HomeMy WebLinkAboutStaff Report 14867
City of Palo Alto (ID # 14867)
City Council Staff Report
Report Type: Action Items Meeting Date: 12/12/2022
City of Palo Alto Page 1
Summary Title: Action Item: ADU Code Changes to PAMC
Title: PUBLIC HEARING/LEGISLATIVE: Adoption of Amendments to Palo Alto
Municipal Code Chapter 18.09, Accessory and Junior Accessory Dwelling
Units due to State Law Changes and Direction from the California
Department of Housing and Community Development. Environmental
Assessment: Exempt from the provisions of the California Environmental
Quality Act (CEQA) pursuant to Public Resources Code Section 21080.17 and
CEQA Guidelines sections 15061(b)(3), 15301, 15302 and 15305. Planning and
Transportation Commission Recommended Approval of the Ordinance.
From: City Manager
Lead Department: Planning and Development Services
Recommendation
Staff recommends the City Council adopt the attached Ordinance (Attachment A) amending
Palo Alto Municipal Code Title18 (Zoning) regulations for Accessory Dwelling Units (ADUs) and
Junior Accessory Dwelling Units (JADUs) to reflect changes in state law and direction from the
California Department of Housing and Community Development (HCD).
Report Summary/Background
On October 26, 2020, the City Council adopted the updated Palo Alto’s Accessory Dwelling Unit
and Junior Accessory Dwelling Unit (ADU and JADU) Ordinance. These were consolidated into
Palo Alto Municipal Code (PAMC) Chapter 18.09. On October 26, 2020, Council also directed
staff to continue working with stakeholders and to present any additional changes to the
Planning and Transportation Commission (PTC). The PTC held multiple hearings to discuss
potential ADU/JADU code changes, and the PTC staff reports, meeting minutes, and videos are
viewable on the City’s PTC webpages.1
1 Link to 2022 PTC Staff reports, meeting minutes, and videos
https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Planning-and-Transportation-
City of Palo Alto Page 2
In September 2022, the Governor signed the California State legislature’s three new bills
regarding ADU/JADU regulations (SB897, AB2221, and AB157). The laws will go into effect on
January 1, 2023; they are intended to incentivize housing unit development. In addition, there
was a Budget Act that appropriates $100 million to bolster CalHFA’s ADU grant program that
provides up to $40,000 for low- and moderate-income homeowners to cover pre-development
costs.
On September 28, 2022, the PTC recommended Council approve a draft ordinance
incorporating the new state legislation and direction from HCD as well as other changes the PTC
discussed in public hearings. The attached ordinance, however, is limited only to the code
updates necessary to comply with the new state law and direction from HCD. The other policy
recommendations will follow early next year. The reason staff is separating these ordinances is
to focus on the more time sensitive state-mandated changes to avoid having the City’s local
ADU/JADU ordinance invalidated, which arguably would be the case if the City does not adopt
an ordinance by January 1, 2023.
The attached draft Ordinance (Attachment A) enables the Council to adopt the State’s 2022
ADU legislation.
Discussion
This staff report touches on the staff response to a California Department of Housing and
Community Development (HCD) letter received in late 2021, as well as describing the 2022
State legislation regarding ADUs and JADUs.
Staff Response to HCD Letter
On December 23, 2021, the City received a letter from HCD regarding the ordinance the City
adopted in November 2020 (Attachment B). HCD raised 12 issues with the City’s ordinance
where it thought the ordinance conflicted with state law or required further clarification. On
February 3, 2022, City staff met with HCD staff to discuss HCD’s comments and concerns as well
as to explain the structure and intent of the language incorporated into the City’s ordinance.
Following that discussion, City staff provided detailed responses to the HCD letter, indicating
areas where the City would incorporate changes and where staff required clarification
(Attachment C). Staff has sought updates from HCD on this request for additional feedback over
the past year but has not received HCD’s response.
Many of the HCD’s changes were minor clarifications, which appear in the draft ordinance as
noted in comment bubbles. In many cases, the proposed adjustments clarify existing policy to
Commission-PTC/Current-PTC-Agendas-Minutes; the most recent PTC hearing was September 28, 2022. Earlier PTC
hearings in 2022 were July 13, 2022 and August 10, 2022.
City of Palo Alto Page 3
provide assurance to the state and the public that the City’s ordinance should be interpreted in
a manner consistent with state law.
Other items (such as #3, #4, and #5 in the HCD letter) are more significant changes to City
policy, where February 2022 meeting left staff uncertain about the HCD’s direction. Staff awaits
further clarification from HCD before proposing an ordinance change for those items. While
staff believes that there are strong arguments in support of the City’s position on these issues,
it is possible that HCD’s eventual response will require further modifications to the ordinance.
Given the uncertainty around when the City can expect a detailed response from HCD, staff
recommends proceeding with the ordinance update, though further ordinance revisions may be
required based on any additional HCD feedback received.
Inclusion of 2022 State ADU Legislation
The Governor signed the following three bills pertaining to ADUs:
• SB 897 allows two-story ADUs in some places, prevents local governments from posting
unnecessary notices, and prevents a local government from changing the Group R
occupancy status as that relates to building codes, among other important changes.
• AB 2221 prevents local governments from imposing front setbacks, establishes a 60-day
timeline for a complete review of ADUs that are denied, and makes other important
changes noted below in the AB 2221 summary section.
• AB 157, a late addition to budget trailer bills, requires CalHFA to convene a working
group of experts to recommend next-phase updates to CalHFA's ADU grant program so
that more homeowners can benefit.
Two of these bills, now laws, are incorporated into provisions of the attached draft ordinance -
SB897 and AB2221. AB 2221 and SB 897 both amended Government Code section 65852.2. AB
2221 was chaptered at 650, and SB 897 was chaptered at 664.
SB 8972 (GC 65852.2 amendment @664) Requires That:
• The City must allow a height of 18 feet for a detached ADU on a lot with an existing or
proposed single-family or multifamily dwelling unit that is within one-half mile walking
distance of a major transit stop or a high-quality transit corridor3, as those terms are
defined in Section 21155 of the Public Resources Code. An additional two feet in height
shall be provided to accommodate a roof pitch on an ADU that is aligned with the roof
pitch of the primary dwelling unit.
• The City must allow a height of 18 feet for a detached ADU on a lot with an existing or
proposed multifamily, multi-story dwelling, regardless of proximity to a transit stop or
2 Link to Summary of SB897: https://legiscan.com/CA/text/SB897/2021
3 See Attachment D for a map of the major transit stops and high-quality transit corridor
City of Palo Alto Page 4
high-quality transit corridor. This would not affect properties with multifamily, single-
story dwellings.
• The City must allow a height of 25 feet or the height limitation in the underlying zone
district that applies to the primary dwelling, whichever is lower, for an ADU that is
attached to a primary dwelling. The ADUs shall not exceed two stories in height.
• The City cannot require modification to an existing, noncomplying, multi-family
residential dwelling to satisfy the height limit or rear or side setback of four feet for an
ADU.
• The City cannot reject an ADU application because an existing multi-family residential
dwelling exceeds the maximum height or rear or side setbacks of less than four feet.
• The City cannot impose parking standards on an ADU that is included in an application
to create a new single-family dwelling unit or new multi-family residential dwelling on
the same lot, provided the ADU meets other specified requirements.
• Enclosed uses within the proposed or existing single-family residence, such as attached
garages, are considered part of the proposed or existing single-family residence.
• A JADU that does not include a separate bathroom must include a separate entrance
from the main entrance to the structure, with an interior entry to the main living area.
• The City cannot deny an application for JADU due to the correction of nonconforming
zoning conditions or building violations, or unpermitted structures that do not present a
threat to public health and safety and are not affected by the construction of the JADU.
• The City cannot deny a permit for an unpermitted ADU constructed before January 1,
2018, because, among other things, the unit is in violation of building standards or state
or local standards applicable to ADUs, unless the local agency makes a finding that
correcting the violation is necessary to protect the health and safety of the public or
occupants of the structure. This prohibition does not apply to a building that is deemed
substandard under specified provisions of law.
AB 22214 (GC 65852.2 amendment @650):
• Clarifies that an ADU may be attached to or located within a detached garage for the
primary dwelling.
• Specifies that the permitting agency action must be approval or denial of the
application. If a permitting agency denies an application for an ADU or JADU, the law
requires a permitting agency to return in writing a full set of comments to the applicant
with a list of items that are defective or deficient and a description of how the
application can be remedied by the applicant within the same timeframes. The law
defines “permitting agency” for its purposes.
4 Link to Summary of AB2221: https://legiscan.com/CA/text/AB2221/2021
City of Palo Alto Page 5
• Prohibits a local agency from enforcing front setbacks, where such setbacks would
preclude the creation of an ADU of at least 800 square feet, with four-foot side and rear
setbacks and 16 feet in height.
Significant Changes
The most significant effects of these state law changes pertain to the increased height
allowances for attached ADUs and detached ADUs located within a half-mile distance from
high-quality transit in the City. In Palo Alto, these areas primarily occur near the University and
California Avenue Caltrain Stations and along El Camino Real, as shown in Attachment D. The
increased height in these areas will inevitably create greater privacy and massing impacts on
adjacent properties that the City is unable to control or prevent. This is, however, consistent
with the approach the state has taken to encourage ADU development in California and will
likely continue to be expanded in the future.
While other new state laws seek to limit a local jurisdiction’s ability to require front yard
setbacks, staff believe that the current phrasing built into the state code only provides that
ability as a last resort to homeowners, when the ADU follows a four-foot side and rear yard
setback, but they would still be unable to create minimum sized 800 square foot ADU. Staff
does not anticipate that this will become a prevalent issue. Many of the state law revisions do
not affect the City’s ADU/JADU ordinance because they are requirements the City already
established in the code and practices staff follow for processing ADU/JADU applications.
Quarterly ADU report dated June 20, 2022
The Council received a quarterly report on ADUs5. In the report, the average size of ADUs was
reported to be around 552 square feet which is an increase largely associated with the
additional flexibility the State provides for minimum sizes of second units that homeowners can
develop by right.
Environmental Review
The adoption of the Draft Ordinance would be exempt from the provisions of the California
Environmental Quality Act (CEQA) pursuant to Public Resources Code Section 21080.17 and
CEQA Guidelines sections 15061(b)(3), 15301, 15302 and 15305 because it meets requirements
related to accessory dwelling units as established in Government Code Section 65852.2, and
these changes are also likely to result in few additional dwelling units dispersed throughout the
City. As such, it can be seen with certainty that the proposed action will not have the potential
for causing a significant effect on the environment.
5 Link to June 2022 quarterly ADU report to Council: https://www.cityofpaloalto.org/files/assets/public/agendas-
minutes-reports/agendas-minutes/city-council-agendas-minutes/2022/20220620/20220620pccsm-amended-final-
final.pdf#page=820
City of Palo Alto Page 6
Public Notification, Outreach & Comments
The PAMC requires notice of this public hearing to be published in a local paper and mailed to
owners and occupants of property within 600 feet of the subject property at least 10 days in
advance. Notice of a public hearing for this project was published in the Daily Post on
December 2, which is 10 days in advance of the meeting.
Attachments:
ATTACHMENT A - Ordinance Amending Title 18 (Zoning) of the PAMC to Amend
Requirements Relating to Accessory Dwelling Units and Junior Accessory Dwelling Units
(PDF)
ATTACHMENT B - HCD Letter on ADU Ordinance (PDF)
ATTACHMENT C - Staff Response to HCD (PDF)
ATTACHMENT D - Half Mile Buffer from High Quality Transit (PDF)
*NOT YET APPROVED*
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Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Amending Title 18 (Zoning) of
the Palo Alto Municipal Code to Amend Requirements Relating to Accessory
Dwelling Units and Junior Accessory Dwelling Units
The Council of the City of Palo Alto does ORDAIN as follows:
SECTION 1. Findings and Declarations. The City Council finds and declares as follows:
A. Housing in California is increasingly unaffordable. In 2017, the average
California home cost about 2.5 times the national average home price and the monthly rent
was 50% higher than the rest of the nation. Rents in San Francisco, San Jose, Oakland, and Los
Angeles are among the top 10 most unaffordable in the nation.
B. Housing in Palo Alto is especially unaffordable. The average Palo Alto home
currently costs about 8 times the national average home price and the monthly rent is about
2.5 times the national average.
C. Palo Alto has a jobs/housing imbalance. When addressing this imbalance, the
City must not only provide housing but also ensure affordability.
D. Assembly Bill (“AB”) 2221 and Senate Bill (“SB”) 897 (“State ADU Law”) pertain to
accessory dwelling units (“ADUs”) and junior accessory dwelling units (“JADUs”) and were
approved by the California Legislature in 2022 and signed by the Governor on September 30,
2022. These bills, codified primarily in California Government Code sections 65952.2 and
65952.22, are intended to spur the creation of lower cost housing by easing regulatory barriers
to the creation of ADUs and JADUs. The City adopted Ordinance 5507 (now Palo Alto Municipal
Code Chapter 18.09), which brought the City’s municipal code into conformance with state laws
AB 68, 587, 671 and 881, and SB 13.
SB 897 allows two‐story ADUs in some places, prevents local governments from
posting unnecessary notices, and prevents a local government from changing the
Group R occupancy status as that relates to building codes, among other
important changes.
AB 2221 adds front setbacks to the list of standards that must give way to permit
an 800sf ADU, establishes a 60‐day timeline for complete review of ADUs that are
denied, and makes other important changes.
E. This ordinance is adopted to incorporate changes in state law that have occurred
since the adoption of Ordinance 5507, respond to comments the City has received from the
California Department of Housing and Community Development regarding its ADU regulations,
respond to additional policies advocated by members of the public, and issues staff has noticed
*NOT YET APPROVED*
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when reviewing permits. This ordinance is also adopted to establish a program for deed‐
restricted affordable ADU/JADUs.
SECTION 2. Chapter 18.09 (Accessory Dwelling Units and Junior Accessory Dwelling Units)
of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read as follows
(additions underlined and deletions struck‐through):
18.09.010 Purpose
The intent of this Chapter is to provide regulations to accommodate accessory and
junior accessory dwelling units (ADU/JADU), in order to provide for variety to the city's housing
stock and additional affordable housing opportunities. These units shall be separate, self‐
contained living units, with separate entrances from the main residence, whether attached or
detached. The standards below are provided to minimize the impacts of units on nearby
residents and throughout the city, and to assure that the size and location of such dwellings is
compatible with the existing or proposed residence(s) on the site and with other structures in
the area.
18.09.020 Applicable Zoning Districts
The establishment of an accessory dwelling unit is permitted in zoning districts when
single‐family or multi‐family residential is a permitted land use. The development of a single‐
family home, ADU, and/or a JADU on a lot that allows for single‐family development shall not be
considered a multifamily development pursuant to PAMC Section 18.04.030, nor shall they
require Architectural Review pursuant to other sections of Chapter 18.
18.09.030 Units Exempt from Generally Applicable Local Regulations
(a) Government Code section 65852.2, subdivision (e) provides that certain units shall
be approved notwithstanding state or local regulations that may otherwise apply. The following
types of units shall be governed by the standards in this section. In the event of a conflict between
this section and Government Code section 65852.2, subdivision (e), the Government Code shall
prevail.
i. An ADU and or JADU within the existing space of a single‐family dwelling or an
ADU within the existing space of an accessory structure (i.e. conversion without
substantial addition).
ii. An ADU and or JADU within the proposed space of a single‐family dwelling.
iii. A detached, new construction ADU on a lot with a proposed or existing single‐
family dwelling, provided the ADU does not exceed 800 square feet, sixteen feet
in height, or four‐foot side and rear (i.e. interior) setbacks.
iv. ADUs created by conversion of portions of existing multi‐family dwellings not used
as livable space.
v. Up to two detached ADUs on a lot with an existing multi‐family dwelling.
Commented [SG1]: Response to HCD item #2
Commented [SG2]: Response to HCD item #2
*NOT YET APPROVED*
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(b) The Development Standards for units governed by this section are summarized in
Table 1. Regulations set forth in section 18.09.040 do not apply to units created under 18.09.030.
The minimum and maximum sizes indicated in Table 1 do not prohibit units that are greater than
800 square feet. These sizes simply serve to distinguish when a unit transitions from regulations
set forth in Table 1 and section 18.09.030 to regulations set forth in Table 2 and section
18.09.040.
Table 1: Development Standards for Units Described in Government Code Section 65852.2(e)
Single‐Family Multi‐Family
Conversion of
Space Within an
the Existing
Space of a
Single‐Family
Home or
Accessory
Structure
Construction of
Attached ADU
Within the
Proposed Space
of a Proposed
Single‐Family
Home
New
Construction of
Detached ADU
Conversion of
Non‐Habitable
Space Within
Existing Multi‐
family Dwelling
Structure
Conversion or
Construction of
Detached(4) ADU
Number
of Units
Allowed
1 ADU and 1 JADU
25% of the
existing units
(at least one)
2
Minimum
size(1) 150 sf
Maximum
size(1) N/A2 800 sf N/A
Setbacks
N/A, if condition
is sufficient for
fire and safety
Underlying zone
standard for
Single Family
Home
(ADU must be
within
allowable space
of Single‐Family
Home)(7)
4 feet from side
and rear lot
lines;
underlying
zoning for front
setback
N/A
4 feet from side
and rear lot
lines; underlying
zoning for front
setback
Daylight
Plane N/A N/A
Maximum
Height(3) N/A 16(5)3 N/A 16(4)(5)(6)
Parking None
State Law
Reference 65852.2(e)(1)(A) 65852.2(e)(1)(A) 65852.2(e)(1)(B) 65852.2(e)(1)(C) 65852.2(e)(1)(D)
(1) Lofts where the height from the floor level to the underside of the rafter or finished roof
surface is 5' or greater shall count towards the unit’s floor area.
(2) Up to 150 sf may be added for the purpose of ingress and egress only.
Commented [SG3]: Response to HCD item #5, #10, #11,
#12
Commented [SG4]: Response to HCD item #1
*NOT YET APPROVED*
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(3) Units built in a flood zone are not entitled to any height extensions granted to the primary
dwelling.
(4) Units must be detached from existing primary dwellings but may be attached to each
other.
(5) A height of 18 feet for a detached ADU on a lot with an existing or proposed single family
or multifamily dwelling unit that is within one‐half of one mile walking distance of a major
transit stop or a high‐quality transit corridor, as those terms are defined in Section 21155
of the Public Resources Code. An additional two feet in height shall be provided to
accommodate a roof pitch on an ADU that is aligned with the roof pitch of the primary
dwelling unit.
(6) A height of 18 feet for a detached ADU on a lot with an existing or proposed multifamily,
multistory dwelling.
(7) A height of 25 feet or the height limitation in the underlying zone district that applies to
the primary dwelling, whichever is lower, for an ADU that is attached to a primary
dwelling. These ADUs shall not exceed two stories in height.
(c) Development standards stated elsewhere in this Section or Title 18, including
standards related to FAR, lot coverage, and privacy, are not applicable to ADUs or
JADUs that qualify for approval under this section.
(d) The establishment of accessory dwelling units and junior accessory dwelling units
pursuant to this section shall not be conditioned on the correction of non‐conforming
zoning conditions; provided, however, that nothing in this section shall limit the
authority of the Chief Building Official to require correction of building standards
relating to health and safety.
(e) The installation of fire sprinklers shall not be required in an accessory dwelling unit if
sprinklers are not required for the primary residence. Nothing in this section shall
preclude the Fire Marshal from accepting fire sprinklers as an alternative means of
compliance with generally applicable fire protection requirements.
(f) Rental of any unit created pursuant to this section shall be for a term of 30 days or
more.
(g) Attached units shall have independent exterior access from a proposed or existing
single‐family dwelling. Except for JADUs, attached units shall not have an interior
access point to the primary dwelling (e.g. hotel door or other similar
feature/appurtenance).
(h) Conversion of an existing accessory structure pursuant to Government Code section
65852.2(e)(1)(A) may include reconstruction in‐place of a non‐conforming structure,
so long as the renovation of reconstruction does not increase the degree of non‐
compliance, such as increased height, envelope, or further intrusion into required
setbacks.
Commented [SG5]: SB 897 and AB 2221 Changes
*NOT YET APPROVED*
5
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(i) Street addresses shall be assigned to all units prior to building permit final to assist in
emergency response.
(j) The unit shall not be sold separately from the primary residence.
(k) Replacement parking is not required when a garage, carport, or covered parking
structure is converted to, or demolished in conjunction with the construction of, an
ADU.
(l) JADUs shall comply with the requirements of Section 18.09.050.
18.09.040 Units Subject to Local Standards
(a) This section shall govern applications for ADUs and JADUs that do not qualify for
approval under section 18.09.030 and for which the City may impose local standards
pursuant to Government Code section 65852.2, subdivisions (a) through (d). Nothing
in this section shall be interpreted to prohibit an ADU of up to 800 square feet, at the
heights stated in Table 2, with a four foot side and rear setbacks.
(b) The Development Standards for units governed by this section are provided in Table
2. These regulations do not limit the height of existing structures converted into
ADU/JADUs unless the envelope of the building is proposed to be modified beyond
any existing legal, non‐conforming condition.
Table 2: All other Units
Attached Detached JADU
Number of Units
Allowed1 1 1
Minimum size 150 sf
Maximum size
900 sf (1,000 sf for two
or more bedrooms);
no more than 50% of
the size of the single‐
family home
900 sf (1,000 sf for
two or more
bedrooms)
500 sf
Setbacks 4 feet from side and rear lot lines;
underlying zone standard for front setback
Daylight Plane
Initial Height 8 feet at lot line
Angle 45 degrees
Maximum Height3
Res. Estate (RE) 30 feet
Open Space (OS) 25 feet
Commented [SG6]: Response to HCD item #6, #9; SB 897
change re height
Commented [SG7]: Response to HCD item #5
*NOT YET APPROVED*
6
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All other eligible
zones 16 feet(5)(6)(7)
Parking None
Square Footage
Exemption Up to 800 sf(4) Up to 500 sf(4)
(1) An attached or detached ADU may be built in conjunction with a JADU on a lot with an
existing or proposed single family home. One attached or detached ADU may be built in
conjunction with an existing or proposed multifamily building.
(2) Lofts where the height from the floor level to the underside of the rafter or finished roof
surface is 5' or greater shall count towards the unit’s floor area.
(3) Units built in a flood zone are not entitled to any height extensions granted to the primary
dwelling.
(4) Lots with both an ADU and a JADU may exempt a maximum combined total of 800 square
feet of the ADU and JADU from FAR, Lot Coverage, and Maximum House Size calculations.
(5) A height of 18 feet for a detached ADU on a lot with an existing or proposed single family
or multifamily dwelling unit that is within one‐half of one mile walking distance of a major
transit stop or a high‐quality transit corridor, as those terms are defined in Section 21155
of the Public Resources Code. An additional two feet in height shall be provided to
accommodate a roof pitch on an ADU that is aligned with the roof pitch of the primary
dwelling unit.
(6) A height of 18 feet for a detached ADU on a lot with an existing or proposed multifamily,
multistory dwelling.
(7) A height of 25 feet or the height limitation in the underlying zone district that applies to
the primary dwelling, whichever is lower, for an ADU that is attached to a primary
dwelling. These ADUs shall not exceed two stories in height.
(c) A single‐family dwelling shall exist on the lot or shall be constructed on the lot in
conjunction with the construction of an ADU/JADU.
(d) ADU and/or JADU square footage shall not be included in FAR, Lot Coverage, and
Maximum House Size calculations for a lot with an existing or proposed single family
home, up to the amounts stated in Table 2. ADU and/or JADU square footage in excess
of the exemptions provided in Table 2 shall be included in FAR, Lot Coverage, and
Maximum House Size calculations for the lot.
(e) Attached units shall have independent exterior access from a proposed or existing
single‐family dwelling. Except for JADUs, attached units shall not have an interior
access point to the primary dwelling (e.g. hotel door or other similar
feature/appurtenance).
(f) No protected tree shall be removed for the purpose of establishing an accessory
dwelling unit unless the tree is dead, dangerous or constitutes a nuisance under
Commented [SG8]: Response to HCD direction.
Commented [SG9]: SB 897 and AB 2221 Changes
*NOT YET APPROVED*
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Section 8.04.050. Any protected tree removed pursuant to this subsection shall be
replaced in accordance with the standards in the Tree Technical Manual.
(g) For properties listed in the Palo Alto Historic Inventory, the California Register of
Historical Resources, the National Register of Historic Places, or considered a historic
resource after completion of a historic resource evaluation, compliance with the
appropriate Secretary of Interior’s Standards for the Treatment of Historic Properties
shall be required.
(h) Noise‐producing equipment such as air conditioners, water heaters, and similar
service equipment. All such equipment shall be insulated and housed, except that the
planning directorDirector may permit installation without housing and insulation,
provided that a combination of technical noise specifications, location of equipment,
and/or other screening or buffering will assure compliance with the city’s Noise
Ordinance at the nearest property line. All service equipment must meet the city’s
Noise Ordinance in Chapter 9.10 of the Municipal Code.
(i) Setbacks
1. Detached units shall maintain a minimum three‐foot distance from the
primary unit, measured from the exterior walls of structures.
2. No basement or other subterranean portion of an ADU/JADU shall encroach
into a setback required for the primary dwelling.
3. Projections, including but not limited to windows, doors, mechanical
equipment, venting or exhaust systems, are not permitted to encroach into
the required setbacks, with the exception of a roof eave of up to 2 feet.
(j) Design
1. Except on corner lots, the unit shall not have an entranceway facing the same
lot line (property line) as the entranceway to the main dwelling unit unless the
entranceway to the accessory unit is located in the rear half of the lot. Exterior
staircases to second floor units shall be located toward the interior side or rear
yard of the property.
2. Privacy
A. Second story doors and decks shall not face a neighboring dwelling
unit. Second story decks and balconies shall utilize screening barriers
to prevent views into adjacent properties. These barriers shall provide
a minimum five‐foot, six‐inch, screen wall from the floor level of the
deck or balcony and shall not include perforations that would allow
visibility between properties.
B. Second story windows, excluding those required for egress, shall have
a five‐foot sill height as measured from the second‐floor level, or utilize
obscured glazing on the entirety of the window when facing adjacent
properties. Second story egress windows shall utilize obscured glazing
on the entirety of the windows which face adjacent properties.
*NOT YET APPROVED*
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C. Second story windows shall be offset from neighbor’s windows to
maximize privacy.
(k) Parking
1. Replacement parking is not required when a garage, carport, or covered
parking structure is converted to, or demolished in conjunction with the
construction of, an ADU.
2. Replacement parking is required when an existing attached garage is
converted to a JADU. These replacement spaces may be provided as
uncovered spaces in any configuration on the lot including within the front or
street side yard setback for the property.
A. The Director shall have the authority to modify required replacement
parking spaces by up to one foot in width and length upon finding that
the reduction is necessary to accommodate parking in a location
otherwise allowed under this code and is not detrimental to public
health, safety or the general welfare.
B. Existing front and street side yard driveways may be enlarged to the
minimum extent necessary to comply with the replacement parking
requirement above. Existing curb cuts shall not be altered except when
necessary to promote public health, safety or the general welfare.
3. When parking is provided, the unit shall have street access from a driveway in
common with the main residence in order to prevent new curb cuts, excessive
paving, and elimination of street trees, unless separate driveway access will
result in fewer environmental impacts such as paving, grading or tree removal.
4. If covered parking for a unit is provided in any district, the maximum size of the
covered parking area for the accessory dwelling unit is 220 square feet. This
space shall count towards the total floor area for the site but does not
contribute to the maximum size of the unit unless attached to the unit.
(l) Miscellaneous requirements
1. Street addresses shall be assigned to all units prior to building permit final to
assist in emergency response.
2. The unit shall not be sold separately from the primary residence.
3. Rental of any unit created pursuant to this section shall be for a term of 30
days or more.
4. The installation of fire sprinklers shall not be required in an accessory dwelling
unit if sprinklers are not required for the primary residence. Nothing in this
section shall preclude the Fire Marshal from accepting fire sprinklers as an
alternative means of compliance with generally applicable fire protection
requirements.
*NOT YET APPROVED*
9
0160097_20221128_ay_16
18.09.050 Additional Requirements for JADUs
(a) A junior accessory dwelling unit shall be created within the walls of an existing or
proposed primary dwelling.
(b) The junior accessory dwelling unit shall include an efficiency kitchen, requiring the
following components: A cooking facility with appliances, and; food preparation
counter and storage cabinets that are of reasonable size in relation to the size of the
junior accessory dwelling unit.
i. A cooking facility with appliances shall mean, at minimum a one burner
installed range, an oven or convection microwave, a 10 cubic foot refrigerator
and freezer combination unit, and a sink that facilitates hot and cold water.
ii. A food preparation counter and storage cabinets shall be of reasonable size in
relation to a JADU if they provide counter space equal to a minimum 24‐inch
depth and 36‐inch length.
(c) For the purposes of any fire or life protection ordinance or regulation or for the
purposes of providing service for water, sewer, or power, a junior accessory dwelling
unit shall not be considered a separate or new unit.
(d) The owner of a parcel proposed for a junior accessory dwelling unit shall occupy as a
primary residence either the primary dwelling or the junior accessory dwelling.
Owner‐occupancy is not required if the owner is a governmental agency, land trust,
or housing organization.
(e) Prior to the issuance of a building permit for a junior accessory dwelling unit, the
owner shall record a deed restriction in a form approved by the city that includes a
prohibition on the sale of the junior accessory dwelling unit separate from the sale of
the single‐family residence, requires owner‐occupancy consistent with subsection (d)
above, does not permit short‐term rentals, and restricts the size and attributes of the
junior dwelling unit to those that conform with this section.
SECTION 3. Section 18.10.030 (Land Uses) of Chapter 18.10 (Low‐Density Residential) of Title 18
(Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read (additions underlined,
deletions struck‐through, and omissions noted with bracketed ellipses):
18.10.030 Land Uses
Table 1 shows the permitted and conditionally permitted uses for the low‐density residential
districts.
*NOT YET APPROVED*
10
0160097_20221128_ay_16
TABLE 1
PERMITTED AND CONDITIONALLY PERMITTED LOW‐DENSITY RESIDENTIAL USES
[P = Permitted Use ‐‐ CUP = Conditional Use Permit Required]
R‐E R‐2 RMD Subject to
Regulations in:
ACCESSORY AND SUPPORT USES
[. . .] [. . .] [. . .] [. . .] [. . .]
Accessory Dwelling
Units
P P(2) P(2) 18.0942.040
Junior Accessory
Dwelling Units
P P(2) P(2) 18.0942.040
[. . .] [. . .] [. . .] [. . .] [. . .]
Footnotes:
(1) Sale of Agricultural Products: No permanent commercial structures for the sale or
processing of agricultural products are permitted.
(2) Junior Accessory Dwelling Units in R‐2 and RMD Zones: An accessory dwelling unit or a A
Junior Accessory Dwelling Unit is permitted only in conjunction with a single family residence,
subject to the provisions of Chapter 18.09.associated with a single‐family residence on a lot in
the R‐2 or RMD zones is permitted, subject to the provisions of Section 18.42.040, and such
that no more than two units result on the lot.
[. . .]
(4) Two Unit Development Pursuant to California Government Code Section 65852.21 (SB 9,
2021): Construction of two units is permitted on an RE‐zoned lot, subject to the regulations in
Section 18.42.180 .
SECTION 4. Section 18.12.030 (Land Uses) of Chapter 18.12 (Single‐Family Residential District)
of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read (additions
underlined, deletions struck‐through, and omissions noted with bracketed ellipses):
18.12.030 Land Uses
The permitted and conditionally permitted uses for the single family residential districts are
shown in Table 1:
Table 1
PERMITTED AND CONDITIONAL R‐1 RESIDENTIAL USES
R‐1 and all R‐1
Subdistricts
Subject to
Regulations for in:
ACCESSORY AND SUPPORT USES
[. . .] [. . .] [. . .]
*NOT YET APPROVED*
11
0160097_20221128_ay_16
Accessory Dwelling Units P(1) 18.0942.040
Junior Accessory Dwelling Units P(1) 18.0942.040
[. . .] [. . .] [. . .]
Footnotes:
(1) An Accessory Dwelling Unit or a Junior Accessory Dwelling Unit associated with a single‐
family residence on a lot is permitted, subject to the provisions of Chapter 18.09Section
18.42.040, and such that no more than two total units result on the lot.
SECTION 5. Section 18.13.030 (Land Uses) of Chapter 18.13 (Multiple‐Family Residential
Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code (“PAMC”) is amended to read
(additions underlined, deletions struck‐through, and omissions noted with bracketed ellipses):
18.13.030 Land Uses
Table 1 specifies the permitted and conditionally permitted land uses in the multiple‐family
residence districts.
Table 1
Multiple Family Residential Uses
[P = Permitted Use • CUP = Conditional Use Permit Required]
RM‐20 RM‐30 RM‐40 Subject to
Regulations in:
ACCESSORY AND SUPPORT USES
[. . .] [. . .] [. . .] [. . .] [. . .]
Accessory Dwelling Unit
when accessory to
permitted single‐family
residence
P(1) & (4) P(1) & (4) P(2) & (4) 18.0942.040
[. . .] [. . .] [. . .] [. . .] [. . .]
Footnotes:
(1) Permitted use only on lots less than 8,500 square feet in size.
[. . .]
(4) An accessory dwelling unit associated with a single‐family residence on a lot is permitted if
it is contained within the existing space of a single‐family residence or an existing accessory
structure in accordance with and pursuant to Section 18.42.040(a)(5), subject to the
provisions of Section 18.42.040 and such that no more than two total units result on the lot.
SECTION 6. Any provision of the Palo Alto Municipal Code or appendices thereto inconsistent
with the provisions of this Ordinance, to the extent of such inconsistencies and no further, is
hereby repealed or modified to that extent necessary to effect the provisions of this Ordinance.
Commented [YA10]: Response to HCD direction
*NOT YET APPROVED*
12
0160097_20221128_ay_16
SECTION 7. If any section, subsection, sentence, clause, or phrase of this Ordinance is for any
reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction,
such decision shall not affect the validity of the remaining portions of this Ordinance. The City
Council hereby declares that it would have passed this Ordinance and each and every section,
subsection, sentence, clause, or phrase not declared invalid or unconstitutional without regard
to whether any portion of the ordinance would be subsequently declared invalid or
unconstitutional.
SECTION 8. The Council finds that the adoption of this Ordinance is exempt from the provisions
of the California Environmental Quality Act (CEQA) pursuant to Public Resources Code Section
21080.17 and CEQA Guidelines sections 15061(b)(3), 15301, 15302 and 15305 because it
constitutes minor adjustments to the City’s zoning ordinance to implement State law
requirements related to accessory dwelling units as established in Government Code Section
65852.2, and these changes are also likely to result in few additional dwelling units dispersed
throughout the City. As such, it can be seen with certainty that the proposed action will not have
the potential for causing a significant effect on the environment.
SECTION 9. This ordinance shall be effective on the thirty‐first date after the date of its adoption.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
NOT PARTICIPATING:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Planning and
Development Services
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 (916) 263-2911 / FAX (916) 263-7453 www.hcd.ca.gov December 23, 2021
Jonathan Lait, Planning Director Planning Department City of Palo Alto
250 Hamilton Avenue – Fifth Floor Palo Alto, CA 94301
Dear Jonathan Lait:
RE: Review of Palo Alto’s Accessory Dwelling Unit (ADU) Ordinance under ADU Law (Gov. Code § 65852.2)
Thank you for submitting the City of Palo Alto (City) accessory dwelling unit (ADU) ordinance (Ordinance No.5507) adopted September 26, 2020, to the California
Department of Housing and Community Development (HCD). The ordinance was received on October 20, 2020. HCD has reviewed the ordinance and is submitting these written findings pursuant to Government Code section 65852.2, subdivision (h). HCD has determined that the ordinance does not comply with section 65852.2 in the manner noted below. Under the statute, the City has up to 30 days to respond to these findings.
Accordingly, the City must provide a written response to these findings no later than January 23, 2022. HCD will review and consider any written response received from the City before that date in advance of taking further action authorized by Government Code section 65852.2.
The adopted ADU ordinance meets many statutory requirements. However, the ordinance must be revised to comply with State ADU Law (Gov. Code, § 65852.2), as follows:
• Section 18.09.030(a)(3) Units Exempt from Generally Applicable Local
Regulations: The text of this Section and the applicable portion of Table 1 indicate the maximum size of a newly constructed detached ADU is 800 square feet. Although a local agency may establish minimum and maximum size requirements for ADUs pursuant to subdivision (c)(1) of Government Code
section 65852.2 within limits, a local agency shall not establish a maximum square footage requirement for either attached or detached ADUs that is less than 850 square feet and 1,000 square feet for an ADU that provides more than one bedroom. (Gov. Code, § 65852.2, subd. (c)(2)(B).) Therefore, all relevant
Jonathan Lait, Planning Director Page 2
sections of the ordinance must be amended to comply with this mandate in State
ADU Law.
• Section 18.09.030 Units Exempt from Generally Applicable Local Regulations: There appears to be a conflict between the text of this section and Table 1. The
number of allowable units are correctly noted in Table 1 as “1 ADU and 1
JADU.” The text of section 18.09.030(a) appears to limit allowable units to “an ADU or JADU.” Government Code section 65852.2, subdivision (e)(1)(A), requires an ordinance to allow “one ADU and one JADU per lot… .” The City must amend the ordinance to correct this inconsistency, clarifying that “one
ADU and one JADU” are permitted if all the conditions of section 65852.2,
subdivision (e)(1)(A) apply.
• Section 18.09.030(b) Application of Development Standards: Local agencies
may establish standards for ADUs pursuant to Government Code section
65852.2, subdivision (a); however, these standards do not apply to ADUs constructed pursuant to subdivision (e). Table 1 impermissibly applies “underlying zoning” “for front setback[s]” to subdivision (e) ADUs. (Mun. Code, §18.09.030(b).) Subdivision (e)(1) describes permitted setbacks in full. Unless
underlying zoning for all residential areas conforms to subdivision (e) limits, this
table must be amended to comply with statute. (Gov. Code, § 65852.2, subd. (e)(1)(A).)
• Section 18.09.030(b)(1) ADU Height in Flood Zones: The City has
impermissibly restricted the height of ADUs. It appears that the City establishes minimum elevations for the first floor of structures in the flood zone, which is essentially the entire city to varying degrees. To account for this, the zoning code allows most residential structures to exceed otherwise maximum
allowable heights for development. The City does not extend this
accommodation to ADUs. Currently, Table 1 states that the maximum height for new, detached ADUs is 16 feet, but includes a caveat that “units built in a flood zone are not entitled to any height extension.” (Mun. Code, § 18.09.030(b).) In many instances, this would operate as an impermissible restriction on ADUs.
Under State ADU Law, the City must accommodate an ADU of at least 800
square feet and 16 feet in height. Thus, the caveat in Table 1 is potentially confusing and could restrict the height to less than 16 feet. If it would in fact operate to effectively limit the height of ADUs to less than 16 feet, it would operate as an impermissible restriction on ADUs. As such, Table 1 should be
revised to clarify that this limitation does not apply where necessary to permit
an 800-square foot ADU that it at least 16 feet tall. (Gov. Code, § 65852.2, subds. (c)(2)(C) and (e)(1)(B)(ii).)
• Section 18.09.040(b) Daylight Plane and ADU Height Standards: Table 2 states
that “daylight plane” acts as a limit on the height of ADUs. In many instances,
Jonathan Lait, Planning Director Page 3
this may not be a problem; however, daylight plane concerns cannot be used to
unduly limit the height of an ADU. ADUs are permitted up to 16 feet high. (Gov.
Code, § 65852.2, subds. (c)(2)(C), (e)(1)(B)(ii).) Therefore, in considering restrictions that the City is imposing on ADUs for daylight planes, the ordinance should note the 16-foot height allowable for ADUs. This Table must be amended to clarify this point.
• Section 18.09.040(b) Units Subject to Local Standards: Table 2 sets out the development standards for ADUs that do not qualify under section 18.09.030. Although the City has more freedom to establish development standards for
these ADUs, that is not without limitation. This section, and Table 2, must be
amended to clarify that—notwithstanding the development standards—an ADU of at least 800 square feet, 16 feet in height, and with four-foot rear and side-yard setbacks is permitted as required by State ADU Law. (Gov. Code, § 65852.2, subd. (c)(2)(C).)
• Section 18.09.040(b) Floor Area and JADUs: Development standards can account for ADUs in their measurement of the floor area restrictions or ratio (FAR). But these standards may not account for or consider JADUs. A JADU
may not be included in this calculation, because a JADU is a unit that is
contained entirely within a single-family residence. (Gov. Code § 65852.22, subd. (h)(1).) Footnote 4 of Table 2 impermissibly includes JADUs as part of the FAR calculations. This footnote must be amended to clarify this point.
• Section 18.09.040(h) Noise-Producing Equipment: Local agencies may impose development standards on ADUs; however, these standards shall not exceed state standards. Section 18.09.040(h) states that noise-producing equipment “shall be located outside of the setbacks.” This section must be revised to only
refer to ADUs since setbacks are not required for JADUs. In addition, this
setback for noise-producing equipment for ADUs must be revised to make clear that this setback requirement will not impede the minimum state standards of four-foot setbacks. (Gov. Code, § 65852.2, subd. (c)(2)(C).)
• Section 18.09.040(i)(2) Setbacks: Currently, this section states, “No basement or other subterranean portion of an ADU/JADU shall encroach into a setback required for the primary dwelling.” Under state law, new attached and detached ADUs have maximum four-foot rear and side-yard setbacks. (Gov. Code, § 65852.2, subds.
(a)(1)(D)(vii), (c)(2)(C), (e)(1)(B), and (e)(1)(D).) Local agencies may impose
setback requirements if the minimum rear and side-yard setbacks established by state law are not exceeded. This restriction is concerning on a number of grounds. First, setbacks may not be required for JADUs as they are constructed within the walls of the primary dwelling. Second, this requirement imposes excessive
restrictions on ADUs converted from an existing area of the primary dwelling or
accessory structure with a basement or subterranean space. Again, these
Jonathan Lait, Planning Director Page 4
structures are not subject to setback requirements. Finally, this section would
violate State ADU Law if the side or rear setback requirement for an ADU or JADU
located in a basement or other subterranean structure exceeded four feet. Requiring ADUs and JADUs to meet the side and rear setbacks for the primary dwellings could exceed the maximum four-foot setbacks set out in State ADU Law. The ordinance must be revised to eliminate these concerns.
• Section 18.09.040(j) Design: This section states, “Except on corner lots, the unit shall not have an entranceway facing the same lot line (property line) as the entranceway to the main dwelling unit unless the entranceway to the
accessory unit is located in the rear half of the lot. Exterior staircases to second
floor units shall be located towards the interior side or rear yard of the property.” These standards appear to apply only to the creation of ADUs and may unduly restrict the placement of an ADU on some lots. Local development standards provided by ordinance pursuant to subdivisions (a) through (d) of Government
Code section 65852.2 do not apply to ADUs created under subdivision (e).
Please consider eliminating this restriction or modifying it such that it applies “when feasible.”
• Section 18.09.040(j)(2)(A) Privacy: The section states, “Second story doors and
decks shall not face a neighboring dwelling unit.” This limitation, however, may place an impermissible constraint on an ADU. For example, excessive constraints would be placed on the creation of a second story ADU if residential units were located on all adjacent parcels. In addition, when operating in
conjunction with Section 18.09.040(j), noted above, this restriction may prohibit
ADUs created under subdivision (e) of Government Code section 65852.2. Accordingly, this provision must be revised to allow for more flexibility. The City could revise the first sentence of this section to state, “Second story doors and decks shall not face a neighboring dwelling unit, where feasible.”
• Section 18.09.040(k)(4) Parking: The ordinance indicates if covered parking for a unit is provided in any district, the maximum size of the covered parking area for the accessory dwelling unit is 220 square feet. Further, under this section, the space for the covered parking count towards the total floor area for the site and
the ADU if attached to the unit. Covered parking should not count towards the total floor area of the site as if it would unduly limit the allowable size of an ADU established by state law, nor should it directly count toward the area available for the ADU. Although standards within an underlying zone may apply when noted in the adopted ADU ordinance, they may not be more restrictive than those
contained in state statute. (See, e.g., Gov. Code, § 65852.2, subs. (a)(1)(B), (a)(1)(D)(vii), (a)(1)(D)(x), (c), and (e).) The portion of this section stating “unit unless attached to the unit” should be deleted, or the section should otherwise be modified to comply with state law.
Jonathan Lait, Planning Director Page 5
In these respects, revisions are necessary to comply with statute.
HCD will consider any written response to these findings, such as a revised ordinance or a detailed plan to bring the ordinance into compliance with law by a date certain, before taking further action authorized pursuant to Government Code section 65852.2. Please note that HCD may notify the Attorney General’s Office in the event that the City
fails to take appropriate and timely action under section 65852.2, subdivision (h).
HCD appreciates the City’s efforts in the preparation and adoption of the ordinance and welcomes the opportunity to assist the City in fully complying with State ADU Law. Please contact Lauren Lajoie of our staff, at (916) 776-7495 or at
Lauren.Lajoie@hcd.ca.gov if you have any questions or would like HCD’s technical
assistance in these matters. Sincerely,
David Zisser
Assistant Deputy Director
Local Government Relations and Accountability
PLANNING & DEVELOPMENT SERVICES
250 Hamilton Avenue, 5th Floor
Palo Alto, CA 94301
(650) 329-2441
February 3, 2022
Lauren Lajoie
Housing & Community Development
Division of Housing Policy Development
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
Lauren.Lajoie@hcd.ca.gov
Dear Ms. Lajoie,
This letter represents the City of Palo Alto’s response to your letter dated December 23, 2021 received by
email, and received by hard copy on January 27, 2022. The content of the Housing and Community
Development’s letter is italicized. The City of Palo Alto’s responses are bolded.
1. ADU Size - Section 18.09.030(a)(3) Units Exempt from Generally Applicable Local Regulations: The
text of this Section and the applicable portion of Table 1 indicate the maximum size of a newly
constructed detached ADU is 800 square feet. Although a local agency may establish minimum and
maximum size requirements for ADUs pursuant to subdivision (c)(1) of Government Code section
65852.2 within limits, a local agency shall not establish a maximum square footage requirement for
either attached or detached ADUs that is less than 850 square feet and 1,000 square feet for an ADU
that provides more than one bedroom. (Gov. Code, § 65852.2, subd. (c)(2)(B).) Therefore, all relevant
sections of the ordinance must be amended to comply with this mandate in State ADU Law.
PAMC Section 18.09.030 is intended to describe the requirements for ADUs built under Gov. Code
65852.2, subdivision (e). This is not intended to create any limitation on ADUs built under
subdivisions (a)-(d), which are governed by PAMC Section 18.09.040. The City will add clarifying
language to this effect at the top of PAMC Section 18.09.030.
2. ADU & JADU - Section 18.09.030 Units Exempt from Generally Applicable Local Regulations: There
appears to be a conflict between the text of this section and Table 1. The number of allowable units
are correctly noted in Table 1 as “1 ADU and 1 JADU.” The text of section 18.09.030(a) appears to
limit allowable units to “an ADU or JADU.” Government Code section 65852.2, subdivision (e)(1)(A),
requires an ordinance to allow “one ADU and one JADU per lot… .” The City must amend the ordinance
to correct this inconsistency, clarifying that “one ADU and one JADU” are permitted if all the
conditions of section 65852.2, subdivision (e)(1)(A) apply.
The City will update its ordinance to reflect the changes made by AB 3182 with respect to 1 ADU
and 1 JADU.
3. Front Setback - Section 18.09.030(b) Application of Development Standards: Local agencies may
establish standards for ADUs pursuant to Government Code section 65852.2, subdivision (a);
however, these standards do not apply to ADUs constructed pursuant to subdivision (e). Table 1
impermissibly applies “underlying zoning” “for front setback[s]” to subdivision (e) ADUs. (Mun. Code,
§18.09.030(b).) Subdivision (e)(1) describes permitted setbacks in full. Unless underlying zoning for
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
all residential areas conforms to subdivision (e) limits, this table must be amended to comply with
statute. (Gov. Code, § 65852.2, subd. (e)(1)(A).)
During our conversation on February 2, 2022, you explained that local rules may apply for front
setbacks, including ADUs built under subdivision (e), and that it is not HCD’s position that
subdivision (e) ADUs must be allowed at the front lot line. You explained that the issue with the
current City ordinance is that it does not make clear that “underlying zoning” is only for front
setbacks. The City will clarify this point in its ordinance.
4. Height - Section 18.09.030(b)(1) ADU Height in Flood Zones: The City has impermissibly restricted the
height of ADUs. It appears that the City establishes minimum elevations for the first floor of structures
in the flood zone, which is essentially the entire city to varying degrees. To account for this, the zoning
code allows most residential structures to exceed otherwise maximum allowable heights for
development. The City does not extend this accommodation to ADUs. Currently, Table 1 states that
the maximum height for new, detached ADUs is 16 feet, but includes a caveat that “units built in a
flood zone are not entitled to any height extension.” (Mun. Code, § 18.09.030(b).) In many instances,
this would operate as an impermissible restriction on ADUs. Under State ADU Law, the City must
accommodate an ADU of at least 800 square feet and 16 feet in height. Thus, the caveat in Table 1 is
potentially confusing and could restrict the height to less than 16 feet. If it would in fact operate to
effectively limit the height of ADUs to less than 16 feet, it would operate as an impermissible
restriction on ADUs. As such, Table 1 should be revised to clarify that this limitation does not apply
where necessary to permit an 800-square foot ADU that it at least 16 feet tall. (Gov. Code, § 65852.2,
subds. (c)(2)(C) and (e)(1)(B)(ii).)
For purposes of health and safety, the City of Palo Alto requires structures built in a flood zone to
have a minimum finished floor height based on FEMA regulations. For a primary residence, the City
provides an extra height allowance of 50% the minimum finished floor height. The City does not
provide this allowance for any accessory structures, including ADUs. Nevertheless, ADUs in the
flood zone can still be built to a height of 16 feet. It is unclear to the City how the failure to provide
additional height above 16 feet represents an impermissible restriction on ADUs. During our
conversation, you related that HCD prefers to have as few restrictions as possible on ADU
production. The only restriction here is on finished floor height in the flood zone, which cannot be
waived or relaxed without impacts on health and safety. Even in areas requiring the most extreme
height above the base flood elevation, an ADU remains feasible within the 16 foot height limit.
5. Daylight Plane - Section 18.09.040(b) Daylight Plane and ADU Height Standards: Table 2 states that
“daylight plane” acts as a limit on the height of ADUs. In many instances, this may not be a problem;
however, daylight plane concerns cannot be used to unduly limit the height of an ADU. ADUs are
permitted up to 16 feet high. (Gov. Code, § 65852.2, subds. (c)(2)(C), (e)(1)(B)(ii).) Therefore, in
considering restrictions that the City is imposing on ADUs for daylight planes, the ordinance should
note the 16-foot height allowable for ADUs. This Table must be amended to clarify this point.
Please note that the City’s daylight plane regulations do not apply to subdivision (e) ADUs, which
are governed by PAMC Section 18.09.030. The City will add a clarifying sentence at the top of
Section 18.09.040 explaining that none of the regulations in PAMC 18.09.040 apply to subdivision
(e) ADUs. In addition, the City will add a clarifying statement that the regulations in PAMC
18.09.040 are not intended to limit the conversion of existing structures to ADUs or JADUs.
For all other ADUs, however, the City has requested clarity on HCD’s position on daylight plane on
numerous occasions, most recently by email dated August 8, 2021. Please see this email, which is
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CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
attached, for an explanation of the City’s position. The City looks forward to continued discussion
of this topic.
6. Clarify - Section 18.09.040(b) Units Subject to Local Standards: Table 2 sets out the development
standards for ADUs that do not qualify under section 18.09.030. Although the City has more freedom
to establish development standards for these ADUs, that is not without limitation. This section, and
Table 2, must be amended to clarify that—notwithstanding the development standards—an ADU of
at least 800 square feet, 16 feet in height, and with four-foot rear and side- yard setbacks is permitted
as required by State ADU Law. (Gov. Code, § 65852.2, subd. (c)(2)(C).)
The City will add a clarifying statement to this effect.
7. Floor Area & JADUs - Section 18.09.040(b) Floor Area and JADUs: Development standards can account
for ADUs in their measurement of the floor area restrictions or ratio (FAR). But these standards may
not account for or consider JADUs. A JADU may not be included in this calculation, because a JADU is
a unit that is contained entirely within a single-family residence. (Gov. Code § 65852.22, subd. (h)(1).)
Footnote 4 of Table 2 impermissibly includes JADUs as part of the FAR calculations. This footnote
must be amended to clarify this point.
Footnote 4 of Table 2 provides additional FAR on a site for ADUs and JADUs. This is an incentive to
promote production of such units without limiting the development potential of a primary unit.
Because a JADU is contained entirely within the space of a single-family residence, it would
normally be included in the floor area of the primary unit. Footnote 4 provides an opportunity for
a property owner to exempt all JADU square footage from the calculation of floor area for the
primary unit. The removal of JADUs from footnote 4 would only serve to restrict the development
of JADUs. The City will attempt to clarify the language of this footnote.
8. Noise-Producing Equipment - Section 18.09.040(h) Noise-Producing Equipment: Local agencies may
impose development standards on ADUs; however, these standards shall not exceed state standards.
Section 18.09.040(h) states that noise-producing equipment “shall be located outside of the
setbacks.” This section must be revised to only refer to ADUs since setbacks are not required for
JADUs. In addition, this setback for noise-producing equipment for ADUs must be revised to make
clear that this setback requirement will not impede the minimum state standards of four-foot
setbacks. (Gov. Code, § 65852.2, subd. (c)(2)(C)).
As noted above, the City will add a clarifying statement that the regulations in PAMC 18.09.040 are
not intended to limit the conversion of existing structures to ADUs or JADUs. For new construction,
however, the City permits JADUs to build at a lesser setback than a single-family home normally
would. Therefore, the removal of JADUs from this section will only serve to restrict the
development of JADUs.
Additionally, the City’s ordinance states that noise producing equipment needs to be placed
outside the setback for an ADU or JADU. This means that the noise producing equipment itself
cannot be placed closer than four-feet to a property line for either type of structure; not that the
ADU or JADU cannot be placed at those locations. This is consistent with the state setback
requirements for an ADU.
9. Basements - Section 18.09.040(i)(2) Setbacks: Currently, this section states, “No basement or other
subterranean portion of an ADU/JADU shall encroach into a setback required for the primary
dwelling.” Under state law, new attached and detached ADUs have maximum four-foot rear and side-
yard setbacks. (Gov. Code, § 65852.2, subds. (a)(1)(D)(vii), (c)(2)(C), (e)(1)(B), and (e)(1)(D).) Local
DocuSign Envelope ID: 26247F48-AB81-46DC-AE75-91A87A8EE538
CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
agencies may impose setback requirements if the minimum rear and side-yard setbacks established
by state law are not exceeded. This restriction is concerning on a number of grounds. First, setbacks
may not be required for JADUs as they are constructed within the walls of the primary dwelling.
Second, this requirement imposes excessive restrictions on ADUs converted from an existing area of
the primary dwelling or accessory structure with a basement or subterranean space. Again, these
structures are not subject to setback requirements. Finally, this section would violate State ADU Law
if the side or rear setback requirement for an ADU or JADU located in a basement or other
subterranean structure exceeded four feet. Requiring ADUs and JADUs to meet the side and rear
setbacks for the primary dwellings could exceed the maximum four-foot setbacks set out in State ADU
Law. The ordinance must be revised to eliminate these concerns.
As noted above, the City will add a clarifying statement that the regulations in PAMC 18.09.040 are
not intended to limit the conversion of existing structures to ADUs or JADUs. In addition, as with
the previous section, the inclusion of JADUs here only serves to increase flexibility of JADU
production.
As noted above, the City will add a clarifying statement an ADU of at least 800 square feet, 16 feet
in height, and with four-foot rear and side- yard setbacks is permitted as required by State ADU
Law.
With these clarifications the City does not believe it would violate State ADU Law to require that a
newly constructed ADU limit any below-grade space to a setback greater than 4 feet. It is the City’s
understanding that it could simply state that basements are not permitted for ADUs built under
subdivisions (a)-(d), so long as it was still feasible to construct an ADU of at least 800 square feet. If
this is the case, the City should have the lesser authority to direct the placement of below-grade
development.
The City has significant concerns about basements in general, and those concerns extend to
basements constructed as part of ADUs. Due to a high water table throughout most of Palo Alto,
the construction of basements requires dewatering (pumping water from the construction site).
While this is allowed, there are significant restrictions on timing and procedures taken during the
dewatering process.
Secondly, development of homes in Palo Alto often includes requirements for the planting and
maintenance of trees used to enhance privacy between properties. Placing ADUs with basements
as close as 4 feet from the property line may jeopardize the health of these trees on the subject
property as well as trees on adjacent properties. The trees could fail, which would both diminish
the tree canopy—important for our environment and adaptation to climate change—and diminish
the privacy between properties.
Building below ground is not required in order to achieve a unit which follows the requirements in
Section 65852.2 and can lead to potential impacts on adjacent lots, such as to large stature trees on
adjacent lots which is a common occurrence in Palo Alto. Building a basement in these scenarios
may cause the tree to fail which is a life, safety, and health hazard which would unduly affect both
homeowners as a result of the action by one individual. There are construction methods which can
be implemented for above ground construction to help limit root damage caused by this
construction to preserve trees but that is not possible for below ground construction and can lead
to significant impacts as noted above.
DocuSign Envelope ID: 26247F48-AB81-46DC-AE75-91A87A8EE538
CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
10. Corner Lots - Section 18.09.040(j) Design: This section states, “Except on corner lots, the unit shall not
have an entranceway facing the same lot line (property line) as the entranceway to the main dwelling
unit unless the entranceway to the accessory unit is located in the rear half of the lot. Exterior
staircases to second floor units shall be located towards the interior side or rear yard of the property.”
These standards appear to apply only to the creation of ADUs and may unduly restrict the placement
of an ADU on some lots. Local development standards provided by ordinance pursuant to subdivisions
(a) through (d) of Government Code section 65852.2 do not apply to ADUs created under subdivision
(e). Please consider eliminating this restriction or modifying it such that it applies “when feasible.”
As noted above, the City will add a clarifying sentence at the top of Section 18.09.040 explaining
that none of the regulations in PAMC 18.09.040 apply to subdivision (e) ADUs. The City will clarify
this is not applicable for subsection (e) ADUs. We are not aware of any evidence that this simple
design requirement creates an excessive constraint on ADU production and that has not been our
experience.
11. Privacy - Section 18.09.040(j)(2)(A) Privacy: The section states, “Second story doors and decks shall not
face a neighboring dwelling unit.” This limitation, however, may place an impermissible constraint on
an ADU. For example, excessive constraints would be placed on the creation of a second story ADU if
residential units were located on all adjacent parcels. In addition, when operating in conjunction with
Section 18.09.040(j), noted above, this restriction may prohibit ADUs created under subdivision (e) of
Government Code section 65852.2. Accordingly, this provision must be revised to allow for more
flexibility. The City could revise the first sentence of this section to state, “Second story doors and decks
shall not face a neighboring dwelling unit, where feasible.”
As noted above, the City will add a clarifying sentence at the top of Section 18.09.040 explaining
that none of the regulations in PAMC 18.09.040 apply to subdivision (e) ADUs. We are not aware of
any evidence that this simple design requirement creates an excessive constraint on ADU
production and that has not been our experience.
The City will clarify this is not applicable for subsection (e) ADUs. We are not aware of any evidence
that this creates an excessive constraint and that has not been our experience.
12. Parking - Section 18.09.040(k)(4) Parking: The ordinance indicates if covered parking for a unit is
provided in any district, the maximum size of the covered parking area for the accessory dwelling unit
is 220 square feet. Further, under this section, the space for the covered parking count towards the
total floor area for the site and the ADU if attached to the unit. Covered parking should not count
towards the total floor area of the site as if it would unduly limit the allowable size of an ADU
established by state law, nor should it directly count toward the area available for the ADU. Although
standards within an underlying zone may apply when noted in the adopted ADU ordinance, they may
not be more restrictive than those contained in state statute. (See, e.g., Gov. Code, § 65852.2, subs.
(a)(1)(B), (a)(1)(D)(vii), (a)(1)(D)(x), (c), and (e).) The portion of this section stating “unit unless
attached to the unit” should be deleted, or the section should otherwise be modified to comply with
state law.
As noted above, the City will add a clarifying sentence at the top of Section 18.09.040 explaining
that none of the regulations in PAMC 18.09.040 apply to subdivision (e) ADUs.
Currently, all covered parking in the single-family zones counts towards floor area for the site and
dwelling unit. The City does not understand how this creates a standard that is more restrictive than
that contained in state statute; none of the subsections cited in your letter speak to whether a
garage for an ADU must be exempted from the unit size for the ADU. Moreover, this provision does
DocuSign Envelope ID: 26247F48-AB81-46DC-AE75-91A87A8EE538
CITY OF PALO ALTO | 250 HAMILTON AVENUE, PALO ALTO, CA. 94301 | 650-329-2441
not create a constraint on ADU production, as a property owner may always choose to provide a
detached garage, uncovered parking, or no parking at all for the ADU.
The City has concerns that allowing attached garages onto these structures will incentivize
individuals to illegally expand the unit into the garage, which would both exceed the City’s
ordinance, contain unpermitted construction, and potentially place the health and safety of the
occupants at risk.
Sincerely,
Jonathan Lait
Director of Planning and Development Services
DocuSign Envelope ID: 26247F48-AB81-46DC-AE75-91A87A8EE538
Certificate Of Completion
Envelope Id: 26247F48AB8146DCAE7591A87A8EE538 Status: Completed
Subject: Please DocuSign: 2022-02-02 Draft HCD ADU Letter response.docx
Source Envelope:
Document Pages: 6 Signatures: 1 Envelope Originator:
Certificate Pages: 2 Initials: 0 Madina Klicheva
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EnvelopeId Stamping: Enabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
250 Hamilton Ave
Palo Alto , CA 94301
Madina.Klicheva@CityofPaloAlto.org
IP Address: 199.33.32.254
Record Tracking
Status: Original
2/3/2022 4:39:53 PM
Holder: Madina Klicheva
Madina.Klicheva@CityofPaloAlto.org
Location: DocuSign
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Jonathan Lait
Jonathan.Lait@CityofPaloAlto.org
Interim Director Planning and Community
Environment
City of Palo Alto
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Garrett Sauls
Garrett.Sauls@CityofPaloAlto.org
Associate Planner
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Rachael Tanner
Rachael.Tanner@CityofPaloAlto.org
Assistant Director of Planning and Development
Services
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Middlefield RoadEl Camino Real
Page Mill Road
Sand Hill Road
Oregon Expressway
Foothill Expressway
Hill
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E m barcadero Road
Quarry Road
Page Mill Road
Foothill Expressway
Cowper Street
Waverley Street
Louis Road
Ross Road
Webster Street
Bryant Street
Channing Avenue
East Bayshore Road
Lincoln Avenue
Newell Road
Seale Avenue
South Court
High Street
Park Boulevard
East Meadow Drive
Stanford Avenue
Colorado Avenue
West Bayshore Road
Hanover Street
Miranda A
venue
Fabian Way
Hamilton Avenue
Homer Avenue
Greer Road
Ramona Street
Edgewood Drive
Loma Verde Avenue
Churchill Avenue
Matadero Avenue
Lowell Avenue
Center Drive
Los Robles Avenue
California Avenue
Barron Avenue
Welch Road
Kingsley Avenue
Maybell Avenue
Wilkie Way
Hansen Way
Coleridge Avenue
Byron Street
Ely Place
Manuela Avenue
Oregon Avenue
Amarillo Avenue
Marion Avenue
North California Avenue
Emerson Street
Embarcadero Road
Pitman Avenue
Laguna Avenue
Ferne Avenue
Nelson Drive
Porter Drive
Castilleja Avenue
Quarry Road
Chimalus Drive
Hale Street
College Avenue
Amherst Street
Seneca Street
Lane 66
Bowdoin Street
Alexis Drive
Harker Avenue
Deer Creek Road
Ames Avenue
El Dorado Avenue
La Para Avenue
Clark Way
Birch Street
Coyote Hill Road
Clara Drive
Columbia Street
Georgia Avenue
Rhodes Drive
Cambridge Avenue
El Verano Avenue
La Donna Street
Parkinson Avenue
Kipling Street
Pasteur Drive
Heather Lane
Alger Drive
Florales Drive
Oxford Avenue
Forest Avenue
Greenwood Avenue
Cornell Street
Amaranta Avenue
Hillview Avenue
Nathan Way
Donald Drive
Harvard Street
Iris Way
Hopkins Avenue
Dana Avenue
Fife Avenue
Fulton Street
Sutherland Drive
Lambert Avenue
Vineyard Lane
Josina Avenue
Marshall Drive
(none)
David Avenue
Old Adobe Road
Ge
ng Roa
d
Orme Street
El Carmelo Avenue
Walnut Drive
Princeton Street
Maddux Drive
Wildwood Lane
Morris DriveMariposa Avenue
Stanley Way
Fernando Avenue
Moreno Avenue
Barbara Drive
Arbutus Avenue
Chaucer Street
Shopping Center Way
Walter Hays Drive
Jackson Drive
Kenneth Drive
Martin Avenue Patricia Lane
Cereza Drive
Guinda Street
Transport Street
Old Trace Road
Ilima Way
Santa Ana Street
Encina Grande Drive
Los Palos Avenue
Lois Lane
Gailen Avenue
Whitsell Street
Janice Way
Southampton Drive
Pomona Avenue
San Antonio Road
Evergreen Drive
Ivy Lane
Rorke Way
Stelling Drive
Ashton Avenue
Military Way
Robb Road
Jefferson Drive
Santa Rita Avenue
Saint Claire Drive
Rinconada Avenue
Seminole Way
Manuela Court
Garland Drive
Kings Lane
Oak Hill Avenue
Nevada Avenue
Madison Way
Southwood Drive
Richardson Court
Lupine Avenue
Campesino Avenue
La Calle
Suzanne Drive
Vernon Terrace
Celia Drive
Washington Avenue
Dennis Drive
Rambow Drive
Portage Avenue
Elwell Court
Stern Avenue
Maclane
Fallen Leaf Street
Wells A ven ue
Tulip Lane
Ross Court
Acacia Avenue
Tasso Street
Stone Lane
Lane D East
Mark Twain Street
Maple Street
El Cerrito Road
Foothill Expressway
La ura L ane
Lane D West
Primrose Way
May Court
Baker Avenue
Melville Avenue
Corina Way
Palm Street
Wellesley Street
Wright Place
Pistache Place
Peral Lane
Bret Harte Street
Carmel Drive
Arcadia Place
Varian Way
Saint Francis Drive
Cardinal Way
Timlott Lane
Marlowe Street
Shauna Lane
Corporation Way
Plum Lane
Randers Court
(none)
Dana Avenue
Oregon Avenue
Fulton Street
Ramona Street
Kipling Street
North California Avenue
Bryant Street
Park Boulevard
Colorado Avenue
Tasso Street
Ramona Street
South Court
Guinda Street
Byron Street
Los Altos
Stanford University
Los Altos Hills
Menlo Park
Mountain View
East Palo Alto
Atherton
This map is a product of City of Palo Alto GIS
[
0 0.4 0.80.2 Miles
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