HomeMy WebLinkAbout2025-05-28 Planning & Transportation Commission Agenda PacketPLANNING AND TRANSPORTATION COMMISSION
Regular Meeting
Wednesday, May 28, 2025
Council Chambers & Hybrid
6:00 PM
Planning and Transportation Commission meetings will be held as “hybrid” meetings with the
option to attend by teleconference/video conference or in person. To maximize public safety
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Meeting ID: 916 4155 9499 Phone: 1(669)900-6833
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CALL TO ORDER/ ROLL CALL
PUBLIC COMMENT
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AGENDA CHANGES, ADDITIONS AND DELETIONS
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CITY OFFICIAL REPORTS
1.Director's Report, Meeting Schedule, and Assignments
STUDY SESSION
Public Comment is Permitted. Three (3) minutes per speaker.
2.Study Session: Parking Data Report and Program Amendment Considerations
Response to PTC Questions added
6:10 PM – 6:45 PM
ACTION ITEMS
Public Comment is Permitted. Applicants/Appellant Teams: Fifteen (15) minutes, plus three (3) minutes rebuttal. All others:
Three (3) minutes per speaker.
3.Recommendation on a Resolution Amending the El Camino Real Retail Node Map for
Purposes of Palo Alto Municipal Code Section 18.40.180: Retail Preservation. CEQA
Status: Addendum to the Comprehensive Plan Environmental Impact Report (EIR),
adopted November 17, 2023 (SCH #2014052101)
6:45 PM – 8:15 PM
COMMISSIONER QUESTIONS, COMMENTS, ANNOUNCEMENTS OR FUTURE MEETINGS AND
AGENDAS
Members of the public may not speak to the item(s).
ADJOURNMENT
OTHER INFORMATION
Public Comments
PUBLIC COMMENT INSTRUCTIONS
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CLICK HERE TO JOIN Meeting ID: 916 4155 9499 Phone:1-669-900-6833
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Item No. 1. Page 1 of 2
Planning & Transportation Commission
Staff Report
From: Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: May 28, 2025
Report #: 2505-4675
TITLE
Director's Report, Meeting Schedule, and Assignments
RECOMMENDATION
Staff recommends that the Planning and Transportation Commission (PTC) review and
comment as appropriate.
BACKGROUND
This document includes the following items:
•Upcoming PTC Agenda Items
•PTC Meeting Schedule
•PTC Representative to City Council (Rotational Assignments)
Commissioners are encouraged to contact Veronica Dao (Veronica.Dao@PaloAlto.gov) to notify
staff 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
https://midpenmedia.org/category/government/cityof-palo-alto/boards-and-
commissions/planning-and-transportation-commission.
Item 1
Staff Report
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Item No. 1. Page 2 of 2
UPCOMING PTC ITEMS
June 11, 2025
•Cancelled (Attachment A) as requested by general consensus at the May 14, 2025 PTC
meeting.
June 25, 2025
•This meeting is tentative, as there are no agenda items scheduled for review as of the
publishing of this report. A determination on potential cancellation will be made at least
10 days prior to the meeting.
ATTACHMENTS
Attachment A: 2025 PTC Schedule & Assignments
AUTHOR/TITLE:
Jennifer Armer, Assistant Director
Item 1
Staff Report
Packet Pg. 7
Planning & Transportation Commission
2025 Meeting Schedule
2025 Schedule
Meeting Dates Time Location Status Planned Absences
1/8/2025 6:00 PM Hybrid Canceled
1/15/2025 6:00 PM Hybrid Special
1/29/2025 6:00 PM Hybrid Regular
2/12/2025 6:00 PM Hybrid Regular
2/26/2025 6:00 PM Hybrid Regular Templeton
3/12/2025 6:00 PM Hybrid Regular
3/26/2025 6:00 PM Hybrid Regular
4/9/2025 6:00 PM Hybrid Regular
4/30/2025 6:00 PM Hybrid Regular
5/14/2025 6:00 PM Hybrid Regular
5/28/2025 6:00 PM Hybrid Regular
6/11/2025 6:00 PM Hybrid CANCELED Chang, Hechtman,
Templeton
6/25/2025 6:00 PM Hybrid Regular
7/9/2025 6:00 PM Hybrid Regular
7/30/2025 6:00 PM Hybrid Regular
8/13/2025 6:00 PM Hybrid Regular
8/27/2025 6:00 PM Hybrid Regular
9/10/2025 6:00 PM Hybrid Regular Hechtman
9/24/2025 6:00 PM Hybrid Regular
10/8/2025 6:00 PM Hybrid Regular
10/29/2025 6:00 PM Hybrid Regular
11/12/2025 6:00 PM Hybrid Regular
11/26/2025 6:00 PM Hybrid Canceled
12/10/2025 6:00 PM Hybrid Regular
12/31/2025 6:00 PM Hybrid Canceled
2025 Assignments - Council Representation (primary/backup)
January February March April May June
Bryna Chang
Bart Hechtman
Allen Akin
Doria Summa
Doria Summa
Cari Templeton
Bart Hechtman
Forest Peterson
Cari Templeton
Kevin Ji
Bryna Chang
Todd James
July August September October November December
Council
Summer Break
Allen Akin
Forest Peterson
Kevin Ji
Bryna Chang
Todd James
Allen Akin
Forest Peterson
Cari Templeton
Bart Hechtman
Kevin Ji
Item 1
Attachment A - 2025 PTC
Schedule & Assignments
Packet Pg. 8
Item No. 2. Page 1 of 5
Planning & Transportation Commission
Staff Report
From: Office of Transportation Director
Lead Department: Office of Transportation
Meeting Date: May 28, 2025
Report #: 2408-3394
TITLE
Study Session: Parking Data Report and Program Amendment Considerations
RECOMMENDATION
Accept a report on Downtown parking trends and provide feedback on key program
improvement areas.
EXECUTIVE SUMMARY
This report provides parking occupancy data relevant to parking availability in Palo Alto’s
Downtown area, and invites discussion of possible program changes to promote better
utilization of existing parking resources, and considerations important for those changes.
Public garages in general have the most parking availability, and have significantly more
availability than do popular curb locations and lots, but these are nearly the same in terms of
price and time limits. The resulting impacts include circling traffic and an experience of limited
parking supply in Downtown’s busiest parking locations, even as significant availability is
minutes away.
Program changes since 2020 have addressed Downtown resident parking advocate concerns,
reducing employee permit availability in Downtown neighborhoods and raising neighborhood
employee permit prices relative to garage and lot employee permits, while remote work trends
opened up additional availability in Downtown garage and lot locations.
BACKGROUND
City of Palo Alto parking policies are managed by the Office of Transportation (OOT), while
parking program tasks are managed and coordinated collaboratively between Administrative
Services, City Clerk, OOT, and Police staff, as well as vendor support.
Reporting parking occupancy data to the public via a parking data portal has been a key task
among other prioritized parking planning activities in recent years. Parking use data is collected
by contracted vendors during the fall and/or spring of select years. This report provides parking
occupancy data from Downtown public lots and garages from October of both 2019 and 2024
for comparison. Additional parking occupancy data is available and will continue to be made
more available on the City’s website in the coming months.
Item 2
Staff Report
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Item No. 2. Page 2 of 5
The City of Palo Alto operates eight parking programs, two commercial districts, and six
residential preferential parking programs. Downtown Palo Alto’s University Avenue parking
district, the larger of the two commercial district programs, has 16 surface lots and garages
with a total of 3,219 parking spaces to support convenient access to businesses and
restaurants, downtown employees and visitors. The Downtown area features a unique Color
Zone system that provides two-hour time limits in both on- and off-street locations. The public
garages also feature longer three-hour time limits, and Daily permits are also available at a
handful of payment kiosks and at City Hall from Revenue Collections.
Map Source: https://www.paloalto.gov/files/assets/public/v/1/transportation/downtown-color-zones.pdf
ANALYSIS / DISCUSSION
The economic impacts of the COVID-19 pandemic, coupled with ongoing shifts in work and
shopping habits away from physical locations to online platforms, have reduced overall parking
demand in Palo Alto parking districts. On-street commercial curb spaces and certain off-street
parking spaces, particularly in lots near University Avenue, remain more popular than others. In
specific blocks and lots, those locations that are most easily accessible, prove to be in high
demand with low parking availability during peak demands, while nearby garage parking spaces
remain plentiful and under utilized during those same times, as their use is un-incentivized and
little known. This is most keenly felt in Downtown Palo Alto in garage and lot locations on, and
immediately off of, University Avenue between Alma Street and Middlefield Road. In the
following tables, parking occupancy rates are displayed as a percentage. Parking occupancies at
85% and above, where finding a space would be more difficult, are colored red. Parking
occupancies at 70% or below, where finding a space would be easier, are colored green.
Item 2
Staff Report
Packet Pg. 10
Item No. 2. Page 3 of 5
Table 1.
Table 2.
Next Steps
Additional historical parking occupancy data is being finalized and will be provided on the City’s
webpage in the coming months. Staff are also concluding a procurement to contract with a new
Tuesday, October 22, 2024 Inventory Noon 3:00 PM 6:00 PM
Location Name Total Spaces Total Count Occupancy Total Occupancy Total Occupancy
Civic Center Garage*721 496 69%411 57%348 48%
Bryant/Lytton Garage*681 387 57%305 45%219 32%
Webster/Cowper Garage*587 169 29%197 34%121 21%
High/Alma South Garage*210 200 95%161 77%115 55%
Ramona/University Garage 133 44 33%41 31%56 42%
High/Alma North Garage 130 47 36%49 38%11 8%
Lytton/Waverley Lot 97 33 34%13 13%6 6%
Cowper/Hamilton Lot 93 25 27%44 47%74 80%
Hamilton/Waverley Lot 84 66 79%55 65%83 99%
Emerson/High Lot 77 76 99%64 83%75 97%
Emerson/Lytton Lot 68 68 100%42 62%68 100%
Gilman/Waverley Lot 53 46 87%35 66%16 30%
High/Hamilton Lot 52 49 94%43 83%45 87%
Lytton/Kipling Lot 52 35 67%24 46%50 96%
Ramona/Lytton Lot 51 35 69%28 55%45 88%
Emerson/Ramona Lot 48 44 92%43 90%42 88%
Florence/Lytton Lot 47 44 94%23 49%34 72%
Gilman/Bryant Lot 35 46 131%43 123%20 57%
Tuesday, October 22, 2019 Inventory Noon 3:00 PM 6:00 PM
Location Name Total Spaces Total Count Occupancy Total Occupancy Total Occupancy
Civic Center Garage*721 579 80%559 78%493 68%
Bryant/Lytton Garage*681 572 84%449 66%338 50%
Webster/Cowper Garage*587 416 71%348 59%185 32%
High/Alma South Garage*210 209 100%177 84%205 98%
Ramona/University Garage 133 84 63%66 50%68 51%
High/Alma North Garage 130 74 57%69 53%40 31%
Lytton/Waverley Lot 97 48 49%43 44%17 18%
Cowper/Hamilton Lot 93 60 65%65 70%80 86%
Hamilton/Waverley Lot 84 84 100%62 74%78 93%
Emerson/High Lot 77 60 78%57 74%76 99%
Emerson/Lytton Lot 68 63 93%44 65%68 100%
Gilman/Waverley Lot 53 46 87%35 66%27 51%
High/Hamilton Lot 52 47 90%45 87%48 92%
Lytton/Kipling Lot 52 21 40%17 33%5 10%
Ramona/Lytton Lot 51 ------
Emerson/Ramona Lot 48 46 96%43 90%46 96%
Florence/Lytton Lot 47 34 72%21 45%33 70%
Gilman/Bryant Lot 35 28 80%24 69%33 94%
Item 2
Staff Report
Packet Pg. 11
Item No. 2. Page 4 of 5
parking citation and permit management services vendor. While this will provide opportunities
to pilot new permit type approaches and services, these will require policy updates reflective of
community goals and ongoing program outreach and engagement. This will need to include
establishing more regular and automated means of reporting out parking occupancy and permit
sales data.
Investment in wayfinding guidance and better advertising of garage parking availability (see the
Automated Parking Guidance System project) will increase utilization of parking spaces, but
cannot address the need to have better tools for managing parking demand, especially in
hyper-localized higher demand areas. Without parking management intervention, driver
searching and re-parking behaviors (for example, drivers circling in search of on-street spaces
that are free and close, and moving one’s vehicle every two hours to avoid employee permit
fees and daily visitor fees) will continue to create congestion at peak demand times on heavily
visited commercial blocks.
In the last five years, there have been significant shifts in work and trip patterns. The City’s
environmental goals and priorities have also necessitated a review of current parking policies
and practices in order to support changing and dynamic travel patterns, economic vitality, and
environmental goals. The Automated Parking Guidance Systems being installed in four
Downtown garages will advertise these garages’ availability more widely, but options for
differentiating parking resources should still be considered, to better support mobility and
environmental goals, and to establish improved program financial sustainability. These could
include hourly rates in to be established zones, customer validation programs, and other
program improvements. Staff will be developing options to explore and will be seeking Planning
and Transportation Commission’s feedback on key program enhancement strategies that staff
should consider exploring over the next year to enhance commercial and residential programs.
FISCAL/RESOURCE IMPACT
Resource impacts are dependent on policy decisions that will be discussed throughout this
process. Potential future enhancements for moving forward will be aligned with previously
budgeted parking planning services underway, proportionately paid out of each of the City's
commercial and residential parking funds. Staff are developing revenue and expense estimates
of policy decisions and proposals to define the relationships between parking funds to
potentially allow for greater flexibility in the City’s overall parking system. As policy direction is
provided, any corresponding budgetary information and recommendations will be brought
forward as appropriate.
STAKEHOLDER ENGAGEMENT
Current parking programs were developed to ensure public parking resources were available to
important constituent stakeholder groups, notably, local employees, residents, and visitors.
Staff will continue to conduct community/stakeholder engagement throughout the
development of improvements to the parking programs.
Item 2
Staff Report
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Item No. 2. Page 5 of 5
ENVIRONMENTAL REVIEW
Providing feedback as recommended in this report is not a project under CEQA and review is not
required at this time.
ATTACHMENTS
None
AUTHOR/TITLE:
Nathan Baird, Manager Transportation Planning
Item 2
Staff Report
Packet Pg. 13
The following additional information has been prepared in response to questions from
Commissioners.
This report is focused on the University Ave. district. In 2021, Downtown RPP permits were
made less available than in previous years. Employee permit sales in both the University
Ave. district and the RPP district are down. Staff will release sales data to the City website
for comparison in the coming months.
The garages with asterisks are the four largest garages in the University Avenue District and
each is receiving an Automated Parking Guidance System.
Regarding the Gilman/Bryant lot’s 131% occupancy. Staff will correct this info with a
verified count of spaces available before posting to the City’s website. The 2024 data
supplied vehicle counts only. It is likely that the 2019 spaces count (which was utilized as
the baseline supply count) undercounted total spaces there for some reason.
The parking occupancy tables included in the staff report are summary counts and include
ADA spaces, general spaces, and permitted spaces. We do not currently have a breakdown
available for the 2024 data, but previous years’ data (2017-2019) did include a breakdown
of parking stall types. Staff will work toward making these available, and in map form, as
possible. In general, permitted spaces are less utilized than they have been in the past, and
employee permit sales are much lower than in previous years. Permit sales data will also
be made available as possible. The 2024 and 2019 tables presented show a basic trend
comparison between pre-Covid usage and post.
Regarding previous parking planning work items and priorities: staff still recommend permit
improvements and more differentiation between public parking resources, including curb
pricing of some sort, as well as validation and customer centric experience improvements.
Central to any movement on these is broader understanding of Downtown parking trends
by all stakeholder groups. The new APGS systems will provide more regular data. And staff
are coordinating across departments, and with new vendors, in the next fiscal year, to more
substantially develop conceptual options for moving forward.
Item 2
Response to PTC
Questions
Packet Pg. 14
Item No. 3. Page 1 of 5
Planning & Transportation Commission
Staff Report
From: Planning and Development Services Director
Lead Department: Planning and Development Services
Meeting Date: May 28, 2025
Report #: 2505-4673
TITLE
Recommendation on a Resolution Amending the El Camino Real Retail Node Map for Purposes
of Palo Alto Municipal Code Section 18.40.180: Retail Preservation. CEQA Status: Addendum to
the Comprehensive Plan Environmental Impact Report (EIR), adopted November 17, 2023 (SCH
#2014052101)
RECOMMENDATION
Staff recommends that the Planning and Transportation Commission (PTC) recommend the City
Council adopt a resolution amending the El Camino Real Retail Node Map, illustrating retail
node locations on El Camino Real that are subject to Palo Alto Municipal Code (PAMC) Section
18.40.180: Retail Preservation, even when developed for housing.
BACKGROUND
The 2023-2031 Housing Element identified the retail preservation ordinance as a potential
constraint to housing development. Housing Element Program 3.4B calls for waivers from and
modifications to these regulations to accommodate more housing density and affordability
while focusing retail development in the most desirable locations in Palo Alto, including retail
node locations in South El Camino Real.
December 2024 Planning and Transportation Commission Hearing
On December 17, 2024, the PTC held a public hearing and recommended that the City Council
adopt an ordinance to modify the Housing Incentive Program, Affordable Housing Incentive
Program, and Retail Preservation Ordinance. As part of the motion, the PTC asked for the map
of retail nodes on El Camino Real to return to the PTC in the first quarter of 2025 to consider
additional retail node locations.
March 2025 City Council Hearing
On March 3, 2025, the City Council adopted, on first reading, an ordinance amending the zoning
code to implement programs in the City’s adopted Housing Element that modify the Housing
Incentive Program (HIP), Affordable Housing Incentive Program (AHIP), and Retail Preservation
Ordinance. The City Council motion was as follows:
Item 3
Staff Report
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Item No. 3. Page 2 of 5
1. Modify the retail node to extend along El Camino Real from Page Mill Road to the
southern city boundary, and refer to the Planning and Transportation Commission for
further discussion and recommendation to City Council; and
2. Exclude auto dealerships (AD overlay) near El Camino Real and Charleston Road from
the HIP Program.
This action has the effect of locating the entire El Camino Real corridor, south of Page Mill to
the City Boundary, within a node and therefore subject to the Retail Preservation Ordinance.
This includes continuing to require compliance with retail preservation regulations at the
automobile dealerships near Charleston Road, should existing tenants vacate their buildings or
the sites were to redevelop.
March & April 2025 Planning and Transportation Commission Hearings
This action item was originally scheduled for the March 26, 2025 PTC meeting with a full staff
report published on the City’s website.1 Due to a lack of time for full consideration, the item
was continued to a date certain, April 30, 2025, with no staff report presentation, public
comment, or discussion by PTC. Please refer to the March 26, 2025 Staff Report for information
on this project. At the April 30, 2025 PTC meeting the project was considered and direction was
provided to staff on changes to be made to the current nodes subject to the Retail Preservation
Ordinance, as described further in the Analysis Section below.
ANALYSIS
Consistent with both the City Council motion and the PTC’s December request, this item is an
opportunity to consider refinements to the large “interim” node along El Camino Real from
Page Mill Road to the southern border, and the possibility of creating new nodes in desired
retail locations.
On April 30, 2025, the PTC provided the following direction for modifications to the existing
retail node map order from northwest to southeast along El Camino Real:
1. Remove California Node;
2. Remove Focus Area Node;
3. South/west side of El Camino Real: Create a new node from Creekside Inn property and
Driftwood Deli through to Los Robles Avenue;
4. North/east side of El Camino Real: Provide two options for this node, (1) Wilton Court to
El Camino Way (including Keys School), or (2) Fernando Ave to North El Camino Way;
5. Extend Triangle Node to include entire island and The Hamlet Retail/Medical Offices
property;
6. Extend Auto Dealership Node to include Walgreens parcel, Americans Tire, Jiffy Lube,
Palo Alto Advanced Dentist, and Jiffy Lube;
7. Exclude the remainder of the interim node not discussed in points above; and
1 March 26, 2025 PTC Meeting, Agenda Item 3:
https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16505
Item 3
Staff Report
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Item No. 3. Page 3 of 5
8. North Ventura Coordinated Area Plan (NVCAP) Node: Provide additional information
about what retail/commercial protections or requirements are already include within
the NVCAP, thereby negating the need for additional protections through the Retail
Preservation Ordinance nodes.
A revised area map, showing the revised nodes is provided as Attachment A, along with a
revised version of the previously provided Working Maps of El Camino Real Districts, Uses, and
Businesses (Attachment B) and a new set of Working Maps of El Camino Real Zoning
Designations (Attachment C). The direction included an intent for further PTC discussion of two
of the nodes described above (items #4 and #8), newly named the North Ventura CAP Node and
the Central Node.
North Ventura CAP Node
The North Ventura CAP Node includes parcels within the North Ventura Coordinated Area Plan
(NVCAP)2 zoned Medium Density Mixed-Use District (NV-MXM) and High Density Mixed-Use
District (NV-MXH):
•The purpose of the NV-MXM district is to allow for a compatible mix of residential and
limited commercial. While there is no maximum density in the NV-MXM district, the
NVCAP anticipates realistic development yields ranging from thirty-one to seventy
dwelling units per acre.
•The purpose of the NV-MXH district is to allow for a mix of retail, restaurant,
entertainment and commercial uses on the ground floor with residential on the upper
floors, while maintaining a pedestrian-oriented streetscape. It is intended that the
active ground floor retail space required will ensure neighborhood-oriented retail and
services are provided within walking distance of high density residential. Ground floor
active uses are required along El Camino Real. While no maximum density in the NV-
MXH district, the NVCAP anticipates realistic development yields ranging from sixty-one
to one hundred dwelling units per acre.
Active ground floor commercial uses in the NVCAP area along El Camino Real are addressed in
Palo Alto Municipal Code (PAMC) Section 18.29.050 (c) Active Ground Floor Commercial Uses:
The NVCAP requires active ground floor uses along the El Camino Real corridor and
encourages active ground floor uses on other designated streets. Active uses are
activities and functions that promote social engagement, vitality, and interaction within
a community. Refer to NVCAP, Section 2.3 for detailed requirements.
(1) Active ground floor commercial uses generally include retail, personal services,
neighborhood business service, and eating and drinking establishments. These may
also include other active uses such as daycare, building lobbies, spaces accessory to
residential uses such as fitness rooms, workspaces, leasing offices, bicycle facilities
(Class I) with direct access to the sidewalk. Office uses may be included only to the
2 Available online here: North Ventura Coordinated Area Plan (NVCAP) – City of Palo Alto, CA
Item 3
Staff Report
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Item No. 3. Page 4 of 5
extent they are permitted in ground floor regulations, are consistent with
18.29.080(a) and have a regular flow of in-person customers.
(2) Ground floor commercial uses are required for properties with frontage along El
Camino Real, as shown in the NVCAP Section 2.3 (Ground Floor Edges).
(3) Ground floor commercial uses shall have a minimum floor to ceiling height of 14
feet.
(4) Retail or retail-like at the ground floor is required at the intersections of El Camino
Real and Olive Avenue, and El Camino Real and Portage Avenue.
(5) 100% affordable housing projects are exempt from providing ground floor
commercial uses.
Given these existing regulations, staff recommends removal of the North Ventura CAP Node
from the El Camino Real Retail Node Map.
Central Node
On April 30, 2025, the PTC discussed the new Central Node in three parts, described above in
Items #3 and #4. The decision of whether the PTC recommendation for the north/east side of
this node would include just (1) Wilton Court to El Camino Way (including Keys School), or (2)
the full length of Fernando Ave to North El Camino Way, was deferred to this future meeting
with a version of the maps (Attachment C) that shows the underlying zoning designations for
those parcels.
As currently shown in the maps, this is more of an extended length/area including multiple
blocks of El Camino Real, rather than a “node.” The intent of these changes to the El Camino
Real Retail Node Map, is stated in Housing Element Implementation Program 3.4B is (italics
added for emphasis):
Allow for sites subject to the City’s retail preservation ordinance – except in the ground
floor (GF) and retail (R) combining districts and strategic locations generally depicted in
the draft South El Camino Real Design Guidelines – to have a reduction in the amount of
retail replacement floor area needed for redevelopment and waive the retail
preservation requirement for identified housing opportunity sites.
Therefore, staff does not recommend inclusion of all three parts, labeled Central Node A,
Central Node B, and Central Node C, but recommends further discussion and reductions of this
retail preservation area.
FISCAL/RESOURCE IMPACT
Changes to the nodes subject to the Retail Preservation Ordinance are not anticipated to have
any direct fiscal impacts on the City budget.
STAKEHOLDER ENGAGEMENT
Preparation of the Housing Element included a range of community outreach methods,
including surveys, Working Group meetings, community workshops, and public hearings.
Hundreds of community members have participated in the Housing Element update over the
Item 3
Staff Report
Packet Pg. 18
Item No. 3. Page 5 of 5
course of the project. Community members have an opportunity to provide feedback on the
draft standards at PTC, Architectural Review Board (ARB), and City Council study sessions and
public hearings.
ENVIRONMENTAL REVIEW
On April 15, 2024, the City Council adopted Resolution No. 10155, approving an Addendum to
the Comprehensive Plan Environmental Impact Report (EIR). The addendum analyzed potential
environmental impacts of the 6th Cycle Draft Housing Element. This includes implementation of
Housing Element Programs 3.4, including changes to the Retail Preservation Ordinance.
ATTACHMENTS
Attachment A: El Camino Real Retail Node Map
Attachment B: Working Maps of El Camino Real Districts, Uses, and Businesses
Attachment C: Working Maps of El Camino Real Nodes with Zoning Designations
AUTHOR/TITLE:
Jennifer Armer, Assistant Director
Item 3
Staff Report
Packet Pg. 19
Triangle NodeNorth Ventura CAP Node
Bike to School Node
Central Node A
Central Node C
Central Node B
EquinoxStarbirdChicken
The ZenHotel
DriftwoodDeli
Chevron
Palo AltoSquareWilmerhale
CoronetMotel
MCDonald'sWellsFargoBank
Shell
MayfieldSoccerComplex
Chipotle Verizon
Palo AltoCommonsStanfordMoterInn
JiffyLube
CreeksideInn
HiltonGarden Inn
Volvo
Tesla
Palo AltoAdvancedDentist
Camino PlaceEmekBeracha
CitiBank
GoodwillXfinityStore
Vista Centerfor the Blind& Visually Im
MontageApartments
KeysSchoolWiltonCourt
The HamletRetail & MedicalOfficess
AvisRental
Hobee's
Jackin theBox
Shell
OdoriSushi
FirstRepublicBank
MassageEnvy Spa
DinahsGardenHotel
Jlee Realty
U.S. Bank
CrownPlazaHotel
AnandaChurch
Palo AltoRedwoodsApartments
HomewoodSuits
Palo AltoEvent Center
Stanford
University
Mountain View
Los Altos
Yale Street
Ramos Way(Private)
Columbia Street
Bowdoin Street
Laguna Avenue
El CentroStreet
El Cerrito
Road
Wellesley
Street
Park Boulevard
Campana Drive
Cornell Street
Harvard Street
Amherst Street
PC-4637
PF
RM-30
CS CS
R-1
R-1 (10000)
RM-40
PF
RE
PC-2930
RM-15
PC-3023
CS
RM-30
CC
(2)(R)
R-2
RM-30
RM-30RM-15
R-2
NV-R4
RM-30
GM
R-2
PF
RM-15
NV-MXH
NV-R3
RE
PF (AS3)
CN
RP (L)
CN
CS (AS1)
RP (L)
R-2
CS
RP (AS2)
RMD
CC (2)(R)(P)
R-2
R-2
R-2
RM-30RM-30
RM-30
CC (2)(R)
CC(2)(R)
CC (2)(R)PF (R)
PF (R)
PC-4127
RM-30
R-1
PF
RM-15 R-2
RM-15
RM-15
RM-30
PF
PF
R-1 (10000)
R-2
RM-15
PC-4268
PC-2224
PC-3028
PC-4354
PC-2293
CC
RM-15
NV-R2
CSPC-4463
PF
RM-40
R-1
RM-15
RM-30
CN
R-1 (S)
R-2
R-1 PF
RM-15
RM-30
PF
PF
PC-2666PC-2666
RM-30
RM-40
R-1 (10000)
R-1
R-2
R-1
CN
RM-15CC(2)
CC (2)
PF
PF
PF
PFPF
PF
RMD (NP)
R-1
PF
RP
PF PF
R-2
RM-15
CS (H)
RM-30
PC-4190
PC-3041
PF
RM-30
R-1
RM-30
PC-2218
PC-2656
RM-15
PC-5116
RM-30
RM-15
PC-3133
PC-4511
RM-15
RM-30
R-1 (7000)
PF
RM-30RM-40
R-1 (S)
CS (L)
PC-4448
CS
CS
(L)
RM-40
RM-15
RM-30
PC-5034
R-1
CC (2)(P)
NV-MXM
CS CSCS
(AD)
PC-4831
PC-4956
PC-2236
R-1 (7000)
R-1 (8000)
R-1
(8000)
CN (GF/P)
PF
PF (D)
R-2
R-1 (10000)
R-1 (8000)
R-1 (7000)(S)
R-1
R-1 (8000)(S)
R-1 (8000)RM-15
RM-15
PC-3036
CS
CS
CS
CS (H)
RM-15
PF
RM-15
CN RM-30
R-2
PF
CN
PC-5069
RM-15CS (L)(D)
PTODRM-40
RM-40CC (2)(R)
CC (2)(R)
CC (2)CC (2)
CC(2)
PF
R-1
NV-R1
NV-MXM
CS
NV-MXH
GM
NV-MXL
NV-PF
This map is a product of
City of Palo Alto GIS
0 480 960240Feet
X Transportation Stations
Housing Element Sites
South El Camino Real Retail Nodes
Zone Districts
City Limit
Automobile
Gas Station
Hotel
Mixed Use
Office
Parking Lot
Public Facility
Public/Private Institution
Residential
Restaurant/Cafe
Retail
Retail/Office
Retail/Restaurant
Under Construction
Vacant
Vacant Lot
Item 3
Attachment A - El Camino Real Retail
Node Map
Packet Pg. 20
North Ventura CAP Node
EquinoxStarbirdChicken
Palo AltoSquareWilmerhale
CoronetMotel
MCDonald'sWellsFargoBankMayfieldSoccerComplex
Chipotle Verizon StanfordMoterInnCitiBank
XfinityStore
Vista Centerfor the Blind& Visually Im
Jackin theBox
Shell
OdoriSushi
FirstRepublicBank
AnandaChurch
Stanford
University
Yale Street
Ramos Way (Private)
Nogal
Lane
(none)
Wellesley Street
Cornell Street
Staunton Court
This map is a product of
City of Palo Alto GIS
0 180 36090Feet
Housing Element Sites
South El Camino Real Retail Nodes
City Limit
Gas Station
Hotel
Mixed Use
Office
Parking Lot
Public Facility
Public/Private Institution
Residential
Restaurant/Cafe
Retail
Retail/Office
Retail/Restaurant
Under Construction
Vacant
Item 3
Attachment B - Working Maps of El
Camino Real Districts, Uses, and
Businesses
Packet Pg. 21
Central Node A
Central Node C
Central Node B
DriftwoodDeli
ChevronShell CStanfordMoterInn
Creekside
Inn
MontageApartmen
KeysSchoolWiltonCourt
Villa Vista
(Private)
El Camino Real
El Camino Way
Magnolia Drive
This map is a product of
City of Palo Alto GIS
0 130 26065Feet
Housing Element Sites
South El Camino Real Retail Nodes
City Limit
Gas Station
Hotel
Mixed Use
Office
Parking Lot
Public/Private Institution
Residential
Restaurant/Cafe
Retail
Retail/Restaurant
Under Construction
Vacant
Vacant Lot
Item 3
Attachment B - Working Maps of El
Camino Real Districts, Uses, and
Businesses
Packet Pg. 22
Triangle Node
Bike to School Node
The ZenHotel
Palo AltoCommons
JiffyLube
HiltonGarden Inn
Volvo
Tesla
Palo AltoAdvancedDentist
Camino Place
EmekBeracha
Goodwill
MontageApartments
The HamletRetail & MedicalOfficess
AvisRental
Hobee's
MassageEnvy Spa
DinahsGardenHotel
Jlee Realty
U.S. Bank
CrownPlazaHotel
Palo Alto
RedwoodsApartments
HomewoodSuits
Palo AltoEvent Center
Mountain View
Los Altos
Amaranta Avenue
Wisteria Lane
(Private)
Campana Drive
This map is a product of
City of Palo Alto GIS
0 180 36090Feet
Housing Element Sites
South El Camino Real Retail Nodes
City Limit
Automobile
Hotel
Mixed Use
Office
Public/Private Institution
Residential
Restaurant/Cafe
Retail
Retail/Restaurant
Under Construction
Vacant Lot
Item 3
Attachment B - Working Maps of El
Camino Real Districts, Uses, and
Businesses
Packet Pg. 23
North Ventura CAP Node
Stanford
University
Yale Street
Ramos Way (Private)
Nogal
Lane
(none)
Wellesley Street
Staunton Court
PC-4637
PF
R-1
CC (2)(R)
NV-R4 GM
R-2
PF
NV-MXH
NV-R3
PF (AS3)
CN
CN
CS (AS1)
RP (L)
R-2
CS
CC (2)(R)(P)
R-2
R-2
R-2
RM-30
RM-30
RM-30
CC(2)(R)
CC (2)(R)
CC
(2)(R)
PF (R)
PF (R)
PF (R)
PF (R)
PC-4127
RM-15
R-1
PF
PF
PC-4268
PC-2224
PC-3028
PC-4354
PC-2293
CC NV-MXL
NV-R2
CS
PC-4463
PF
RM-40
CC (2)
CC (2)
PF
PF PF
RMD (NP)
R-1 RP
CC (2)(P)
NV-MXM
PC-4831
CN
PC-5069
PTOD
RM-40
RM-40
CC (2)(R)
PTOD(R)CC (2)(R)
CC (2)
CC (2)
PF
PF
PC-4753
NV-R1
NV-MXM
CS
NV-MXH
GM
NV-MXL
NV-PF
This map is a product of
City of Palo Alto GIS
0 180 36090Feet
Housing Element Sites
South El Camino Real Retail Nodes
Zone Districts
City Limit
Item 3
Attachment C - Working Maps of El
Camino Real Nodes with Zoning
Designations
Packet Pg. 24
Central Node A
Central Node C
Central Node B
Villa Vista
(Private)
El Camino Real
El Camino Way
MadelineCourt(Private)
Magnolia Drive
RM-30
CS CS
R-1
CS (H)
RM-40 PC-2930
CS
RM-30
GM
PF
RP(L)
RM-15
CS
R-1
RM-15
RM-30
CN
R-2
R-1
PF
RM-15
RM-30
R-1
CN
RM-15
RP
PC-5116
NV-MXM
NV-MXM
CS
NV-MXH
NV-MXL
NV-PF
This map is a product of
City of Palo Alto GIS
0 130 26065Feet
Housing Element Sites
South El Camino Real Retail Nodes
Zone Districts
City Limit
Item 3
Attachment C - Working Maps of El
Camino Real Nodes with Zoning
Designations
Packet Pg. 25
Triangle Node
Bike to School Node
Mountain View
Los Altos
Amaranta Avenue
Wisteria
Lane(Private)
Campana Drive
R-1 (10000)
PC-2930
RM-15
PC-3023
CS
RM-30
RM-15
R-1
CN
PF
RM-30
PF
PF
R-1
R-2
R-1
CN
RM-15 RM-15
CS (H)
RM-30
PC-4190
PC-3041
PF
RM-30
R-1
PC-2218
PC-2656
RM-15
PC-5116
RM-30
RM-15
PC-3133
PC-4511
RM-15
RM-30
R-1 (7000)
PF
RM-30RM-40
R-1 (S)
CS (L)
PC-4448
CS
CS (L)
RM-40
RM-30 PC-5034
R-1
CS
CS
CS (AD)
R-1 (10000)
R-1 (8000)
RM-15 PC-3036
CS
CS
CS
CS (H)
RM-15
PF
R-2
RM-15 CS (L)(D)
This map is a product of
City of Palo Alto GIS
0 180 36090Feet
Housing Element Sites
South El Camino Real Retail Nodes
Zone Districts
City Limit
Item 3
Attachment C - Working Maps of El
Camino Real Nodes with Zoning
Designations
Packet Pg. 26
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Juanita G. Goggins
· Palo Alto · California · 94301
May 14, 2025
Via Email
City Manager's Office
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
RE: Formal Complaint Regarding the Conduct of the Office of Transportation
Dear Mr. Shikada,
We are writing as co-owners of the home located at 590 East Crescent Drive to raise
serious concerns regarding the conduct of the City of Palo Alto’s Office of Transportation
(OT) in connection with the planning, decision-making, and communication related to the
temporary berm installed at the intersection of East Crescent Drive and Southwood Drive—
directly in front of our home.
We believe the Office of Transportation has acted in a manner that is dismissive of resident
concerns, unaccountable to governing bodies, and, at times, deliberately misleading. What
follows is a troubling chronology of how the OT has failed to uphold the standards of
transparent, data-driven, and community-centered planning:
1. Lack of Notification and Input
Throughout the process of identifying the site at East Crescent/Southwood location and
determining what would be installed, the residents of 590 East Crescent Drive were never
notified or consulted. We first learned of the project on the day the berm was constructed
in front of our home four years ago.
2. Misrepresentation of Safety Data to the Planning Commission and City Council
Traffic consultants hired by the OT concluded that the data collected to evaluate the
berm’s efficacy was "inconclusive" and that “sufficient safety data is not available to
assess the effects of the project quantitatively”—an unsurprising result given the shifts in
traffic patterns before and after the COVID-19 pandemic. (See 11.21.22 “Post Pilot Memo”
from Fehr & Peers to Chirag Panchal, Shahla Yazdy, and Ripon Bhatia.) Despite this, the OT
did not disclose this finding to the Planning Commission or City Council, choosing instead
to present a narrative that supported their preferred outcome. In direct contradiction of its
own consultants’ report, the OT falsely represented to the Planning Commission (multiple
times) and the City Council that the consultants’ “analysis showed significant
improvements in cut-through traffic and vehicle speeds, successfully achieving the
project’s goals.” (See, e.g., 4.9.25 Staff Report to Planning Commission.)
3. Failure to Disclose to City Council the Objections of the Planning Commission
During the June 14, 2023 Planning Commission hearing regarding the berm, the Planning
Commission expressed serious concerns regarding the berm at 590 E. Crescent Drive. The
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Juanita G. Goggins
· Palo Alto · California · 94301
commissioners described the berm as “ugly”, “bizarre”, “large and visually distracting from
the beauty of the landscaping of the home”, an “eyesore”, and “not acceptable.” They told
the OT: “Mr. Girand’s bulb-out needs to be rethought completely.” (See 6.14.23 Transcript
from Hearing.) However, the report submitted by the OT for the November 6, 2023 City
Council meeting did not reflect ANY of these comments or concerns. The Planning
Commission observed at the April 9, 2023 hearing that no meaningful changes had been
made to the plans they previously deemed unacceptable.
4. Failure to Consider Less Invasive Alternatives
At no point did the OT explore or test simpler and more conventional traffic-calming
measures —such as stop signs or speed bumps—before installing the berm with the stop
signs. None of these less invasive solutions would choke off the flow of traffic the way the
berm does. These alternative solutions are less obtrusive, less expensive, and would have
been welcome alternatives.
5. Ignoring Evidence of Safety Hazards
The oversized berm has made the intersection more dangerous, not less. It severely
constricts the already narrow neighborhood streets, making it impossible for two vehicles
to pass simultaneously and creating unsafe turning conditions. This was clearly
demonstrated at the April 16, 2025 on-site meeting, where drivers honked, shouted, and
exited their vehicles to complain directly to OT staff—who were visibly identifiable in bright
yellow vests. Rather than acknowledge the problem witnessed first hand and redesign the
plans, the OT chose to ignore it. The intersection has remained in this hazardous state for
four years.
6. Disregard for Evidence-Based Decision Making
When questioned about moving forward with the permanent berm despite inconclusive
data from their own consultants, OT civil engineer Ms. Yazdy acknowledged that the data
does not support their claims of improved safety but stated that she didn’t need empirical
evidence because she simply “knew” the berm would work. This is an unacceptable
standard for any public infrastructure decision.
7. Disability and Accessibility Concerns Ignored
Our father, who is elderly and disabled, has struggled daily to safely access the front
entrance of our home since the berm’s installation. Recently, he suffered a serious fall just
feet from the berm. Captured on security cameras, the footage shows him unable to get up
and forced to crawl to the front door. When we shared news at the April 16, 2025 in person
meeting of his fall and his confusion associated with his ability to access his home, OT staff
members appeared indifferent and did not ask any questions about how the berm was
complicating our father's mobility and his access to the front of his house.
8. Inappropriate Behavior During Meetings
During that same meeting, Mr. Bhatia claimed he was there to photograph the site for
reference. Instead, he began photographing my sister, Lisa Lawson, and me while we were
speaking. When we objected to his taking pictures of us, he had no explanation. Moreover,
he took no pictures of the site throughout the hour-long meeting. He and Ms. Yazdy
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Juanita G. Goggins
· Palo Alto · California · 94301
defended the behavior by claiming it is “common practice” for them to take photos of
people during meetings—a justification we find highly questionable and intrusive.
9. Contradictory Statements Regarding Drainage
At the April 16, 2025 in-person meeting, the OT staff admitted to us that installing the berm
would result in rainwater pooling in front of our property due to inadequate grading. This
directly contradicts assurances made to the Planning Commission at its April 9, 2025
meeting, where the OT stated that drainage would not be an issue.
10. Dismissal of Planning Commission Directives
On April 9, 2025 the Planning Commission rejected the OT’s proposed design for the
permanent berm and directed the department to work collaboratively with us to address
concerns regarding accessibility and aesthetics. Comments included, "I am not going to
approve anything that prevents an elderly, disabled man from accessing his home", "meet
with the homeowner", "come to an agreement", "listen", and "I am expecting design
changes to incorporate outstanding issues". (See Transcript from 4.9.25 Planning
Commission Meeting.) Yet at the April 16, 2025 in-person site meeting, OT staff told us that
they were under no obligation to incorporate input from either us or the Planning
Commission, citing prior City Council approval. They showed up at the meeting without
any copies of the plans and stated that they were only there to “answer any questions” we
had about the plans. The plans the OT sent subsequent to our April 16, 2025 meeting
reflect none of our concerns. On 5.14.24, Ms. Yazdy conclusively informed us no changes
would be made to the plans. This blatant disregard for oversight and community
engagement is deeply troubling.
It should be noted that when adjacent neighbors who were directly impacted by a proposed
“traffic calming” measure for the intersection of University and Crescent complained
about the design, the OT abandoned the project at that intersection entirely. We do not
understand why we have not been afforded the same respect and have instead been forced
to spend countless hours trying to make our concerns heard and addressed.
Conclusion
The Office of Transportation has failed in its responsibility to engage constructively with
residents, to be transparent with city leadership, and to base its decisions on reliable data.
The lack of accountability, empathy, and professionalism shown by OT staff during this
process is unacceptable.
We respectfully request that the City Manager’s Office take the following actions:
1. Immediately halt any further construction related to the berm at East Crescent Drive
and Southwood.
2. Conduct a neutral formal investigation into the Office of Transportation’s conduct in
this matter, including staff behavior, community engagement, and data practices. We
request that the City engage an objective, outside investigator who is experienced in similar
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Juanita G. Goggins
· Palo Alto · California · 94301
matters to conduct the investigation. We request that relevant documents be reviewed and
witnesses be interviewed. We also request that the City preserve all evidence that may be
relevant to the above issues.
3. Implement formal protocols to ensure that future projects are based on sound
evidence, include meaningful community input (which does not exclude those directly
impacted by proposed projects), and respect the authority of oversight bodies like the
Planning Commission.
Thank you for your attention to this urgent matter. We are prepared to speak at your
convenience to discuss a resolution that prioritizes safety, accountability, and respect for
all Palo Alto residents.
Sincerely,
Juanita Goggins, Lisa Lawon, James Girand, Co-owners
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is addressed. If you believe you received this e-mail in error, please notify the sender immediately, delete the e-mail from your
computer and do not copy or disclose it to anyone else. If you are not an existing client of H&K, do not construe anything in this e-
mail to make you a client unless it contains a specific statement to that effect and do not disclose anything to H&K in reply that you
expect it to hold in confidence. If you properly received this e-mail as a client, co-counsel or retained expert of H&K, you should
maintain its contents in confidence in order to preserve the attorney-client or work product privilege that may be available to protect
confidentiality.
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560 Mission Street, Suite 1900 | San Francisco, CA 94105 | T 415.743.6900 | F 415.743.6910
Holland & Knight LLP | www.hklaw.com
Genna Yarkin
Tamsen Plume
Atlanta | Austin | Birmingham | Boston | Century City | Charlotte | Chattanooga | Chicago | Dallas | Denver | Fort Lauderdale
Houston | Jacksonville | Los Angeles | Miami | Nashville | Newport Beach | New York | Orlando | Philadelphia | Portland
Richmond | San Francisco | Seattle | Stamford | Tallahassee | Tampa | Tysons | Washington, D.C. | West Palm Beach
May 14, 2025
Via email: planning.commission@paloalto.gov
Palo Alto Planning & Transp. Comm.
250 Hamilton Avenue
Palo Alto, CA 94301
Re: Palo Alto’s Planning and Transportation Commission Must Approve the
Vesting Tentative Parcel Map for the 3150 El Camino Real Project
Dear All:
Acclaim Companies, through its entity 3150 ECR PA LLC (the “Applicant”), proposes the construction of 368 multifamily including 74 low income units (the “Project”) pursuant to the Streamlined Housing Development Review process and proceeding under the El Camino Real Focus Area Plan (the “Focus Area Plan”) standards, at 3128 and 3150-3160 El Camino Real (the
“Property”) in Palo Alto (the “City”). Before you this evening is the Vesting Tentative Parcel Map
(the “VTPM”) for the Project (24 PLN-00230). The purpose of this letter is to remind the Planning and Transportation Commission (the “PTC”) of its obligations under both State housing laws and the City’s code, to approve the VTPM for this Project without imposing any conditions of approval that would reduce the Project’s density or negatively impacts its feasibility, and without applying
any “subjective” criteria.
Acclaim brought forth two original development proposals (one brought under SB 330 and the State Density Bonus Law and one brought under the “Builder’s Remedy” provision of the Housing Accountability Act) that did not receive positive receptions from the City, mainly with regard to the processes proposed. The Applicant has since worked cooperatively with the City to “toll” those
two development applications and instead bring forward the Project. On November 7, 2024 the
Architectural Review Board reviewed the Project and had overwhelmingly positive feedback, expressing appreciation for the Applicant and City staff’s partnership to bring forward a development that complies with the City’s objective development standards with 20% low income units, instead of relying on the Builder’s Remedy and the State Density Bonus Law.
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Palo Alto Planning & Transp. Comm. May 14, 2025 Page 2
#521411327_v1
The Project is a “housing development project” protected by the Housing Accountability Act (the “HAA”).1 It has been designed to be consistent with all of the City’s applicable, objective standards, and as the City’s Zoning Code accurately explains, the City’s discretion to deny or
condition the Project is “thereby limited by Government Code section 65589.5” (the HAA).2 The
Project must be approved (inclusive of its VTPM), because as spelled out in the City’s Zoning Code, evidence for the following findings is present:
(A) The application complies with all applicable and objective standards in the Comprehensive Plan, the Palo Alto Municipal Code, and other City plans or policies.
(B) Approving the application will not result in a specific, adverse, impact upon the public
health or safety, which cannot feasibly be mitigated or avoided in a satisfactory manner. As used in this Section, a "specific, adverse impact" means a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was
deemed complete.3
Further, the PTC is prohibited by the HAA from imposing any requirements on the Project that would have the effect of denying, reducing the density of , or rendering the Project infeasible.4
We appreciate your attention to this matter.
Sincerely,
HOLLAND & KNIGHT LLP
Genna Yarkin Tamsen Plume
1 Govt. Code Section 65589.5, et al. 2 Pal0 Alto Zoning Code Section 18.77.073(a).
3 Palo Alto Zoning Code Section 18.77.073(d) 4 Govt. Code Section 65589.5(a)(2)(K), (f)(1), (j)(1).
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The appeal of a director's decision is processed in accordance with Palo Alto Municipal Code (PAMC) Section
18.77.070(f):
(f) Decision by the City Council
The appeal of the director’s decision shall be placed on the consent calendar of the city council within 45
days. The city council may:
(1) Adopt the findings and decision of the director; or
(2) Remove the appeal from the consent calendar, which shall require three votes, and direct that
the appeal be set for a new noticed hearing before the city council, following which the city council
shall adopt findings and take action on the application.
Please submit an appeal letter containing:
1. Appellant Name
2. Appellant Address
3. Appellant Phone
4. Appellant email
5. Specific reference to Director's Interpretation being appealed (with issuance date) and reasons for appeal
There will also be a $740 appeal fee required (Per Fee Schedule: palo-alto-fee-schedule.pdf).
As stated in Director Lait's email below, the deadline for appeal is 14 days from issuance of the interpretation, so
your appeal will need to be submitted by 5:00 p.m. on Thursday, May 22, 2025. Once you have submitted your
appeal via email (to myself Jennifer.Armer@paloalto.gov, and Charlotte Tran Charlotte.Tran@paloalto.gov) we can
send you an invoice for the appeal fee.
Sincerely,
Jennifer
JENNIFER ARMER, AICP
Assistant Director
Planning and Development Services Department
(650) 329-2191 | jennifer.armer@paloalto.gov
www.paloalto.gov
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From: Lait, Jonathan <Jonathan.Lait@paloalto.gov>
Sent: Thursday, May 8, 2025 3:50 PM
To: Petersen, Joe ; Mindie S. Romanowsky
Cc: Yang, Albert <Albert.Yang@paloalto.gov>; Armer, Jennifer <Jennifer.Armer@paloalto.gov>
Subject: Director's Zoning Interpretation: PAMC 18.70.080 - 100
Mr. Petersen,
Attached is the subject interpretation.
@Armer, Jennifer will follow up with details on how to appeal this determination; the deadline for appeal
is 14 days from today and referenced in the attachment.
One point of clarification as I have seen it referenced in your public records request and in an email. I am
not aware of a City request to ‘correct all non conformities’ that may apply to the project prompting this
interpretation. If you believe you have received that feedback related to your project, please let me
know.
Regards,
JONATHAN LAIT
Director
Planning and Development Department
(650) 329 2679 | jonathan.lait@paloalto.gov
www.paloalto.gov
Confidentiality Notice
This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U S C Section 2510,
and its disclosure is strictly limited to the recipient intended by the sender of this message This transmission, and any attachments, may contain
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confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, any disclosure, copying, distribution or
use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. Please contact us immediately by return e-mail or
at 404 815 6500, and destroy the original transmission and its attachments without reading or saving in any manner.
***DISCLAIMER*** Per Treasury Department Circular 230 Any U S federal ta advice contained in this communication (including any attachments) is not
intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing
or recommending to another party any transaction or matter addressed herein
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Subject – Appeal of Director’s Application of PAMC § 18.70.100 to Project Concerning 3886 Magnolia Drive, #25BLD-00025
Dear Mayor Lauing and Members of the City Council: My wife and I hereby appeal the Director’s May 8, 2025, Interpretation Regarding Relocation of Noncomplying Residential Gross Floor Area Under PAMC Chapter 18.70 (the “Determination”).
The Planning Department, on the sole basis of the Determination, has rejected our application for
a small remodel of our home in Barron Park which was built in 1948, long prior to Palo Alto’s annexure of our section of the City of Palo Alto. Background on Our Proposed Project
Our home is currently two stories (although the second story is quite small and is essentially a permitted loft space). Our project is designed to convert our home fully into a single-floor home (in that respect, it is very much unlike the many second story additions routinely processed by the Planning Department). Essentially, the aim of the project is to create a closet in the room that
we are using as our primary bedroom and relocate some utilities, such as the laundry and
additional kitchen and cleaning storage, to a permitted rumpus room and provide interior access to that room from our existing kitchen. Currently, we maintain a closet in an upstairs, permitted loft area which entails navigating a
steep and narrow staircase (the “Unsafe Permitted Loft Area”). The project does not enlarge the
building envelope, add floor area, or replace any space that is “damaged or destroyed.” It removes from FAR the Unsafe Permitted Loft Area and does not “replace” or “reconstruct” that space (i.e., there will no longer be an upstairs loft area in my home and my home will be a single floor structure).
Despite the project’s very modest scope (which is wholly consistent with the City’s goals of enabling aging in place), the Director has arbitrarily and erroneously invoked Palo Alto Municipal Code § 18.70.100 to deny the application. By its express and unambiguous terms, that provision applies when property is “damaged or destroyed” and that portion is “replaced” or
“reconstructed.” We are, in fact, not “replacing” or “reconstructing” the Unsafe Permitted Loft
Area and thus § 18.70.100 is inapplicable on its face. Instead, § 18.70.080 applies and our project was carefully designed to comply with that provision. Analysis
Relevant Law and the Standard of Review When interpreting an ordinance, courts apply the same rules of interpretation applicable to statutes. See Save Our Heritage Organisation v. City of San Diego (2015) 237 Cal.App.4th 163,
174, 187 Cal.Rptr.3d 754.). Courts first examine the language of the ordinance, giving the words
their usual and ordinary meaning, in the context of the ordinance as a whole and its purpose. See
Audio Visual Services Group, Inc. v. Super. Ct., 182 Cal. Rptr. 3d 748, 754 (Cal. App. 2d Dist. 2015). In addition, courts “apply common sense to the language at hand” and interpret a
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provision in a manner that makes “it workable and reasonable” and avoids an absurd result. Wasatch Property Management v. Degrate (2005) 35 Cal.4th 1111, 1122, 29 Cal.Rptr.3d 262,
112 P.3d 647.
Interpretation of the Municipal Code presents a pure question of law and as such the Director’s interpretation is entitled to no deference. See MacIsaac v. Waste Management Collection & Recycling, Inc. (2005) 134 Cal.App.4th 1076, 10. See also Manriquez v. Gourley, 130 Cal. Rptr.
2d 209, 214 (Cal. App. 4th Dist. 2003) (review of an agency’s factual determinations are subject
to the substantial evidence rule but “where … the determinative question is one of statutory or regulatory interpretation, an issue of law, [courts] may exercise … independent judgment.”). If we are forced to proceed with an appeal to Santa Clara Superior Court, the City would face the
prospect of a significant award of attorneys’ fee award as we would be seeking to vindicate the
public’s interest in the proper interpretation of the Palo Alto Municipal Code. See CCP § 1858 (“Upon motion, a court may award attorneys’ fees to a successful party against one or more opposing parties in any action which has resulted in the enforcement of an important right affecting the public interest …”). Also, in litigation the Planning Department would be subject to
discovery aimed at determining whether it is invoking Section 100 even-handedly to small
remodels like ours (this issue is also the subject of a pending request under the California Public Records Act and I respectfully reserve the right to update the Council once the City has produced adequate records in response to our request).1
The Director’s Determination
The Director largely bases his rejection of our plan on Section 18.70.100.2 That section governs reconstruction of a residential structure that already exceeds current zoning limits and is damaged or deliberately demolished, and it generally (and sensibly) requires that if that facility is
“replac[ed]” or “reconstruct[ed] that such replacement or reconstruction not reinstate the
noncompliance. The full text of that provision is appended below with relevant highlighting.
1 Indeed, if Section 100 applies to our small project the Planning Department would necessarily have to reject every single remodel of any noncomplying facility (action which would invite a cascade of litigation centered on unlawful taking of property). Judging by the number of projects
that are ongoing in Barron Park every day of the week, not even the Planning Department is
taking such a restrictive view of Section 100. Indeed, and to its credit, the Planning Department attempted to get some clarity around the meaning and scope of Section 100 back in 2015 but that effort did not gain traction with the members of the City Council at that time. See City Council Staff Report # 6333. We suspect that the Planning Department would benefit from and even
appreciate this Council’s guidance on this important issue.
2 Until the Determination was issued on May 8, 2025, the Director entirely rested his rejection on Section 100. In the Determination, he attempts to buttress the rejection with a new claim that we do not satisfy Section 80. This late argument clearly suggests that the Director lacks confidence
in his application of Section 100. In any event, the Director’s belated interpretation of Section 80
suffers from the same type of flaw that infects his analysis of Section 100, namely that he inserts terms that are not found in the text of the Code (see infra at 4).
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We are clearly not “replacing” or “reconstructing” the Unsafe Permitted Loft Area. We are
demolishing it altogether and not replacing or reconstructing it. The Director would of course be
correct if we were altering the Unsafe Permitted Loft Area and keeping it as loft space. But that
is not our plan. Since we are not replacing or reconstructing the Unsafe Permitted Loft Area, Section 100 is
inapplicable because it only governs replacing or reconstructing space (see highlighting below).
The Director elides this unmistakable fact by arguing in the Determination that what we are doing is “relocating” non-complying floor area and that somehow triggers Section 100. We in fact do not agree that we are “relocating” square footage. Instead, and consistent with § 18.70.080, we are “enlarging” or “improving” a facility in a manner that does not “affect the
particular degree of or manner in which the facility does not comply with one or more provisions
of this title.” However, even if the Director were correct in characterizing our project as “relocating” square footage, even then he would be incorrect in claiming that such “relocating” triggers Section
100. This is for the simple and unmistakable reason that Section 100 applies to replacing or
reconstructing a portion of a noncomplying facility and we are not replacing or reconstructing the Unsafe Permitted Loft Area. The ordinary dictionary definition of replace is “to restore to a former place or position.” See https://www.merriam-webster.com/dictionary/replace. The ordinary dictionary definition of “reconstruct” is “to build or assemble (something) again.” See
https://www.merriam-webster.com/dictionary/reconstruct. Our project does not restore the
Unsafe Permitted Loft Area nor does it assemble it again. As such, Section 100 is wholly inapplicable and the Director has invoked it erroneously. Essentially, and improperly, the Director attempts to graft the additional terms bolded in red
below to the following portion of Section 100:
When the damage or destruction of a noncomplying facility affects a portion of the facility that constituted or contributed to the noncompliance, any replacement or reconstruction to such damaged portion, [or
relocation thereof,] shall be accomplished in such manner as not to
reinstate the noncompliance or degree of noncompliance caused by the destroyed or damaged portion of the facility, and otherwise in full compliance with this title.
But the term “relocation” appears nowhere in the text of Section 100. It is clearly improper for
the Director to insert new terms and limitations in existing Code. If the City wishes to revise the Code it is of course free to do so after complying with State and locale procedure for such modifications. Until then, the Planning Department is obligated to apply the Code as written. See CCP § 1858 (“In the construction of a statute or instrument, the office of the Judge is simply to
ascertain and declare what is in terms or in substance contained therein, not to insert what has
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been omitted, or to omit what has been inserted; and where there are several provisions or particulars, such a construction is, if possible, to be adopted as will give effect to all.”).3
Our Project Is In Full Compliance with § 18.70.080 Fortunately, the Palo Alto Municipal Code has a provision that is specifically crafted to provide Palo Alto homeowners with much needed breathing room to update and modernize their homes.
Section 80 allows “enlargements” of facilities so long as they “do not increase the degree or
manner of non-compliance.” The flexibility offered by Section 80 is essential to the Code’s statutory scheme. Without it, the City would invite challenges under both the California and U.S. Constitutions (regulatory takings
jurisprudence), as well as under the Housing Crisis Act of 2019 and the Housing Accountability
Act, which limit a local agency’s ability to down zone or impose new standards midstream. “Degree” in the context of Section 80 unquestionably speaks to quantity (the same 2,000 sq ft remains) and “manner” speaks to type of violation. Our proposed project keeps the existing Site
Coverage and actually reduces FAR by 11 square feet.
Nonetheless, the Director asserts that “relocating” floor area changes the “manner” of non-compliance because the second floor excess becomes first floor excess. To begin, and as noted above, the Director’s assertion that we are “relocating” floor area is simply incorrect. More
fundamentally, there is nothing in the Code that says the vertical placement of excess floor area
is itself a violation. The Director’s logic invents a brand-new metric—location—that appears nowhere in §§ 80, 90, or 100. Under the plain meaning rule, his attempt to graft new terms into existing code should be
rejected. See Cnty. of Sacramento v. P. Gas & Elec. Co., 238 Cal. Rptr. 305, 311 (Cal. App. 3d
Dist. 1987) (“Where the language is plain and admits of no more than one meaning, the duty of interpretation does not arise, and the rules which are to aid doubtful meanings need no discussion.”) (quotation omitted); see also Franklin v. Appel, 10 Cal. Rptr. 2d 759, 765 (Cal. App. 2d Dist. 1992) (“The court will not, under the guise of construction, rewrite a law, and will
not give the words an effect different from the plain and direct import of the terms used.”).
Thus, there is no question that our project comports with Section 80. Indeed, during the application process the Planning Department based its rejection of our plan solely on Section 100. It was only in the Determination that the Director first claimed that we do not satisfy
3 In his Determination, the Director cites in support of his interpretation the 2015 Council’s
consideration of an amendment to a different provision of the Code, section 18.18.120. This provision of the Code is not at issue here and relates to commercial buildings in the Palo Alto Commercial District. (Determination at 3). The proceedings referenced by the Director related to a proposed amendment to the Code and not an interpretation of it. The fact that the Planning
Department recognized in 2015 that it needed to amend the Code to apply to relocated space as
to commercial buildings in the Commercial District underscores that the Department would need to do the same here to obtain the outcome the Director seeks.
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Section 80 as well (as noted above in footnote 1, the last-minute citation to Section 80 likely reflects the Director’s growing realization that Section 100 is not in fact applicable to our
project).
Once again, the Director tries to graft terms into the Planning Code that are simply not there. The Determination claims that Section 80 “is intended to allow the improvement of a noncomplying facility in a manner unrelated to the particular degree or manner of noncompliance.”
(Determination at 2, emphasis added). But the Code uses the term “affect” not “unrelated.” Our
home does not affect the degree of noncompliance because it does not add to it in any respect. Here as well the Director must apply the Code as written and not language that the Director apparently wishes it contained.4
Conclusion
In sum, and viewing the provisions “holistically” (as the Director purports to do), Section 80 allows “enlargements” of noncomplying facilities provided they do not “affect the particular degree of or manner in which the facility does not comply with one or more provisions of this
title.” § 18.70.080 (emphasis added). Section 100 applies when a property owner seeks to replace
or reconstruct a non-complying facility or a portion of a non-complying facility. § 18.70.100 (emphasis added). With respect to our project, we are proposing an addition that does not affect the degree of non-
compliance of our project. We are removing the Unsafe Permitted Loft Area and not
reconstructing it. As such, Section 80 applies and is satisfied and Section 100 has no application
as a matter of law. It is therefore not within the Director’s discretion to deny the application nor is his legal interpretation of provisions of the Code entitled to any degree of deference by the Council (or, if need be, a court).
Relief Requested The relief we seek is modest: the ability to improve safety and accessibility in our longtime home without being compelled to demolish legally built, character defining portions of the structure.
Timely intervention will spare everyone protracted appeals and public controversy, restore trust
in the permitting system, and align City practice with the letter of its own ordinances.
4 California is of course in a housing crisis. It is therefore quite concerning to my wife and I and a
number of other Palo Alto homeowners that the Director is so hostile to reasonable development
efforts that he seems to create limitations on the right to develop property when none exist. Indeed, the State of California has directed complaints to the Planning Department for precisely this reason. See https://www.paloaltoonline.com/palo-alto/2025/04/03/state-orders-palo-alto-to-revise-laws-on-backyard-dwellings/. It is therefore no surprise that the Planning Department
under the Director’s leadership receives abysmal reviews and remains the subject of much
frustration in our community. See https://www.paloaltoonline.com/palo-
alto/2024/12/10/residents-pan-permitting-laud-libraries-in-new-survey/.
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My wife and I respectfully request that the Council reverse the Director’s May 8 determination and find that our remodel complies with § 18.70.080 and that § 18.70.100 does not apply and
direct staff to issue ministerial approvals forthwith.
We are available to answer any questions or provide supplemental material at the Council’s request.
Respectfully submitted, /s/ Joseph and Colleen Petersen Owners / Applicants
3886 Magnolia Drive, Palo Alto, California 94306
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Appendix Relevant Provisions of the Palo Alto Municipal Code
18.70.100 Noncomplying facility - Replacement. A noncomplying facility which is damaged or destroyed by any means except ordinary wear and tear and depreciation may be reconstructed only as a complying facility, except as follows:
(a) When the damage or destruction of a noncomplying facility affects only a portion of the
facility that did not constitute or contribute to the noncompliance, said portion may be repaired or reconstructed to its previous configuration. (b) When the damage or destruction of a noncomplying facility affects a portion of the facility that constituted or contributed to the noncompliance, any replacement or reconstruction to such
damaged portion shall be accomplished in such manner as not to reinstate the noncompliance or
degree of noncompliance caused by the destroyed or damaged portion of the facility, and otherwise in full compliance with this title; however, if the cost to replace or reconstruct the noncomplying portion of the facility to its previous configuration does not exceed fifty percent of the total cost to replace or reconstruct the facility in conformance with this subsection, then the
damaged noncomplying portion may be replaced or reconstructed to its previous configuration.
In no event shall such replacement or construction create, cause, or increase any noncompliance with the requirements of this title. (c) Notwithstanding subsections (a) and (b) hereof, a noncomplying facility in the commercial CS, CN and CC zones and the industrial MOR, ROLM, RP and GM districts, except for those
areas designated as special study areas, existing on August 1, 1989, which when built was a
complying facility, shall be permitted to be remodeled, improved or replaced in accordance with applicable site development regulations other than floor area ratio, provided that any such remodeling, improvement or replacement shall not result in increased floor area. (d) Notwithstanding subsections (a), (b) and (c) hereof, a noncomplying facility housing a
conforming use in the R-1 and RE zones, which when built was a complying facility, which is
damaged or destroyed by non-willful means (i.e., acts of God) shall be permitted to be replaced, on the same site, and in its previous configuration, without necessity to comply with the current site development regulations, provided that any such replacement shall not result in increased floor area, height, length or any other increase in the size of the facility.
(e) Except as otherwise provided in this section with regard to replacement or reconstruction
of a portion of a facility to its previous noncomplying condition, all reconstruction shall be subject to all applicable laws, regulations, and procedures otherwise governing construction on the site at the time said construction is undertaken. (Ord. 5381 § 7, 2016: Ord. 4102 § 1 (part), 1992: Ord. 4016 § 46, 1991: Ord. 3905 § 18, 1989:
Ord. 3890 § 21, 1989: Ord. 3048 (part), 1978)
18.70.080 Noncomplying facility - Enlargement. (a) Except as specifically permitted by subsections (b) and (c) hereof or by Section 18.12.050(a), no enlargement, expansion, or other addition or improvement to a
noncomplying facility shall be permitted which increases the noncompliance. This section shall
not be construed to prohibit enlargement or improvement of a facility, otherwise permitted by this title, which does not affect the particular degree of or manner in which the facility does not comply with one or more provisions of this title.
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(b) Except in areas designated as special study areas, the director of planning and development services may permit minor additions of floor area to noncomplying facilities in the
commercial CC, CS and CN zones and in the industrial MOR, ROLM, RP and GM districts,
subject to applicable site development regulations, for purposes of on-site employee amenities, resource conservation, or code compliance, upon the determination that such minor additions will not, of themselves, generate substantial additional employment. Such additions may include, but not be limited to, the following:
(1) Area designed and used solely for providing on-site services to employees of the
facility, such as recreational facilities, credit unions, cafeterias and day care facilities; (2) Area designated for resource conservation, such as trash compactors, recycling and thermal storage facilities; and (3) Area designed and required for hazardous materials storage facilities, handicapped
access, and seismic upgrades.
(Ord. 5494 § 3, 2020: Ord. 5381 § 7, 2016: Ord. 5373 § 22 (part), 2016: Ord. 3890 § 20, 1989: Ord. 3683 § 18, 1986: Ord. 3048 (part), 1978)
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PLANNING & DEVELOPMENT SERVICES
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
(650) 329-2441
CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
DATE:May 8, 2025
TO:Planning & Development Services Staff and Interested Community Members
FROM:Jonathan Lait, Director
SUBJECT:Director’s Interpretation Regarding Relocation of Noncomplying Residential Gross Floor
Area Under PAMC Chapter 18.70
Authority
Palo Alto Municipal Code (PAMC) Section 18.01.025 authorizes the Director of Planning and
Development Services to interpret provisions of Titles 16, 18, and 21 of the Palo Alto Municipal Code.
When warranted, formal written interpretations may be issued and posted on the City’s website. Such
decisions become effective fourteen days after posting unless appealed in accordance with PAMC
Section 18.77.070.
Director’s Interpretation
Where an existing residential building exceeds the allowable gross floor area (GFA) PAMC Chapter 18.70
prohibits the relocation of non-complying floor area from one location to another.
Applicable Code Section(s)
18.70.080: Noncomplying Facility – Enlargement
18.70.090: Noncomplying facility – Maintenance and repair
18.70.100: Noncomplying facility – Replacement
Discussion
Palo Alto’s zoning code limits the allowable GFA on residential properties to regulate bulk, scale, and
neighborhood compatibility. Some structures that comply with development standards at the time they
are constructed may become noncomplying as a result of a change in the applicable regulations (e.g.
rezoning or annexation). PAMC Chapter 18.70 sets forth the rules under which such noncomplying
facilities may be maintained. Relocation of noncomplying GFA may be independently prohibited by
PAMC Sections 18.70.080 and 18.70.100; in addition, relocated GFA does not fall within the scope of
permitted alterations under PAMC Section 18.70.090.
PAMC Section 18.70.080: Noncomplying Facility – Enlargement
Section 18.70.080, subd. (a), expressly prohibits any improvement to a noncomplying facility that
increases the noncompliance. If further clarifies that it does not prohibit improvement of a facility,
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otherwise permitted by Title 18 (the zoning code), which does not affect the particular degree or
manner of the noncompliance.
Taken holistically, staff interprets this section to prohibit an improvement that does affect the particular
degree or manner of the noncompliance. For example, if a structure is noncomplying because a parapet
at the rear of the property exceeds the maximum height by five feet, it would not be permitted to
demolish the parapet and reconstruct it identically at the front of the property instead. Even if the new
parapet would not increase the amount by which the structure exceeds the maximum height, the
change in location would affect the particular manner of noncompliance. Similarly, the relocation of
non-complying floor area would violate this prohibition.
Section 18.70.080 is intended to allow the improvement of a noncomplying facility in a manner
unrelated to the particular degree or manner of noncompliance. For example, it would allow a structure
that is non-complying for height to receive additional GFA provided the new area otherwise complied
with the zoning code (e.g. setbacks, lot coverage and floor area limitations, height).
PAMC Section 18.70.090: Noncomplying Facility – Maintenance and repair
Section 18.70.090 allows for the maintenance and repair of a noncomplying facility. It allows for
incidental alterations that do not increase the degree of noncompliance. It also allows for structural
alterations that do not increase the degree of noncompliance, so long as they are “necessary to comply
with the requirements of law or to accommodate a conforming use.”
Incidental alterations are defined in PAMC Section 18.04.030 to mean alterations to the interior of a
building that do not increase its structural strength; alterations to mechanical, electrical and plumbing
systems; and changes to fenestrations that do not increase the building’s structural strength. Structural
alterations are defined as any other alteration.
Staff interprets this section to allow structural alterations only when necessary to comply with the
requirements of law (e.g. building code) or when necessary to accommodate a change to a conforming
use (e.g. to provide sufficient egress for a residential use). Absent a change to a conforming use,
structural alterations would only be permitted to comply with requirements of law. An alternative
interpretation would leave the phrase “necessary to accommodate a conforming use” without any
meaning and collapse the distinction between the allowances for incidental and structural alterations in
Section 18.70.090.
Section 18.70.090 is intended to allow incidental maintenance and repair of noncomplying facilities in a
manner that does not increase noncompliance. It is less permissive regarding structural alterations. The
relocation of noncomplying floor area will typically involve structural alterations; in the absence of a
change to a conforming use, such alterations are only permitted to the extent necessary to comply with
law.
PAMC Section 18.70.100: Noncomplying Facility – Replacement
Section 18.70.100 governs the reconstruction of a noncomplying facility that is damaged or destroyed by
any means other than ordinary wear and tear. This includes willful damage and destruction as part of a
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construction project as well as non-willful means.1 The general rule expressed this section is that a
damaged or destroyed noncomplying facility may only be reconstructed as a complying facility unless an
enumerated exception applies.
Proposed relocation of noncomplying GFA falls under subdivision (b), which states that a portion of a
facility that contributes to the noncompliance, if damaged or destroyed, may only be replaced or
reconstructed in a manner that does not reinstate the noncompliance or the degree of noncompliance.2
Staff interprets the term “replacement” to include replacing demolished GFA in the same or a different
location. This section therefore prohibits the removal of floor area that was willfully destroyed and
contributed to a noncomplying GFA condition, as well as its reinstatement – whether in whole or in part
– at any location within the structure. For example, a project that removes existing GFA and proposes to
reconstruct that floor area in a location that requires demolition and reconstruction of exterior building
walls to accommodate the removed GFA would involve reconstruction that constitutes a reinstatement
of the noncompliance.
The interpretations provided herein are the only ones that give coherent and internally consistent
meaning to each of the code sections discussed. In particular, if either section 18.70.080(a) or section
18.70.090(c) is interpreted to allow the relocation of noncomplying floor area, it is unclear what
meaning section 18.70.100(b) could have. These interpretations are also consistent with prior direction
from the City Council regarding interpretation of similar provisions in PAMC section 18.18.120; in 2015,
the City Council directed that the noncomplying facility provision in that section should not be
interpreted to allow the relocation of noncomplying floor area in the CD district.
_____________________________
Jonathan Lait, Director
Planning and Development Services
Attachment: Applicable Municipal Code Sections
Posted on Website: May 8, 2025
Appeal Deadline: May 22, 2025
1 An alternative interpretation that applies section 18.70.100 only to non-willful damage or destruction would
render subdivision (d) unnecessary, as that section provides a different rule for noncomplying facilities that are
damaged and destroyed by non-willful means.
2 Subdivision (b) also provides an exception where the cost to replace or reconstruct the facility in compliance
would be at least double the cost to replace or reconstruct the facility to its previous configuration; this analysis
assumes that the exception is not triggered.
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Attachment: Applicable Municipal Code Sections
Page 4
18.70.080 Noncomplying facility - Enlargement.
(a) Except as specifically permitted by subsections (b) and (c) hereof or by Section 18.12.050(a), no
enlargement, expansion, or other addition or improvement to a noncomplying facility shall be permitted
which increases the noncompliance. This section shall not be construed to prohibit enlargement or
improvement of a facility, otherwise permitted by this title, which does not affect the particular degree
of or manner in which the facility does not comply with one or more provisions of this title.
(b) Except in areas designated as special study areas, the director of planning and development
services may permit minor additions of floor area to noncomplying facilities in the commercial CC, CS
and CN zones and in the industrial MOR, ROLM, RP and GM districts, subject to applicable site
development regulations, for purposes of on-site employee amenities, resource conservation, or code
compliance, upon the determination that such minor additions will not, of themselves, generate
substantial additional employment. Such additions may include, but not be limited to, the following:
(1) Area designed and used solely for providing on-site services to employees of the facility, such as
recreational facilities, credit unions, cafeterias and day care facilities;
(2) Area designated for resource conservation, such as trash compactors, recycling and thermal
storage facilities; and
(3) Area designed and required for hazardous materials storage facilities, handicapped access, and
seismic upgrades.
(Ord. 5494 § 3, 2020: Ord. 5381 § 7, 2016: Ord. 5373 § 22 (part), 2016: Ord. 3890 § 20, 1989: Ord. 3683
§ 18, 1986: Ord. 3048 (part), 1978)
18.70.090 Noncomplying facility - Maintenance and repair.
(a) Normal and routine maintenance of a noncomplying facility shall be permitted for the purpose of
preserving its existing condition, retarding or eliminating wear and tear or physical depreciation, or
complying with the requirements of law.
(b) Incidental alterations to a noncomplying facility shall be permitted, provided such alterations do
not increase the degree of noncompliance, or otherwise increase the discrepancy between existing
conditions and the requirements of this title.
(c) Structural alterations to a noncomplying facility shall be permitted when necessary to comply with
the requirements of law, or to accommodate a conforming use when such alterations do not increase
the degree of noncompliance, or otherwise increase the discrepancy between existing conditions and
requirements of this title.
(Ord. 5381 § 7, 2016: Ord. 3683 § 17, 1986: Ord. 3048 (part), 1978)
18.70.100 Noncomplying facility - Replacement.
A noncomplying facility which is damaged or destroyed by any means except ordinary wear and tear
and depreciation may be reconstructed only as a complying facility, except as follows:
(a) When the damage or destruction of a noncomplying facility affects only a portion of the facility
that did not constitute or contribute to the noncompliance, said portion may be repaired or
reconstructed to its previous configuration.
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Attachment: Applicable Municipal Code Sections
Page 5
(b) When the damage or destruction of a noncomplying facility affects a portion of the facility that
constituted or contributed to the noncompliance, any replacement or reconstruction to such damaged
portion shall be accomplished in such manner as not to reinstate the noncompliance or degree of
noncompliance caused by the destroyed or damaged portion of the facility, and otherwise in full
compliance with this title; however, if the cost to replace or reconstruct the noncomplying portion of
the facility to its previous configuration does not exceed fifty percent of the total cost to replace or
reconstruct the facility in conformance with this subsection, then the damaged noncomplying portion
may be replaced or reconstructed to its previous configuration. In no event shall such replacement or
construction create, cause, or increase any noncompliance with the requirements of this title.
(c) Notwithstanding subsections (a) and (b) hereof, a noncomplying facility in the commercial CS, CN
and CC zones and the industrial MOR, ROLM, RP and GM districts, except for those areas designated as
special study areas, existing on August 1, 1989, which when built was a complying facility, shall be
permitted to be remodeled, improved or replaced in accordance with applicable site development
regulations other than floor area ratio, provided that any such remodeling, improvement or
replacement shall not result in increased floor area.
(d) Notwithstanding subsections (a), (b) and (c) hereof, a noncomplying facility housing a conforming
use in the R-1 and RE zones, which when built was a complying facility, which is damaged or destroyed
by non-willful means (i.e., acts of God) shall be permitted to be replaced, on the same site, and in its
previous configuration, without necessity to comply with the current site development regulations,
provided that any such replacement shall not result in increased floor area, height, length or any other
increase in the size of the facility.
(e) Except as otherwise provided in this section with regard to replacement or reconstruction of a
portion of a facility to its previous noncomplying condition, all reconstruction shall be subject to all
applicable laws, regulations, and procedures otherwise governing construction on the site at the time
said construction is undertaken.
(Ord. 5381 § 7, 2016: Ord. 4102 § 1 (part), 1992: Ord. 4016 § 46, 1991: Ord. 3905 § 18, 1989: Ord. 3890
§ 21, 1989: Ord. 3048 (part), 1978)
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Joseph Petersen
Kilpatrick Townsend & Stockton LLP
| Suite 175 | Menlo Park, CA 94025
Kilpatrick Townsend & Stockton LLP
New York, NY 10036
My Profile | vCard
* Admitted in California and New York
From: Armer, Jennifer <Jennifer.Armer@paloalto.gov>
Sent: Tuesday, May 13, 2025 11:23 AM
To: Lait, Jonathan <Jonathan.Lait@paloalto.gov>; Petersen, Joe ; Mindie S. Romanowsky
Cc: Yang, Albert <Albert.Yang@paloalto.gov>; Tran, Charlotte <Charlotte.Tran@paloalto.gov>
Subject: Re: Director's Zoning Interpretation: PAMC 18.70.080 - 100
Good Morning Mr. Peterson,
The appeal of a director's decision is processed in accordance with Palo Alto Municipal Code (PAMC) Section
18.77.070(f):
(f) Decision by the City Council
The appeal of the director’s decision shall be placed on the consent calendar of the city council within 45
days. The city council may:
(1) Adopt the findings and decision of the director; or
(2) Remove the appeal from the consent calendar, which shall require three votes, and direct that
the appeal be set for a new noticed hearing before the city council, following which the city council
shall adopt findings and take action on the application.
Please submit an appeal letter containing:
1. Appellant Name
2. Appellant Address
3. Appellant Phone
4. Appellant email
5. Specific reference to Director's Interpretation being appealed (with issuance date) and reasons for appeal
There will also be a $740 appeal fee required (Per Fee Schedule: palo-alto-fee-schedule.pdf).
As stated in Director Lait's email below, the deadline for appeal is 14 days from issuance of the interpretation, so
your appeal will need to be submitted by 5:00 p.m. on Thursday, May 22, 2025. Once you have submitted your
appeal via email (to myself Jennifer.Armer@paloalto.gov, and Charlotte Tran Charlotte.Tran@paloalto.gov) we can
send you an invoice for the appeal fee.
Sincerely,
Jennifer
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***DISCLAIMER*** Per Treasury Department Circular 230: Any U.S. federal tax advice contained in this communication (including any attachments) is not
intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing
or recommending to another party any transaction or matter addressed herein.
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1
Thomas W. Kellerman
Palo Alto, CA 94301
Ozzy Arce
Project Manager & Senior Transportation Planner
City of Palo Alto Office of Transportation
City Hall
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
Re: Bicycle Boulevard Projects
Dear Mr. Arce:
I have read with interest the current available information regarding the Palo Alto Bicycle and
Pedestrian Plan Update. Thank you for the thoughtful and detailed analysis being undertaken by the
Office of Transportation with respect to this very important undertaking. I am writing with respect to
one very specific concern related to possible revisions to the Bicycle Boulevard system in the
Professorville area. Most specifically, I note the following two projects under consideration:
Bryant Street Bike Boulevard
Install traffic diverters, speed bumps, traffic circles, or other similar interventions on Bryant
Boulevard between Embarcadero Road and downtown. Include a turn restriction from
Embarcadero Road going northbound onto Bryant Boulevard.
Kingsley Avenue Bike Boulevard
Construct a bike boulevard on Kingsley Avenue from Emerson St to Middlefield Rd to
provide access to the Embarcadero Rd undercrossing of Alma St.
I am a strong proponent for the continued enhancement of Palo Alto’s bicycle network and efforts
to promote safe bicycle and pedestrian mobility throughout the City. I live very close to the
intersection of Emerson Street, Embarcadero Road and Kingsley Avenue. While not currently
designated as a “Safe Route to School”, in fact this intersection and the Alma Street and railroad
underpass on Embarcadero Road are very heavily used by bicyclists and pedestrians. In fact, a
prior traffic consultant confirmed that the volume of bicycle crossings at this intersection is at least
as high as the crossing at Churchill Avenue during school run hours. As the Office of Transportation
is aware, this intersection is particularly dangerous due to the high level of vehicular traffic both
entering and exiting Embarcadero Road at this location. While it is not immediately obvious, the
1100 block of Emerson Street is effectively a cloverleaf for vehicles transiting from Alma Street to
Westbound Embarcadero Road at the intersection in question, resulting in a far higher volume of
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2
traffic than would otherwise be expected on a residential block. In addition, the layout of this
intersection reduces visibility for vehicles and bicyclists and creates a hazard. When the high
volume of bicycle crossings is taken into consideration, the hazard is further enhanced. As you are
aware, safety improvements to this intersection have previously been designed by your office, but
this project is currently on hold. (Please see the following description: Embarcadero Road Improvements
(Alma to Emerson))
Based on the foregoing situation, possible revisions to the Bryant Street Bike Boulevard North of
Embarcadero Road need to thoughtfully take into consideration the potential impacts of any
changes on adjacent streets. As is always the case, if one route is closed to vehicular traffic, that
traffic will move to the next available route. Emerson is the next available exit from Embarcadero
Road after Bryant Street. If Bryant Street were closed to vehicles turning from Embarcadero Road, it
would inevitably result in a significant increase in the number of vehicles turning onto Emerson
Street. Unfortunately, such a change would make the existing safety concern at the Emerson/
Embarcadero intersection even more hazardous. Accordingly, I believe adjustments other than
closure at Bryant Street should be adopted.
Please note that I am in favor of adding additional traffic calming to Bryant Street, such as traffic
circles, speed humps or other measures designed to slow vehicular traffic on this important bicycle
artery. I recognize that there is not a perfect solution to these issues. However, if the Office of
Transportation were to observe the flow of vehicles and bicycles at this intersection, particularly in
the hours before and after the school day, I am confident you would gain an appreciation of the
importance of these decisions.
Thank you for considering my input. I am happy to have a discussion with your staff if I can provide
any additional background.
Sincerely,
Thomas W. Kellerman
cc: Palo Alto Planning and Transportation Commission
Pat Burt, City Council
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These statements reflect a core belief of Zionist ideology: that Palestinians
must be expelled from their ancestral lands, in order to make way for
colonial occupation.
The violence that began in 1947-48 has never stopped. It continues in the
mass starvation and bombardment of Gaza. In the armed settler violence
and military incursions in the West Bank.
But Palestinians will not be erased. Today we reaffirm our solidarity
with Palestinians, our support for the Palestinian right of return, and our
commitment to fighting for an end to Zionism’s ongoing catastrophes.
Read IJV's full statement here
Arms Embargo Now Campaign Call this Sunday
Arms Embargo Now Campaign Call this Sunday
Since launching a year ago, the Arms Embargo Now campaign has changed
the national narrative about Canada’s complicity in Israel’s genocide, and
forced our leaders to take unprecedented steps to slow down our export of
arms to Israel. But we have a long way to go.
When confronted during the election campaign about their complicity in
Israel’s escalating genocide in Gaza, many politicians lied to their
constituents, claiming that Canada has stopped exporting weapons to
Israel. Unfortunately, for all their talk, the Liberals have left the vast
majority of exports untouched.
With the election over, a new government in Ottawa, and Israel’s
siege and assault on Gaza reaching ever new levels of devastation,
it is time to reconnect, reassess, and refocus on how to advance
our demand and win a full two-way arms embargo.
Join us this Sunday May 18th, at 11am PT / 12pm MT / 1pm CT / 2pm ET /
3pm AT for this urgent organizing call. You will hear from organizers
with the Arms Embargo Now campaign about the current status of
Canada’s arms trade with Israel, why an arms embargo is a key way for
our government to sanction Israel, and the next steps of the campaign.
Register Today
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In solidarity,
Iso
Iso Setel
Communications Coordinator
Independent Jewish Voices
iso@ijvcanada.org
Join IJV
Bonjour Aram,
Le 15 mai, nous commémorons la Nakba, la catastrophe infligée au peuple
palestinien par les milices sionistes et l'armée israélienne naissante. Plus
de 750 000 personnes ont été violemment expulsées et forcées de
fuir leurs terres, plus de 530 villages ont été détruits et des
communautés entières ont été massacrées et détruites par les
sionistes.
Cette année, nous célébrons l'anniversaire de cette catastrophe, qui s'est
traduite par 77 ans de nettoyage ethnique, de dépossession et de
déshumanisation, et maintenant par 19 mois de génocide.
Depuis sa création, le sionisme est un projet de colonisation fondé sur
l'effacement des Palestinien.ne.s.
En 1937, David Ben-Gourion, qui deviendra plus tard le premier Premier
ministre d'Israël, écrivait : « Nous devons expulser les Arabes et
prendre leur place ». Trois ans plus tard, Yosef Weitz, du Fonds national
juif, déclarait : « Il n'y a pas de place pour les deux peuples dans ce
pays... il ne faut laisser aucun village, aucune tribu. »
Ces déclarations reflètent une croyance fondamentale de l'idéologie
sioniste : les Palestiniens doivent être expulsés de leurs terres ancestrales
pour faire place à l'occupation coloniale.
La violence qui a commencé en 1948 n'a jamais cessé. Elle se poursuit par
la famine de masse et le bombardement de Gaza. Dans la violence armée
des colons et les incursions militaires en Cisjordanie.
Mais les Palestiniens ne seront pas effacés. Aujourd'hui, nous
réaffirmons notre solidarité avec les Palestiniens, notre soutien au droit au
retour des Palestiniens et notre engagement à lutter pour mettre fin aux
catastrophes continues du sionisme.
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Lire la déclaration complète de VJI ici
Embargo sur les armes maintenant : Appel de la
campagne ce dimanche
Depuis son lancement il y a un an, la campagne « Embargo sur les armes
maintenant » a changé le discours national sur la complicité du Canada
dans le génocide israélien et a forcé nos dirigeants à prendre des mesures
sans précédent pour ralentir nos exportations d'armes vers Israël. Mais il
reste encore beaucoup à faire.
Lorsqu'ils ont été confrontés pendant la campagne électorale à leur
complicité dans l'escalade du génocide israélien à Gaza, de nombreux
politiciens ont menti à leurs électeurs, affirmant que le Canada avait cessé
d'exporter des armes vers Israël. Malheureusement, malgré tous leurs
discours, les libéraux n'ont pas touché à la grande majorité des
exportations.
Avec la fin des élections, un nouveau gouvernement à Ottawa, et le siège
et l'assaut d'Israël sur Gaza atteignant de nouveaux niveaux de
dévastation, il est temps de se reconnecter, de réévaluer et de se recentrer
sur la façon de faire avancer notre demande et d'obtenir un embargo
complet sur les armes dans les deux sens.
Rejoignez-nous ce dimanche 18 mai, à 11h PT / 12h MT / 13h CT / 14h ET
/ 15h AT pour cet appel urgent à la mobilisation. Les organisateurs de
la campagne Embargo sur les armes maintenant vous expliqueront l'état
actuel du commerce des armes entre le Canada et Israël, pourquoi un
embargo sur les armes est un moyen essentiel pour notre gouvernement
de sanctionner Israël, et quelles sont les prochaines étapes de la
campagne.
S'inscrire maintenant
Adhérer à VJI
Iso Setel
Coordonnateur des communications
Voix juives indépendantes
iso@ijvcanada.org
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PO Box 30087 RPO Woodbine Heights
1500 Woodbine Avenue
Toronto, ON M4C 5J2
Canada
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