
measuring a plan or project’s impact upon drivers (LOS) to measuring the impact of driving
(VMT) on achieving its goals of reducing GHG emissions, encouraging infill development, and
improving public health through active transportation.
Hexagon Transportation Consultants, Inc. prepared a VMT Analysis (Appendix A) for the
proposed HEU to determine whether it would generate a significant VMT impact. The City
adopted a VMT threshold for residential projects on June 15, 2020. A residential project that
exceeds a level of 15 percent below existing (baseline) County home-based VMT per resident
may indicate a significant transportation impact.
The City of Palo Alto Travel Forecasting Model (PA model) was used to estimate VMT for the
proposed project. According to the PA model, the countywide VMT per resident is 12.89 miles.
Based on the Palo Alto VMT Criteria, a project generating a VMT that is 15 percent or more
below this value, or 10.96 miles per capita, would have a less-than-significant VMT impact.
Based on the results of the PA model, as shown in Table 26, the project would have a projected
VMT rate of 9.13 miles per resident, lower than the significance threshold of 10.97 miles, since
the proposed project would concentrate new residential units in urbanized areas in proximity
to transit, jobs, and services compared to other parts of the County. Therefore, impacts would
be less than significant, and further analysis is not warranted.
Table 26 Vehicle Miles Traveled Analysis Summary
VMT Metric
Baseline
VMT Rate
Significance
Threshold
Project
VMT Rate Resulting Significance
VMT per resident (Countywide baseline) 12.89 10.96 9.13 Less than significant
Sources: Hexagon Transportation Consultants, Inc 2023; Appendix A
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c. Would the project substantially increase hazards due to a geometric design feature (e.g.,
sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)?
In the absence of specific project applications to review, analyzing impacts based on project
design features would be wholly speculative. CEQA does not require public agencies to
speculate. Adoption of the proposed HEU analyzes the amount of new housing units the City
will accommodate during the 2023-2031 planning period and sets goals and policies for how
this housing is implemented. It does not grant entitlements for any specific project or future
development. Thus, the plan for new housing and the goals and policies needed to achieve that
housing do not have a specific transportation safety impact or hazard. The proposed project
would not include hazardous geometric design features or incompatible uses. Each housing
application would be evaluated at the project specific level and undergo design review which
would ensure design features would be in accordance with all applicable City standards to
minimize design hazards. Furthermore, future projects facilitated would be infill projects or
would include increasing density and height of existing sites, and therefore would not involve
the creation of new roadways or intersections or incompatible uses within Palo Alto. While new
intersections of existing local streets with proposed new streets internal to these sites may be
created if these sites would be developed, they would be subject to the project-level review
processes described above to ensure hazards from design features or incompatible uses are not
created. Therefore, impacts from hazardous design features or incompatible uses would be less
than significant and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan as analyzed in the 2017 EIR. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
d. Would the project result in inadequate emergency access?
Similar to Scenario 6 as discussed in the 2017 EIR, traffic increases would contribute to
congestion on freeway segments, which could contribute to cumulative traffic conditions that
have the potential to impede emergency vehicle access on US 101. However, isolated instances
of emergency vehicles being impeded vary on a case-by-case basis and more information would
be needed to determine the precise problem causing a particular event. It would be speculative
to try to determine how future traffic associated with development in Palo Alto would
cumulatively contribute to such events. In addition, approximately 15 percent of the traffic
signals maintained by the City of Palo Alto are equipped with emergency vehicle preemption
devices. The city will continue to install traffic signal preemption devices where appropriate.
Emergency vehicles have the right to use lights and sirens to allow them to bypass congestion,
and all other vehicles are required by State law to pull over to allow emergency vehicles to
pass. Additionally, future development would be required to comply with comply with basic
building designs and standards for residential buildings as mandated by the Palo Alto Fire Code
pursuant to PAMC Chapter 15.04. Future projects would be required to incorporate all
applicable design and safety requirements as set forth in the most current adopted building
codes and fire and life safety standards. Additionally, as discussed under Section 9, Hazards and
Hazardous Materials, the proposed HEU would not impair implementation of or physically
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interfere with an adopted emergency response plan or emergency evacuation plan. Therefore,
impacts would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan as analyzed in the 2017 EIR. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not conflict with a program, plan,
ordinance or policy addressing the circulation system; result in a significant VMT impact;
substantially increase hazards due to a geometric design feature or incompatible use; or result
in inadequate emergency access. Therefore, the project would not result in new significant
effects not addressed in the prior EIR, and no new mitigation measures are warranted. This
issue does not require further study in an EIR.
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18 Tribal Cultural Resources
Where was
Impact
Analyzed in
the EIR?
Could
Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of
the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that
is:
a. Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register
of historical resources as
defined in Public Resources
Code Section 5020.1(k)?
EIR Pages
4.4-2
through
4.4-5
No No No Yes
b. A resource determined by the
lead agency, in its discretion and
supported by substantial
evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public
Resources Code Section 5024.1?
EIR Pages
4.4-7
through
4.4-9
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR does not specifically discuss impacts to tribal cultural resources or compliance
with Assembly Bill 52 (AB 52), which was signed into law in 2014. AB 52 expanded CEQA by
defining a new resource category, “tribal cultural resources,” and requires lead agencies to
complete consultation with California Native American Tribes regarding proposed projects,
because it became effective after the issuance of the Notice of Preparation for 2017 EIR.
However, as described in Section 5, Cultural Resources, of this Addendum, the 2017 EIR
incorporated required mitigation measures CULT-1 and CULT-3 for procedures in the event
archaeological resources, tribal resources, and human remains are discovered during
construction.
ASSEMBLY BILL 52 OF 2014
AB 52 establishes that “A project with an effect that may cause a substantial adverse change in
the significance of a tribal cultural resource is a project that may have a significant effect on the
environment” (PRC Section 21084.2). It further states that the lead agency shall establish
measures to avoid impacts that would alter the significant characteristics of a tribal cultural
resource, when feasible (PRC Section 21084.3).
PRC Section 21074 (a)(1)(A) and (B) defines tribal cultural resources as “sites, features, places,
cultural landscapes, sacred places, and objects with cultural value to a California Native
American tribe” and are:
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1. Listed or eligible for listing in the California Register of Historical Resources, or in a local register
of historical resources as defined in Public Resources Code section 5020.1(k), or
2. A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying these criteria, the lead agency shall consider the significance of
the resource to a California Native American tribe.
AB 52 also establishes a formal consultation process for California tribes regarding those
resources. The consultation process must be completed before a CEQA document can be
certified. Under AB 52, lead agencies are required to “begin consultation with a California
Native American tribe that is traditionally and culturally affiliated with the geographic area of
the proposed project.” Native American tribes to be included in the process are those that have
requested notice of projects proposed within the jurisdiction of the lead agency.
The requirements of AB 52 do not apply to the proposed project because it falls under a
previously certified EIR. Nonetheless, the City of Palo Alto conducted tribal consultation in
accordance with AB 52 as well as in accordance with Senate Bill 18. The City sent out letters via
certified mail on September 29, 2022, to the following eight Native American Tribes that that
were identified by the NAHC as being traditionally and culturally affiliated with the geographic
area:
Amah Mutsun Tribal Band
Amah Mutsun Tribal Band of Mission San Juan Bautista
Indian Canyon Mutsun Band of Costanoan
Muwekma Ohlone Indian Tribe of the SF Bay Area
Northern Valley Yokuts Tribe
The Ohlone Indian Tribe
Wuksache Indian Tribe/Eshom Valley Band
Tamien Nation
Under AB 52, Native American tribes typically have 30 days to respond and request further
project information and formal consultation. Under SB 18, Native American tribes have 90 days
to respond and request further project information and request formal consultation. To date,
the City of Palo Alto has not received responses requesting consultation under AB 52 or SB 18
from the Tribes. AB 52 and SB 18 correspondence is included in Appendix C.
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IMPACT ANALYSIS
a. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource as defined in Public Resources Code Section 21074 that is listed or eligible for
listing in the California Register of Historical Resources, or in a local register of historical
resources as defined in Public Resources Code Section 5020.1(k)?
b. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource as defined in Public Resources Code 21074 that is a resource determined by the
lead agency, in its discretion and supported by substantial evidence, to be significant
pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1?
No specific tribal cultural resources were identified in the City of Palo Alto as a result of
consultation with the Tribes. Similar to what was assumed in the 2017 EIR, although
development under the proposed HEU would occur on non-vacant and underutilized sites in
previously disturbed areas, ground-disturbing activities such as earthmoving and excavation
could still potentially damage and/or destroy unrecorded tribal cultural resources in subsurface
soils within the housing sites. Adherence to the requirements of AB 52 would require Tribal
consultation with local California Native American Tribes prior to implementation of project
activities subject to CEQA. AB 168 would require Tribal consultation with local California Native
American Tribes prior to implementation of project activities subject to SB 35. In compliance
with AB 52, a determination of whether project-specific substantial adverse effects on tribal
cultural resources would occur along with identification of appropriate project-specific
avoidance, minimization, or mitigation measures would be required. Due to the programmatic
nature of the proposed HEU it is not possible to fully determine impacts of specific projects on
specific sites; however, no tribal cultural resources were identified during consultation. Future
projects subject to CEQA and SB 35 would require project-specific tribal cultural resource
identification and consultation, and the appropriate avoidance, minimization, or mitigation
would be incorporated. Project-specific tribal cultural resource consultation will occur when
specific projects are implemented, and consultation conducted pursuant to the requirements of
AB 52. Future development would also be required to comply with policies L-7.16 through 7.18
of the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measure CULT-3 of
the 2017 EIR, which would reduce impacts on tribal cultural resources to a less than significant
level. Because there would be no new or substantially more severe significant impacts than
what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, development would occur in the same areas as those
analyzed in the 2017 EIR. Further, future development would be required to comply with
federal, State, and local regulations pertaining to tribal cultural resources as well as policies
adopted in compliance with Mitigation Measure CULT-3 from the 2017 EIR, which would reduce
impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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19 Utilities and Service Systems
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Require or result in the
relocation or construction of
new or expanded water,
wastewater treatment or
storm water drainage,
electric power, natural gas, or
telecommunications facilities,
the construction or relocation
of which could cause
significant environmental
effects?
EIR Pages
4.14-2
through
4.14-7; 4.14-
14 through
4.14-15;
4.14-18
through
4.14-19;
4.14-25
through
4.14-28;
4.14-33
through
4.14-38
No No No N/A
b. Have sufficient water supplies
available to serve the project
and reasonably foreseeable
future development during
normal, dry and multiple dry
years?
EIR Pages
4.14-2
through
4.14-4
No No No N/A
c. Result in a determination by
the wastewater treatment
provider which serves or may
serve the project that it has
adequate capacity to serve
the project’s projected
demand in addition to the
provider’s existing
commitments?
EIR Pages
4.14-10
through
4.14-16
No No No N/A
d. Generate solid waste in
excess of State or local
standards, or in excess of the
capacity of local
infrastructure, or otherwise
impair the attainment of solid
waste reduction goals?
EIR Pages
4.14-25
through
4.14-28
No No No N/A
e. Comply with federal, state,
and local management and
reduction statutes and
regulations related to solid
waste?
EIR Pages
4.14-28
through
4.14-30
No No No N/A
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ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.14, Utilities and Service Systems, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to utilities and service systems. The 2017 EIR found that sufficient water
supplies from existing entitlements would be available to serve Scenario 6 and the increased
demand in water would not result in the substantial physical deterioration of a water utility
facility. Additionally, the 2030 Comprehensive Plan would not prompt a need to expand
treatment facilities or regional water system conveyance and storage facilities in order to meet
its demand. New or expanded local water distribution facilities would require permitting and
review in accordance with CEQA, which would ensure environmental impacts are disclosed and
mitigated. Therefore, impacts would be less than significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would not exceed wastewater
treatment requirements of the RWQCB or wastewater treatment capacity of the Regional
Water Quality Control Plant (RWQCP). Furthermore, the 2030 Comprehensive Plan would not
result in substantial physical deterioration of the RWQCP or adverse physical impacts from new
or expanded wastewater utility facilities since the existing RWQCP would provide adequate
capacity to meet dry weather and maximum month flows through at least 2035 and beyond.
Therefore, impacts would be less than significant.
The 2017 EIR found that the 2030 Comprehensive Plan would not require or result in the
construction of new stormwater facilities or expansion of existing facilities since development
would be required to comply with Provision C.3 of the MRP, as well as the City’s post-
construction site design measures, source control measures, and stormwater treatment
measures. The 2030 Comprehensive Plan would not result in a substantial physical
deterioration of stormwater facilities with compliance with existing State, regional, and local
regulations. Therefore, impacts would be less than significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would be served by 17 different
landfills with sufficient permitted capacity to accommodate the increased waste disposal needs.
However, the 2017 EIR found that the 2030 Comprehensive Plan could potentially fall out of
compliance with federal, State, and local statutes and regulations related to solid waste, and
mitigation measure UTIL-15 would be required to reduce impacts to a less than significant level.
The 2017 EIR also analyzes impacts to energy supply and efficiency which is discussed in Section
6, Energy, of this document.
Table 27 lists the mitigation measures from the 2017 EIR related to utilities and service systems.
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Table 27 2017 EIR Mitigation Measures: Utilities and Service Systems
Mitigation
Measure # Mitigation Text
Impact UTIL-15: Without the adoption of policies to promote recycling and conservation, the proposed Plan could
potentially fall out of compliance with federal, State, and local statutes and regulations related to solid waste. (Potentially
Significant and Mitigable)
UTIL-15 To ensure that future development under Scenarios 2, 3, and 4 would comply with applicable solid
waste regulations, the proposed Plan shall include policies that address the following topics:
Substantial landfill diversion by 2030, and ultimately zero waste.
Reduced solid waste generation.
Use of reusable, returnable, recyclable, and repairable goods.
Enhanced recycling and composting programs for all waste generators.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project require or result in the relocation or construction of new or expanded
water, wastewater treatment or storm water drainage, electric power, natural gas, or
telecommunications facilities, the construction or relocation of which could cause
significant environmental effects?
WATER
As discussed under Threshold Question (b) below, water supply and demand for the proposed
HEU would be similar to that of Scenario 6 of the 2017 EIR. The City receives 100 percent of its
potable water from the SFPUC. The City does not own or operate a water treatment plant
(WTP). The water purchased from the SFPUC may be treated at one or more WTPs operated by
SFPUC. SFPUC treats water to meet all applicable drinking water standards. SFPUC periodically
makes improvements to its WTPs in order to improve system reliability and accommodate
projected growth in its regional service areas. For example, the Water System Improvement
Program (WSIP) includes capacity expansion and other improvements in order to upgrade
SFPUC’s regional and local water systems. The WSIP also includes many projects to improve the
Regional Water System distribution lines and storage reservoirs (City of Palo Alto 2017a).
Although existing local distribution lines within the city could potentially be undersized for
future projects and improvements under the proposed HEU could require replacement with
larger diameter pipes, potential environmental impacts that could result from pipeline
improvements would be project specific. New or expanded local water distribution facilities
would require permitting and review in accordance with CEQA, which would ensure
environmental impacts are disclosed and addressed in the environmental analysis. Therefore,
similar to Scenario 6, the proposed HEU would not result in the expansion or construction of
new treatment facilities or regional water system conveyance and storage facilities in order to
meet its demand and this impact would be less than significant, generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
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WASTEWATER
As discussed under Threshold Question (c), the existing RWQCP facilities would provide
adequate capacity to meet dry weather and maximum month flows through at least 2035 and
beyond, and that new or expanded facilities would not be needed as a result of the proposed
HEU. Some aging facilities will need to be replaced, based on the treatment processes design
criteria and historical performance. However, these facility upgrades and replacements are
anticipated based on existing planning documents and would not be necessitated as a result of
the proposed HEU. In addition, the LRFP anticipates that the existing RWQCP facilities will
provide adequate capacity to meet dry weather and maximum month flows through at least
2035, assuming the same level of treatment is required. Therefore, similar to Scenario 6, the
proposed HEU would not result in the expansion or construction of new wastewater facilities
and this impact would be less than significant, generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
STORMWATER
Although the proposed HEU would increase the number of residential units by 665 compared to
Scenario 6 of the 2017 EIR, new future development would be required to comply with the C.3
provisions of the MRP and implement BMPs and LID features to minimize stormwater runoff
impacts. In particular, during construction, future projects would be required to implement
flow control BMPs to minimize potential impacts. Similar to Scenario 6, the proposed HEU does
not propose the conversion of open space areas, creeks, or wetlands to impervious surfaces
and would not alter the course of a stream or river. The City’s Department of Public Works
requires all new development projects to provide storm drain flow and detention calculations,
including pre-project and post-project conditions and flow rates. On-site stormwater detention
is also required as per the C.3 provisions of the MRP. In addition, per section C.3.j, future
applicants would be required to complete and implement a Green Infrastructure Plan for the
inclusion of low impact development drainage design into storm drain infrastructure on public
and private lands, including streets, roads, storm drains, parking lots, building roofs, and other
storm drain infrastructure elements (City of Palo Alto 2017a). Compliance with State and local
stormwater regulations would reduce impacts to a less than significant level, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
TELECOMMUNICATIONS
The proposed HEU would require connections to existing adjacent utility infrastructure to meet
the needs of future residents. Similar to Scenario 6 of the 2017 EIR, the proposed HEU would
only facilitate development on non-vacant and underutilized sites in urbanized areas. Based on
the availability of existing telecommunications infrastructure, construction of new telephone
and cable lines would not be required, and all future development would be able to connect to
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existing infrastructure. Development facilitated by the project would be required to adhere to
applicable laws and regulations related to the connection to existing telecommunication
infrastructure. Therefore, there would be adequate telecommunications facilities to serve the
development facilitated by the project, and impacts would be less than significant, generally
the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because
there would be no new or substantially more severe significant impacts than what was analyzed
in the 2017 EIR, further analysis is not warranted.
ELECTRICITY AND NATURAL GAS
As discussed in the 2017 EIR, Scenario 6 would result in a long-term increase in electrical service
energy demand ranging from 10 percent to 11 percent over 2014 baseline levels within the
CPAU’s service territory for electrical service. This average incremental increase in electrical
service demand would be less than a one percent increase per year. Although the proposed
HEU would increase the number of residential units by 665 compared to Scenario 6 of the 2017
EIR, it would not include non-residential uses and therefore electricity demand would be similar
to that of Scenario 6 and would result in less than a one percent increase per year. Since the
proposed HEU would also facilitate development in non-vacant and underutilized sites with
existing infrastructure, it is not anticipated that the construction of new electrical transmission
and distribution lines would be required. Therefore, the proposed HEU would not result in the
relocation or construction of new or expanded electrical facilities and impacts would be less
than significant, generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
Similarly, for the same reasons described above, the proposed HEU would not substantially
increase natural gas demand compared to Scenario 6 and future development would also be
subject to the City’s most updated Reach Code and All-Electric Mandate which requires all-
electric building design for single-family, low-rise multi-family, and non-residential
development (City of Palo Alto 2022a). Therefore, the proposed HEU would not result in the
relocation or construction of new or expanded natural gas facilities and impacts would be less
than significant, generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
b. Would the project have sufficient water supplies available to serve the project and
reasonably foreseeable future development during normal, dry and multiple dry years?
As discussed in the 2017 EIR, the increased water demand for Scenario 6 would be
approximately 13,767 acre-feet per year (AFY), and the city’s Individual Supply Guarantee
through 2035 is 19,118 AFY. As shown on Table 28, the additional 665 units facilitated by the
proposed HEU compared to the 2017 EIR would increase water demand by approximately
43,225 gallons per day (gpd) or 48.4 acre-feet per year (AFY) in 2031 assuming full buildout.
According to the city’s 2020 Urban Water Management Plan (UWMP), by 2030, the city would
have a water demand of 11,394 AFY and an Individual Supply Guarantee of 18,579 AFY.
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Therefore, the proposed project would increase Palo Alto’s estimated 2030 normal-year water
demand by approximately 0.4 percent.
Table 28 Estimated Water Use for the Proposed HEU
Potential Buildout
Development/Land Use
Water Generation
Factor (gpd/unit) 1
Projected Number
of Housing Units
Projected Water
Demand in 2031 (gpd)
Projected Water
Demand in 2031 (AFY)
Multi-family residential 65 665 43,225 48.4
1 Per unit water demand factors from Palo Alto are not available, therefore, this analysis is based water use factors provided by the
East Bay Municipal Utilities District, 65 gpd/unit for a low-rise apartment.
gpd =gallons per day. AFY = acre-feet per year
According to the city’s 2020 UWMP, the City of Palo Alto analyzed three different hydrological
conditions to determine the reliability of water supplies for the City: average/normal water
year, single dry water year, and multiple dry water year period. In each of the three
hydrological conditions, the projected water demand was calculated taking into account growth
in billing data, water conservation efforts, and demographics. The UWMP states that the City of
Palo Alto can reliably meet the projected water demand in normal years. However, there would
be a potable water supply shortfall for single dry year and multiple dry years. Under these
conditions, residents would be required to reduce water usage by 30 to 50 percent depending
on the length of the dry year. The San Francisco Public Utilities Commission (SFPUC) and Bay
Area Water Supply and Conservation Agency (BAWSCA) are also evaluating alternative water
supplies during and seeking water supplies and solutions for drought years. In addition, the City
of Palo Alto has formed partnerships such as the one with Valley Water and is embarking on a
One Water plan which will have dry year water supply reliability as a central tenet (City of Palo
Alto 2021). The City of Palo Alto also offers many resources to help residents use water wisely,
including free water surveys, conservation devices, educational programs, and rebates for
appliance or landscape upgrades (City of Palo Alto 2017a). The City presents drought updates to
the Utilities Advisory Commission monthly and has held numerous public meetings to update
the community on the drought, responses by the State and the City, and available resources.
Therefore, sufficient water supplies would be available to serve the proposed HEU during
normal, single- and multiple-dry years, and impacts would be less than significant, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
c. Would the project result in a determination by the wastewater treatment provider which
serves or may serve the project that it has adequate capacity to serve the project’s
projected demand in addition to the provider’s existing commitments?
As discussed in the 2017 EIR, Scenario 6 would increase wastewater generation by 631,032
gallons per day (GPD) and this estimated worst-case increase in water flow would represent
less than four percent of the existing excess dry flow capacity of 18 million gallons per day
(MGD) available at the RWQCP. The Long Range Facilities Plan (LRFP) also further estimates that
the RWQCP would have at least 5 MGD of excess capacity in 2062. Assuming that wastewater
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generation is 80 percent of water use, the proposed HEU would increase wastewater
generation by approximately 34,580 gpd.13 This would constitute approximately 0.2 percent of
the RWQCP’s excess dry flow capacity and therefore the RWQCP would have sufficient capacity
to accommodate the 665 additional units proposed under the HEU. Although some aging
facilities will need to be replaced, based on the treatment processes design criteria and
historical performance, the LRFP anticipates that the existing RWQCP facilities would l provide
adequate capacity to meet dry weather and maximum month flows through at least 2035,
assuming the same level of treatment is required. Projected dry weather flows are anticipated
to be between 28 and 34 MGD in the year 2062, which is below the dry weather flow design
capacity of the plant (39 MGD). Therefore, the RWQCP’s existing capacity would be sufficient to
accommodate the anticipated residential development under the proposed HEU. Development
facilitated by the proposed project would not result in the need to expand the capacity of the
RWQCP. This impact would be less than significant and generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
d. Would the project generate solid waste in excess of State or local standards, or in excess of
the capacity of local infrastructure, or otherwise impair the attainment of solid waste
reduction goals?
e. Would the project comply with federal, state, and local management and reduction
statutes and regulations related to solid waste?
As discussed in the 2017 EIR, Scenario 6 would generate an approximate increase of 15,315
tons per year of solid waste over baseline at buildout. Additionally, the city’s disposal rate per
resident in 2014 was 3.6 pounds per day (PPD), which was below the CalRecycle target of 7.1
PPD per resident. The city’s disposal rates for both residents and employees have been below
target rates since 2007 (City of Palo Alto 2017a).
CalRecycle estimates that multi-family residential uses generate an average of four pounds of
solid waste per unit per day (CalRecycle 2023). As shown in Table 29, prior to implementation
of State-mandated diversion requirements, development associated with the proposed HEU
would generate an estimated 2,660 pounds per day of solid waste, which equates to 1.3 tons or
11.8 cubic yards per day. In accordance with California’s Integrated Waste Management Act of
1989 (AB 939), cities and counties are required to divert 50 percent of all solid wastes from
landfills. Additionally, pursuant to AB 341 adopted in 2012, all businesses that generate four
cubic yards or more of commercial solid waste per week including multi-family dwelling that
consists of five units or more would be required to divert 75 percent of all solid wastes. The City
of Palo Alto has achieved a diversion rate of 82 percent, which substantially exceeds AB 939
State requirement (City of Palo Alto 2018). Assuming that this diversion rate continues to apply
to new development on the project sites, implementation of the project would generate
approximately 0.2 tons or 2.1 cubic yards per day of solid waste for disposal at landfills.
13 43,225 gpd times 0.8 = 34,580 gpd
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Table 29 Estimated Solid Waste Generation
Potential Buildout
Development/ Land
Use Quantity Units Generation Rate1
Solid Waste
(pounds per day)
Solid Waste
(tons per day)
Solid Waste
(cubic yards
per day)2
Residential 665 dwelling
units
4 pounds/unit/day 2,660 1.3 11.8
Total Assuming 82% Diversion Rate 479 0.2 2.1
1 CalRecycle 2023
2 RecycleMania/USEPA 2022, assumes 225 pounds per cubic yard of residential waste
In 2019, CalRecycle reported that the overall total of 47,023 tons of solid waste from Palo Alto
was disposed at 17 different landfills. The majority (42,252 tons) were disposed at three
landfills: Kirby Canyon Landfill, Corinda Los Trancos Landfill (Ox Mountain), and Monterey
Peninsula Landfill (CalRecycle 2022). The Kirby Canyon Landfill has a closure year of 2059 and a
remaining capacity of 16,191,600 cubic yards (CalRecycle 2022b); the Ox Mountain Landfill has
a closure year of 2034 and a remaining capacity of 22,180,000 cy (CalRecycle 2022c); and the
Monterey Peninsula Landfill has a closure year of 2107 and a remaining capacity of 48,560,000
(CalRecycle 2022d). With development facilitated by the proposed HEU, it is estimated that the
665 units would generate approximately 2.1 cubic yards of solid waste per day, or 767 cubic
yards of solid waste per year for disposal at landfills. This represents 0.00004 percent of the
current total remaining landfill capacity at the Kirby Canyon Landfill. The projected closure
years and remaining capacities of these three main landfills currently accepting solid waste
from the city would be able to accommodate the projected increase in solid waste under
Scenario 6 and the proposed HEU. There are also 14 more landfills that received waste from
Palo Alto in 2019. If one or more of these landfills were unavailable in the future, it is likely Palo
Alto’s solid waste volume could be increased at one or more of the other landfills that already
serve Palo Alto. Moreover, the city has ongoing and planned measures to divert increasing
amounts of Palo Alto’s solid waste away from landfills. Future development would be required
to comply with PAMC Section 16.14.260 which requires an 80 percent diversion of construction
and demolition debris, and preparation of a Waste Management Plan for on-site sorting of
construction debris, which is submitted to the City for approval, in order to ensure that the
covered project meets the diversion requirement for reused or recycled construction and
demolition debris. Development facilitated by the proposed HEU would also be required to
comply with applicable federal, State, and local statutes and regulations related to solid waste
such as AB 939, which requires the City to divert 50 percent of solid waste from landfills, as well
as SB 1838, which would require mandatory organic waste recycling for future residents.
Furthermore, future development would be required to comply with policies S-3.8, 3.9, and
3.11 of the 2030 Comprehensive EIR, adopted in compliance with Mitigation Measure UTIL-15
of the 2017 EIR, which would ensure waste diversion and increased recycling. Therefore, the
existing landfills would be able to accommodate development under the proposed HEU, and
the proposed HEU would comply with federal, State, and local regulations related to solid
wastes. Impacts would be less than significant with mitigation and generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
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new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in the construction or
expansion of utilities facilities, and existing infrastructure would be sufficient to accommodate
the increased residential units. Therefore, the project would not result in new significant effects
not addressed in the prior EIR, and no new mitigation measures are warranted. This issue does
not require further study in an EIR.
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UTILITIES AND SERVICE SYSTEMS
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20 Wildfire
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a. Substantially impair an
adopted emergency response
plan or emergency evacuation
plan?
N/A No No No N/A
b. Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks and thereby
expose project occupants to
pollutant concentrations from
a wildfire or the uncontrolled
spread of a wildfire?
EIR Pages
4.7-8
through
4.7-9
No No No N/A
c. Require the installation or
maintenance of associated
infrastructure (such as roads,
fuel breaks, emergency water
sources, power lines or other
utilities) that may exacerbate
fire risk or that may result in
temporary or ongoing impacts
to the environment?
N/A No No No N/A
d. Expose people or structures to
significant risks, including
downslopes or downstream
flooding or landslides, as a
result of runoff, post-fire slope
instability, or drainage
changes?
EIR Pages
4.7-8
through
4.7-9
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR does not directly address the issue area of wildfire, but discusses wildfire impacts
in Section 4.7, Hazards and Hazardous Materials, of the 2017 EIR. As discussed in the 2017 EIR,
much of the area surrounding Palo Alto west of I-280 is considered to have a moderate and
high risk of wildland fire, whereas all of the urbanized areas of Palo Alto do not have any
wildland fire hazards. The 2017 EIR found that there would be less than significant impacts
related to wildfire.
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WILDFIRE
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IMPACT ANALYSIS
a. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project substantially impair an adopted emergency response plan
or emergency evacuation plan?
b. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project, due to slope, prevailing winds, and other factors,
exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations
from a wildfire or the uncontrolled spread of a wildfire?
c. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts
to the environment?
d. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project expose people or structures to significant risks, including
downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
As shown in the CAL FIRE Fire Hazard Severity Zone Map, only the area west of I-280 is located
in a High Fire Hazard Severity Zone (HFHSZ) while the rest of the city east of I-280 is located in
an area with low wildfire risk. Similar to what was analyzed in the 2017 EIR, the proposed HEU
would facilitate development in non-vacant and underutilized sites in urbanized areas of the
city, and would not facilitate development in locations near the HFHSZ. New development
would also be located in proximity to Fire Stations 1, 2, 3, and 4 which would protect future
residents from wildfire hazards. Additionally, future development would be required to comply
with the CAL FIRE Strategic Plan and the CFC pursuant to PAMC Chapter 15.04. The CFC requires
the clearance of debris and vegetation within a prescribed distance from structures in wildlife
hazard areas. The proposed HEU would facilitate residential development primarily on infill
sites in urbanized areas, and would not require the construction of additional roads, power
lines, or other utilities that would exacerbate existing fire risk. Housing sites that require utility
connections would likely install underground connections, and development within
underground utility districts would be required to install new utility connections underground.
Therefore, the project would not impair an adopted emergency response or evacuation plan
related to wildfire; exacerbate wildfire risks; or expose people to post-fire risks related to
runoff, flooding, or landslides. Impacts would be less than significant and generally the same as
the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be
no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
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CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not impair an adopted
emergency response or evacuation plan related to wildfire; exacerbate wildfire risks; or expose
people to post-fire risks related to runoff, flooding, or landslides. Therefore, the project would
not result in new significant effects not addressed in the prior EIR, and no new mitigation
measures are warranted. This issue does not require further study in an EIR.
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WILDFIRE
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21 Cumulative Impacts
CEQA defines “cumulative impacts” as two or more individual impacts that, when considered
together, are substantial or will compound other environmental impacts. Cumulative impacts
are the combined changes in the environment that result from the incremental impact of
development of the proposed project and other nearby projects. For example, noise impacts of
two nearby projects may be less than significant when analyzed separately but could have a
significant impact when analyzed together. Cumulative impact analysis provides a reasonable
forecast of future environmental conditions and can more accurately gauge the effects of a
series of projects.
This analysis is cumulative in nature in that it analyzes future development under the proposed
HEU throughout Palo Alto and takes into consideration the effects associated with
development of multiple projects in the housing element cycle through 2031. For analyses that
may have more localized or neighborhood implications (aesthetics, agriculture, biological
resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology
and water quality, land use and planning, mineral resources, noise, public services, recreation,
utilities, tribal cultural resources, wildfire), the geographic scope for cumulative impacts
includes the city of Palo Alto. For these issue areas, generally, impacts are site specific and
cumulative impacts would not be significant. Therefore, the proposed project would not result
in a cumulatively considerable contribution to the above-mentioned issue areas. Future
development projects would be reviewed by the City pursuant to CEQA to identify potential
impacts to on a project-by-project basis. While there is the potential for significant cumulative
impacts, it is anticipated that potential impacts associated with individual development projects
would be addressed on a case-by-case basis and would be subject to the mitigation measures
outlined in this Addendum, City policies, and State and local regulations regarding the
protection of such resources. With compliance with the existing policies and regulations, and
mitigation measures, future development would be required to avoid or mitigate impacts.
Therefore, the proposed project’s incremental contribution to cumulative impacts associated
with aesthetics, agriculture, biological resources, cultural resources, geology and soils, hazards
and hazardous materials, hydrology and water quality, land use and planning, mineral
resources, noise, public services, recreation, utilities, tribal cultural resources, and wildfire
would not be cumulatively considerable, and cumulative impacts would be less than significant.
Some analyses including air quality, energy, greenhouse gas emissions, transportation, and
population and housing, rely on much larger geographic areas such as the Bay Area region. For
issues that may have regional cumulative implications, the cumulative impact analysis is based
on Plan Bay Area 2050, the Bay Area’s most recent Regional Transportation Plan/Sustainable
Communities Strategy (RTP/SCS).
As discussed in Section 3, Air Quality, the project would be consistent with the 2017 Clean Air
Plan control measures as development facilitated by the project would comply with the latest
Title 24 regulations and would increase density in urban areas in proximity to transit, allowing
for greater use of alternative modes of transportation. Additionally, the increase in VMT would
not exceed the projected population increase per the BAAQMD CEQA Air Quality Guidelines for
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CUMULATIVE IMPACTS
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operational emissions from plans. Discussion of these impacts considers the cumulative nature
of criteria pollutants in the region. Therefore, the project would not result in a cumulatively
considerable contribution to an air quality impact.
As discussed in Section 6, Energy, development facilitated by the project would not result in a
wasteful, inefficient, or unnecessary consumption of energy, and operation of the new
residential structures would not result in potentially significant environmental effects due to
the wasteful, inefficient, or unnecessary consumption of energy. Development facilitated by the
project would be consistent with the energy-related goals, policies, and actions of the
Statewide plans and the City’s 2030 Comprehensive Plan; therefore, the project would not
make a cumulatively considerable contribution to a significant cumulative impact with respect
to consistency with renewable energy and energy efficiency plans. Projects throughout the Bay
Area are required to adhere to applicable renewable energy and energy efficiency laws,
programs, and policies such as California’s RPS, AB 2076, and Title 24 standards to avoid the
wasteful, inefficient, or unnecessary consumption of energy.
As discussed in Section 8, Greenhouse Gas Emissions, the impact of GHG emissions generated
by development facilitated by the proposed HEU is inherently cumulative. GHG emissions from
one project cannot, on their own, result in changes in climatic conditions; therefore, the
emissions from any project must be considered in the context of their contribution to
cumulative global emissions, which is the basis for determining a significant cumulative impact.
This is determined through the project’s consistency with applicable GHG emission thresholds
and applicable plans, policies, or regulations adopted for the purpose of reducing the emissions
of GHGs. GHG emissions from development facilitated by the project would not exceed the
BAAQMD interpolated 2031 plan-level threshold. In addition, development facilitated by the
project would be consistent with the 2022 Scoping Plan, Plan Bay Area 2050, 2030
Comprehensive Plan, and the City’s S/CAP. Therefore, the project would not result in a
significant cumulative impact related to GHG emissions.
As discussed in Section 14, Population and Housing, the proposed HEU would result in an
increase of 665 more housing units compared to Scenario 6 of the 2017 EIR. However, the
proposed project would be consistent with State requirements for the RHNA and would further
assist in addressing the existing housing crisis and meeting the housing needs of the City’s
communities. Therefore, the project would not result in a cumulatively considerable
contribution to a population and housing impact.
As discussed in Section 17, Transportation, the proposed HEU would not result in a significant
cumulative VMT impact. Therefore, the project would not result in a cumulatively considerable
contribution to a transportation impact.
Therefore, with continued implementation of mitigation measures from the 2017 EIR, impacts
of the proposed HEU would not be cumulatively considerable. Impacts would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
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22 Other CEQA Required Discussions
The proposed HEU would not substantially change the discussion and findings presented for the
2030 Comprehensive Plan in Section 7, CEQA-Mandated Sections, of the 2017 EIR. These other
required discussions include impacts found not to be significant, growth-inducing impacts, and
irreversible changes. As with the 2017 EIR, the proposed HEU would not directly induce growth
because it would not extend services to an undeveloped area. The proposed HEU would direct
growth to specific areas that are already urbanized and underutilized and would improve
mobility while not making new areas within or outside of Palo Alto easier to develop. Although
employment growth that occurs during the life of the proposed HEU could indirectly induce
additional growth by contributing to an increased demand for housing, similar to the 2017 EIR,
future development would be required to comply with policies within the 2030 Comprehensive
Plan to ensure growth occurs in a sustainable manner. All potential impacts associated with
population and housing growth would be mitigated to less than significant levels. Given that the
State is currently in an ongoing housing crisis due to an insufficient housing supply, the
additional units under the proposed project would further assist in addressing the existing crisis
and meeting the housing needs of the City’s communities, and would allow the city to satisfy its
fair share of RHNA.
The proposed HEU would allow land uses largely consistent with current land uses and
redevelopment would occur in areas that are already urbanized, which would not result in
irreversible land use changes. Additionally, as discussed in Section 9, Hazards and Hazardous
Materials, of this Addendum, compliance with federal, State, and local hazardous materials
regulations and local emergency plans would ensure that irreversible changes to the physical
environment from the accidental release of hazardous materials are less than significant. As
with the 2017 EIR, the proposed HEU would irretrievably commit non-renewable resources for
the construction and maintenance of buildings and infrastructure. These non-renewable
resources include mined materials such as sand, gravel, steel, lead, copper, and other metals.
Buildout of the proposed HEU would also result in a long-term commitment to the consumption
of fossil fuels, natural gas, and gasoline. Increased energy demands would be used for
construction, lighting, heating, and cooling of residences, and transportation of people within,
to, and from the housing inventory sites. However, the proposed project would place residents
in proximity to transit, services, and jobs, which would reduce consumption of fossil fuels
through the reduced reliance on single-occupancy vehicles and promote bicycling and walking.
Additionally, future development would be required to include an all-electric design pursuant
to the City’s Reach Code and would utilize 100 percent carbon neutral electricity supplied by
CPAU. Therefore, by facilitating residential development that would maximize conservation,
energy efficiency, and solar energy generation, impacts would be less than significant.
As described above in Sections 1 through 20, the proposed project would not result in new or
substantially more severe significant direct, indirect, or cumulative impacts beyond those
identified in the 2017 EIR for the 2030 Comprehensive Plan. Therefore, the proposed project
would also result in no new or substantially more severe significant impacts found not to be
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OTHER CEQA REQUIRED DISCUSSIONS
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significant, growth-inducing impacts, and irreversible changes beyond those previously
discussed in the 2017 EIR.
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CONCLUSION
As demonstrated in the discussions above regarding the potential effects of the proposed HEU,
substantial changes are not proposed to the 2030 Comprehensive Plan nor have substantial
changes in circumstances occurred that would require major revisions to the 2017 EIR prepared
for the 2030 Comprehensive Plan. Significant impacts beyond those identified and analyzed in
the 2017 EIR would not be expected to occur as a result of the proposed project. Overall, the
proposed HEU would result in no new information of substantial importance that would have
new, more severe impacts, or new mitigation measures from what was identified in the 2017
EIR. As such, the proposed project would not result in conditions identified in State CEQA
Guidelines Section 15162, and a Subsequent or Supplemental EIR is not required for the
proposed project. Again, it should be noted that the proposed project would be subject to all
previously required mitigation measures from the 2017 EIR, as applicable. The MMRP adopted
for the 2030 Comprehensive Plan would continue to be applicable to the proposed project.
Based on the above analysis, this Addendum to the 2017 EIR for the 2030 Comprehensive Plan
has been prepared in accordance with Section 15164 of the State CEQA Guidelines.
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CONCLUSION
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REFERENCES
BIBLIOGRAPHY
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21.pdf
BAAQMD. 2017a. California Environmental Quality Act: Air Quality Guidelines. San Francisco, CA. May
2017. http://www.baaqmd.gov/~/media/files/planning-and-
research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en
______. 2017b. Final 2017 Clean Air Plan. April 19, 2017.
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-
plan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en
California Air Resources Board (CARB). 2005. Air Quality and Land Use handbook: A Community Health
Perspective. https://sfmohcd.org/sites/default/files/20%20-
%20CARB%2C%20Air%20Quality%20and%20Land%20Use%20Handbook%202005.pdf
______. 2017. 2017 Climate Change Scoping Plan.
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______. 2021. Overview: Diesel Exhaust & Health. https://ww2.arb.ca.gov/resources/overview-diesel-
exhaust-and-health
California Department of Conservation (DOC). 2002. California Geomorphic Provinces.
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CalRecycle. 2022a. Jurisdiction Disposal and Alternative Daily Cover (ADC) Tons by Facility.
https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility
______. 2022b. Kirby Canyon Landfill.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1370?siteID=3393
______. 2022c. Corinda Los Trancos Landfill (Ox Mountain).
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223
______. 2022d. Monterey Peninsula Landfill.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2642?siteID=1976
______. 2023. Estimated Solid Waste Generation Rates.
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates
DecisionInsite. 2021. Annual Enrollment Projection Report Palo Alto Unified School District.
https://go.boarddocs.com/ca/pausd/Board.nsf/files/C29PNR646AA6/$file/20210420Attachmen
t4DecisionInsiteEnrollmentProjectionReport.pdf
Department of Finance (DOF). 2022. E-5 Population and Housing Estimates for Cities, Counties, and the
State 2020-2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-
housing-estimates-for-cities-counties-and-the-state-2020-2022/
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REFERENCES
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IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the
Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte,
V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M. I. Gomis,
M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu
and B. Zhou (eds.)] Cambridge University Press.
https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf
Office of Emergency Services. 2017. Santa Clara County Operational Area Hazard Mitigation Plan.
https://emergencymanagement.sccgov.org/sites/g/files/exjcpb261/files/For%20Partners/Local-
Hazard-Mitigation-Plan-LHMP-Vol-1.pdf
Palo Alto, City of. 2005. Palo Alto Single-Family Individual Review Guidelines. Adopted June 10, 2005.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/file-
migration/current-planning/forms-and-guidelines/individual-review-ir-guidelines.pdf
______. 2012. City of Palo Alto Bicycle and Pedestrian Transportation Plan.
https://www.cityofpaloalto.org/files/assets/public/transportation/projects/bicycle-pedestrian-
transportation-plan_adopted-july-2012.pdf
______. 2016. City of Palo Alto Comprehensive Plan Draft EIR Volume 1. Adopted February 5, 2016.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/paloaltocompplandeir_vol1_web-1.pdf
______. 2017a. City of Palo Alto Comprehensive Plan Update Supplement to the Draft EIR.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/paloalto_compplanupdate_suppeir_feb2017.pdf
______. 2017b. City of Palo Alto Comprehensive Plan. Adopted November 13, 2017.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/full-comp-plan-2030_with-june21-amendments.pdf
______. 2018. City of Palo Alto Zero Waste Plan. Adopted August 2018.
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zero-waste-plan.pdf
______. 2020. Regulations for Groundwater Dewatering during Construction of Below Ground
Structures. https://www.cityofpaloalto.org/files/assets/public/public-works/engineering-
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construction-of-below-ground-structures-2021.pdf
______. 2021. 2020 Urban Water Management Plan and Water Shortage Contingency Plan.
https://www.cityofpaloalto.org/files/assets/public/utilities/uwmp/2020-uwmp_final-
submission-to-dwr.pdf
______. 2022a. Green Building Code Requirements. https://www.cityofpaloalto.org/City-
Hall/Sustainability/Green-Building-Code-Requirements
______. 2022b. Carbon Neutral Electricity and Natural Gas.
https://www.cityofpaloalto.org/Departments/Utilities/Sustainability/Carbon-Neutral-Electricity-
and-Natural-Gas
______. 2022c. 2022 Sustainability and Climate Action Plan Goal and Key Actions. Adopted October 3,
2022. https://www.cityofpaloalto.org/files/assets/public/sustainability/policies-and-plans/2022-
scap-goals-and-key-actions.pdf
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______. 2022d. Dewatering Sites.
https://www.google.com/maps/d/viewer?mid=14ztztkt6te1yanSaxzUhuJONY-
E&ll=37.43630527807649%2C-122.13162251821232&z=14
______. 2022e. Fire Station No. 4 Replacement Project.
https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-Services/Engineering-
Projects/Fire-Station-No.-4-Replacement-Project
______. 2023. Below Market Rate Housing. https://www.cityofpaloalto.org/Departments/Planning-
Development-Services/Long-Range-Planning/Housing-Policies-and-Programs/Below-Market-
Rate-Housing
Santa Clara County Airport Land Use Commission. 2016. Comprehensive Land Use Plan Santa Clara
County Palo Alto Airport. Amended November 16, 2016.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/aluc_pao_clup_2017.pdf
United States Environmental Protection Agency (US EPA). 2021. Overview of Greenhouse Gases.
https://www.epa.gov/ghgemissions/overview-greenhouse-gases
LIST OF PREPARERS
Rincon Consultants, Inc. prepared this Addendum under contract to the City of Palo Alto.
Persons involved in data gathering analysis, project management, and quality control include
the following:
RINCON CONSULTANTS, INC.
Abe Leider, AICP CEP, Principal in Charge
Karly Kaufman, MESM, Project Manager
Heather Dubois, Senior Air Quality Specialist
Bill Vosti, Program Manager – Air Quality, GHG Emissions, and Noise
Nichole Yee, Environmental Planner
Gina Gerlich, GIS Analyst
Debra Jane Seltzer, Publishing Specialist
Yaritza Ramirez, Publishing Specialist
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Appendix A
Vehicle Miles Traveled Analysis
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Technical Memorandum
Date: February 17, 2023
To: Karly Kaufman
From: At van den Hout
Subject: VMT Analysis for the Palo Alto Housing Element Update (HEU)
Hexagon Transportation Consultants, Inc. has conducted a CEQA transportation VMT analysis for the
proposed residential developments under the Palo Alto Housing Element. This memorandum presents a
summary of the vehicle miles traveled (VMT) methodology and analysis findings.
Project Description
The proposed Housing Element would amend the City of Palo Alto’s 2030 Comprehensive Plan by replacing
the current Housing Element with the proposed 2023‐2031 Housing Element. The proposed Housing
Element identifies 289 sites that could provide additional housing of 6,668 residential units within the City
of Palo Alto. The majority of the sites are located throughout Palo Alto’s Downtown and South of the Forest
Area in districts that allow for a mix of residential and commercial uses near transit and services.
Senate Bill 743
Based on revisions in State law to implement Senate Bill (SB) 743, public agencies in California
are mandated to use vehicle miles traveled (VMT) as the metric for CEQA transportation
analyses starting July 1, 2020. The CEQA Guidelines now identify VMT as the most appropriate metric for
evaluating a project’s transportation impacts. With the California Natural Resources Agency’s certification
and adoption of the changes to the CEQA Guidelines, automobile delay and congestion, as measured by
level of service (LOS) and other similar metrics, no longer constitutes a significant environmental effect
under CEQA. However, LOS is used outside the CEQA document to evaluate other non‐CEQA transportation
impacts of development projects, such as congestion, circulation, and safety issues and concerns.
Palo Alto Vehicle Miles Traveled Policy
On June 15, 2020, Palo Alto City Council established a VMT policy by adopting a resolution updating the
City’s transportation analysis methodology under CEQA to comply with California Senate Bill 743. In
addition, City Council adopted a local transportation impact analysis policy to evaluate level of service and
other local roadway impacts. The VMT policy contains screening criteria to identify projects that can be
presumed to have a less than significant transportation impact. The Governor’s Office of Planning and
Research (OPR) recommends that agencies use screening criteria to identify projects known to reduce VMT
or be low VMT generators, and that are thus expected to have a less than significant VMT impact. These
projects would then be exempt from performing a quantitative VMT analysis. The use of screening criteria
streamlines analysis for projects already presumed to have a less than significant impact on VMT. Palo
Alto’s Comprehensive Plan policies encourage housing developments to protect local‐serving
retail, and to reduce traffic on the roadway network. Therefore, projects aligned with City policies do not
have to procure costly and redundant transportation analyses that will show they are low‐VMT
generators under CEQA. If a project meets the screening criteria, a quantitative VMT analysis
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would not be required; however, the CEQA analysis would still include a qualitative assessment of
VMT, discussing the site(s) and location characteristics.
The City of Palo Alto has established the following VMT screening criteria to determine land use
development projects that may be exempt from additional VMT analysis under the City’s VMT guidelines:
Small Projects: Projects that generate fewer than 110 trips per day. This may equate to non‐
residential projects of 10,000 sq. ft., or less and residential projects of 20 units or less.
Projects in Low VMT Areas: Residential and office projects located in low‐VMT areas1 with similar
features (i.e., density, mix of uses, transit accessibility) as existing developments in these areas.
Projects in Proximity to Major Transit Stops: Projects that are located within a half mile of an
existing or planned high‐quality transit corridor or major transit stations, and meet the following
additional criteria:
(1) is high density (minimum floor area ratio of 0.75),
(2) does not exceed parking requirements,
(3) is consistent with Plan Bay Area, and
(4) does not replace affordable units with smaller numbers of moderate‐ or above moderate‐
income units.
Affordable Housing: 100% affordable housing projects in infill locations.
Local Serving Retail: Retail projects of 50,000 sq. ft. or less.
Thresholds of Significance
Land use projects not screened out will require quantitative VMT analyses, and their VMTs must be below
pre‐determined thresholds to be considered as having a less‐than‐significant impact. Consistent with State
CEQA Guidelines Section 15064.3, the City of Palo Alto has adopted the thresholds of significance for
residential projects. A residential project that exceeds a level of 15% below existing (baseline) County
home‐based VMT per resident may indicate a significant transportation impact.
VMT Analysis Methodology and Findings
When applying the above thresholds for residential projects, VMT is compared to a threshold based on the
countywide (2015) baseline VMT value, which is the home‐based VMT per resident. Home‐based VMT per
resident is defined as the number of all home‐based automobile vehicle trips traced back to the residence
multiplied by the vehicle distance. This home‐based VMT is then divided by the population to calculate
home‐based VMT per resident.
1 Residential projects located in areas where baseline VMT is 15% below the existing county average per resident,
and office projects located in areas where baseline VMT is 15% below the existing regional average per employee
could be considered to be in low‐VMT areas and presumed to have a less than significant VMT impact.
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Travel Forecasting Model
The VMT calculations are done with the recently completed Palo Alto Travel Forecasting Model (PA model).
The PA model is a refinement of Santa Clara Valley Transportation Authority’s (VTA’s) Bi‐County Travel
Forecasting Model (VTA model)2. The PA model is the best available tool to simulate travel in Palo Alto and
serves as the primary forecasting tool for the City. The model is a mathematical representation of travel in
the nine Bay Area counties and Santa Cruz, San Benito, Monterey, and San Juaquin counties, focusing on
travel within the City of Palo Alto. The model has four main components: 1) trip generation, 2) trip
distribution, 3) mode choice, and 4) trip assignment. The model uses socioeconomic inputs (i.e., population,
income, employment) aggregated into geographic areas, called transportation analysis zones (TAZs), to
estimate travel within the modeled area. There are 110 TAZs within the model that represent the City of
Palo Alto, and the 289 Housing Element sites are spread out over 44 TAZs.
Scenarios Analyzed
In addition to evaluating VMT for the Housing Element, VMT associated with Scenario 6 of the City’s
Comprehensive Plan was also analyzed. The land use assumptions and transportation networks of the PA
model were updated to reflect the year 2031 conditions. The year 2031 land use data outside Palo Alto was
interpolated between VTA’s 2015 and 2040 land use assumptions. Palo Alto’s two future land use scenarios
reflect the increases in households and employment proposed for the Comprehensive Plan and the Housing
Element, respectively. The following scenarios are addressed in the VMT analysis.
Baseline (2015) Conditions: The baseline (2015) PA model is used to determine the baseline home‐
based VMT per resident for the TAZs in Palo Alto, as well as to determine the countywide average
VMT per resident and the 85 percentile of the countywide average VMT per resident.
Comprehensive Plan (2031) Conditions: This scenario includes the proposed land uses assumed for
Scenario 6 of Palo Alto’s Comprehensive Plan. Scenario 6 contains 6,000 additional housing units
and 8,868 jobs.
Housing Element (2031) Conditions: This scenario includes the proposed land uses assumed in the
Housing Element. The Housing Element includes 6,668 additional housing units and 8,868 jobs.
Figures 1 and 2 present the growth in housing units for the TAZs assumed for the Comprehensive Plan and
the Housing Element Plan, respectively. The increase in jobs, which is assumed to be the same for both the
Comprehensive Plan and the Housing Element Plan, is shown on Figure 3.
2 Documentation of the Palo Alto Travel Forecasting Model Update is summarized in a Technical Memorandum: Palo Alto
Model Update and Validation Results, January 5, 2023.
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Figure 1
Increase in Housing Units by Palo Alto TAZ for the Comprehensive Plan
City of Palo Alto
13
12
14
5
1
6
6
3
1
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3
4
5
6
7
7
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222
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896
108
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81
114
148
155
117
63
134
72
103
68
676868
8673
Legend
Increase in the Number of Housing Units
0
1 - 50
51 - 200
201 - 500
501 - 896
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Figure 2
Increase in Housing Units by Palo Alto TAZ for the Housing Element
City of Palo Alto
3
5
43
35
51
278
58
93
52
9
37
31
56
55
45
54
173
23
11
229
10
1909
542
15
330
40 13
237
305
62
74
916
17
197
104
91
29
15
54
67
687
64
Legend
Increase in the Number of Housing Units
0 - 1
2 - 50
51 - 200
201 - 500
501 - 1909
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44
38
40
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29
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364
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1899
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355
58
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24
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8564
22
58
546943
5853
222
Legend
Increase in the Number of Jobs
0 - 1
2 - 100
101 - 200
201 - 500
501 - 1899 Figure 3
Increase in Employment by Palo Alto TAZ
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Residential VMT Analysis
The PA model was used to estimate the 2015 baseline countywide VMT, the VMT for the Comprehensive
Plan, and the Housing Element. Table 1 below shows the residential VMT, the number of housing units, the
population, and the VMT per resident for Santa Clara County and three Palo Alto scenarios. The county
average VMT per resident for residential development is 12.89, and the threshold of significance is 85
percent of 12.89 or 10.96 daily vehicle miles per resident. As a whole, the Comprehensive Plan and the
Housing Element have a residential VMT of 8.88 and 9.13, respectively, which is less than 85 percent of the
county average VMT per resident. Thus, the VMT per resident for the Housing Element (and also for the
Comprehensive Plan) as a whole would be below the threshold of 10.96 VMT per resident. Therefore,
implementation of the Housing Element would result in a less‐than‐significant VMT impact on
transportation.
Table 1: VMT Projections for Palo Alto and Santa Clara County
Site-Specific VMT Analysis
The 289 Housing Element sites are spread out over 44 TAZs. A VMT analysis for each of the 44 TAZs shows
that the Housing Element sites in three TAZs have a VMT per resident higher than the threshold of 85
percent of the countywide average, but these VMTs are still lower than the county average of 12.89. A
summary of the VMT data for those three TAZs is shown in Table 2. A map of the VMT per resident for the
Housing Element TAZs is shown on Figure 4. The sites in the other 41 TAZs have VMT per resident values
less than 85 percent of the county average.
Table 2
Housing Sites in TAZs with VMTs Higher than 85 Percent of the County Average
Individual housing development projects located at sites in these three TAZs are subject to mitigate VMT
impacts. A list of TDM strategies to mitigate VMT impacts can be found in Appendix G of the document “SB
743 Implementation Decisions for Palo Alto” at this link.
Area Scenario
Residential
VMT 1
Housing
Units Population
VMT per
Resident 2
2015 639,185 27,771 69,537 9.19
2031 Comp 751,323 33,771 84,597 8.88
2031 HEU 787,447 34,439 86,277 9.13
Santa Clara County 2015 23,879,300 627,249 1,852,178 12.89
1 Residential VMT = Home‐Based Trip Productions * Travel Distance
2 VMT per Resident = Residential VMT / Population
City of Palo Alto
TAZ
Residential
VMT 1
Total Housing
Units Population
VMT per
Resident 2
HEU Housing
Units
477 26,125 916 2,299 11.36 916
496 7,920 327 626 12.65 17
533 15,208 677 1,314 11.58 62
1 Residential VMT = Home‐Based Trip Productions * Travel Distance
2 VMT per Resident = Residential VMT / Population
Note: The threshold of significance is 85 percent of the county average, or 10.96 daily miles per resident
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Figure 4
Home-Based VMT per Resident for the Housing Element TAZs
City of Palo Alto
9.87 8.56 8.5
9.23
9.38
3.65
8.47
10.51
8.01
9.76
6.25
5.93
10.88
7.92
9.86
7.835.8
10.88
10.42
6.1
9.72
8.46
12.65
5.75
10.1
7.14
7.92
8.8
6.52
10.54
9.65
11.36
9.16
5.43
11.58
6.59
9.67
8.71
4.47
5.75
8.59
5.6
7.24
7.48
Legend
VMT is less than 85% of the County Average
VMT is between 85% and 100 % of the County Average
XX.XX = Home-Based VMT per Resident
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Appendix B
Greenhouse Gas Emissions Modeling Results
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Palo Alto HEU - GHG Emissions Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
3. Construction Emissions Details
3.1. Demolition (2023) - Unmitigated
3.3. Site Preparation (2023) - Unmitigated
3.5. Grading (2023) - Unmitigated
3.7. Building Construction (2023) - Unmitigated
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3.9. Building Construction (2024) - Unmitigated
3.11. Building Construction (2025) - Unmitigated
3.13. Building Construction (2026) - Unmitigated
3.15. Paving (2026) - Unmitigated
3.17. Architectural Coating (2025) - Unmitigated
3.19. Architectural Coating (2026) - Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.2. Unmitigated
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
4.5. Waste Emissions by Land Use
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4.5.2. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
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5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
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5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
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5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Palo Alto HEU - GHG Emissions
Lead Agency —
Land Use Scale Plan/community
Analysis Level for Defaults County
Windspeed (m/s)4.20
Precipitation (days)18.8
Location Palo Alto, CA, USA
County Santa Clara
City Palo Alto
Air District Bay Area AQMD
Air Basin San Francisco Bay Area
TAZ 1726
EDFZ 1
Electric Utility City of Palo Alto
Gas Utility City of Palo Alto Ultilities
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
Population Description
Apartments Mid Rise 665 Dwelling Unit 17.5 638,400 0.00 0.00 1,669 —
1.3. User-Selected Emission Reduction Measures by Emissions Sector
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No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.4.77 46.2 39.8 38.9 0.06 1.81 19.8 21.6 1.66 10.1 11.8 —9,373 9,373 0.43 0.48 24.5 9,549
Daily,
Winter
(Max)
——————————————————
Unmit.3.57 46.1 27.4 35.5 0.04 1.20 5.25 5.74 1.10 1.25 1.70 —9,011 9,011 0.33 0.50 0.64 9,168
Average
Daily
(Max)
——————————————————
Unmit.2.54 27.7 18.1 24.6 0.03 0.76 4.50 5.26 0.70 1.82 2.52 —6,362 6,362 0.22 0.34 7.40 6,477
Annual
(Max)
——————————————————
Unmit.0.46 5.05 3.31 4.49 0.01 0.14 0.82 0.96 0.13 0.33 0.46 —1,053 1,053 0.04 0.06 1.22 1,072
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
——————————————————
2023 4.77 4.01 39.8 37.1 0.06 1.81 19.8 21.6 1.66 10.1 11.8 —8,639 8,639 0.43 0.46 24.5 8,813
2024 3.47 2.95 15.1 35.4 0.04 0.52 4.46 4.98 0.48 1.07 1.55 —8,533 8,533 0.29 0.46 23.0 8,701
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2025 3.79 46.2 15.2 38.9 0.04 0.49 5.25 5.74 0.45 1.25 1.70 —9,373 9,373 0.30 0.48 24.5 9,549
2026 3.46 46.0 14.3 37.1 0.04 0.43 5.25 5.68 0.40 1.25 1.65 —9,246 9,246 0.30 0.48 22.2 9,420
Daily -
Winter
(Max)
——————————————————
2023 3.56 3.01 27.4 34.0 0.04 1.20 4.46 5.04 1.10 1.07 1.60 —8,324 8,324 0.33 0.47 0.64 8,474
2024 3.40 2.87 15.6 32.5 0.04 0.52 4.46 4.98 0.48 1.07 1.55 —8,225 8,225 0.32 0.47 0.59 8,374
2025 3.57 46.1 15.7 35.5 0.04 0.49 5.25 5.74 0.45 1.25 1.70 —9,011 9,011 0.32 0.50 0.64 9,168
2026 3.40 45.8 14.8 34.0 0.04 0.43 5.25 5.68 0.40 1.25 1.65 —8,892 8,892 0.32 0.50 0.58 9,048
Average
Daily
——————————————————
2023 2.54 2.14 18.1 20.0 0.03 0.76 4.50 5.26 0.70 1.82 2.52 —4,092 4,092 0.16 0.12 2.37 4,134
2024 2.42 2.05 11.0 23.0 0.03 0.38 3.16 3.53 0.35 0.75 1.10 —5,921 5,921 0.22 0.34 7.07 6,035
2025 2.48 27.7 10.9 24.6 0.03 0.34 3.61 3.95 0.32 0.86 1.18 —6,362 6,362 0.22 0.34 7.40 6,477
2026 1.43 18.8 6.56 14.5 0.02 0.21 2.04 2.25 0.19 0.49 0.68 —3,689 3,689 0.13 0.19 3.77 3,752
Annual ——————————————————
2023 0.46 0.39 3.31 3.65 0.01 0.14 0.82 0.96 0.13 0.33 0.46 —677 677 0.03 0.02 0.39 685
2024 0.44 0.37 2.01 4.21 < 0.005 0.07 0.58 0.64 0.06 0.14 0.20 —980 980 0.04 0.06 1.17 999
2025 0.45 5.05 1.99 4.49 < 0.005 0.06 0.66 0.72 0.06 0.16 0.22 —1,053 1,053 0.04 0.06 1.22 1,072
2026 0.26 3.43 1.20 2.64 < 0.005 0.04 0.37 0.41 0.03 0.09 0.12 —611 611 0.02 0.03 0.62 621
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.14.1 30.9 12.8 113 0.23 0.64 7.54 8.18 0.64 1.33 1.97 324 27,711 28,035 23.5 0.97 44.0 28,954
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——————————————————Daily,
Winter
(Max)
Unmit.10.4 27.2 13.4 71.0 0.22 0.63 7.54 8.17 0.62 1.33 1.95 324 26,464 26,788 23.6 1.04 5.59 27,692
Average
Daily
(Max)
——————————————————
Unmit.10.7 27.9 6.46 81.8 0.17 0.11 7.16 7.28 0.11 1.26 1.37 324 17,642 17,966 23.3 0.96 20.7 18,854
Annual
(Max)
——————————————————
Unmit.1.96 5.10 1.18 14.9 0.03 0.02 1.31 1.33 0.02 0.23 0.25 53.6 2,921 2,974 3.86 0.16 3.43 3,122
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Mobile 9.92 9.24 5.85 72.7 0.19 0.10 7.54 7.64 0.09 1.33 1.42 —19,279 19,279 0.72 0.73 39.4 19,554
Area 4.21 21.6 6.91 40.7 0.04 0.54 —0.54 0.55 —0.55 0.00 8,432 8,432 0.16 0.02 —8,441
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————101 0.00 101 0.35 0.22 —176
Waste ———————————222 0.00 222 22.2 0.00 —778
Refrig.————————————————4.57 4.57
Total 14.1 30.9 12.8 113 0.23 0.64 7.54 8.18 0.64 1.33 1.97 324 27,711 28,035 23.5 0.97 44.0 28,954
Daily,
Winter
(Max)
——————————————————
Mobile 9.59 8.88 6.85 68.2 0.18 0.10 7.54 7.64 0.09 1.33 1.42 —18,133 18,133 0.81 0.80 1.02 18,393
Area 0.77 18.4 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 271
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
11 / 53
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————101 0.00 101 0.35 0.22 —176
Waste ———————————222 0.00 222 22.2 0.00 —778
Refrig.————————————————4.57 4.57
Total 10.4 27.2 13.4 71.0 0.22 0.63 7.54 8.17 0.62 1.33 1.95 324 26,464 26,788 23.6 1.04 5.59 27,692
Average
Daily
——————————————————
Mobile 9.00 8.34 6.12 63.1 0.17 0.09 7.16 7.26 0.09 1.26 1.35 —17,387 17,387 0.73 0.73 16.2 17,640
Area 1.72 19.6 0.33 18.7 < 0.005 0.02 —0.02 0.02 —0.02 0.00 255 255 0.01 < 0.005 —256
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————101 0.00 101 0.35 0.22 —176
Waste ———————————222 0.00 222 22.2 0.00 —778
Refrig.————————————————4.57 4.57
Total 10.7 27.9 6.46 81.8 0.17 0.11 7.16 7.28 0.11 1.26 1.37 324 17,642 17,966 23.3 0.96 20.7 18,854
Annual ——————————————————
Mobile 1.64 1.52 1.12 11.5 0.03 0.02 1.31 1.32 0.02 0.23 0.25 —2,879 2,879 0.12 0.12 2.68 2,921
Area 0.31 3.57 0.06 3.42 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 0.00 42.2 42.2 < 0.005 < 0.005 —42.3
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————16.8 0.00 16.8 0.06 0.04 —29.2
Waste ———————————36.8 0.00 36.8 3.68 0.00 —129
Refrig.————————————————0.76 0.76
Total 1.96 5.10 1.18 14.9 0.03 0.02 1.31 1.33 0.02 0.23 0.25 53.6 2,921 2,974 3.86 0.16 3.43 3,122
3. Construction Emissions Details
3.1. Demolition (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 272
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
12 / 53
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
3.39 2.84 27.3 23.5 0.03 1.20 —1.20 1.10 —1.10 —3,425 3,425 0.14 0.03 —3,437
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
3.39 2.84 27.3 23.5 0.03 1.20 —1.20 1.10 —1.10 —3,425 3,425 0.14 0.03 —3,437
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.46 0.39 3.75 3.22 < 0.005 0.16 —0.16 0.15 —0.15 —469 469 0.02 < 0.005 —471
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.08 0.07 0.68 0.59 < 0.005 0.03 —0.03 0.03 —0.03 —77.7 77.7 < 0.005 < 0.005 —77.9
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 273
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
13 / 53
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.06 0.06 0.05 0.71 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —134 134 0.01 < 0.005 0.61 136
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.06 0.05 0.06 0.61 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —124 124 < 0.005 0.01 0.02 125
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —17.1 17.1 < 0.005 < 0.005 0.04 17.4
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.84 2.84 < 0.005 < 0.005 0.01 2.88
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.3. Site Preparation (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 274
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
14 / 53
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
4.70 3.95 39.7 35.5 0.05 1.81 —1.81 1.66 —1.66 —5,295 5,295 0.21 0.04 —5,314
Dust
From
Material
Movement
——————19.7 19.7 —10.1 10.1 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.39 0.32 3.27 2.92 < 0.005 0.15 —0.15 0.14 —0.14 —435 435 0.02 < 0.005 —437
Dust
From
Material
Movement
——————1.62 1.62 —0.83 0.83 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.07 0.06 0.60 0.53 < 0.005 0.03 —0.03 0.02 —0.02 —72.1 72.1 < 0.005 < 0.005 —72.3
Dust
From
Material
Movement
——————0.29 0.29 —0.15 0.15 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 275
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
15 / 53
——————————————————Daily,
Summer
(Max)
Worker 0.07 0.06 0.05 0.83 0.00 0.00 0.14 0.14 0.00 0.03 0.03 —156 156 0.01 0.01 0.71 159
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.01 0.01 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —12.0 12.0 < 0.005 < 0.005 0.03 12.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.99 1.99 < 0.005 < 0.005 < 0.005 2.02
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.5. Grading (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
4.43 3.72 37.3 31.4 0.06 1.59 —1.59 1.47 —1.47 —6,598 6,598 0.27 0.05 —6,621
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 276
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
16 / 53
———————3.653.65—9.209.20——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.91 0.76 7.66 6.45 0.01 0.33 —0.33 0.30 —0.30 —1,356 1,356 0.05 0.01 —1,360
Dust
From
Material
Movement
——————1.89 1.89 —0.75 0.75 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.17 0.14 1.40 1.18 < 0.005 0.06 —0.06 0.06 —0.06 —224 224 0.01 < 0.005 —225
Dust
From
Material
Movement
——————0.35 0.35 —0.14 0.14 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.08 0.07 0.06 0.95 0.00 0.00 0.17 0.17 0.00 0.04 0.04 —178 178 0.01 0.01 0.81 181
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 277
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
17 / 53
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.02 0.01 0.01 0.17 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —34.3 34.3 < 0.005 < 0.005 0.07 34.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —5.68 5.68 < 0.005 < 0.005 0.01 5.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.7. Building Construction (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.50 1.26 11.8 13.2 0.02 0.55 —0.55 0.51 —0.51 —2,397 2,397 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.50 1.26 11.8 13.2 0.02 0.55 —0.55 0.51 —0.51 —2,397 2,397 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 278
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
18 / 53
Average
Daily
——————————————————
Off-Road
Equipment
0.32 0.27 2.50 2.78 < 0.005 0.12 —0.12 0.11 —0.11 —507 507 0.02 < 0.005 —508
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.06 0.05 0.46 0.51 < 0.005 0.02 —0.02 0.02 —0.02 —83.9 83.9 < 0.005 < 0.005 —84.2
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.93 1.77 1.44 22.6 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,268 4,268 0.21 0.16 19.4 4,339
Vendor 0.20 0.07 2.70 1.29 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,974 1,974 0.12 0.29 5.12 2,068
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.86 1.68 1.76 19.5 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,951 3,951 0.12 0.17 0.50 4,004
Vendor 0.19 0.07 2.85 1.32 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,975 1,975 0.12 0.29 0.13 2,064
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.39 0.35 0.34 4.07 0.00 0.00 0.83 0.83 0.00 0.19 0.19 —844 844 0.02 0.04 1.77 857
Vendor 0.04 0.01 0.59 0.28 < 0.005 0.01 0.10 0.11 0.01 0.03 0.03 —417 417 0.03 0.06 0.47 437
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.07 0.06 0.06 0.74 0.00 0.00 0.15 0.15 0.00 0.04 0.04 —140 140 < 0.005 0.01 0.29 142
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 279
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
19 / 53
Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —69.1 69.1 < 0.005 0.01 0.08 72.3
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.9. Building Construction (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.44 1.20 11.2 13.1 0.02 0.50 —0.50 0.46 —0.46 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.44 1.20 11.2 13.1 0.02 0.50 —0.50 0.46 —0.46 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
1.03 0.86 8.04 9.39 0.02 0.36 —0.36 0.33 —0.33 —1,717 1,717 0.07 0.01 —1,723
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.19 0.16 1.47 1.71 < 0.005 0.07 —0.07 0.06 —0.06 —284 284 0.01 < 0.005 —285
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 280
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
20 / 53
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.84 1.67 1.29 21.0 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,186 4,186 0.07 0.16 17.8 4,252
Vendor 0.20 0.07 2.58 1.23 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,949 1,949 0.12 0.29 5.12 2,043
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.77 1.60 1.62 18.1 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,877 3,877 0.11 0.17 0.46 3,929
Vendor 0.19 0.07 2.72 1.27 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,950 1,950 0.12 0.29 0.13 2,039
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 1.26 1.14 1.05 12.8 0.00 0.00 2.80 2.80 0.00 0.66 0.66 —2,807 2,807 0.07 0.12 5.49 2,850
Vendor 0.14 0.05 1.91 0.89 0.01 0.02 0.36 0.37 0.02 0.10 0.12 —1,396 1,396 0.09 0.21 1.58 1,462
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.23 0.21 0.19 2.33 0.00 0.00 0.51 0.51 0.00 0.12 0.12 —465 465 0.01 0.02 0.91 472
Vendor 0.03 0.01 0.35 0.16 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 —231 231 0.01 0.03 0.26 242
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.11. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 281
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
21 / 53
Off-Road
Equipment
1.35 1.13 10.4 13.0 0.02 0.43 —0.43 0.40 —0.40 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.35 1.13 10.4 13.0 0.02 0.43 —0.43 0.40 —0.40 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.96 0.80 7.46 9.31 0.02 0.31 —0.31 0.28 —0.28 —1,713 1,713 0.07 0.01 —1,719
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.18 0.15 1.36 1.70 < 0.005 0.06 —0.06 0.05 —0.05 —284 284 0.01 < 0.005 —285
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.75 1.59 1.16 19.6 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,103 4,103 0.07 0.16 16.2 4,168
Vendor 0.18 0.07 2.46 1.19 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,918 1,918 0.11 0.28 5.08 2,008
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.58 1.53 1.47 16.8 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,801 3,801 0.10 0.17 0.42 3,853
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 282
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
22 / 53
Vendor 0.18 0.07 2.58 1.21 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,919 1,919 0.11 0.28 0.13 2,004
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 1.11 1.08 0.94 11.8 0.00 0.00 2.79 2.79 0.00 0.65 0.65 —2,745 2,745 0.06 0.11 5.00 2,784
Vendor 0.13 0.05 1.82 0.86 0.01 0.02 0.35 0.37 0.02 0.10 0.12 —1,370 1,370 0.08 0.20 1.57 1,432
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.20 0.20 0.17 2.15 0.00 0.00 0.51 0.51 0.00 0.12 0.12 —454 454 0.01 0.02 0.83 461
Vendor 0.02 0.01 0.33 0.16 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 —227 227 0.01 0.03 0.26 237
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.13. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.28 1.07 9.85 13.0 0.02 0.38 —0.38 0.35 —0.35 —2,397 2,397 0.10 0.02 —2,405
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.28 1.07 9.85 13.0 0.02 0.38 —0.38 0.35 —0.35 —2,397 2,397 0.10 0.02 —2,405
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 283
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
23 / 53
Average
Daily
——————————————————
Off-Road
Equipment
0.50 0.41 3.82 5.02 0.01 0.15 —0.15 0.13 —0.13 —929 929 0.04 0.01 —932
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.09 0.08 0.70 0.92 < 0.005 0.03 —0.03 0.02 —0.02 —154 154 0.01 < 0.005 —154
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.55 1.51 1.02 18.3 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,026 4,026 0.07 0.16 14.7 4,089
Vendor 0.18 0.06 2.34 1.15 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,885 1,885 0.11 0.28 4.59 1,974
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.50 1.34 1.33 15.6 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,730 3,730 0.10 0.17 0.38 3,782
Vendor 0.17 0.05 2.47 1.16 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,886 1,886 0.11 0.28 0.12 1,971
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.57 0.51 0.45 5.97 0.00 0.00 1.52 1.52 0.00 0.35 0.35 —1,461 1,461 0.03 0.06 2.46 1,482
Vendor 0.07 0.02 0.94 0.45 0.01 0.01 0.19 0.20 0.01 0.05 0.06 —730 730 0.04 0.11 0.77 764
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.10 0.09 0.08 1.09 0.00 0.00 0.28 0.28 0.00 0.06 0.06 —242 242 0.01 0.01 0.41 245
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 284
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
24 / 53
Vendor 0.01 < 0.005 0.17 0.08 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —121 121 0.01 0.02 0.13 127
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.15. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.91 0.76 7.12 9.94 0.01 0.32 —0.32 0.29 —0.29 —1,511 1,511 0.06 0.01 —1,516
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.91 0.76 7.12 9.94 0.01 0.32 —0.32 0.29 —0.29 —1,511 1,511 0.06 0.01 —1,516
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.11 0.10 0.90 1.25 < 0.005 0.04 —0.04 0.04 —0.04 —190 190 0.01 < 0.005 —191
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 285
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
25 / 53
Off-Road
Equipment
0.02 0.02 0.16 0.23 < 0.005 0.01 —0.01 0.01 —0.01 —31.5 31.5 < 0.005 < 0.005 —31.6
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.05 0.05 0.03 0.57 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —126 126 < 0.005 < 0.005 0.46 128
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.05 0.04 0.04 0.49 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —117 117 < 0.005 0.01 0.01 118
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.01 0.01 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —14.9 14.9 < 0.005 < 0.005 0.03 15.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.46 2.46 < 0.005 < 0.005 < 0.005 2.50
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.17. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 286
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
26 / 53
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.09 0.08 0.52 0.68 < 0.005 0.02 —0.02 0.01 —0.01 —79.2 79.2 < 0.005 < 0.005 —79.4
Architect
ural
Coatings
—25.5 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.01 0.10 0.12 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —13.1 13.1 < 0.005 < 0.005 —13.2
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 287
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
27 / 53
Architect
Coatings
—4.65 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.35 0.32 0.23 3.91 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —821 821 0.01 0.03 3.24 834
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.32 0.31 0.29 3.36 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —760 760 0.02 0.03 0.08 771
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.18 0.18 0.16 1.96 0.00 0.00 0.46 0.46 0.00 0.11 0.11 —456 456 0.01 0.02 0.83 462
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.03 0.03 0.03 0.36 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —75.4 75.4 < 0.005 < 0.005 0.14 76.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.19. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 288
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
28 / 53
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.15 0.12 0.86 1.13 < 0.005 0.02 —0.02 0.02 —0.02 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.15 0.12 0.86 1.13 < 0.005 0.02 —0.02 0.02 —0.02 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.06 0.05 0.35 0.46 < 0.005 0.01 —0.01 0.01 —0.01 —54.6 54.6 < 0.005 < 0.005 —54.8
Architect
ural
Coatings
—17.6 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.06 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —9.04 9.04 < 0.005 < 0.005 —9.07
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 289
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
29 / 53
————————————————3.21—Architect
ural
Coatings
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.31 0.30 0.20 3.65 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —805 805 0.01 0.03 2.94 818
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.30 0.27 0.27 3.12 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —746 746 0.02 0.03 0.08 756
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.12 0.11 0.10 1.26 0.00 0.00 0.32 0.32 0.00 0.07 0.07 —308 308 0.01 0.01 0.52 313
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.02 0.02 0.02 0.23 0.00 0.00 0.06 0.06 0.00 0.01 0.01 —51.1 51.1 < 0.005 < 0.005 0.09 51.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 290
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
30 / 53
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
9.92 9.24 5.85 72.7 0.19 0.10 7.54 7.64 0.09 1.33 1.42 —19,279 19,279 0.72 0.73 39.4 19,554
Total 9.92 9.24 5.85 72.7 0.19 0.10 7.54 7.64 0.09 1.33 1.42 —19,279 19,279 0.72 0.73 39.4 19,554
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
9.59 8.88 6.85 68.2 0.18 0.10 7.54 7.64 0.09 1.33 1.42 —18,133 18,133 0.81 0.80 1.02 18,393
Total 9.59 8.88 6.85 68.2 0.18 0.10 7.54 7.64 0.09 1.33 1.42 —18,133 18,133 0.81 0.80 1.02 18,393
Annual ——————————————————
Apartme
nts
Mid Rise
1.64 1.52 1.12 11.5 0.03 0.02 1.31 1.32 0.02 0.23 0.25 —2,879 2,879 0.12 0.12 2.68 2,921
Total 1.64 1.52 1.12 11.5 0.03 0.02 1.31 1.32 0.02 0.23 0.25 —2,879 2,879 0.12 0.12 2.68 2,921
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Item 3
Attachment A - Draft Addendum
2017 Comp Plan EIR
Packet Pg. 291
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
31 / 53
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
Annual ——————————————————
Apartme
nts
Mid Rise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Daily,
Winter
(Max)
——————————————————
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Apartme
Mid Rise
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Annual ——————————————————
Apartme
nts
Mid Rise
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
4.3. Area Emissions by Source
4.3.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Hearths 0.77 0.38 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
Consum
er
Products
—13.7 ————————————————
Architect
ural
Coatings
—4.31 ————————————————
Landsca
pe
Equipme
nt
3.44 3.26 0.35 37.9 < 0.005 0.01 —0.01 0.02 —0.02 —101 101 < 0.005 < 0.005 —101
Total 4.21 21.6 6.91 40.7 0.04 0.54 —0.54 0.55 —0.55 0.00 8,432 8,432 0.16 0.02 —8,441
Daily,
Winter
(Max)
——————————————————
Hearths 0.77 0.38 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
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Consum
Products
—13.7 ————————————————
Architect
ural
Coatings
—4.31 ————————————————
Total 0.77 18.4 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
Annual ——————————————————
Hearths < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 0.00 34.0 34.0 < 0.005 < 0.005 —34.0
Consum
er
Products
—2.49 ————————————————
Architect
ural
Coatings
—0.79 ————————————————
Landsca
pe
Equipme
nt
0.31 0.29 0.03 3.41 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —8.24 8.24 < 0.005 < 0.005 —8.26
Total 0.31 3.57 0.06 3.42 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 0.00 42.2 42.2 < 0.005 < 0.005 —42.3
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————101 0.00 101 0.35 0.22 —176
Total ———————————101 0.00 101 0.35 0.22 —176
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Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————101 0.00 101 0.35 0.22 —176
Total ———————————101 0.00 101 0.35 0.22 —176
Annual ——————————————————
Apartme
nts
Mid Rise
———————————16.8 0.00 16.8 0.06 0.04 —29.2
Total ———————————16.8 0.00 16.8 0.06 0.04 —29.2
4.5. Waste Emissions by Land Use
4.5.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————222 0.00 222 22.2 0.00 —778
Total ———————————222 0.00 222 22.2 0.00 —778
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————222 0.00 222 22.2 0.00 —778
Total ———————————222 0.00 222 22.2 0.00 —778
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Annual ——————————————————
Apartme
nts
Mid Rise
———————————36.8 0.00 36.8 3.68 0.00 —129
Total ———————————36.8 0.00 36.8 3.68 0.00 —129
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————————4.57 4.57
Total ————————————————4.57 4.57
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————————4.57 4.57
Total ————————————————4.57 4.57
Annual ——————————————————
Apartme
nts
Mid Rise
————————————————0.76 0.76
Total ————————————————0.76 0.76
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4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
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Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
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Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Avoided ——————————————————
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Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Annual ——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
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5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description
Demolition Demolition 2/7/2023 4/18/2023 5.00 50.0 —
Site Preparation Site Preparation 4/19/2023 5/31/2023 5.00 30.0 —
Grading Grading 6/1/2023 9/14/2023 5.00 75.0 —
Building Construction Building Construction 9/15/2023 7/17/2026 5.00 740 —
Paving Paving 7/31/2026 10/3/2026 5.00 46.0 —
Architectural Coating Architectural Coating 3/4/2025 7/28/2026 5.00 366 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38
Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40
Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40
Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
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Building Construction Cranes Diesel Average 1.00 7.00 367 0.29
Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20
Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45
Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36
Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Demolition ————
Demolition Worker 15.0 11.7 LDA,LDT1,LDT2
Demolition Vendor —8.40 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck ——HHDT
Site Preparation ————
Site Preparation Worker 17.5 11.7 LDA,LDT1,LDT2
Site Preparation Vendor —8.40 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck ——HHDT
Grading ————
Grading Worker 20.0 11.7 LDA,LDT1,LDT2
Grading Vendor —8.40 HHDT,MHDT
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Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck ——HHDT
Building Construction ————
Building Construction Worker 479 11.7 LDA,LDT1,LDT2
Building Construction Vendor 71.1 8.40 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck ——HHDT
Paving ————
Paving Worker 15.0 11.7 LDA,LDT1,LDT2
Paving Vendor —8.40 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck ——HHDT
Architectural Coating ————
Architectural Coating Worker 95.8 11.7 LDA,LDT1,LDT2
Architectural Coating Vendor —8.40 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck ——HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 2,542,752 847,584 0.00 0.00 —
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5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy)Material Exported (cy)Acres Graded (acres)Material Demolished (sq. ft.)Acres Paved (acres)
Demolition 0.00 0.00 0.00 ——
Site Preparation ——45.0 0.00 —
Grading ——225 0.00 —
Paving 0.00 0.00 0.00 0.00 —
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Land Use Area Paved (acres)% Asphalt
Apartments Mid Rise —0%
5.8. Construction Electricity Consumption and Emissions Factors
kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2023 0.00 0.00 0.00 0.00
2024 0.00 0.00 0.00 0.00
2025 0.00 0.00 0.00 0.00
2026 0.00 0.00 0.00 0.00
5.9. Operational Mobile Sources
5.9.1. Unmitigated
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Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Apartments Mid Rise 3,618 3,265 2,720 1,255,235 27,403 24,733 20,603 9,508,239
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 339
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 326
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft)Residential Exterior Area Coated (sq ft)Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area Coated
(sq ft)
Parking Area Coated (sq ft)
2542752 847,584 0.00 0.00 —
5.10.3. Landscape Equipment
Season Unit Value
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Snow Days day/yr 0.00
Summer Days day/yr 180
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr)
Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr)
Apartments Mid Rise 7,837,103 0.00 0.0000 0.0000 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
Apartments Mid Rise 47,436,451 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
Apartments Mid Rise 164 0.00
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
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10.02.502.50< 0.0052,088R-410AApartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
Apartments Mid Rise Household refrigerators
and/or freezers
R-134a 1,430 0.12 0.60 0.00 1.00
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr)Daily Heat Input (MMBtu/day)Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
——
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
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Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG
emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 11.8 annual days of extreme heat
Extreme Precipitation 4.05 annual days with precipitation above 20 mm
Sea Level Rise 0.00 meters of inundation depth
Wildfire 10.7 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed
historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full
day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider different
increments of sea level rise coupled with extreme storm events. Users may select from four model simulations to view the range in potential inundation depth for the grid cell. The four simulations make
different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature
possibilities (MIROC5). Each grid cell is 50 meters (m) by 50 m, or about 164 feet (ft) by 164 ft.
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Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate,
vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make
different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature
possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest
exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the
greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
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Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest
exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the
greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 10.6
AQ-PM 15.6
AQ-DPM 54.0
Drinking Water 38.1
Lead Risk Housing 68.1
Pesticides 0.00
Toxic Releases 28.4
Traffic 30.2
Effect Indicators —
CleanUp Sites 73.7
Groundwater 91.9
Haz Waste Facilities/Generators 51.9
Impaired Water Bodies 23.9
Solid Waste 0.00
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Sensitive Population —
Asthma 0.66
Cardio-vascular 4.54
Low Birth Weights 36.4
Socioeconomic Factor Indicators —
Education 3.87
Housing 22.1
Linguistic 24.8
Poverty 8.07
Unemployment 29.4
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 95.14949313
Employed 43.98819453
Median HI 99.29423842
Education —
Bachelor's or higher 99.60220711
High school enrollment 100
Preschool enrollment 73.48902862
Transportation —
Auto Access 68.11240857
Active commuting 83.57500321
Social —
2-parent households 94.40523547
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Voting 96.57384833
Neighborhood —
Alcohol availability 81.20107789
Park access 81.35506224
Retail density 46.32362376
Supermarket access 56.22994996
Tree canopy 94.4180675
Housing —
Homeownership 63.76235083
Housing habitability 86.19273707
Low-inc homeowner severe housing cost burden 41.33196458
Low-inc renter severe housing cost burden 96.25304761
Uncrowded housing 87.19363531
Health Outcomes —
Insured adults 99.75619145
Arthritis 0.0
Asthma ER Admissions 96.2
High Blood Pressure 0.0
Cancer (excluding skin)0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 97.7
Cognitively Disabled 80.8
Physically Disabled 96.9
Heart Attack ER Admissions 93.0
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Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 19.6
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 95.8
Children 64.0
Elderly 25.8
English Speaking 76.2
Foreign-born 51.5
Outdoor Workers 79.5
Climate Change Adaptive Capacity —
Impervious Surface Cover 86.7
Traffic Density 34.0
Traffic Access 87.4
Other Indices —
Hardship 0.9
Other Decision Support —
2016 Voting 98.7
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7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a)7.00
Healthy Places Index Score for Project Location (b)99.0
Project Located in a Designated Disadvantaged Community (Senate Bill 535)No
Project Located in a Low-Income Community (Assembly Bill 1550)No
Project Located in a Community Air Protection Program Community (Assembly Bill 617)No
a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Land Use Pursuant to DOF 2.51 residents per household, consistent with Pop and Housing
Construction: Construction Phases Architectural coating occurs simultaneously as building construction
Construction: Architectural Coatings BAAQMD Regulation 8 Rule 3, Nonflat Coating
Operations: Architectural Coatings BAAQMD Regulation 8 Rule 3, Nonflat Coating
Operations: Energy Use Pursuant to Palo Alto's All-Electric Ordinance, natural gas converted to electricity
Operations: Water and Waste Water WTP 100% aerobic
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Appendix C
Native American Tribal Correspondence
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September 29, 2022
Amah Mutsun Tribal Band
Valentin Lopez, Chairperson
PO Box 5272
Galt, California 95632
Via Email: vlopez@amahmutsun.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Lopez:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your name
as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the proposed
project. The input of the Amah Mutsun Tribal Band is important to the City of Palo Alto’s planning process and we
invite you to engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and
Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have regarding
Native American cultural resources located in or near the proposed project area that may be affected by project
activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
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within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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September 29, 2022
Amah Mutsun Tribal Band of Mission San Juan Bautista
Irene Zwierlein, Chairperson
3030 Soda Bay Road
Lakeport, California 95453
Via email: amahmutsuntribal@gmail.com
Dear Chairperson, Zwierlein:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Amah Mutsun Tribal Band of Mission San Juan Bautista is important to the City of
Palo Alto’s planning process and we invite you to engage in scoping consultation pursuant to Government Code
§65352.4 (Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide
any information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
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Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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September 29, 2022
Indian Canyon Mutsun Band of Costanoan
Kanyon Sayers-Roods, MLD Contact
1615 Pearson Court
San Jose, California 95122
Via email: kanyon@kanyonkonsulting.com
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Sayers-Roods:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of Indian Canyon Mutsun Band of Costanoan is important to the City of Palo Alto’s
planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
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within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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September 29, 2022
Indian Canyon Mutsun Band of Costanoan
Ann Marie Sayers, Chairperson
P.O. Box 28
Hollister, California 95024
Via email: ams@indiancanyons.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Marie Sayers:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Indian Canyon Mutsun Band of Costanoan is important to the City of Palo Alto’s
planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
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within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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September 29, 2022
Muwekma Ohlone Indian Tribe of the SF Bay Area
Monica Arellano, Vice Chairwoman
20885 Redwood Road, Suite 232
Castro Valley, California 94546
Via email: marellano@muwekma.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Arellano:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Muwekma Ohlone Indian Tribe of the SF Bay Area is important to the City of Palo
Alto’s planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
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within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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September 29, 2022
The Ohlone Indian Tribe
Andrew Galvan
P.O. Box 3388
Fremont, California 94539
Via email: chochenyo@AOL.com
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Galvan:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Ohlone Indian Tribe is important to the City of Palo Alto’s planning process and
we invite you to engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and
Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have
regarding Native American cultural resources located in or near the proposed project area that may be affected by
project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
Item 3
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within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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September 29, 2022
Wuksache Indian Tribe/Eshom Valley Band
Kenneth Woodrow, Chairperson
1179 Rock Haven Ct.
Salinas, California 93906
Via email: kwood8934@aol.com
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Woodrow:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Wuksache Indian Tribe/Eshom Valley Band is important to the City of Palo Alto’s
planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
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within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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June 21, 2022
Tamien Nation
Quirina Luna Geary, Chairperson
P.O. Box 8053
San Jose, California 95155
Via email: qgeary@tamien.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Geary:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development (HCD) that the City’s Housing Element has
identified adequate land use capacity and implementing policies to accommodate its Regional Housing Needs
Allocation (RHNA) in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017
Comprehensive Plan anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the
addition of 3,545 to 4,420. Although no development is specifically proposed as part of the Housing Element Update,
the City’s CEQA analysis will evaluate the potential buildout of these housing units within the boundaries of the City
of Palo Alto. The Housing Element will also identify a list of Housing Inventory Sites which reflect the sites within the
City as the highest likelihood of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions
boundaries as well as a list of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your name
as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the proposed
project. The input of the Tamien Nation is important to the City of Palo Alto’s planning process and we invite you to
engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and Government Code §
65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have regarding Native American
cultural resources located in or near the proposed project area that may be affected by project activities.
In accordance with AB 52 your tribes have 30 days from receipt of this letter to respond in writing if you wish to
consult on the proposed project. Under the provisions of SB 18, your tribe has 90 days from receipt of this letter to
respond in writing if you wish to consult on the proposed project. Therefore, the City respectfully requests receipt of
any questions or comments on this project within 90 days of receipt of this letter. If you require any additional
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information or have any questions, please contact me at (650) 329-2493 or via e-mail at tim.wong@cityofpaloalto.org.
Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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Tamien Nation September 29, 2022
Johnathan Wasaka Costillas, THPO
P.O. Box 866
Clearlake Oaks, California 94523
Via email: thpo@tamien.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson, Costillas:
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development (HCD) that the City’s Housing Element has
identified adequate land use capacity and implementing policies to accommodate its Regional Housing Needs
Allocation (RHNA) in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017
Comprehensive Plan anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the
addition of 3,545 to 4,420. Although no development is specifically proposed as part of the Housing Element Update,
the City’s CEQA analysis will evaluate the potential buildout of these housing units within the boundaries of the City
of Palo Alto. The Housing Element will also identify a list of Housing Inventory Sites which reflect the sites within the
City as the highest likelihood of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions
boundaries as well as a list of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your name
as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the proposed
project. The input of the Tamien Nation is important to the City of Palo Alto’s planning process and we invite you to
engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and Government Code §
65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have regarding Native American
cultural resources located in or near the proposed project area that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 329-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
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Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
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Item No. 4. Page 1 of 5
Planning & Transportation Commission
Staff Report
From: Jonathan Lait, Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: March 8, 2023
TITLE
Amendment to Palo Alto Municipal Code Title 18 Chapter 18.42, Standards for Special Uses, to
Codify Firearms Sales Limitations Ordinance; CEQA status—exempt under CEQA Guidelines
section 15061(c)(3)
RECOMMENDATION
Staff recommends PTC review and recommend Council adopt a new section 18.42.210 that would
codify Ordinance 5559, the temporary, uncodified firearms ordinance council adopted as an
interim ordinance in June 2022 and extended in August 2022.
EXECUTIVE SUMMARY
In the summer of 2022, Palo Alto City Council adopted a temporary ordinance to require firearms
dealers to acquire a Conditional Use Permit before offering firearm retail services in the City of
Palo Alto (Ordinance 5559). Ordinance 5559 will expire in June 2023 if the Council does not
extend it or adopt a permanent ordinance. The attached ordinance (Attachment A) is to codify
the requirements of Ordinance 5559 in Title 18 of the Palo Alto Municipal Code (PAMC), Chapter
18.42 (Standards for Special Uses). Any changes to Title 18 require review and recommendation
by the Planning and Transportation Commission (PTC).
In Palo Alto, a firearms dealership is considered a retail land use and since Council adopted
Ordinance 5559 in June 2022, this retail use is only conditionally permitted, as well as subject to
the approval of a firearms permit from the Police Chief per PAMC Chapter 4.57.1 Regulations for
the storage of firearms are set forth in PAMC 9.07.2
1 Link to PAMC Chapter 4.57 https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-
64381#JD_Chapter4.57
2 Link to PAMC Chapter 9.07: https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-
84510#JD_Chapter9.07
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Item No. 4. Page 2 of 5
The permanent ordinance continues the requirement for approval of a Conditional Use Permit
(CUP) to establish a firearms dealership, in addition to the firearms permit requirement set forth
in PAMC Chapter 4.57, Section 4.57.020. This is part of the City’s efforts to keep Palo Alto safe.3
PROJECT DESCRIPTION
The attached ordinance contains two components to insert into PAMC Title 18, Zoning.
1.Definition: Chapter 4.57 (Firearms Dealers) of the Palo Alto Municipal Code (PAMC)
defines “Firearms dealer” for purposes of that chapter only. The attached draft ordinance
references the same definition in Title 18, Chapter 18.424, Standards for Special Uses.
“Firearms dealer” means a person engaged in the business of selling, transferring or
leasing or advertising for sale, transfer or lease or offering or exposing for sale, transfer,
or lease any firearm”.
2. CUP Requirement: A new section in the attached draft ordinance is inserted into PAMC
Chapter 18.42. The new section would codify the requirement for approval of a
Conditional Use Permit pursuant to PAMC Section 18.765 (Permits and Approvals),
incorporate the CUP process in Chapter 18.776 (Processing of Permits and Approvals), and
formalize the City’s ability to impose reasonable conditions of approval. The new section
would also relate to PAMC Section 18.76.015 regarding formula retail in (R) combining
district and PAMC Section 18.77.060 Standard Staff Review Process, as discussed further
below.
Firearms Dealers Permits
A Conditional Use Permit (CUP) is distinct from a Firearms Dealer Permit, which is still required
in Palo Alto to establish a firearms dealership as per PAMC 4.57. Firearms permit issuance criteria
restrict firearm dealerships within 250 feet of zoning district where housing is a principal use, or
daycare centers, schools, massage establishments, and other land uses. Based on these
parameters, a firearms dealership could be established in certain areas of the City in locations
are shown in Attachment B, including portions of the Stanford Research Park, which is not
anticipated to be a likely location for firearms dealerships.
Conditional Use Permit Findings
In addition to the Firearms Permit issuance criteria, the standard findings for a CUP are required
for approval of a firearms dealership. To grant a CUP, the director of planning and development
3 In addition to this ordinance, the City Council on March 6 was scheduled to adopt ordinances to prohibit the
carrying of firearms in certain “sensitive places” as explicitly authorized by the Supreme Court (item 10,
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=1085)
4 Link to PAMC Chapter 18.42: https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-
80499#JD_Chapter18.42
5 Link to PAMC Chapter 18.76: https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-81678
6 Link to PAMC Chapter 18.77: https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-81843
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Item No. 4. Page 3 of 5
services or the city council must find that the grant would (1) “[n]ot be detrimental or injurious
to property or improvements in the vicinity, and will not be detrimental to the public health,
safety, general welfare, or convenience,” and (2) “[b]e located and conducted in a manner in
accord with the Palo Alto Comprehensive Plan and the purposes of this title (Zoning).” A CUP may
also impose reasonable conditions or restrictions as needed to protect the public interest, such
as to protect public health, safety and general welfare.
Note that PAMC 18.76.015 (Additional Findings for Specified Retail Uses) places additional
restrictions on formula retail uses within the (R, Retail) combining zone district, which at present,
only occurs in the California Avenue business district.
BACKGROUND
Temporary Ordinance Expiring June 20, 2023
On June 21, 2022, City Council adopted a temporary emergency ordinance requiring a conditional
use permit to establish a firearms dealership in Palo Alto. Ordinance 5559 became effective for
an initial period of 45 days and Council extended it to remain in effect for an additional period of
10 months and 15 days - until June 20, 2023. Staff has prepared a permanent ordinance for this
PTC hearing and recommendation to City Council, so Council can adopt the permanent ordinance
prior to June 20, 2023.
Staff brought the temporary ordinance forward in part due to an inquiry received at the public
planning counter in 2022 regarding permissible locations for a firearms dealership in the City. To
establish a firearms dealership, an individual would need to find a qualifying site (Map shown on
Attachment B), identify an available building or tenant space with a willing property owner to
lease the premises, and obtain a firearms dealership permit from the Police department.
Palo Alto requires a conditional use permit when retail is a conditional use in a zoning district but
would allow it by right where retail is a permitted land use. At present, based on the location of
various land uses highlighted above, the only available properties that could accommodate a
firearms dealership also require a conditional use permit. However, this could change if certain
land uses discontinue, such as a massage establishment, altering the location of where a firearms
dealership may be located.
Definition of Firearms Dealer
PAMC Chapter 4.57 sets forth the firearms permit process and includes a definition of firearms
dealer. A firearms dealer is a person engaged in the business of selling, transferring, or leasing,
or advertising for, sale, transfer, or lease, or offering or exposing for sale, transfer, or lease, any
firearm. Section 4.57.010 (Definitions) provides a definition of “firearm”7 and also includes any
7 “[A]ny revolver, rifle, shotgun or any other device designed to be used as a weapon, from which a projectile is
expelled through a barrel by the force of an explosion or any other form of combustion.”
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definition in the California Penal Code. The definition of "firearm" is located in section 16520 of
the Penal Code of the State of California and this definition is referenced in PAMC Chapter 9.07,
Safe Storage of Firearms, Section 9.070.010, definition (a) Firearm.
In Palo Alto, a firearms dealership is considered a retail land use and since Council adopted
Ordinance 5559 in June 2022, this retail use is only conditionally permitted, as well as subject to
approval of a firearms permit from the Police Chief per PAMC Chapter 4.57.
ANALYSIS
Staff recommends that the City’s policy for firearms dealerships be consistent in requiring a
conditional use permit regardless of whether the underlying zoning would otherwise permit retail
by right.
The location of where firearms dealerships may be located can change when certain land uses
are discontinued.
Presently, a conditional use permit is required for firearms dealerships. The City has not received
any CUP applications for firearms dealers since the passage of ordinance 5595.
The proposed permanent ordinance would require all firearms dealers to obtain a conditional
use permit, even where retail is otherwise permitted. A CUP is a planning entitlement that would
be handled via the standard staff review process. CUPs may be called up for review by the
Planning and Transportation Commission in a public hearing, followed by consent calendar
placement on a City Council agenda.
FISCAL/RESOURCE IMPACT
There are no significant resource impacts associated with this action.
ENVIRONMENTAL REVIEW
Adoption of the attached ordinance is exempt from the California Environmental Quality Act
(CEQA) pursuant to CEQA Guidelines section 15061(c)(3), because it can be seen with certainty
that there is no possibility of a significant adverse impact on the environment.
ATTACHMENTS
Attachment A: Draft Ordinance Firearms CUP
Attachment B: Map of Firearms Business Siting
AUTHOR/TITLE:
Amy French, Chief Planning Official
Report #: 2301-0848
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Not Yet Approved
7
4
3
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Chapter 18.42
(Standards for Special Uses) to Require a Conditional Use Permit for Firearms
Dealers
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. On June 21, 2022, the City Council adopted Ordinance No. 5559 on an
interim, urgency basis. Ordinance No. 5559 was adopted pursuant to Palo Alto
Municipal Code Section 2.04.270 based on the need to protect the public safety, health,
and welfare, as set forth in the findings and declarations of that ordinance. Ordinance
No. 5559 was also adopted in compliance with Government Code Section 65858, to the
extent that section was applicable, as an interim urgency measure to address a current
and immediate threat to the public health, safety, or welfare, for the reasons forth in
the findings and declarations in that ordinance.
B. On August 1, 2022 the City Council adopted Ordinance No. 5560,
extending Ordinance No. 5559 for a period of 10 months and 15 days.
C. The conditions that gave rise to the need for Ordinance No. 5559 still
exist and the City Council now wishes to adopt a permanent ordinance to amend the
zoning code in accordance with section 18.80.080 of the Palo Alto Municipal Code.
SECTION 2. Section 18.42.210 (Firearms Dealers) is added to Chapter 18.42
(Standards for Special Uses) of Title 18 (Zoning) of the Palo Alto Municipal Code as follows:
18.42.210 Firearms Dealers
(a) Purpose
The purpose of this section is to protect the public health, safety, and welfare by
imposing reasonable land use regulations on the sale of firearms within the city.
(b) Definitions
In addition to the definitions in section 18.04.030 of this code, the definitions in
section 4.57.010 of the Palo Alto Municipal Code, as may be amended from time to
time, shall apply to this section, unless the context indicates otherwise.
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(c) Conditional Use Permit Required in Tandem with Firearms Dealer Permit
A conditional use permit shall be required to operate a firearms dealer business in
any district where such use is permitted. This requirement shall apply in addition to
the requirement for a firearms dealer permit issued by the chief of police in
accordance with Chapter 4.57 (Firearms Dealers).
SECTION 3. If any section, subsection, clause or phrase of this Ordinance is for
any reason held to be invalid, such decision shall not affect the validity of the remaining portion
or sections of the Ordinance. The Council hereby declares that it should have adopted the
Ordinance 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. The Council finds that this project is exempt from the provisions
of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA
Guidelines, because it can be seen with certainty that there is no possibility that the ordinance
will have a significant effect on the environment.
//
//
//
//
//
//
//
//
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//
SECTION 5. This extension ordinance shall take on the thirty first (31st) day
following its adoption.
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INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
City Attorney City Manager
____________________________
Director of
____________________________
Director of Administrative
Services
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Alma Street
El Camino Real
Sand Hill Road
Page Mill Road
Arastradero Road
San Antonio Road
Lytton Avenue
Hillview Avenue
Hamilton Avenue Embarcadero Road
Charleston Road
Arboretum Road
Quarry Road
Page Mill Road
Oregon Expressway
Foothill Expressway
Foothill Expressway Foothill Expressway
Stanford
Los Altos
Los Altos Hills
Mountain View
Stanford University
Menlo Park
East Palo Alto
Atherton
Portola Valley
This map is a product of
City of Palo Alto GIS
[
0 0.850.425Miles
Firearms Business Siting
Municipal Code Analysis
Scenario 2: Flexible Residential
Los Altos HillsPortola Valley
Los Altos
StanfordWoodside
Legend
Firearm Sales Permitted with CUP
Excluded Areas
Assessor Parcels
City Limit
£¤101
§¨¦280
§¨¦280
Rev: June 9, 2022
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Item No. 5. Page 1 of 2
Planning & Transportation Commission
Staff Report
From: Jonathan Lait, Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: March 8, 2023
Report #: 2302-1008
TITLE
Approval of Planning & Transportation Commission Draft Verbatim Minutes of February 8, 2023
RECOMMENDATION
Staff recommends that the Planning and Transportation Commission (PTC) adopt the meeting
minutes.
EXECUTIVE SUMMARY
PROJECT DESCRIPTION
BACKGROUND
Draft verbatim minutes from the February 8, 2023 Planning and Transportation Commission
(PTC) meetings were made available to the Commissioners prior to the March 8, 2023 meeting
date. The draft PTC minutes can be viewed online on the City’s website at bit.ly/PaloAltoPTC.
ANALYSIS
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
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ENVIRONMENTAL REVIEW
ALTERNATIVE ACTIONS
ATTACHMENTS
Attachment A:
AUTHOR/TITLE:
Veronica Dao, Administrative Associate
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