HomeMy WebLinkAboutStaff Report 2304-1372CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, May 08, 2023
Council Chambers & Hybrid
5:00 PM
Agenda Item
7.Adoption of a Resolution Adopting the 2023-31 Housing Element and Consideration of
the Associated California Environmental Quality Act (CEQA) Addendum to the
Comprehensive Plan 2017 Final Environmental Impact Report
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City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: May 8, 2023
Report #:2304-1372
TITLE
Adoption of a Resolution Adopting the 2023-31 Housing Element and Consideration of the
Associated California Environmental Quality Act (CEQA) Addendum to the Comprehensive Plan
2017 Final Environmental Impact Report
RECOMMENDATION
Staff recommends the following actions:
Planning and Transportation Commission:
1. Consider the Addendum (Attachment B) to the 2017 Comprehensive Plan Final
Environmental Impact Report along with the 2017 Comprehensive Plan Final EIR;
2. Review the staff responses to the HCD Comment Letter, as incorporated in the Draft 2023-
31 Housing Element (Attachment A) and recommend City Council adopt the Draft 2023-
31 Housing Element.
City Council:
1. Consider and approve the Addendum the 2017 Comprehensive Plan Final Environmental
Impact Report along with the 2017 Comprehensive Plan Final EIR;
2. Direct staff to make appropriate changes to the Draft 2023-31 Housing Element
(Attachment A), including additional revisions recommended by staff in the staff report.
3. Adopt a Resolution (Attachment C) making the findings required under CEQA and Housing
Element Law, and adopting the 2023-31 Housing Element, as revised, as an amendment
to the City’s Comprehensive Plan.
EXECUTIVE SUMMARY
On December 23, 2022, the City submitted its Draft 2023-31 Housing Element for its initial 90-
day review by the State Department of Housing and Community Development (HCD). On March
23, 2023, at the end of the 90-day review period, the City received a 14-page comment letter
from HCD. The letter requested greater research and analysis for a number of areas, but most
comments focused on:
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•More explicit revisions to development standards and permit processing (Housing
Constraints),
•More Fair Housing Analysis including housing needs for Special needs Groups (Housing
Need and Assessment of Fair Housing), and
•More Housing program implementation earlier in the planning period and commitments
to specific actions and objectives (Housing Plan).
In response to HCD comments, staff revised the text of the Housing Element document where
appropriate (see redline edits in Attachment A). A City Response Matrix that reflects HCD
comments and proposed staff responses, with page numbers for easy reference, will be provided
to the Council next week as Attachment F. The HCD comment letter is also provided as
Attachment D.
During the 90-day HCD review period, on March 8, 2023, the Planning and Transportation
Commission (PTC) reviewed the Draft Housing Element submitted to HCD and unanimously
recommended adoption of the draft 2023-31 Housing Element, contingent on the refinements
needed to address HCD comments.
Staff is requesting that: First, the PTC consider the EIR Addendum, review the staff responses to
HCD comments, and recommend the City Council adopt the draft 2023-31 Housing Element with
the proposed responses. Second, the Council consider the EIR Addendum, and adopt a resolution
making all findings required by CEQA and state Housing Element Law and adopting the 2023-31
Housing Element, with any additional revisions it deems necessary.
BACKGROUND
The Housing Element is the City’s plan to provide housing for its current and future residents. It
is the only element of the City’s Comprehensive Plan that requires certification by the State. The
Housing Element covers a period of eight years; the 5th Cycle of Housing Elements that covered
2015 through January 31, 2023 ended recently. The 6th Cycle covers the eight years between
2023 and 2031. The deadline to adopt a compliant Housing Element for the 6th Cycle Housing
Element was January 31, 2023. For reference, a copy of the 5th Cycle Housing Element is available
online.1
As part of the Housing Element, the City needs to plan for its “fair share” of housing for the 6th
Cycle planning period. The City must plan for its Regional Housing Needs Allocation (RHNA) of
6,086 units. In addition, programs must be included in the Housing Element that support
increased housing production in the City. Over the last two years, the City has evaluated and
updated its draft Housing Element for the 2023-31 planning period. A history of City events and
actions over the past two years is available online at www.paloaltohousingelement.com.
1 5th Cycle Housing Element: https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-
services/3.-comprehensive-plan/comprehensive-plan/certified-15-23-housing-element.pdf
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Regional Housing Need Allocation
Per state law requirements, the draft Housing Element contains information about the City’s
housing needs, constraints to building housing, available housing sites, an explanation of City
resources for supporting housing development, as well as goals, policies and programs that will
help address the city’s share of regional housing needs as identified by the Association of Bay
Area Governments (ABAG). The City’s housing needs are quantified in the RHNA, which includes
housing targets at all income levels. As shown in Table 1, the minimum RHNA requirement for
Palo Alto in the 2023-31 planning period is 6,086 homes across four income levels.
Table 1: City of Palo Alto 2023-31 RHNA Requirement
City of Palo Alto 2023-31 RHNA
Income Level Very Low
Income
Low Income Moderate
Income
Above Moderate
Income
Total
Area Median
Income (AMI)
<50% AMI 50-80% of
AMI
80-120% AMI >120% AMI
Units 1,556 896 1,013 2,621 6,086
Housing Element Document Requirements
The Palo Alto 2023-31 Housing Element identifies and analyzes existing and projected housing
needs and establishes goals, policies, quantified objectives, and scheduled programs for the
preservation, improvement, and development of housing across income levels. It identifies areas
in the City where new housing may be built and estimates how many housing units could be built
on specific sites. Furthermore, it helps the City plan for future housing needs of all residents at
all income levels, including emergency shelters, special housing for the elderly, persons with
disabilities, large families, and unhoused residents.
The Housing Element contains several mandated sections including: Executive Summary;
Introduction; Housing Needs; Housing Resources; Housing Constraints; and Housing Plan
(includes Housing Element programs). Additionally, Appendix C in the draft Housing Element
contains the City’s analysis of Affirmatively Furthering Fair Housing (AFFH). AFFH is a new State
requirement that mandates each jurisdiction take meaningful actions to further fair housing to
overcome patterns of segregation and foster inclusive communities free from barriers that
restrict access to opportunity based on protected characteristics. The Housing Element, including
the sites inventory and programs, must be reviewed through the filter of AFFH requirements.
Draft Housing Element Submittal to HCD
The City submitted its Draft 2023-31 Housing Element for its initial 90-day review by HCD in
December 2022. This submittal included all the required components as well as the public
comments received; the City received 14 comments from individuals and organizations. Due to
the timing of the Council review and HCD submittal, Council did not have the opportunity to
specifically review the comments collectively. A summary of the public comments, which were
grouped into the 10 common themes, is included as Attachment E.
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Planning and Transportation Commission Review
At its March 8, 2023 meeting, the PTC reviewed and considered a recommendation to the City
Council to adopt the City’s 2023-31 Housing Element2. Staff reviewed the November 28, 2022
Council directed changes3 included in the draft Housing Element submitted to HCD, the CEQA
Addendum, and next steps in the update process. The PTC reviewed the draft Addendum to the
2017 Comprehensive Plan Environmental Impact Report and did not have any requested
changes. The PTC had clarifying questions regarding the City’s process in meeting its RHNA, the
adoption process and its relation to HCD certification of the Addendum. The PTC recommended
that the Council adopt the draft Housing Element subject to refinement following receipt of the
comments from HCD.
Council Adoption of the Housing Element
Following the PTC’s recommendation action, the City Council can take the action to adopt the
Draft Housing Element and then submit it to HCD, providing all the required findings outlined in
the attached Resolution can be made. This action would mean that City has considered the HCD
comments and appropriately responded to those comments and finds the Draft Housing Element
to substantially comply with Housing Element Law.
ANALYSIS
On March 23, 2022, the City received HCD’s comment letter (Attachment D) on the City’s Draft
Housing Element. In general, HCD’s comments requested that the City provide additional analysis
in a number of areas ranging from reviewing the City’s development standards to the City’s Code
Enforcement practices within the Housing Element. HCD determined that the City’s Initial Draft
Housing Element addresses many statutory requirements, but revisions are necessary to comply
with State Housing Element law. HCD’s comment letter categorized the comments into the
following four topics:
A. Review previous housing element to evaluate cumulative effectiveness of special
needs housing goals and programs;
B. Housing needs, resources, and constraints (area with the majority of comments);
C. Housing programs; and
D. Quantified objectives.
Because of the wide breadth of comments received, highlights of the more notable comments
and revisions are discussed below.
2 March 8, 2022 PTC Housing Element Report
https://cityofpaloalto.primegov.com/meeting/document/1784.pdf?name=Staff%20Report
3 November 28, 2022 Council Action Minutes
https://cityofpaloalto.primegov.com/Public/CompiledDocument?meetingTemplateId=12221&compileOutputType
=1
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Housing Constraints
HCD requested greater analysis of housing constraints including the City’s land use controls and,
more specifically, a greater evaluation of the cumulative impacts of development standards on
housing supply and affordability in the City.
Development Standards
HCD had a number of questions related to the City’s land use regulations as being a potential
development constraint. Typically, the development standards are one of the main perceived
“sources” of constraints to housing. In addition, development standards generally have been
frequently mentioned by developers as a cause for higher housing costs. In response to the
comments, the revised Housing Element provides additional analysis of the individual and
cumulative impacts of the City’s development standards to determine if they represent
constraints to housing production.
Part of the additional analysis included the results of a physical site test modeling study currently
underway (as part of Program 3.4). This study involves physical modeling of standards in the City’s
zoning districts to understand whether current development standards yield the densities
identified in the Sites Inventory and required to meet the RHNA. An example of the preliminary
modeling for the CN district is shown below; additional details and findings are described in
Chapter 4: Constraints
These graphics model a prototypical
residential mixed use project in the
CN district, given the required
development standards, including
setbacks, floor area ratio, height,
daylight plane, retail requirements,
landscape coverage, and parking. In this example, the existing regulations yield 12 apartments
and a ground-floor retail space, but necessitate underground parking. The analysis finds that the
ground-level landscaping standard is a constraint to attaining the 40 du/ac density threshold
identified in the Sites Inventory for this particular site/district.
Source: Lexington Planning, Urban Field Studio, City of Palo Alto, 2023.
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The preliminary modeling revealed that some development standards are a constraint to housing
production at the density levels identified in the Sites Inventory to meet the RHNA. These include:
•ground-level landscaping requirements that limit lot coverage in the commercial mixed
use districts (e.g., CD(C), CS, CN), and
•in the case of the ROLM district, floor area ratio, height, lot coverage, and parking
As part of implementation of Program 1.1, the rezoning of sites to meet the RHNA, the City will
need to update the zoning ordinance to increase residential densities as outlined in Chapter 3 of
the Element and in the Sites Inventory and modify development standards to reduce these
constraints.
To further increase housing production, beyond density thresholds identified in the RHNA,
Program 3.4 proposes to expand the Housing Incentive Program, including more flexibility for
development standards for market rate and 100% below-market rate projects.
Processing Timelines
HCD received public comment that the City’s entitlement process is lengthy and burdensome. In
response, staff added clarifying language about changes the City has made to decrease the
amount of processing time while providing additional information on the City’s efforts in reducing
processing timelines with the approval of the Objective Standards and the Streamlined Housing
Development Review Process. The response also noted that the City will institute Program 3.7 to
consistently monitor progress in decreasing processing timelines, including Building Permit
processes, to validate that the proposed measures will have the desired results.
Ordinances
HCD advised the City to review local ordinances that directly impact the cost of housing and
specifically pointed to the City’s Retail Preservation Ordinance and Tree Protection Ordinance.
The State had requested additional information about the Retail Preservation Ordinance and why
it was not a constraint. Staff outlined how future program proposals will limit the impact of the
ordinance while achieving its intent to protect retail at key locations along El Camino Real and
the City’s two downtown areas as noted in Program 3.4. HCD received a public comment on how
the revisions to the Tree Protection Ordinance could be a constraint to housing. Staff described
that the City recognizes this potentially could be constraint and that the Council plans to reassess
the new revisions later this year. Overall, the City will implement Program 3.2 which will analyze
any new proposed ordinance to determine if it is a constraint to housing as well as annually
monitoring current codes as constraints.
Housing Programs
More Specific Commitments and Timelines for Program Language and Implementation
HCD had comments about the City’s programs. Specifically, a number of City’s programs had
language to “explore or consider” programs rather than “implement or establish.” In addition,
HCD felt that some programs needed to be completed sooner than what was specified so that
they could make an impact during the 8-year planning period. Based on the HCD comment,
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numerous programs have been revised. There will be more proactive measures included in each
of the different programs including annual reporting, monitoring, and outreach than in the initial
draft Housing Element version. To fully address these comments, it is anticipated that additional
consulting resources will be needed to achieve more program implementation in a shorter
amount of time.
With regards to the timing of implementing the various programs, staff is still evaluating this to
make sure that the timelines are realistic. HCD was clear that they wanted to see more actions
completed earlier in the planning period. However, nearly half of the approximately 120
implementing objectives are proposed for completion by the end of 2025. This expedited
timeline presents a significant staffing resource impact for the PDS department. As noted below,
staff requests Council direction to make further refinements subsequent to the Council’s review
to adjust the expectation of when some objectives will be initiated or completed.
As a side note about housing programs, while not a specific HCD comment, HCD wants to ensure
the effectiveness of the proposed programs. Therefore, additional implementing objectives have
been added to the Housing Plan chapter (Chapter 5) to monitor the effectiveness of some City
actions (i.e. monitor activity from the revised ADU and HIP programs). In addition, HCD is
emphasizing more proactive measures like reporting and outreach. There are approximately
thirty annual actions the City must perform during each year in the revised Housing Element.
Other Program Modifications
To further address HCD comments, staff made the following additional changes:
•Revised several programs to include more stakeholder outreach, including, where
appropriate, engagement with developers to help inform policy development.
•Added new Fair Housing program objective 6.3 Middle Housing Program to encourage
and support lower price homeownership opportunities and a mix of housing types,
particularly infill and converted existing housing. As described in Appendix C: Assessment
of Fair Housing, although Palo Alto does not have Racially or Ethnically Concentrated
Areas of Poverty (RECAPs), it does have Racially Concentrated Areas of Affluence (RCAAs),
as result of historic discriminatory redlining practices. This program will further leverage
the development opportunities created by SB 9 state legislation to create by-right
opportunities for up to four units on a single-family zoned lot to encourage housing for
middle-income households. Specifically, the program proposes to increase the current
floor area limitation from 800 to 1,200 square feet per unit for SB 9 projects so that
projects could accommodate 1- and 2-bedroom units. In this way, the program aims to
expand access to high resources neighborhoods and reduce RCAAs. See the AFFH section
below for further details.
•Clarified program objective 4.2 Housing and Neighborhood Preservation to include code
enforcement protocols, including inspection and enforcement, when a complaint about
substandard housing is received.
•Clarified program objective 6.6 Fair Housing/Tenant Protections regarding Tenant
Relocation Assistance (TRA) to specify Code Enforcement will enforce TRA payments if a
complaint is received. This represents a change from the City’s current enforcement
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philosophy, which would treat this as a civil matter between the tenant and property
owner or landlord.
•Recommended Program Removals:
o Staff recommends the removal of Program 3.5 Pedestrian and Transit Oriented
Development (PTOD) that specifies a review of the existing development
standards and review process to determine modifications that would support
higher density development.
With the Housing Element focus on the Housing Incentive Program (HIP), it seems
more appropriate to consider applying the HIP to the PTOD area. The HIP
standards are focused on supporting housing development and would be
appropriate for the Cal Ave PTOD area as well.
o Staff recommends the removal of the implementing objective 6.3 (D) to review
the Workforce Housing Overlay regulations to better align with the intended
housing population (120%-140% AMI). This task does not support new housing
development and should be considered outside of the Housing Element initiatives.
Removing these two programs does not preclude the City from pursuing this work in the future.
However, in light of the multitude of other assignments required of the new Housing Element,
staff does not consider these two initiatives a top priority that would spur housing production.
Housing Needs
Meeting RHNA/Realistic Capacity
Public comments were received about the housing inventory and the ability for the City to meet
its RHNA. The public comments included the possibility of entitled projects not moving forward
to become housing, redevelopment of non-vacant sites, and ADU production. Staff responded
with additional information using entitlement data since 2013 demonstrating that a high majority
of entitled projects do move forward to obtain building permits and subsequently become
housing units. Additional analysis was provided to substantiate the City’s development history of
converting non-vacant sites to residential developments. In addition, staff has engaged multiple
times with large land-holding property representatives in the GM/ROLM zone districts to discuss
potential significant housing development in the area, and property owners have expressed
strong interest in housing development in this area. Through Program 3.2, the City will also
annually monitor its current codes for potential housing constraints.
Special Needs Housing
The HCD letter requested greater analysis on the City’s past actions in meeting the housing needs
of special needs groups as well as providing more local knowledge of special needs populations
in the City. The letter also pointed out more revisions were needed to the Housing Programs to
provide for alternative housing types such as transitional housing and farmworker housing per
State requirements. Understanding that more can be done to assist special needs groups,
programs have been added to provide preferences to special needs population when affordable
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housing units become available (Program 6.1) as well as encouraging alternative types of housing
for special needs populations (Program 6.5).
Affirmatively Furthering Fair Housing (AFFH)
AFFH is a new State requirement and it is defined as taking meaningful actions to:
a) combat discrimination,
b) overcome patterns of discrimination,
c) foster inclusive communities,
d) replace segregated living patters with integration and,
e) transform areas with racial and poverty concentration.
Programs must be created to have proactive measures that address these areas.
Since this is a new requirement with many jurisdictions still navigating through its requirements,
a number of HCD comments focused on the City’s AFFH discussion (Appendix C of the Housing
Element) and programs. The City’s fair housing analysis provided County and local information
and trends. However, HCD comments requested a larger regional study of fair housing, as well
as, greater local knowledge. The regional analysis has been expanded to the entire Bay Area
instead of the County and additional sources of local knowledge have been added. Based on the
new information, areas of discussion including Racially Concentrated Areas of Affluence (RCAAs)
or housing for persons with special needs have been revised. Specifically, HCD requested to
analyze additional trends and data for special needs groups/populations and further explanation
about certain areas of the City regarding their racial and income demographics.
Based on the additional information and analysis, a significant amount of revisions and additions
were made to the existing programs and implementing objectives for the fair housing programs
to address HCD comments. (Program 6). Many of the existing programs and implementing
objectives have been revised to provide more proactive measures and specifics.
Program 6.3 is proposed to address RCAAs. RCAAs are defined as affluent white communities
where the census tract comprises of 1.25 times more white individuals than the general
population and have 1.5 times the median income of the region or State, whichever is lower. Palo
Alto does have ten RCAAs. The Housing Element provides some historical detail about the City
practices of exclusionary zoning, redlining, and other discriminatory practices that led to these
RCAAs. Although the discriminatory practices have been eliminated and high tech buyers, which
are highly diverse, are purchasing throughout the City, the effects of historic redlining remain in
persistent RCAAs. These trends will slowly reduce the number of RCAAs in the City. But to further
help address RCAAs, staff has proposed Program 6.3, Middle Housing Program. Leveraging SB 9,
the program will increase the floor area limitation that will allow for more units on a single family
lot. This will also help promote housing mobility throughout the City, especially in the City’s lower
density areas. And it will also provide greater housing opportunities for more segments of the
community.
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Program 6.1 was revised to add specific commitments to supporting housing for persons with
special needs. The City provided additional local data for persons with disabilities and seniors.
Per information provided by AbilityPath, a high percentage of adults with a developmental
disability are a risk of losing their housing within a decade. Also provided is a survey from
Avenidas that shows 19% of the respondents earn less than $50,000 per year. This demonstrates
the immediate need for housing for persons with special needs. Program 6.1, “Housing for
Persons with Special Needs” originally proposed preferences for populations with special needs.
However, the revised program offers much greater detail and specificity. The City will now modify
its Affordable Housing guidelines to facilitate special needs housing. The guidelines will include
the annual preparation of a Notice of Funding Availability (NOFA) for future projects with scoring
priorities for special needs housing units. The City will also offer streamlined permit processing.
This will help provide for greater housing opportunities for persons or households with special
needs.
There are five “objectives’ to AFFH requirements. City staff has prepared an AFFH matrix to
demonstrate how the City’s AFFH programs are meeting those five objectives. Please see AFFH
matrix in Attachment A, Appendix C (Assessment of Fair Housing).
Additional Revisions Recommended by Staff
In order to permit the timely preparation of Attachment A, staff and the City‘s consultant were
unable to include a few final revisions that are important to a complete Housing Element. Staff
therefore recommends that the City Council direct the following revisions to Attachment A as
part of its adoption and prior to submittal to HCD.
1. Add to Chapter 2, Housing Needs, a discussion of the number of shelter beds that go
unused on an average monthly basis within a one-year period, and the percentage of
those in emergency shelters that move to permanent housing solutions. Specifically, add
the following paragraph to Page 2-84, following the paragraph ending “The shelter is
hosted at rotating places of worship throughout Palo Alto and operates from November
to April.”:
a. Based on information obtained from Hotel de Zink, unused beds on an average
monthly basis between January 1, 2022 and December 31, 2022 ranged from 0.6
unused beds per night in May 2022 to 4.3 unused beds per night in September
2022, with an annual average of 2.6 unused beds per night. The County of Santa
Clara provided slightly different data, but reached approximately the same annual
average of 2.8 unused beds per night. The complete dataset is provided in Table
2.xx. Both Hotel de Zink and the County provided data that approximately 14% of
individuals in the emergency shelter transitioned to permanent housing solutions.
The City was not able to obtain information from Heart and Home Collaborative,
nor was the County able to provide any data.
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Table 2.XX Monthly Average Unused Emergency Shelter Beds – 2022
Data from Hotel de Zink Data from County of Santa Clara
Month Daily
Capacity
Average
daily usage
Average
daily
unused
beds
Monthly
total
capacity
Monthly
total usage
Monthly
total
unused
beds
January 12 8.2 3.8 310 253 57
February 15 11 4.0 336 309 27
March 15 11.8 3.2 434 365 69
April 15 14 1.0 450 419 31
May 15 14.4 0.6 496 447 49
June 15 12.6 2.4 480 379 101
July 15 12.7 2.3 496 393 103
August 15 11.4 3.6 496 353 143
September 15 10.7 4.3 480 321 159
October 15 12.5 2.5 496 380 116
November 15 12.9 2.1 480 356 124
December 15 13.8 1.2 372 337 35
2. Revise Chapter 5 Program 1.1A to clarify the City’s compliance strategy for Government
Code Section 65583.2(h) as follows:
a. The rezone/upzoning shall include the following provisions of Government Code
Section 65583.2(h) and (i) for sites accommodating lower incomes: (1) By-right
development of multi-family developments in which 20 percent or more of units
are affordable to lower income households and no subdivision is needed; (2)
Accommodation of at least 16 units per site; (3) Minimum density of 20 units per
acre; (4) At least Because 50 percent of the lower-income need must cannot be
accommodated on sites designated for residential use only, a portion shall be
accommodated or on sites zoned for mixed uses that accommodate all of the very
low and low-income housing need, if those sites: allow 100 percent residential
use, and require that residential use occupy at least 50 percent of the total floor
area of a mixed-use project.
3. Authorize staff to refine the objectives timelines to meet the State’s interests to advance
meaningful change early in the 6th Cycle to available staff resources, including reasonable
expectations for Council-supported consultant resources.
FISCAL/RESOURCE IMPACT
The implementation of the Housing Element will require staff or consultant resources to
complete rezones, program implementation, and prepare studies. Generally, all tasks will need
to be completed within the first few years of Housing Element adoption. Now with the more
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specific commitments and reduced timelines, staff will need to implement more programs in a
shorter span of time. This will involve greater staff resources and the use of consultants for the
studies. Budget requests related to these activities will be reflected in the annual budget
development process.
STAKEHOLDER ENGAGEMENT
The Housing Element update process included substantial public outreach and engagement
opportunities. The City formed the Housing Element Working Group (Working Group), a 17-
member group that advised the City Council with the Housing element update. The Working
Group represented a demographic cross-section of the City. The Working Group included renters,
affordable housing residents, seniors, persons of color, a representative from the unhoused
community, and an affordable housing developer.
There were other outreach efforts to educate the community about the Housing Element update
effort and to receive community input. In addition to the project’s webpage, the City conducted
an online survey with 430 respondents, hosted three community workshops and held over 30
public meetings (includes Working Group, Council Ad-hoc, PTC, and City Council). Additionally,
staff had numerous presentations with civic groups, meetings and calls with members of the
public and developers to address questions and provide information. More recently, on April 21,
2023, in separate meetings, staff met with representatives from Palo Alto Forward and Palo
Altans for Sensible Zoning. Staff also provided a Housing Element presentation to Leadership Palo
Alto on April 20, 2023. Lastly, City staff was able to meet with its HCD reviewer on
April 19, 2023. See Appendix B of the draft Housing Element (Attachment A of this report) for
more details. The draft Housing Element Introduction also provides a more detailed breakdown
of each of the public meetings as well as summaries of other community engagement efforts.
The Palo Alto Municipal Code requires notice of this public hearing to be published in a local
paper. Notice of a public hearing for this project was published in the Daily Post on April 28, 2023,
which is 10 days in advance of the meeting. Interested parties were sent the public notice via
electronic mail. Notice of the public hearing was also posted on the City’s Housing Element
website at www.paloaltohousingelement.com.
In addition, as required by State law, the attached revised draft Housing Element (and any future
revisions) must be made available for public review for at least seven days before any action can
occur. The 7-day public review period for the revised Housing Element started on April 28, 2023
and concluded on May 5, 2023. The revised draft was available online at
www.paloaltohousingelement.com.
Consequences for Non-compliance
The deadline for Bay Area jurisdictions to adopt a compliant Housing Element was January 31,
2023. As of April 19, 2023, no Santa Clara County jurisdiction is compliant or certified. The City of
Campbell is the only Santa Clara County jurisdiction to be substantially compliant with State
requirements. They will not be fully compliant until their Housing Element is adopted and
resubmitted to HCD with additional revisions. On a regional level, of the 109 cities and counties
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in the Association of Bay Area Governments, 19 jurisdictions are compliant with the State. For a
broader perspective, according to HCD’s online housing element review and compliance report,
only 50% of jurisdictions in the Southern California Association of Governments are compliant.
Their State deadline was October 2021. Consequences for noncompliance include jurisdictions
facing the possibility of loss of local housing land use discretion, housing grant ineligibility, and
fines.
More recently, there has been statewide discussions about a “builder’s remedy” in the Housing
Accountability Act (HAA) and jurisdictions with non-compliant Housing Elements. In short, the
builder’s remedy refers to a provision of the Housing Accountability Act that obligates a
jurisdiction that does not have a compliant housing element to approve certain affordable
housing projects even if the projects are inconsistent with local zoning or general plan
regulations. Staff previously provided a discussion of the builder’s remedy as a supplemental
memo to Item #12 on the Council’s November 7, 2022 agenda.4 The City has received one
“builders remedy” application explicitly invoking the “builder’s remedy” as of April 19, 2023. In
the event the City adopts a Housing Element and denies a housing project for non-compliance
with local regulations prior to receiving certification from HCD, a court would likely determine
the adequacy of the City‘s Housing Element.
TIMELINE
The Housing Element update process has been underway for over two years. Table 2 shows the
significant milestones that have been achieved up with some significant milestones in the future.
Concurrent with the preparation of the Housing Element, staff has already begun work on some
of the programs, notably, updating the Housing Incentive Program (Program 3.4), as well as
starting to prepare the needed zone changes to meet the City’s RHNA (Program 1.1).
Table 2: 2023-31 Housing Element Progress Milestones
MILESTONE DATE
Formation of HE Working Group (HEWG)Feb. 2021
1st Meeting of HEWG April 2021
PTC consideration of HE sites February 2022
Council approval of HE sites April 2022
PTC consideration of HE programs August 2022
Council approval of HE programs October 2022
Public Review HE draft released for 30-day comment period November 2022
Draft HE submitted to HCD for 90-day review December 2022
PTC adoption of HE March 2023
HCD Comment letter received March 2023
PTC & Council HE adoption May 2023
Submittal of revised HE June 2023
4 https://www.cityofpaloalto.org/files/assets/public/agendas-minutes-reports/agendas-minutes/city-council-
agendas-minutes/2022/20221107/20221107pccsm-amended-linked-q.a-2.pdf
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Rezoning of Site to meet RHNA January 2024
NEXT STEPS
If the Council adopts the Housing Element, staff will make any required revisions to the Housing
Element based on Council direction. The City then has 30 days from adoption to submit the
adopted Housing Element to HCD; it is anticipated that HCD would review the revised Housing
Element within 60 days following submittal.
If HCD determines the City’s revisions address and meet all the comments in the HCD review
letter, HCD may issue a “substantial compliance” letter to the City confirming compliance with
the requirements of state law. Alternatively, if HCD believes only minor revisions are required, it
may issue a letter stating that if the City adopts the Housing Element as outlined in HCD’s
responses, the Housing Element substantially complies with the State Housing Element
requirements. Finally, if HCD believes significant revisions are required, it could simply issue
further comments without any indication regarding compliance with state law.
Staff believe the Housing Element document before the Council fully responds to all of the
comments in HCD‘s March 23, 2023 letter and that it meets all statutory requirements.
Accordingly, staff believe the Housing Element is appropriate for adoption and are hopeful that
HCD will confirm its compliance with state law. As noted above, even in the absence of a
substantial compliance letter from HCD, the City may still assert that its Housing Element is
substantially compliant.
ENVIRONMENTAL REVIEW
The subject project has been assessed in accordance with the authority and criteria contained in
the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the
environmental regulations of the City. Specifically, the City, acting as the lead agency, has
prepared an Addendum to the 2017 Palo Alto Comprehensive Plan Environmental Impact Report5
for the draft Housing Element.
The CEQA analysis for the Housing Element is focused on the resulting physical changes on the
identified RHNA sites that would take place as a result of the implementation of the required
rezonings to meet RHNA and implementing those programs which help increase housing
production. For CEQA purposes, the review assessed a higher density on some of the identified
RHNA sites than strictly required to meet RHNA as well as other sites that may be developed from
the proposed incentives (i.e. expansion of the HIP program). For example, the City parking lots
were assigned a maximum density of 50 du/ac for RHNA purposes however it was assigned a
density of 100du/ac for the CEQA analysis. This is considered the “reasonable maximum
development scenario,” to fully analyze potential impacts if development occurs at a rate higher
5 https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Long-Range-Planning/2030-
Comprehensive-Plan. Please see “Additional Comprehensive Plan Resources”.
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than it has historically. This reasonable maximum development scenario assumes that the entire
housing sites inventory would develop as housing and does not account for existing development
(primarily low-rise commercial uses) that would be demolished to allow for housing. As a result,
the impact analysis represents a conservative approach of potential impacts.
Table 3 shows the final unit count analyzed in the CEQA document, applying increased densities
and assuming program implementation, primarily the expansion of the City’s Housing Incentive
Program (HIP).
Table 3: Total Housing Element Buildout for CEQA Analysis
Sites Units
RHNA Sites Inventory + Additional Density Assumption1 289 6,936
Sites removed from CEQA review2 (123) (1,387)
Increase in allowable density in ROLM/GM zones (Housing Element Program 1.1B) 3 13 294
HIP Standards Enhanced Citywide (Housing Element Program 3.4C) 4 0 294
HIP Expanded to All RM Zones (Housing Element Program 3.4D) 5 69 528
Total 248 6,665
( ) denotes subtraction
1 The CEQA unit yield is higher than the RHNA sites yield because of an assumed higher density development assigned to the sites.
2 123 sites do not involve changes in development density; therefore, they have been excluded from the CEQA buildout because the
development density is already permitted
3 Additional sites added due to higher feasibility of development due to proposed upzoning.
4 HIP allows for greater density and more relaxed development standards thus some developers will take advantage of the incentives.
5 Extending the HIP to the RM zones will allow property owners to take advantage of the development incentives.
The projected Housing Element buildout of 6,665 units is slightly above the assumed 6,000 unit
buildout of Scenario 6 of the 2030 Comprehensive Plan Supplement to the draft Environmental
Review. Therefore, the Addendum focused on the impact of the 665 more residential units
assumed in the Housing Element buildout. The Addendum focused on the potential impacts to
circulation and air quality of the additional units. In the review, the new State metric of Vehicle
Miles Traveled (VMT) instead of Level of Service (LOS) was used and the review concluded there
would not be a significant impact in citywide circulation patterns.
Air quality was also analyzed based on the greenhouse gas emissions generated from the
calculated vehicle trips. It was determined that the air quality impacts did not exceed the CEQA
thresholds.
COUNCIL ALTERNATIVE ACTION
The following are alternative actions that Council can take:
1. Continue Council’s deliberation to May 15.
2. Continue to date uncertain and direct staff to perform additional analysis/revisions and
return with a revised draft for review and recommendation.
3. Direct staff to submit Attachment A as a subsequent draft to HCD for review and
comment (rather than an adopted version). This will require the City to prepare an
additional analysis to plan for emergency shelters pursuant to AB 2339. This analysis is
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required for drafts submitted to HCD after April 1, 2023, but not for adopted housing
elements.
ATTACHMENTS
Attachment A: Clean and Strikeout/Underlined Draft 2023-31 Housing Element, April 2023
(hard copy of strikeout/underline provided to Council and available at
Rinconada Library)
Attachment B: Draft Addendum to the 2017 Palo Alto Comprehensive Plan Environmental
Impact Report
Attachment C: Draft Resolution to Adopt Housing Element and CEQA Findings
Attachment D: HCD Comment Letter, March 23, 2023
Attachment E: Summary of Public Comments Submitted to HCD, December 2022
Attachment F: City Response Matrix to HCD Comment Letter (to be provided separately)
APPROVED BY:
Jonathan Lait, Planning and Development Services Director
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Attachment A
Meeting Date: May 8, 2023
Clean and Strikeout/Underlined Draft 2023-31 Housing Element, April 2023
Please visit https://paloaltohousingelement.com/ to see both the clean and
strikeout/underlined versions of the draft document.
Hardcopies of the strikeout/underlined Housing Element version will be provided to the
Planning & Transportation Commission and City Council.
The public can view a hardcopy of the strikeout/underline Housing Element at Rinconada
Library.
Attachment B
Meeting Date: May 8, 2023
Draft Addendum to the 2017 Palo Alto Comprehensive Plan Environmental Impact Report
An electronic version of the Draft Addendum is also available online at:
https://paloaltohousingelement.com/
The 2017 Palo Alto Comprehensive Plan EIR can be viewed online at:
https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Housing-
Policies-Projects/2030-Comprehensive-Plan
ADDENDUM TO THE 2030 COMPREHENSIVE PLAN
ENVIRONMENTAL IMPACT REPORT
(SCH #2014052101)
City of Palo Alto 2023-2031 Housing Element
PREPARED BY: City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Contact: Tim Wong, Senior Planner
PREPARED WITH THE ASSISTANCE OF: Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
REPORT DATE: April 2023
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TABLE OF CONTENTS
Introduction .................................................................................................................................................. 1
Project Description ....................................................................................................................................... 5
Impact Analysis ........................................................................................................................................... 23
1 Aesthetics ................................................................................................................................ 25
2 Agriculture and Forestry Resources ........................................................................................ 31
3 Air Quality ................................................................................................................................ 35
4 Biological Resources ................................................................................................................ 53
5 Cultural Resources ................................................................................................................... 59
6 Energy ...................................................................................................................................... 63
7 Geology and Soils .................................................................................................................... 71
8 Greenhouse Gas Emissions ..................................................................................................... 77
9 Hazards and Hazardous Materials ........................................................................................... 87
10 Hydrology and Water Quality .................................................................................................. 93
11 Land Use and Planning .......................................................................................................... 101
12 Mineral Resources ................................................................................................................. 109
13 Noise ...................................................................................................................................... 111
14 Population and Housing ........................................................................................................ 121
15 Public Services ....................................................................................................................... 125
16 Recreation ............................................................................................................................. 131
17 Transportation ....................................................................................................................... 133
18 Tribal Cultural Resources ....................................................................................................... 141
19 Utilities and Service Systems ................................................................................................. 145
20 Wildfire .................................................................................................................................. 155
21 Cumulative Impacts ............................................................................................................... 159
22 Other CEQA Required Discussions ........................................................................................ 161
Conclusion ................................................................................................................................................. 163
References ................................................................................................................................................ 165
FIGURES
Figure 1 Regional Location ........................................................................................................................ 6
Figure 2 City of Palo Alto Location ............................................................................................................ 7
Figure 3 Housing Element Update Sites Inventory Locations ................................................................. 12
Figure 4 GM and ROLM Zones ................................................................................................................ 16
Figure 5 Existing and Proposed HIP Sites ................................................................................................ 18
TABLE OF CONTENTS
i i | P a g e Addendum to the 2030 Comprehensive Plan EIR
TABLES
Table 1 RHNA Allocation and Percentage of Income Distribution for Palo Alto ................................... 10
Table 2 Total Housing Element Proposed Sites and Units to Meet the RHNA ...................................... 15
Table 3 Total Housing Element Buildout for CEQA Analysis .................................................................. 20
Table 4 Total Development Evaluated in the Comprehensive Plan EIR Compared to the
Housing Element Update .......................................................................................................... 20
Table 5 2017 EIR Mitigation Measures: Aesthetics ............................................................................... 26
Table 6 2017 EIR Mitigation Measures: Air Quality ............................................................................... 36
Table 7 BAAQMD Criteria Air Pollutant Screening Levels ...................................................................... 39
Table 8 BAAQMD Criteria Air Pollutant Significance Thresholds .......................................................... 40
Table 9 BAAQMD Odor Source Thresholds ........................................................................................... 42
Table 10 Project Consistency with Applicable 2017 Clean Air Plan Control Measures ........................... 44
Table 11 Increase in Population Compared to Vehicle Trips Under Project ........................................... 45
Table 12 2017 EIR Mitigation Measures: Cultural Resources .................................................................. 60
Table 13 2017 EIR Mitigation Measures: Energy ..................................................................................... 64
Table 14 Consistency with State Renewable Energy and Energy Efficiency Plans .................................. 67
Table 15 Project Consistency with Applicable 2030 Comprehensive Plan policies ................................. 69
Table 16 2017 EIR Mitigation Measures: Greenhouse Gas Emissions ..................................................... 78
Table 17 Operational GHG Emissions ...................................................................................................... 82
Table 18 Proposed Project Compliance with Applicable S/CAP Actions ................................................. 83
Table 19 2017 EIR Mitigation Measures: Hydrology and Water Quality ................................................. 95
Table 20 2017 EIR Mitigation Measures: Land Use and Planning ......................................................... 102
Table 21 Project Consistency with Plan Bay Area 2050 ......................................................................... 104
Table 22 Project Consistency with Relevant 2030 Comprehensive Plan Goals and Policies ................. 105
Table 23 2017 EIR Mitigation Measures: Noise ..................................................................................... 113
Table 24 2017 EIR Mitigation Measures: Public Services and Recreation ............................................. 126
Table 25 2017 EIR Mitigation Measures: Transportation and Traffic .................................................... 134
Table 26 Vehicle Miles Traveled Analysis Summary .............................................................................. 137
Table 27 2017 EIR Mitigation Measures: Utilities and Service Systems ................................................ 147
Table 28 Estimated Water Use for the Proposed HEU .......................................................................... 150
Table 29 Estimated Solid Waste Generation ......................................................................................... 152
APPENDICES
Appendix A Vehicle Miles Traveled Analysis
Appendix B Greenhouse Gas Emissions Modeling Results
Appendix C Native American Tribal Correspondence
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INTRODUCTION
This document is an addendum to the Environmental Impact Report (EIR) (State Clearinghouse
[SCH] #2014052101) certified in 2017 (“2017 EIR”) for the 2030 Comprehensive Plan. This
addendum is being prepared for the City’s 2023-2031 Housing Element Update (HEU),
henceforth known as the “proposed project” or “proposed HEU.” The City of Palo Alto was the
lead agency for the certified EIR and is the lead agency for this addendum. The addendum
analyzes the environmental effects of proposed revisions to the previously approved project
analyzed in the 2017 EIR to address the proposed HEU and has been prepared in accordance
with relevant provisions of the California Environmental Quality Act (CEQA) of 1970 (as
amended) and the CEQA Guidelines.
According to CEQA Guidelines Section 15164, an addendum to a previously certified EIR or
negative declaration is the appropriate environmental document in instances when “only minor
technical changes or additions are necessary” and when the new information does not involve
new significant environmental effects or a substantial increase in the severity of a significant
effect beyond those identified in the previous EIR. CEQA Guidelines Section 15164 states that:
a. The lead agency or responsible agency shall prepare an addendum to a previously certified
EIR if some changes or additions are necessary but none of the conditions described in
Section 15162 calling for preparation of a subsequent EIR have occurred [these are listed
below in Section 1.2].
b. [Omitted – applies to Negative Declarations]
c. An addendum need not be circulated for public review but can be included in or attached to
the final EIR or adopted negative declaration.
d. The decision-making body shall consider the addendum with the final EIR or adopted
negative declaration prior to making a decision on the project.
e. A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section
15162 should be included in an addendum to an EIR, the lead agency’s findings on the
project, or elsewhere in the record.
BACKGROUND AND PURPOSE OF THE EIR ADDENDUM
2017 EIR BACKGROUND
The City of Palo Alto prepared and certified the Comprehensive Plan Update EIR (State
Clearinghouse #2014052101) on February 5, 2016. The EIR analyzed four scenarios (scenarios 1,
2, 3, and 4) and their environmental impacts. The City then prepared and certified the
Comprehensive Plan Update Supplement to the Draft EIR (State Clearinghouse #2014052101)
on February 10, 2017, which analyzed two more scenarios (scenarios 5 and 6) with higher
buildouts compared to scenarios 1 through 4. This addendum analyzes the proposed HEU’s
impacts in relation to the 2017 EIR, which analyzed a maximum buildout of 6,000 new housing
units and 14,080 new residents in Scenario 6. The City also prepared and adopted a Mitigation,
Monitoring and Reporting Program (MMRP); CEQA findings; and a Statement of Overriding
Considerations in 2017.
INTRODUCTION
2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
BASIS FOR THE ADDENDUM
As discussed in the CEQA Guidelines, between the date an environmental document for a
project is completed and the date that project is implemented fully, one or more of the
following changes may occur: 1) the project may change; 2) the environmental setting of the
project may change; or 3) previously unknown information can arise. Before proceeding with a
project, CEQA requires the lead agency to evaluate these changes to determine whether they
affect the conclusions in the prior environmental document. When an EIR has been adopted
and a project is modified or otherwise changed after adoption, additional CEQA review may be
necessary. The key considerations in determining the need for the appropriate type of
additional CEQA review are outlined in Public Resources Code Section 21166 (CEQA) and CEQA
Guidelines Sections 15162 and 15164.
CEQA Guidelines Section 15162(a) provides that a Subsequent EIR is not required unless the
following occurs:
1) Substantial changes are proposed in the project which will require major revisions of the
previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of identified significant
effects;
2) Substantial changes occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR or Negative Declaration
due to the involvement of new significant environmental effects or a substantial increase in
the severity of identified significant effects; or
3) New information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified
as complete or the Negative Declaration was adopted, shows any of the following:
A) The project will have one or more significant effects not discussed in the previous EIR or
negative declaration;
B) Significant effects previously examined will be substantially more severe than shown in
the previous EIR;
C) Mitigation measures or alternatives previously found not to be feasible would in fact be
feasible, and would substantially reduce one or more significant effects of the project,
but the project proponents decline to adopt the mitigation measure or alternative; or
D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant effects
on the environment, but the project proponents decline to adopt the mitigation
measure or alternative.
Pursuant to CEQA Guidelines Section 15164(a), an addendum to a previously certified EIR may
be prepared if some changes or additions are necessary but none of the conditions described in
Section 15162 have occurred that require preparation of a Subsequent EIR. An addendum must
include a brief explanation of the agency’s decision not to prepare a Subsequent EIR and must
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be supported by substantial evidence in the record as a whole (Section 15164[e]). The decision-
making body must consider the addendum prior to approving the project (Section 15164[d]).
An addendum to the 2017 EIR is appropriate to address the proposed project, because the
proposed modifications to the 2030 Comprehensive Plan project do not meet the conditions of
Section 15162(a) for preparation of a Subsequent EIR as described herein.
This addendum presents an analysis of the environmental topics identified in Appendix G of the
State CEQA Guidelines using a modified checklist that determines for each topic whether the
circumstances set forth in Public Resources Code Section 21166 and its implementing State
CEQA Guidelines sections 15162 and 15163 are present with respect to the proposed project or
the circumstances surrounding the project.
The 2017 EIR and this addendum serve as documents to inform decision-makers and the public
of the potential environmental consequences of approving the proposed project. This
addendum neither controls nor determines the ultimate decision for approval of the proposed
project. The information presented in this addendum to the certified EIR will be considered by
the City of Palo Alto alongside the certified EIR prior to deciding whether to approve the
proposed project.
INTRODUCTION
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PROJECT DESCRIPTION
The proposed project, herein referred to as the “Housing Element Update,” “proposed Housing
Element Update,” or “HEU,” would amend the City of Palo Alto’s 2030 Comprehensive Plan
(hereinafter referred to as the “2030 Comprehensive Plan”) by replacing the current Housing
Element with the proposed 2023-2031 Housing Element and amending the 2030
Comprehensive Plan and Palo Alto Municipal Code (PAMC) as needed for consistency and HEU
implementation.
The proposed HEU establishes programs, policies, and actions to further the goal of
accommodating projected housing demand, as mandated by the State; increasing housing
production to meet this demand; improving housing affordability; preserving existing
affordable housing; improving the safety, quality and condition of existing housing; facilitating
the development of housing for all income levels and household types, including special needs
populations; improving the livability and economic prosperity of all Palo Alto residents; and
promoting fair housing choice for all.
This section describes the proposed project, including the project location, major project
characteristics, project objectives, and discretionary actions needed for approval.
LEAD AGENCY NAME, ADDRESS, AND CONTACT
City of Palo Alto
250 Hamilton Avenue
Palo Alto, California 94301
Contact: Tim Wong, Senior Planner, Tim.Wong@cityofpaloalto.org, 650-329-2493
PROJECT LOCATION
The study area considered in this analysis includes the entire city of Palo Alto (hereinafter
referred to as “City” or “Palo Alto”). Palo Alto is located 35 miles south of San Francisco and 14
miles north of San Jose. Palo Alto encompasses an area of approximately 26 square miles,
about a third of which is open space, including 34 city-owned parks, and 1,700 acres of
protected Baylands. The regional location of Palo Alto is shown in Figure 1 and the city limits
are show in Figure 2.
PROJECT DESCRIPTION
6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Figure 1 Regional Location
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Figure 2 City of Palo Alto Location
PROJECT DESCRIPTION
8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
EXISTING SETTING
Palo Alto includes primarily single-family residential uses (approximately 61 percent of Palo
Alto) as well as schools, civic buildings, parks and open space, and commercial uses. The
developable area within Palo Alto, located between Junipero Serra Boulevard and the Bayshore
Freeway (US 101), is largely built out. Less than 0.5 percent of the developable land area is
vacant. A large percentage of Palo Alto’s land area is also undeveloped Baylands and hillsides.
The housing stock of Palo Alto in 2022 was made up of 16,403 single-family detached
residences, 1,218 single-family attached residences, 1,958 multi-family residences with 2 to 4
units, 9,489 multi-family residences with 5 or more units, and 97 mobile homes (California
Department of Finance [DOF] 2022 1).
PROJECT CHARACTERISTICS
The proposed project consists of a complete update to the Comprehensive Plan Housing
Element. The updates are intended to enable Palo Alto to accommodate housing in accordance
with State law while continuing to provide services, parks, schools, and environmental setting,
and offering new programs that support the city’s diversity and housing affordability.
HOUSING ELEMENT UPDATE
The Housing Element is one of the State-mandated elements of the Comprehensive Plan. The
current Housing Element was adopted in 2014 and is in effect through January 31, 2023. The
Housing Element identifies Palo Alto’s housing conditions and needs, and establishes the goals,
objectives, and policies that comprise the City’s housing strategy to accommodate projected
housing needs, including the provision of adequate housing for low-income households and for
special-needs populations (e.g., unhoused people, seniors, single-parent households, large
families, and persons with disabilities).
The proposed HEU would bring the element into compliance with State legislation passed since
adoption of the 2015-2023 Housing Element and with the current Regional Housing Needs
Allocation (RHNA). In December 2021, the Association of Bay Area Governments (ABAG)
Executive Board adopted the 6th Cycle Final RHNA, which includes a “fair share” allocation for
meeting regional housing needs for each community in the ABAG region.
The proposed HEU includes the following components, as required by State law:
Evaluation of the 2015-2023 Housing Element: An evaluation of the results of the goals,
policies, and programs adopted in the 2015-2023 Housing Element that compares projected
outcomes with actual achieved results.
1 California Department of Finance (DOF). 2022. E-5 Population and Housing Estimates.
https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-counties-and-the-
state-2020-2022/
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Demographics and Housing Needs Assessment: An analysis of the existing and projected
housing needs of the community. It provides a profile of socio-demographic information,
such as population characteristics, household information, housing stock, tenure, and
housing affordability. The assessment also considers local special housing needs, such as
seniors, farmworkers, unhoused persons, large households, and female-headed households.
Housing Capacity Analysis and Methodology: An inventory listing adequate sites that are
suitably zoned and available within the planning period to meet the city’s fair share of
regional housing needs across all income levels.
Housing Resources: An identification of resources to support the development,
preservation, and rehabilitation of housing.
Constraints to Housing Production: An assessment of impediments to housing production
across all income levels covering both governmental (e.g., zoning, fees, etc.) and
nongovernmental (e.g., market, environmental, etc.) impediments.
Housing Plan: This section provides a statement of the community’s goals, policies and
quantified objectives to maintain, preserve, improve, and develop housing, as well as a
schedule of implementable actions to be taken during the planning period. Quantified
objectives are included to make sure that both the existing and the projected housing needs
are met, consistent with the city’s share of the RHNA.
The draft Housing Element is available on the City’s website:
https://paloaltohousingelement.com/
REGIONAL HOUSING NEEDS ALLOCATION
The Housing Element must address the City's fair share of the regional housing need and
specific State statutory requirements and must reflect the vision and priorities of the local
community. ABAG has allocated the region’s 441,176 housing unit growth needs among each
city and county in its region through a process called the Regional Housing Needs
Determination. From the determination, ABAG assigns each jurisdictions Regional Housing
Needs Allocation (RHNA). The RHNA represents the minimum number of housing units that the
City is required to plan for in its Housing Element by providing adequate sites through the
Comprehensive Plan and zoning.
As shown in Table 1, Palo Alto’s RHNA for the 2023-2031 planning period is 6,086 units, which is
distributed among four income categories (a fifth category for extremely low-income
households is added in Table 1).
PROJECT DESCRIPTION
1 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 1 RHNA Allocation and Percentage of Income Distribution for Palo Alto
Income Level Percent of Area Median Income (AMI) Units Percent
Extremely Low <30% 778 12.7%
Very Low <50% 778 12.7%
Low 50-80% 896 14.7%
Moderate 80-120% 1,013 16.6%
Above Moderate >120% 2,621 43.0%
Total – 6,086 100%
Source: Association of Bay Area Governments Methodology and numbers were approved by ABAG’s Executive board on January 21, 2021
(Resolution No. 02-2021).
MEETING THE RHNA
To meet the RHNA and provide sufficient capacity to accommodate future housing
development, the HEU specifies sites suitable for residential development, identifies sites to
increase permitted residential densities to meet affordability requirements, and includes other
goals, policies, and programs to encourage housing. However, the Housing Element in and of
itself does not develop housing – it is a plan. This housing plan would be supported by new and
revised zoning standards. Not all of the housing anticipated by the RHNA will necessarily be
built, as housing development is mainly accomplished by the private sector and dependent on
factors independent of City control, such as financial resources. The sections below introduce
the Sites Inventory, sites proposed to meet the RHNA, and then a subset of the inventory
describing sites that require rezoning to meet the RHNA.
The Department of Housing and Community Development (HCD) guidance is to identify enough
housing sites inventory to not only cover the jurisdiction’s RHNA, but to also provide for an
additional buffer capacity to accommodate realistic production rates of affordable housing
units. Having a surplus or buffer can also allow for instances when a smaller residential unit
count may have to be considered for a given property. The “No Net Loss” Law (Government
Code Section 65863) requires maintenance of sufficient sites to meet the RHNA for all income
levels throughout the planning period.
SITES INVENTORY
The City assessed capacity in entitled and proposed development, accessory dwelling units
(ADU) and underutilized sites to meet the RHNA. Some of the underutilized sites are already
zoned to accommodate multifamily housing at appropriate densities. However, other sites
require rezoning to increase densities to allow multifamily housing and meet the remaining
shortfall in accommodating the RHNA. These categories are further explained below. The City
has identified 289 sites that could provide housing to meet the City’s RHNA and buffer. These
sites are shown on Figure 3.
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ENTITLED AND PROPOSED DEVELOPMENT
Approved and permitted residential developments can be credited towards the City’s RHNA for
the 6th cycle Housing Element provided it can be demonstrated that the units will be built
during the planning period. The city has identified 19 projects that are entitled or under review.
Entitled and proposed development would generate 1,016 new units within the city.
ACCESSORY DWELLING UNITS
The City anticipates that it will permit an average of 64 accessory dwelling units (ADU) per year
or 512 units during the planning period. ADUs, also referred to as granny flats or secondary
units, provide an affordable housing option and are an important tool to help meet the housing
needs in communities. The ADUs can also be credited towards RHNA. The proposed HEU
includes programs for the City to incentivize and promote ADUs, such as by new incentives for
rent-restriction ADUs that are affordable to low and very low income households and by
allowing the construction of an ADU or Junior ADU with the construction of a new residence,
whether on vacant property or on any property that is proposed to be redeveloped. The 64-unit
annual projection is based on the City’s average ADU production from 2019-2021.
IDENTIFYING UNDERUTILIZED SITES
After crediting the entitled or under review 1,106 units and the 512 projected ADUs towards
total RHNA (and buffer) of 6,695 units, there is a shortfall of 5,077 units. The proposed HEU
identifies 289 sites that could accommodate 5,189 units 2 to meet the RHNA allocation during
the 2023-2031 period plus an additional buffer. Most of the parcels are developed but
underutilized. Parcels that were considered during this phase included:
Underutilized sites such as lots with uses that are no longer needed or need rehabilitation
Locations where housing could be denser
Locations near public transit and services
Locations where housing could be added near commercial buildings or in business parks to
create “live-work” neighborhoods
2 Note that the identified sites’ yield of 5,189 exceeds the calculated shortfall of 5,077 units by 112 units; the revised total unit
yield to meet RHNA is 6,807 units.
PROJECT DESCRIPTION
1 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Figure 3 Housing Element Update Sites Inventory Locations
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Due to a lack of vacant available parcels, the City relies on non-vacant and underutilized sites to
accommodate nearly all of its RHNA.
SITES REQUIRING ZONING CHANGES
Of the 289 sites identified to meet RHNA, the majority (166 sites) would need to be rezoned to
a higher density to meet the estimated unit yields. The sites that do not require rezoning
already allow for the development density to reach the estimated unit yields.
STRATEGIES TO MEET RHNA
The City identified nine strategies to identify additional housing opportunity sites to
accommodate for the remaining total shortfall of 5,077 residential units. These strategies
include:
1. General up-zone of sites that allow for multi-family residential use;
2. Sites located within ½ mile of a Caltrain station;
3. Sites within ½ mile of high-frequency bus transit corridors;
4. Parking lots owned by the City;
5. Surface parking surrounding local faith-based institutions;
6. Sites within the General Manufacturing (GM) zone;
7. Sites within Research, Office, and Limited Manufacturing (ROLM) zone;
8. Sites owned by Stanford University; and,
9. Additional sites identified by City staff.
Overall, it is estimated that 166 sites would be rezoned and these rezoned sites would have a
capacity for an estimated 4,000 residential units distributed among all income categories. These
sites are also shown on Figure 3.
GENERAL UP-ZONING STRATEGIES
The City would allow more residential development by increasing the maximum allowable
density on sites where multi-family development is currently allowed. Medium to high density
residential zones, or commercial zones that currently allow a maximum density of 20 dwelling
units per acre would be up-zoned to allow a maximum of 30 dwelling units per acre. Similarly,
areas zoned for a density of 30 dwelling units per acre would be up-zoned to allow up to 40
dwelling units per acre. Those identified parcels within 0.25 mile of Caltrain stations would
receive an up-zone to 50 dwelling units per acre while those sites within a quarter to half a mile
would be up-zoned to 40 units per acre.
This strategy would increase the capacity of the city’s RM-20, RM-30, CN, CC, and CS zones on
99 sites. These sites are generally spread throughout the city but are predominately located
within the CS zone along El Camino Real with additional sites in the Downtown and North
Ventura Coordinated Area Plan (NVCAP) areas, and along Colorado Avenue and San Antonio
Road.
PROJECT DESCRIPTION
1 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
SITES WITHIN 0.5 MILE OF A CALTRAIN STATION
This strategy focuses on facilitating transit-oriented residential development within a 0.5-mile
buffer of the three Caltrain stations that serve Palo Alto, which includes the Downtown,
California Avenue, and San Antonio Stations. Twenty-seven sites located within 0.25 mile of one
of these stations were identified to be re-zoned to allow multi-family development at densities
up to 50 dwelling units per acre, while 21 sites within 0.25 to 0.5 mile of one of these stations
were identified to be re-zoned to allow up to 40 dwelling units per acre. These sites are
primarily located in proximity to the Downtown and California Avenue Stations.
SITES WITHIN 0.5 MILE OF FREQUENT BUS ROUTES
This strategy would increase residential densities in areas located within walking distance of
frequent bus and shuttle service stops, specifically VTA route 22, 522-El Camino Real and VTA
route 21 – San Antonio Avenue, Middlefield Road, and University Avenue. These sites are
primarily located along El Camino Real.
CITY-OWNED PARKING LOTS
Several city-owned surface parking lots can be redeveloped to include affordable housing, if
appropriate. Four of these sites are located in the University Avenue Downtown area and two
additional sites are located near California Avenue, within the California Avenue Business
District.
SURFACE PARKING AND VACANT LAND ON SITES WITH FAITH-BASED INSTITUTIONS
Underutilized areas on sites occupied by faith-based institutions, such as excess parking lots
and vacant segments of properties, could accommodate additional residential units.
GM AND ROLM ZONES
Nearly all sites in GM and ROLM zones are currently occupied by, or reserved for, office uses.
This strategy would rezone these sites to allow for high-density multi-family residential uses
and would accommodate approximately 35 percent of the city’s overall remaining need.
Program 1.1 of the proposed HEU would rezone ROLM and GM zoned properties to allow multi-
family residential housing as a permitted use with a base density of 65 dwelling units per acre
for those properties nearest Bayshore Freeway and generally bounded by East Charleston Road
and Loma Verde Avenue.
STANFORD SITES
Stanford University owns multiple properties within city limits that could be used as sites for
potential housing. Two sites were identified for use as residential development under the
proposed HEU, which would be available for Stanford University affiliated employees and not
for students.
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ADDITIONAL SITES IDENTIFIED BY CITY STAFF
Nineteen additional sites were included in the Sites Inventory. These are sites where
development interest has been expressed, sites that have been pre-screened by developers for
residential projects, or the sites adequate for Palo Alto’s Housing Incentives Program (HIP).
TOTAL SITES INVENTORY
Table 2 shows the total inventory of sites and units to meet the RHNA. The City of Palo Alto has
assumed a 10 percent buffer which requires the site identification of an additional 609 units for
a total of 6,695. As shown in the table, with entitled and proposed development, ADUs,
underutilized sites with no rezoning required, and rezoning to meet the RHNA, a total of 6,807
units can be accommodated, which is more than the RHNA plus 10 percent buffer of 6,695
units.
Table 2 Total Housing Element Proposed Sites and Units to Meet the RHNA
Sites Units
Entitled and Proposed Development – Credit N/A1 1,1,06
ADU – Credit N/A2 512
Underutilized Sites (no rezoning required) 123 1,187
Rezoning to Meet the RHNA 166 4,002
Total 289 6,8074
1 The 19 project sites for entitled and proposed development are not counted in the 289 RHNA sites therefore they are not
included in this table.
2 ADU development is assumed throughout the city.
OTHER ZONING CHANGES NOT REQUIRED TO MEET THE RHNA
The HEU includes additional programs to support housing development production and/or
affordability throughout the city, some of which require zoning changes. Although these zoning
changes are not required to meet the RHNA, they facilitate the goals of the Housing Element.
These programs identified in the proposed HEU could modify zoning standards as follows:
Rezone ROLM and GM zoned properties to increase densities for multi-family residential
housing beyond 65 dwelling units per acre, for those properties nearest Bayshore Freeway
and generally bounded by East Charleston Road and Loma Verde Avenue. The GM and
ROLM zones are shown in Figure 4.
Extend the Affordable Housing Incentive Program (AHIP) to all housing opportunity sites.
Modify AHIP development standards to expand housing feasibility and affordability,
including allowing more residential floor area, taller building heights, and align the City’s
parking requirements to be consistent with State Density Bonus law.
PROJECT DESCRIPTION
1 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Figure 4 GM and ROLM Zones
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Modify the Housing Incentive Program (HIP) to amend development standards including
floor area, building height, aligning the City’s parking requirements to be consistent with
State Density Bonus law; and modifying retail preservation requirements to allow more
flexibility in redevelopment outside of essential retail locations (i.e., ground floor (GF) and
retail (R) combining districts and strategic locations generally depicted in the draft South El
Camino Real Design Guidelines). These revisions will promote greater housing production
and affordability.
Extend the HIP to multi-family residential districts and the ROLM and GM districts in
northeast portion of the City nearest the Bayshore Freeway and generally bounded by East
Charleston Road to the east and Loma Verde Avenue. The existing and proposed HIP
expanded HIP areas are shown in Figure 5.
Assess the existing Pedestrian and Transit Oriented Development (PTOD) Combining District
development standards and the review process to identify modifications needed to support
higher density housing production.
Amend the City's seismic hazards identification program to strengthen regulations and
require seismic upgrades of vulnerable housing stock through a combination mandatory
provisions and voluntary incentives.
Explore development incentives to encourage larger units, such as floor area ratio
exemptions for three or more bedroom units to encourage a mix of different bedroom units
in each development.
Amend the Palo Alto Municipal Code (PAMC) to reduce commercial floor area allowances or
other commercial incentives at strategic locations to shift the economic benefit of
redevelopment toward home building.
Assess the City's Workforce Housing Overlay regulations and consider amendments to
better align the target housing population with a housing typology that provides clear
reduced rents compared to market rate rents for a comparable unit.
Adopt incentives to encourage lot consolidation to encourage high density housing with
additional incentives for 100 percent affordable housing developments.
The zoning changes resulting from the implementation of these Housing Element programs may
stimulate development on housing opportunity sites identified in the Housing Element to meet
the RHNA or on other sites not identified in the Housing Element. This CEQA document
evaluates implementation of this broader set of zoning tools and housing development on sites
beyond the Housing Element sites inventory that may take advantage of these incentives. In
this way, the analysis accounts for a scenario in which development occurs at a rate higher than
it has historically or that is likely to occur.
PROJECT DESCRIPTION
1 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Figure 5 Existing and Proposed HIP Sites
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HOUSING ELEMENT UPDATE CEQA ASSUMPTIONS
CEQA BUILDOUT ASSUMPTIONS
For the purposes of the California Environmental Quality Act (CEQA) analysis, this document
assesses a higher range of development potential, considered the “reasonable maximum
development scenario,” to fully analyze potential impacts if development occurs at a rate
higher than it has historically. This reasonable maximum development scenario assumes that
the entire housing sites inventory would develop as housing and does not account for removal
of existing development (primarily low-rise commercial uses) that would be demolished to
allow for housing. As a result, the impact analysis represents a conservative approach of
potential impacts.
The CEQA analysis for the HEU is focused on the resulting physical changes that would take
place as a result of the implementation of the required rezonings to meet RHNA as explained in
Section 2.3.3 and program implementation as outlined in Section 2.3.4.
As shown on Table 2, there are 289 sites identified to meet RHNA; 123 of those do not require a
zone change. Therefore, while they are identified sites for the purpose of meeting RHNA they
are not assessed for the purposes of the CEQA analysis because they could be built to the
projected Housing Element buildout with or without adoption of the Housing Element.
Further, although Table 2 shows a total 6,807 units associated with the 289 RHNA sites, the
CEQA analysis assumes a higher unit yield because of an assumed higher density assigned to
these sites. While the assumed yield count is lower for the purposes of demonstrating capacity
to meet the RHNA, for the CEQA analysis the assumed yield is higher to allow for a reasonable
maximum development scenario to account for potential environmental impacts.
Lastly, because HEU programs 1.1B, 3.4C, and 3.4C involve increased residential density, the
CEQA buildout assumptions include an additional 82 sites and 1,116 units.
Table 3 shows the total buildout assumed with implementation of the Housing Element for the
purposes of the CEQA analysis, which is 248 sites with a yield of 6,665 units.
PROJECT DESCRIPTION
2 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 3 Total Housing Element Buildout for CEQA Analysis
Sites Units
RHNA Sites Inventory + Additional Density Assumption1 289 6,936
Sites removed from CEQA review2 (123) (1,387)
Increase in allowable density in ROLM/GM zones (Housing Element Program 1.1B) 3 13 294
HIP Standards Enhanced Citywide (Housing Element Program 3.4C) 4 0 294
HIP Expanded to All RM Zones (Housing Element Program 3.4D) 5 69 528
Total 248 6,665
( ) denotes subtraction
1 The CEQA unit yield is higher than the RHNA sites yield because of an assumed higher density development assigned to the sites.
2 123 sites do not involve changes in development density; therefore, they have been excluded from the CEQA buildout because the
development density is already permitted
3 Additional sites added due to higher feasibility of development due to proposed upzoning.
4 HIP allows for greater density and more relaxed development standards thus some developers will take advantage of the incentives.
5 Extending the HIP to the RM zones will allow property owners to take advantage of the development incentives.
CEQA BASELINE AND COMPARISON TO THE 2017 EIR
The CEQA baseline for this analysis is the maximum allowable development for residential uses
under the City’s 2030 Comprehensive Plan Environmental Impact Report (EIR). The
Comprehensive Plan Supplement to the Draft EIR analyzed six scenarios for development under
the 2030 Comprehensive Plan. Scenario 6 of the 2030 Comprehensive Plan Supplement to the
Draft EIR assumed a buildout of 6,000 residential units and 14,080 residents, similar to the
residential buildout of the HEU. Table 4 compares the potential buildout under the proposed
HEU to the buildout contemplated in Scenario 6 of the Comprehensive Plan EIR.
As shown on Table 4, buildout under the proposed HEU would result in 665 more residential
units and 2,650 more residents compared to Scenario 6 as studied in the Comprehensive Plan
EIR. Additionally, the construction of these units could result in an overall reduction in office
uses, but this document utilizes a conservative approach of simply analyzing the additional
impacts of the residential units, without assuming a reduction in the commercial buildout that
was analyzed for the Comprehensive Plan EIR.
Table 4 Total Development Evaluated in the Comprehensive Plan EIR Compared to the
Housing Element Update
Buildout under
Comprehensive Plan EIR
Buildout under
Proposed Housing
Element Update Change in Buildout
New Housing Units (# of units) 6,000 6,665 +665
New Population (# of people) 14,080 16,7301 +2,650
1 Based on Palo Alto persons per household of 2.51 (DOF 2022)
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PROJECT OBJECTIVES
The purpose of the project is to address the housing and safety needs of the City, to support
City programs to increase diversity and housing affordability, and to update the Comprehensive
Plan to meet the requirements of current State law. The proposed Housing Element includes
the following objectives:
Accommodating projected housing demand, as mandated by the State;
Increasing housing production to meet this demand;
Improving housing affordability;
Preserving existing affordable housing;
Improving the safety, quality and condition of existing housing;
Facilitating the development of housing for all income levels and household types, including
special needs population;
Improving the livability and economic prosperity of all City residents; and
Promoting fair housing choice and affirmatively furthering fair housing for all.
REQUIRED APPROVALS
With recommendations from the Planning and Transportation Commission, the City Council
would need to take the following discretionary actions in conjunction with the proposed HEU:
Adoption of the 2023-2031 Housing Element of the Comprehensive Plan
Amendments to the City’s Zoning Ordinance
Amendments to the Comprehensive Plan to ensure internal consistency between the
Housing Element and other chapters. This would include changes to land use designations in
the Land Use Element and changes to the Safety Element to meet current State law
requirements.
CALIFORNIA NATIVE AMERICAN TRIBAL CONSULTATION
On September 29, 2022, the City of Palo Alto contacted California Native American Tribal
governments by sending an Assembly Bill (AB) 52 and Senate Bill (SB) 18 notification letter via
email to tribes with an affiliation with the project area based on a list provided by the Native
American Heritage Commission (NAHC). Under AB 52, Native American tribes have 30 days to
respond and request further project information and request formal consultation. Under SB 18,
Native American tribes have 90 days to respond and request further project information and
request formal consultation. The City did not receive a request for formal consultation under
AB 52 or SB 18. Therefore, no California Native American Tribes traditionally or culturally
affiliated with the project area have requested consultation pursuant to Public Resources Code
Section 21080.3.1.
PROJECT DESCRIPTION
2 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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IMPACT ANALYSIS
A comparative analysis has been prepared of the potential impacts associated with the
proposed project and the potential impacts of the scenarios analyzed in the 2017 EIR, using the
CEQA Guidelines Appendix G checklist as a guide. The checklist considers the full range of
environmental issues subject to analysis under CEQA (in rows), and then poses a series of
questions (in columns) aimed at identifying the degree to which the issue was analyzed in the
EIR. The checklist also includes a column identifying whether the proposed changes to the
Comprehensive Plan meet any of the criteria of CEQA Guidelines Section 15162 requiring a
subsequent EIR relative to each environmental issue. The questions posed in each column are
described below:
Where was impact analyzed? This column provides a cross-reference to the portions of the
2017 EIR where information and analyses may be found relative to the environmental issue
listed under each topic. The cross-references identified in this column correspond with page
numbers and section numbers of the 2017 EIR.
Could proposed changes involve new or substantially more severe impacts? In accordance
with the CEQA Guidelines Section 15162(a)(1), this column indicates whether the proposed
project would involve new significant environmental impacts or a substantial increase in the
severity of identified significant impacts that, in turn, would require major revisions of the 2017
EIR.
Are there new circumstances resulting in new or substantially more severe impacts? In
accordance with CEQA Guidelines Section 15162(a)(2), this column indicates whether changes
to the circumstances under which the proposed project is undertaken or implemented have
occurred that would involve new significant environmental impacts or a substantial increase in
the severity of identified significant impacts that, in turn, would require major revisions of the
2017 EIR.
Is there new information resulting in new or substantially more severe significant impacts? In
accordance with CEQA Guidelines Sections 15162(a)(3)(A) and 15162(a)(3)(B), this column
indicates whether new information of substantial importance, which was not known and could
not have been known with the exercise of reasonable diligence at the time the EIR was
certified, shows additional or substantially more severe significant impacts not discussed in the
2017 EIR.
Do mitigation measures included in the certified EIR address and/or resolve impacts? In
accordance with CEQA Guidelines Sections 15162(a)(3)(C) and 15162(a)(3)(D), this column
indicates whether new mitigation measures or alternatives previously found not to be feasible
in the 2017 EIR would in fact be feasible and would substantially reduce one or more significant
effects of the project, or whether such mitigation measures or alternatives which are
considerably different from those analyzed in the 2017 EIR would substantially reduce one or
more significant effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
IMPACT ANALYSIS
2 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
If impacts have been adequately analyzed in the 2017 EIR or would be less than significant,
major revisions of the 2017 EIR would not be required and no further environmental review
under CEQA would be required.
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1 Aesthetics
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Except as provided in Public Resources Code Section 21099, would the project:
a. Have a substantial
adverse effect on a
scenic vista?
EIR Page 4.1-5
through 4.1-7
No No No N/A
b. Substantially damage
scenic resources,
including but not limited
to, trees, rock
outcroppings, and
historic buildings within
a state scenic highway?
EIR Page 4.1-5
through 4.1-7
No No No N/A
c. In non-urbanized areas,
substantially degrade the
existing visual character
or quality of public views
of the site and its
surroundings? (Public
views are those that are
experienced from a
publicly accessible
vantage point). If the
project is in an urbanized
area, would the project
conflict with applicable
zoning and other
regulations governing
scenic quality?
EIR Pages 4.1-2
through 4.1-5
No No No N/A
d. Create a new source of
substantial light or glare
that would adversely
affect daytime or
nighttime views in the
area?
EIR Pages 4.1-7
through 4.1-8
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENT
Section 4.1, Aesthetics, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts
related to aesthetics. The 2017 EIR determined that the 2030 Comprehensive Plan would have
significant but mitigable impacts related to aesthetics. The 2017 EIR states that the project
could potentially substantially degrade the existing visual character or quality of the affected
areas of the city and their surroundings since it would introduce housing on sites previously
used for non-residential purposes and increase the scale of development on existing housing
IMPACT ANALYSIS
AESTHETICS
2 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
sites. Therefore, Mitigation Measure AES-1 would be required and would reduce impacts to a
less than significant level.
The 2017 EIR found that the 2030 Comprehensive Plan would not significantly alter public
viewsheds, view corridors, or scenic resources, and would not create a new source of
substantial light or glare which would adversely affect day or nighttime views in the area. These
impacts were found to be less than significant.
Table 5 lists the mitigation measure from the 2017 EIR related to aesthetics.
Table 5 2017 EIR Mitigation Measures: Aesthetics
Mitigation
Measure # Mitigation Text
Impact AES-1: Implementation of the proposed Plan would have the potential to substantially degrade the existing visual
character or quality of the area and its surroundings. (Potentially Significant and Mitigable)
AES-1 To ensure that increased residential densities would not degrade the visual character or quality of the area,
the proposed Plan shall include policies that address the following topics:
High-quality building and site design.
Compatibility with surrounding development and public spaces.
Enhancement of existing commercial centers.
Requirements for landscaping and street trees.
Preservation and creation of a safe and inviting pedestrian environment.
Appropriate building form, massing, and setbacks.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project have a substantial adverse effect on a scenic vista?
An adverse effect would occur if a proposed plan or project would block or otherwise damage
the scenic vista upon implementation. The City does not contain designated scenic views or
scenic vistas. However, Palo Alto identifies the backdrop of forested hills to the southwest and
San Francisco Bay to the northeast as views that are character-defining features of the city,
including the East Bay hills and the Santa Cruz Mountains (City of Palo Alto 2016).
The proposed HEU involves policies or programs that could increase allowed height (an
estimated additional 10 to 35 feet of height in some zoning districts) and floor area of
development in the city. The proposed HEU involves numerous programs and policies to
facilitate the development of housing in Palo Alto. However, areas proposed for development
were also analyzed for development in the 2017 EIR. Overall, the proposed HEU would result in
665 more residential units compared to what was analyzed in the 2017 EIR. As discussed in the
2017 EIR, future development facilitated by the 2030 Comprehensive Plan would be required to
comply with design guidelines such as the El Camino Real Design Guidelines which address site,
building, and landscaping design issues; South of Forest Avenue Coordinated Area Plan
guidelines which provides planning policies, development regulations, and design guidelines for
the South Forest Area; and the Downtown Urban Design Plan which includes conceptual
designs for specific locations and offers examples of desirable architectural and landscape
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treatments. These guidelines and standards would also generally apply to development under
the HEU. Furthermore, future multi-family development would be subject to the City’s
Architectural Review Board and/or designed in accordance with objective multi-family design
standards, to ensure that visual resources in Palo Alto are protected through compliance with
applicable development standards. However, consistent with what was analyzed in the 2017
EIR, the proposed HEU would introduce housing on sites previously used for non-residential
purposes, such as in ROLM and GM zones, and would increase the scale of development on
some existing housing sites, leading to newer and larger structures.
Nonetheless, even with potentially increased allowed height limits, development facilitated
under the proposed HEU compared to what is currently allowed would not substantially block
views, as most views are already fully or intermittently impeded by urban development,
including mature trees and existing buildings, and urbanized areas do not offer near or far field
views of scenic vistas. Therefore, an increase in height would not directly or substantially block
views. This impact would be less than significant and would be generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project substantially damage scenic resources, including but not limited to, trees,
rock outcroppings, and historic buildings within a state scenic highway?
While there are no officially designated State scenic highways in Palo Alto, the City identifies
several scenic routes, including Sand Hill Road, University Avenue, Embarcadero Road, Page Mill
Road, Oregon Expressway, I-280, Arastradero Road (west of Foothill Expressway), Junipero
Serra Boulevard/Foothill Expressway, and Skyline Boulevard as having high scenic value (City of
Palo Alto 2016). The proposed rezoning that would occur under the proposed HEU would allow
for increased residential density in RM-20, RM-30, CN, CC, and CS zones, and would allow for
residential uses in non-residential zones such as ROLM and GM zones. Overall, the proposed
HEU would result in 665 more units compared to what was analyzed in the 2017 EIR, which
could affect scenic views toward scenic routes. However, the housing inventory sites are all
located in areas that are already developed, and development would occur on underutilized or
non-vacant sites. Furthermore, development within the urbanized areas of the town such as
the Downtown area has already been planned to reinforce the existing development pattern.
Since there are no State-designated scenic highways in Palo Alto, the HEU would not facilitate
development that would substantially damage scenic resources within a state scenic highway.
Future multi-family development would be subject to the city’s Major Architectural Review,
which would help ensure that development complies with the applicable design guidelines and
development standards, including protection of scenic resources. Or, if projects qualify for
streamlined review, multifamily projects would be subject to objective design standards that
aim to create high-quality design and compatibility with surrounding uses and character.
Therefore, this impact would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
IMPACT ANALYSIS
AESTHETICS
2 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
c. In non-urbanized areas, substantially degrade the existing visual character or quality of
public views of the site and its surroundings? (Public views are those that are experienced
from a publicly accessible vantage point). If the project is in an urbanized area, would the
project conflict with applicable zoning and other regulations governing scenic quality?
The proposed HEU includes goals, policies, and programs to encourage housing in Palo Alto.
The proposed rezoning that would occur under the proposed HEU would allow for increased
residential density in RM-20, RM-30, CN, CC, and CS zones, and would allow for residential uses
in non-residential zones such as ROLM and GM zones. Overall, the proposed HEU would result
in 665 more units compared to what was analyzed in the 2017 EIR. Additional residential
development could result on other sites in urbanized areas of the city as a result of new
incentives in the HIP. However, future development would be subject to the city’s Major
Architectural Review which includes a hearing and recommendation by the Architectural
Review Board on whether the individual project is consistent with the findings for Architectural
Review outlined in PAMC Section 18.76.020. Or, if projects qualify for streamlined review,
multifamily projects would be subject to objective design standards that aim to create high-
quality design and compatibility with surrounding uses and character. This process aims to
promote orderly and harmonious development in the city and promote visual environments
that are of high aesthetic quality and variety and which, at the same time, are considerate of
each other. Additionally, future development in locations within specific area plans would be
required to adhere to development guidelines outlined within the respective area plans.
Although the proposed HEU would introduce housing on sites previously used for non-
residential purposes and increase the height and scale of development on existing underutilized
sites, as with the 2017 EIR, future development would be required to comply with policies L-1.1,
L-6.1, L-4.2, and N-2.1 of the 2030 Comprehensive Plan, adopted in compliance with Mitigation
Measure AES-1 of the 2017 EIR, which would ensure that increased residential densities would
not degrade the visual character or quality of the area. Therefore, this impact would be less
than significant with mitigation, and would be generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
d. Would the project create a new source of substantial light or glare that would adversely
affect daytime or nighttime views in the area?
Palo Alto is an urbanized city with commensurate level of light and glare. Development
facilitated by the project would, in large part, occur as infill on already developed parcels within
existing neighborhoods. New lighting could occur on buildings for safety and in pedestrian
walkways, and light could be emitted from interior sources through windows on upper stories
of tall buildings. The main source of glare would likely be from the sun shining on reflective or
light-colored building materials and glazing.
Development facilitated by the proposed HEU would occur as redevelopment of existing built
and underutilized sites. When facilities such as parking lots are replaced with buildings, these
replacements may reduce nighttime sources of light, because parking lots are often more
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brightly lit during the nighttime than most buildings. Development of underutilized parcels may
result in new light sources, but they would likely be congruous with nearby light sources (e.g.,
lighting from residential windows). Furthermore, as the development facilitated by the project
would be residential units, light from windows would be mostly filtered or obscured by window
coverings. Light spillover from exterior residential lighting is typically blocked by adjacent
structures or trees.
Furthermore, future development would be required to comply with PAMC Section 18.40.250,
which outlines guidelines for building exterior lighting and downward illumination; interior
lighting; unnecessary continued illumination; and timing devices and dimmers. Additionally,
future commercial and multi-family development would be subject to the city’s Major
Architectural Review which would ensure that all development comply with the applicable
design guidelines and development standards, including lighting and glare.
Overall, new residential development would be in existing residential neighborhoods or along
commercial corridors where sources of light and glare already exist. Development under the
proposed HEU would not create new sources of substantial light or glare that would adversely
affect daytime or nighttime views in the area and the impact therefore would be less than
significant. Therefore, this impact would be less than significant, and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
The project would have less than significant impacts on aesthetic resources, the same as those
identified in the 2017 EIR, with compliance with policies adopted in compliance with Mitigation
Measure AES-1. Therefore, the project would not result in new significant effects not addressed
in the prior EIR, and no new mitigation measures are warranted. This issue does not require
further study in an EIR.
IMPACT ANALYSIS
AESTHETICS
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2 Agriculture and Forestry Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Convert Prime Farmland,
Unique Farmland, Farmland
of Statewide Importance
(Farmland), as shown on
maps prepared pursuant to
the Farmland Mapping and
Monitoring Program of the
California Resources Agency,
to non-agricultural use?
EIR Pages 7-1
through 7-2
No No No N/A
b. Conflict with existing zoning
for agricultural use or a
Williamson Act contract?
EIR Pages 7-1
through 7-2
No No No N/A
c. Conflict with existing zoning
for, or cause rezoning of,
forest land (as defined in
Public Resources Code
Section 12220(g));
timberland (as defined by
Public Resources Code
Section 4526); or timberland
zoned Timberland
Production (as defined by
Government Code Section
51104(g))?
EIR Pages 7-1
through 7-2
No No No N/A
d. Result in the loss of forest
land or conversion of forest
land to non-forest use?
EIR Pages 7-1
through 7-2
No No No N/A
e. Involve other changes in the
existing environment which,
due to their location or
nature, could result in
conversion of Farmland to
non-agricultural use or
conversion of forest land to
non-forest use?
EIR Pages 7-1
through 7-2
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR addresses agricultural and forestry resources in Chapter 7, CEQA-Mandated
Sections. The 2017 EIR found that the implementation of the 2030 Comprehensive Plan would
have no impacts related to agricultural and forestry resources.
IMPACT ANALYSIS
AGRICULTURE AND FORESTRY RESOURCES
3 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
PROJECT-SPECIFIC IMPACTS
a. Would the project convert Prime Farmland, Unique Farmland, Farmland of Statewide
Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping
and Monitoring Program of the California Resources Agency, to non-agricultural use?
Although there are approximately nine acres of Prime Farmland and 11 acres of Unique
Farmland within Palo Alto, none of the sites in the Sites Inventory or areas proposed to be
rezoned are located on agricultural land. The proposed HEU would facilitate increased housing
on non-vacant and underutilized sites that are in urbanized areas. Therefore, the project would
not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-
agricultural use, and there would be no impact, generally the same as the impact analyzed in
the 2017 EIR for the 2030 Comprehensive Plan. Because would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
b. Would the project conflict with existing zoning for agricultural use, or a Williamson Act
contract?
According to the 2017 EIR, there are a total of 24 properties under the Williamson Act Contract.
The proposed HEU would facilitate increased housing on non-vacant and underutilized sites
that are in urbanized areas and would not involve changes to existing agricultural land or
conflict with a Williamson Act Contract. Therefore, there would be no impact, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as
defined in Public Resources Code Section 12220(g)), timberland (as defined by Public
Resources Code Section 4526), or timberland zoned Timberland Production (as defined by
Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest
use?
e. Would the project involve other changes in the existing environment, which, due to their
location or nature, could result in conversion of Farmland to non-agricultural use?
According to the 2017 EIR and the California Department of Forestry and Fire Protection (CAL
FIRE), forest lands are primarily located in the southern foothills. CAL FIRE also shows scattered,
isolated forestland within urbanized areas of the city. However, these areas are contained
within parks, creek corridors, and built-out residential neighborhoods. No forest land,
timberland, or timberland zoned Timberland Production are proposed for redevelopment,
rezoning, or land use changes by the proposed HEU. The proposed HEU would facilitate
increased housing only on non-vacant and underutilized sites that are in urbanized areas.
Therefore, there would be no impact, generally the same as the impact analyzed in the 2017
EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially more
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severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
CONCLUSION
The project would have less than significant impacts on agriculture or forestry resources, the
same as those identified in the 2017 EIR. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
AGRICULTURE AND FORESTRY RESOURCES
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3 Air Quality
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Conflict with or obstruct
implementation of the
applicable air quality
plan?
EIR Pages 4.2-2
through 4.2-13
No No No No
b. Result in a cumulatively
considerable net
increase of any criteria
pollutant for which the
project region is non-
attainment under an
applicable federal or
state ambient air quality
standard?
EIR Pages 4.2-13
through 4.2-21
No No No No
c. Expose sensitive
receptors to substantial
pollutant
concentrations?
EIR Pages 4.2-22
through 4.2-29
No No No No
d. Result in other emissions
(such as those leading to
odors) adversely
affecting a substantial
number of people?
EIR Pages 4.2-29
through 4.2-31
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.2, Air Quality, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts
related to air quality. The 2017 EIR found that implementation of the 2030 Comprehensive Plan
could conflict with or obstruct the implementation of the 2010 Bay Area Clean Air Plan.
Although Scenario 6 was found to result in a lower vehicle miles traveled (VMT) per capita and
a lower VMT per service population than under existing conditions at the time, it could not be
verified whether the 2030 Comprehensive Plan would aid or hinder implementation of control
measures outlined in the 2010 Bay Area Clean Air Plan. Therefore, Mitigation Measure AIR-1
would be required to reduce impacts to a less than significant level.
The 2017 EIR also found that the 2030 Comprehensive Plan could violate an air quality
standard; contribute substantially to an existing or project air quality violation; and/or result in
a cumulatively considerable net increase of any criteria pollutant for which the project region is
nonattainment under an applicable federal or State ambient air quality standard, resulting in
significant and unavoidable impacts. Even with implementation of mitigation measures AIR-2a
through 2d, impacts would be significant since future development projects would contribute
to increases in concentrations of air pollutants.
IMPACT ANALYSIS
AIR QUALITY
3 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
The 2017 EIR found that implementation of the 2030 Comprehensive Plan could expose
sensitive receptors to substantial concentrations of Toxic Air Contaminants (TACs), and
mitigation measures AIR-3a through 3d would be required to reduce impacts to a less than
significant level. Additionally, the implementation of the 2030 Comprehensive Plan could
expose a substantial number of people to objectionable odors. Therefore, mitigation measure
AIR-4 would be required to reduce odor impacts to a less than significant level.
Table 6 lists the mitigation measures from the 2017 EIR related to air quality.
Table 6 2017 EIR Mitigation Measures: Air Quality
Mitigation
Measure # Mitigation Text
Impact AIR-1: Without inclusion of air quality policies, implementation of the proposed Plan could conflict with or
obstruct implementation of the applicable air quality plan. (Significant and Mitigable)
AIR-1 To ensure consistency with the 2010 Bay Area Clean Air Plan, the proposed Plan shall include policies
that address the following topics:
Reduction in emissions of particulates from automobiles, manufacturing, construction activity, and
other sources (e.g. dry cleaning, wood burning, landscape maintenance).
Support for regional, State, and federal programs that improve air quality.
Support for transit, bicycling, and walking.
Mix of uses (e.g. housing near employment centers) and development types (e.g. infill) to reduce the
need to drive.
Impact AIR-2: Implementation of the proposed Plan could violate an air quality standard; contribute substantially to an
existing or project air quality violation; and/or result in a cumulatively considerable net increase of any criteria pollutant
for which the Project region is nonattainment under an applicable federal or State ambient air quality standard (including
releasing emissions which exceed quantitative thresholds for ozone precursors). (Significant and Unavoidable)
AIR-2a As part of the City’s development approval process, the City shall require applicants for future
development projects to comply with the current BAAQMD basic control measures for reducing
construction emissions of PM10 (Table 8-1, Basic Construction Mitigation Measures Recommended for
All Proposed Projects, of the BAAQMD CEQA Guidelines).
AIR-2b Prior to issuance of construction permits, development project applicants that are subject to CEQA and
have the potential to exceed the BAAQMD screening-criteria listed in the BAAQMD CEQA Guidelines
shall prepare and submit to the City of Palo Alto a technical assessment evaluating potential project
construction-related air quality impacts. The evaluation shall be prepared in conformance with BAAQMD
methodology in assessing air quality impacts. If construction related criteria air pollutants are
determined to have the potential to exceed the BAAQMD thresholds of significance, as identified in the
BAAQMD CEQA Guidelines, the City of Palo Alto shall require that applicants for new development
projects incorporate mitigation measures (Table 8-2, Additional Construction Mitigation Measures
Recommended for Projects with Construction Emissions Above the Threshold, of the BAAQMD CEQA
Guidelines or applicable construction mitigation measures subsequently approved by BAAQMD) to
reduce air pollutant emissions during construction activities to below these thresholds. These identified
measures shall be incorporated into all appropriate construction documents (e.g., construction
management plans) submitted to the City and shall be verified by the City’s Planning and Community
Environment Department.
AIR-2c To ensure that development projects that have the potential to exceed the BAAQMD screening criteria
air pollutants listed in the BAAQMD CEQA Guidelines reduce regional air pollutant emissions below the
BAAQMD thresholds of significance, the proposed Plan shall include policies that address the following
topic:
Require compliance with BAAQMD requirements, including BAAQMD CEQA Guidelines
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Mitigation
Measure # Mitigation Text
AIR-2d Implement Mitigation Measure TRANS-1a. In addition, to reduce long-term air quality impacts by
emphasizing walkable neighborhoods and supporting alternative modes of transportation., the
proposed Plan shall include policies that address the following topic:
Enhanced pedestrian and bicycle connections between commercial and mixed-use centers.
Impact AIR-3: Implementation of the proposed Plan would expose sensitive receptors to substantial concentrations of air
pollution. (Significant and Mitigable)
AIR-3a The City of Palo Alto shall update its CEQA Procedures to require that future non-residential projects
within the city that: 1) have the potential to generate 100 or more diesel truck trips per day or have 40
or more trucks with operating diesel powered TRUs, and 2) are within 1,000 feet of a sensitive land use
(e.g., residential, schools, hospitals, nursing homes), as measured from the property line of a proposed
project to the property line of the nearest sensitive use, shall submit a health risk assessment (HRA) to
the City of Palo Alto prior to future discretionary Project approval or shall comply with best practices
recommended for implementation by the BAAQMD. The HRA shall be prepared in accordance with
policies and procedures of the State Office of Environmental Health Hazard Assessment and the Bay
Area Air Quality Management District. If the HRA shows that the incremental cancer risk exceeds the
BAAQMD significance thresholds, the applicant will be required to identify and demonstrate that
mitigation measures are capable of reducing potential cancer and noncancer risks to an acceptable
level, including appropriate enforcement mechanisms.
Mitigation measures and best practices may include but are not limited to:
Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible.
Electrifying warehousing docks.
Requiring use of newer equipment and/or vehicles.
Restricting off-site truck travel through the creation of truck routes.
Mitigation measures identified in the project-specific HRA shall be identified as mitigation measures in
the environmental document and/or incorporated into the site development plan as a component of a
proposed project.
AIR-3b To ensure that new industrial and warehousing projects with the potential to generate new stationary
and mobile sources of air toxics that exceed the BAAQMD project level and/or cumulative significance
thresholds for toxic air contaminants and PM2.5 listed in the BAAQMD CEQA Guidelines reduce
emissions below the BAAQMD thresholds of significance, the proposed Plan shall include policies that
address the following topic:
Require compliance with BAAQMD requirements, including BAAQMD CEQA Guidelines.
AIR-3c The City of Palo Alto shall update its CEQA Procedures to require that residential and other sensitive
land use projects (e.g., hospitals, nursing homes, and day care centers) that are subject to CEQA and are
not classified as exempt within 1,000 feet of a major sources of TACs (e.g., warehouses, industrial areas,
freeways, and roadways with traffic volumes over 10,000 vehicle per day), as measured from the
property line of the project to the property line of the source/edge of the nearest travel lane, shall
submit a health risk assessment (HRA) to the City of Palo Alto prior to future discretionary Project
approval or shall comply with best practices recommended by the BAAQMD.
The HRA shall be prepared in accordance with policies and procedures of the State Office of
Environmental Health Hazard Assessment (OEHHA) and the BAAQMD. The latest OEHHA guidelines shall
be used for the analysis, including age sensitivity factors, breathing rates, and body weights appropriate
for children age zero to 16 years. If the HRA exceeds the BAAQMD significance thresholds, the applicant
will be required to identify and demonstrate that mitigation measures are capable of reducing potential
cancer and non-cancer risks to an acceptable level (i.e., below 10 in one million or a hazard index of 1.0),
including appropriate enforcement mechanisms.
Measures and/or best practices to reduce risk may include but are not limited to:
Air intakes located away from high volume roadways and/or truck loading zones.
Heating, ventilation, and air conditioning systems of the buildings provided with appropriately sized
Maximum Efficiency Rating Value (MERV) filters.
IMPACT ANALYSIS
AIR QUALITY
3 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Mitigation
Measure # Mitigation Text
Mitigation measures identified in the HRA and best practices shall be incorporated into the site
development plan as a condition of approval. The air intake design and MERV filter requirements shall
be noted and/or reflected on all building plans submitted to the City and shall be verified by the City.
AIR-3d Amend the Palo Alto Municipal Code to require applicants for new ministerial projects, or new
discretionary projects that are exempt from CEQA, within 1,000 feet of a major sources of TACs (e.g.,
warehouses, industrial areas, freeways, and roadways with traffic volumes over 10,000 vehicle per day),
as measured from the property line of the project to the property line of the source/edge of the nearest
travel lane, to either submit an HRA showing that BAAQMD significance thresholds would not be
exceeded, or provide a filtration system capable of filtering out 90 percent of fine inhalable particulates
and diesel particulate matter.
Impact AIR-4: Implementation of the proposed Plan could create or expose a substantial number of people to
objectionable odors unless policies are integrated into the proposed Plan. (Significant and Mitigable)
AIR-4 To reduce odor impacts, the proposed Plan shall include policies that address the following topic:
Buffers and other mitigation methods to avoid human health impacts from sources of odor and/or
toxic air contaminants.
Source: City of Palo Alto 2016
BAAQMD SIGNIFICANCE THRESHOLDS
This analysis uses the Bay Area Air Quality Management District’s (BAAQMD’s) May 2017 CEQA
Air Quality Guidelines to evaluate air quality. The plan-level thresholds specified in the May
2017 BAAQMD CEQA Air Quality Guidelines were used to determine whether the proposed
HEU’s impacts would exceed the thresholds identified in CEQA Guidelines Appendix G.
CONSISTENCY WITH AIR QUALITY PLAN
Under BAAQMD’s methodology, a determination of consistency with CEQA Guidelines
thresholds should demonstrate that a project:
1. Supports the primary goals of the 2017 Clean Air Plan
2. Includes applicable control measures from the 2017 Clean Air Plan
3. Does not disrupt or hinder implementation of any 2017 Clean Air Plan control measures
CONSTRUCTION EMISSIONS THRESHOLDS
The BAAQMD’s May 2017 CEQA Air Quality Guidelines have no plan-level significance
thresholds for construction air pollutants emissions. However, they do include project-level
screening and emissions thresholds for temporary construction-related emissions of air
pollutants. These thresholds represent the levels at which a project’s individual emissions of
criteria air pollutants or precursors would result in a cumulatively considerable contribution to
the San Francisco Bay Area Air Basin’s (SFBAAB) existing air quality conditions and are discussed
in detail below (BAAQMD 2017a). Construction emissions associated with plan implementation
are discussed qualitatively to evaluate potential air quality impacts.
The BAAQMD developed screening criteria in the 2017 CEQA Air Quality Guidelines to provide
lead agencies and project applicants with a conservative indication of whether a project could
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result in potentially significant air quality impacts. The screening criteria for residential land
uses are shown in Table 7.
Table 7 BAAQMD Criteria Air Pollutant Screening Levels
Land Use Type
Operational Criteria
Pollutant Screening Size (du)
Construction Criteria
Pollutant Screening Size (du)
Single-family 325 (NOX) 114 (ROG)
Apartment, low-rise 451 (ROG) 240 (ROG)
Apartment, mid-rise 494 (ROG) 240 (ROG)
Apartment, high-rise 510 (ROG) 249 (ROG)
Condo/townhouse, general 451 (ROG) 240 (ROG)
Condo/townhouse, high-rise 511 (ROG) 252 (ROG)
Mobile home park 450 (ROG) 114 (ROG)
Retirement community 487 (ROG) 114 (ROG)
Congregate care facility 657 (ROG) 240 (ROG)
du = dwelling unit; NOX = oxides of nitrogen; ROG = reactive organic gases
Source: BAAQMD 2017a
If a project meets the screening criteria, then the lead agency or applicant would not need to
perform a detailed air quality assessment of their project’s air pollutant emissions. These
screening levels are generally representative of new development on greenfield sites without
any form of mitigation measures taken into consideration (BAAQMD 2017a).
In addition to the screening levels above, several additional factors are outlined in the 2017
CEQA Air Quality Guidelines that construction activities must satisfy for a project to meet the
construction screening criteria:
All basic construction measures from the 2017 CEQA Guidelines must be included in project
design and implemented during construction
Construction-related activities would not include any of the following:
Demolition
Simultaneous occurrence of more than two construction phases (e.g., paving and
building construction would occur simultaneously)
Simultaneous construction of more than one land use type (e.g., project would develop
residential and commercial uses on the same site) (not applicable to high density infill
development)
Extensive material transport (e.g., greater than 10,000 cubic yards of soil import/export)
requiring a considerable amount of haul truck activity
For projects that do not meet the screening criteria above, the BAAQMD construction
significance thresholds for criteria air pollutants, shown in Table 8, are used to evaluate a
project’s potential air quality impacts.
IMPACT ANALYSIS
AIR QUALITY
4 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 8 BAAQMD Criteria Air Pollutant Significance Thresholds
Pollutant
Construction Thresholds
Average Daily Emissions (lbs/day)
Operational Threshold
Average Daily Emissions (lbs/day)
Operational Threshold
Maximum Annual
Emissions (tons/year)
ROG 54 54 10
NOX 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
Fugitive Dust Construction Dust Ordinance or other
Best Management Practices
Not Applicable Not Applicable
lbs = pounds; NOX = oxides of nitrogen; ROG = reactive organic gases; PM2.5 = particulate matter with an aerodynamic diameter equal to or
less than 2.5 microns
Source: BAAQMD 2017a
For all projects in the SFBAAB, the BAAQMD 2017 CEQA Air Quality Guidelines recommends
implementation of the Basic Construction Mitigation Measures listed in Table 8-2 of the
Guidelines (BAAQMD 2017a). For projects that exceed the thresholds in Table 8, the BAAQMD
2017 CEQA Air Quality Guidelines recommends implementation of the Additional Construction
mitigation measures listed in Table 8-3 of the Guidelines (BAAQMD 2017a).
OPERATIONAL EMISSIONS THRESHOLDS
The BAAQMD’s 2017 CEQA Air Quality Guidelines contain specific operational plan-level
significance thresholds for criteria air pollutants. Plans must show the following over the
planning period:
Consistency with current air quality plan control measures, and
A proposed plan’s projected VMT or vehicle trips (either measure may be used) increase is
less than or equal to the plan’s projected population increase.
The current air quality plan is the 2017 Clean Air Plan. If a plan can demonstrate consistency
with both criteria, then impacts would be less than significant.
For project-level thresholds, the screening criteria for operational emissions are shown in
Table 7. For projects that do not meet the screening criteria, the BAAQMD operational
significance thresholds for criteria air pollutants, shown in Table 8, are used to evaluate a
project’s potential air quality impacts.
CARBON MONOXIDE HOTSPOTS
BAAQMD provides a preliminary screening methodology to conservatively determine whether a
proposed project would exceed carbon monoxide (CO) thresholds. If the following criteria are
met, a project would result in a less than significant impact related to local CO concentrations:
The project is consistent with an applicable congestion management program established
by the county congestion management agency for designated roads or highways, regional
transportation plan, and local congestion management agency plans.
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Project traffic would not increase traffic volumes at affected intersections to more than
44,000 vehicles per hour.
Project traffic would not increase traffic volumes at affected intersections to more than
24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited
(e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade
roadway).
A CO hotspot is a localized concentration of CO that is above a CO ambient air quality standard.
The entire Basin is in conformance with state and federal CO standards (BAAQMD 2017c). There
are no current exceedances of CO standards within the BAAQMD jurisdiction and have not had
a CO exceedance in the Bay Area since before 1994.3 For 2019 the Bay Area’s reported
maximum 1-hour and average daily concentrations of CO were 5.6 ppm and 1.7 ppm
respectively (BAAQMD 2019).4 These are well below the respective 1-hour and 8-hour
standards of 20 ppm and 9 ppm. Given the ambient concentrations, which include mobile as
well as stationary sources, a project in the Bay Area would need to emit concentrations three
times the hourly maximum ambient emissions for all sources before project emissions would
exceed the 1-hour standard. Additionally, the project would need to emit seven times the daily
average for ambient concentrations to exceed the 8-hour standards. Typical development
projects, even plan level growth, would not emit the levels of CO necessary to result in a
localized hot spot.
TOXIC AIR CONTAMINANTS
For health risks associated with TAC and PM2.5 emissions, the BAAQMD May 2017 CEQA Air
Quality Guidelines state a project would result in a significant impact if the any of the following
thresholds are exceeded (BAAQMD 2017b):
Non-compliance with Qualified Community Risk Reduction Plan;
Increased cancer risk of > 10.0 in a million;
Increased non-cancer risk of > 1.0 Hazard Index (Chronic or Acute); or
Ambient PM2.5 increase of > 0.3 µg/m3 annual average
ODORS
The BAAQMD provides minimum distances for siting of new odor sources shown in Table 9. A
significant impact would occur if the project would result in other emissions (such as odors)
affecting substantial numbers of people or would site a new odor source as shown in Table 9
within the specified distances of existing receptors.
3 BAAQMD only has records for annual air quality summaries dating back to 1994.
4 Data for 2019 was used as the data for 2020 and 2021 are not currently available.
IMPACT ANALYSIS
AIR QUALITY
4 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 9 BAAQMD Odor Source Thresholds
Odor Source Minimum Distance for Less than Significant Odor Impacts (in miles)
Wastewater treatment plant 2
Wastewater pumping facilities 1
Sanitary Landfill 2
Transfer Station 1
Composting Facility 1
Petroleum Refinery 2
Asphalt Batch Plant 2
Chemical Manufacturing 2
Fiberglass Manufacturing 1
Painting/Coating Operations 1
Rendering Plant 2
Source: BAAQMD 2017a
METHODOLOGY
CONSTRUCTION EMISSIONS
Construction-related emissions are temporary but may still result in adverse air quality impacts.
Construction of development facilitated by the project would generate temporary emissions
from three primary sources: the operation of construction vehicles (e.g., scrapers, loaders,
dump trucks, etc.); ground disturbance during site preparation and grading, which creates
fugitive dust; and the application of asphalt, paint, or other oil-based substances.
At this time, there is not sufficient detail to provide analysis of individual construction projects
that would be facilitated by the project, and thus it would be speculative to analyze project-
level impacts. Rather, consistent with the programmatic nature of the project, construction
impacts for the project are discussed qualitatively and emissions are not compared to the
project-level thresholds.
OPERATION EMISSIONS
Based on plan-level guidance from the BAAQMD 2017 CEQA Air Quality Guidelines, long-term
operational emissions associated with implementation of the proposed project are discussed
qualitatively by comparing the proposed project to the 2017 Clean Air Plan goals, policies, and
control measures. In addition, comparing the rate of increase of plan vehicle trips or VMT and
population is recommended by BAAQMD for determining significance of criteria pollutants. If
the proposed project does not meet either criterion then impacts would be potentially
significant.
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PROJECT-SPECIFIC IMPACT ANALYSIS
a. Would the project conflict with or obstruct implementation of the applicable air quality
plan?
The most current clean air plan, Spare the Air, Cool the Climate: A Blueprint for Clean Air and
Climate Protection in the Bay Area (2017 Clean Air Plan) was adopted by BAAQMD April 2017
(BAAQMD 2017b). The legal impetus for the 2017 Clean Air Plan was to update the previous
2010 Clean Air Plan to comply with State air quality planning requirements as codified in the
California Health & Safety Code. The 2017 Clean Air Plan either has updated or replaced the air
quality plans that were discussed in the 2017 EIR.
The California Clean Air Act requires that air districts create a Clean Air Plan that describes how
the jurisdiction will meet air quality standards. To fulfill State ozone planning requirements, the
2017 Clean Air Plan control strategy includes all feasible measures to reduce emissions of ozone
precursors—ROG and NOX—and reduce transport of ozone and its precursors to neighboring air
basins. The Clean Air Plan builds upon and enhances the BAAQMD’s efforts to reduce emissions
of fine particulate matter and TACs. The 2017 Clean Air Plan does not include control measures
that apply directly to individual development projects. Instead, the control strategy includes
control measures related to stationary sources, transportation, energy, buildings, agriculture,
natural and working lands, waste management, water, and super-GHG pollutants.
The 2017 Clean Air Plan focuses on two paramount goals, both consistent with the mission of
BAAQMD:
Protect air quality and health at the regional and local scale by attaining all national and
state air quality standards and eliminating disparities among Bay Area communities in
cancer health risk from TACs; and
Protect the climate by reducing Bay Area GHG emissions to 40 percent below 1990 levels by
2030, and 80 percent below 1990 levels by 2050
Under BAAQMD’s methodology, a determination of consistency with the 2017 Plan should
demonstrate that a project:
Supports the primary goals of the air quality plan
Includes applicable control measures from the air quality plan
Does not disrupt or hinder implementation of any air quality plan control measures
A project that would not support the 2017 Clean Air Plan’s goals would not be considered
consistent with the 2017 Clean Air Plan. Table 10 shows project consistency with applicable
control measures from the 2017 Clean Air Plan.
IMPACT ANALYSIS
AIR QUALITY
4 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 10 Project Consistency with Applicable 2017 Clean Air Plan Control Measures
Control Measures Consistency
Transportation
TR9: Bicycle and Pedestrian Access and
Facilities. Encourage planning for bicycle and
pedestrian facilities in local plans, e.g., general
and specific plans, fund bike lanes, routes, paths
and bicycle parking facilities.
Consistent: The proposed HEU would facilitate development of
increased housing compared to the 2030 Comprehensive Plan within
urbanized sites and in areas such as along El Camino Real, the California
Avenue area, the Downtown area, near Bayshore Road, and in
underutilized commercial areas. These areas are mostly near or adjacent
to transportation corridors currently served by Class I, II, and III bicycle
lanes such as University Avenue, Bryant Street, California Avenue, and
Bayshore Road, which would encourage the use of bicycles and reduce
reliance on single-occupancy vehicles. Future residents would also be
able to utilize bicycle parking facilities around the city which would
encourage residents to bicycle and walk to transit and services (City of
Palo Alto 2012).
Energy
EN2: Decrease Electricity Demand. Work with
local governments to adopt additional energy-
efficiency policies and programs. Support local
government energy efficiency program via best
practices, model ordinances, and technical
support. Work with partners to develop
messaging to decrease electricity demand during
peak times.
Consistent. Development facilitated by the project would be required to
comply with the PAMC Chapters 16.14 (California Green Building
Standards Code) and 16.17 (California Energy Code), which mandates
the implementation of the City’s sustainability and energy efficiency
measures. Newly constructed buildings would be required to comply
with the City’s All-Electric Mandate which requires an all-electric
building design for single-family, low-rise multi-family, and non-
residential development (City of Palo Alto 2022a). Although the
inclusion of all-electric construction would increase electricity demand,
electricity would be provided by City of Palo Alto Utilities (CPAU), which
has provided 100 percent carbon neutral electricity since 2013 (City of
Palo Alto 2022b).
Buildings
BL1: Green Buildings. Collaborate with partners
such as KyotoUSA to identify energy-related
improvements and opportunities for on-site
renewable energy systems in school districts;
investigate funding strategies to implement
upgrades. Identify barriers to effective local
implementation of the CALGreen (Title 24)
statewide building energy code; develop
solutions to improve
implementation/enforcement. Work with
ABAG’s BayREN program to make additional
funding available for energy-related projects in
the buildings sector. Engage with additional
partners to target reducing emissions from
specific types of buildings.
Consistent: Development facilitated by the project would be required to
comply with the energy and sustainability standards of Title 24
(including the California Energy Code and CALGreen) and the City’s
associated amendments that are in effect at that time. For example, the
current 2022 CALGreen standards require a minimum of 65 percent
diversion of construction and demolition debris while the City’s
Construction and Demolition Debris Diversion Ordinance (PAMC Section
16.14.260) requires a minimum of 80 percent diversion for projects with
a valuation of $25,000 or greater. Future development would be
required to comply with the most recent Title 24 standards, which are
updated every three years and become increasingly more stringent over
time. Future development would also be subject to the Reach Code
which would requires all-electric building design for single-family, low-
rise multi-family, and non-residential development. Pursuant to Section
16.14.420 of the PAMC, new multi-family residences would be required
to provide at least one Electric Vehicle Supply Equipment (EVSE) Ready
outlet or EVSE installed for each residential unit in the structure for
residential parking, and would be required to provide Conduit Only,
EVSE Ready Outlet, or EVSE installed for at least 25 percent of guest
parking spaces, among which at least 5 percent shall be EVSE installed.
Future development facilitated by the project would be required to
comply with the most updated EV requirements in both the City’s Reach
Code and Title 24 at the time of construction.
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Control Measures Consistency
Water
WR2: Support Water Conservation. Develop a
list of best practices that reduce water
consumption and increase on-site water
recycling in new and existing buildings;
incorporate into local planning guidance.
Consistent: Future development that needs new or expanded water
service would be required to comply with the San Francisco Public
Utilities Commission’s (SFPUC) and CALGreen’s water efficiency
regulations, and the State’s Model Water Efficiency Landscape
Ordinance to reduce indoor and outdoor water use.
Source: BAAQMD 2017b
As shown in Table 10, the project would be consistent with the applicable measures as
development facilitated by the project would be required to comply with the latest Title 24
regulations and would increase density along transportation corridors and in the downtown
area, allowing for greater use of alternative modes of transportation. Development facilitated
by the project would not contain elements that would disrupt or hinder implementation of a
2017 Clean Air Plan control measures. Therefore, the project would be consistent with the 2017
Clean Air Plan.
PROJECT VEHICLE TRIP AND POPULATION GROWTH
According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air
pollutants and precursors includes an assessment of the rate of increase of either the plan VMT
or vehicle trips versus population growth. As discussed above under Environmental Setting, to
result in a less than significant impact, the analysis must show that either the project’s
projected VMT or vehicle trip increase would be less than or equal to its projected population
increase. As shown in Table 11, vehicle trips associated with project buildout would increase by
approximately 16.2 percent over baseline 2015 conditions and would not exceed the rate of
increase from the forecast population of approximately 24.1 percent over baseline 2015
conditions. Therefore, the project’s vehicle trip increase would not conflict with the BAAQMD’s
2017 CEQA Air Quality Guidelines operational plan-level significance thresholds for criteria air
pollutants and would be consistent with the 2017 Clean Air Plan. Accordingly, impacts would be
less than significant, and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Although not required, the project’s VMT increase was also
assessed and, at 24.4 percent, was roughly equal to the rate of increase in population.
Table 11 Increase in Population Compared to Vehicle Trips Under Project
Scenario Baseline (2015)
2023-2031 Housing
Element Update
(Proposed Project) Net Increase Percent Change
Population 69,537 86,277 16,740 24.1%
Vehicle Trips 96,097 111,636 15,539 16.2%
Source: Data provided by Hexagon Transportation Consultants, Inc. 2023
IMPACT ANALYSIS
AIR QUALITY
4 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
b. Would the project violate any air quality standard or contribute substantially to an existing
or projected air quality violation?
CONSTRUCTION
Development facilitated by the proposed HEU would involve activities that result in air
pollutant emissions. Construction activities such as demolition, grading, construction worker
travel, delivery and hauling of construction supplies and debris, and fuel combustion by on-site
construction equipment would generate pollutant emissions. These construction activities
would temporarily create emissions of dust, fumes, equipment exhaust, and other air
contaminants, particularly during site preparation and grading. The extent of daily emissions,
particularly ROGs and NOX emissions, generated by construction equipment, would depend on
the quantity of equipment used and the hours of operation for each project. The extent of
PM2.5 and PM10 emissions would depend upon the following factors: 1) the amount of disturbed
soils; 2) the length of disturbance time; 3) whether existing structures are demolished; 4)
whether excavation is involved; and 5) whether transporting excavated materials offsite is
necessary. Dust emissions can lead to both nuisance and health impacts. According to the 2017
BAAQMD CEQA Air Quality Guidelines, PM10 is the greatest pollutant of concern during
construction (BAAQMD 2017a).
As discussed above under BAAQMD Significance Thresholds, BAAQMD’s 2017 CEQA Air Quality
Guidelines have no plan-level significance thresholds for construction air pollutant emissions
that would apply to the project. However, the guidelines include project-level thresholds for
construction emissions. If an individual project’s construction emissions fall below the project-
level thresholds, the project’s impacts on regional air quality would be individually and
cumulatively less than significant. Mitigation Measure AIR-2b of the 2017 EIR would require
future development that does not meet the BAAQMD construction screening criteria under
Table 7 to conduct individual air quality analysis and compare emissions to BAAQMD
significance thresholds as detailed under Table 8, and to implement mitigation measures to
reduce emissions.
Construction of development envisioned under the project would temporarily increase air
pollutant emissions, possibly creating localized areas of unhealthy air pollution concentrations
or air quality nuisances. Therefore, construction air quality impacts would be potentially
significant. Furthermore, site preparation and grading during construction activities facilitated
by development under the proposed project may cause wind-blown dust that could contribute
particulate matter into the local atmosphere. The BAAQMD has not established a quantitative
threshold for fugitive dust emissions but rather states that projects that incorporate best
management practices (BMPs) for fugitive dust control during construction would have a less-
than-significant impact related to fugitive dust emissions. The BAAQMD has identified feasible
fugitive dust control measures for construction activities. These Basic Construction Mitigation
Measures are recommended for all projects (BAAQMD 2017a). In addition, the BAAQMD and
CARB have regulations that address the handling of hazardous air pollutants such as lead and
asbestos, which could be aerially disbursed during demolition activities. BAAQMD rules and
regulations address both the handling and transport of these contaminants. Mitigation
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Measure AIR-2a of the 2017 EIR would require future development to comply with the
BAAQMD Basic Construction Mitigation Measures to reduce fugitive dust emissions. However,
as discussed in the 2017 EIR, construction impacts would still remain significant and
unavoidable due to the programmatic nature of the project, similar to the 2030 Comprehensive
Plan as analyzed in the 2017 EIR. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
OPERATION
According to the BAAQMD 2017 CEQA Air Quality Guidelines, the threshold for criteria air
pollutants and precursors includes an assessment of the rate of increase of plan VMT or vehicle
trips versus population growth. As discussed above under Environmental Setting, to result in a
less than significant impact, the analysis must show that the project’s projected VMT or vehicle
trips increase would be less than or equal to its projected population increase. Table 11 under
Checklist Question (a) summarizes the net increase in population versus vehicle trips based on
modeling performed by Hexagon Transportation Consultants, Inc. Because the vehicle trips
associated with project buildout would increase by approximately 16.2 percent over baseline
2015 conditions, it would not exceed the rate of increase from the forecast population growth
of approximately 24.1 percent over baseline 2015 conditions. Vehicle trips increase at a lower
percentage because the proposed project would concentrate increased residential units in
proximity to jobs and services to reduce singular vehicle trips and encourage alternative models
of travel. Therefore, impacts concerning criteria pollutants generated from operation of the
project would be less than significant and would be generally the same as for the 2030
Comprehensive Plan as analyzed in the 2017 EIR.
Future development would continue to be required to implement policies N-5.1, N-5.5, T-1.9,
and L-2.2 of the 2030 Comprehensive Plan, adopted in compliance with mitigation measures
AIR-2c and 2d of the 2017 EIR, which would require compliance with BAAQMD requirements
and support for alternative modes of transportation. However, as analyzed in the 2017 EIR,
Scenario 6 would cumulatively contribute to the nonattainment designations (ozone, PM10, and
PM2.5) of the Basin and would have a significant and unavoidable impact by contributing to the
regional air quality problem. Therefore, since the proposed HEU would increase the number of
residential units by 665 units compared to Scenario 6, operational impacts for the proposed
HEU would be slightly increased compared to those identified in the 2017 EIR and would remain
significant and unavoidable. However, similar to the 2017 EIR, development facilitated by the
proposed HEU would place residents in urbanized areas in proximity to services, jobs, and
transit, which would reduce VMT by reducing reliance on single-occupancy vehicles.
Additionally, the prohibition of natural gas and inclusion of all-electric new construction would
reduce the amount of criteria air pollutants, and the required inclusion of EVSE in new multi-
family dwelling units would also further reduce emissions due to increased vehicle efficiency.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
IMPACT ANALYSIS
AIR QUALITY
4 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
c. Would the project result in a cumulatively considerable net increase of any criteria pollutant
for which the project region is non-attainment under an applicable federal or state ambient
air quality standard (including releasing emissions that exceed quantitative thresholds for
ozone precursors)?
CARBON MONOXIDE HOTSPOTS
As discussed above under BAAQMD Significance Thresholds, typical development projects, even
plan level growth, would not emit the levels of CO necessary to result in a localized hotspot.
Therefore, CO hotspots are not discussed further in this analysis. Impacts to CO hotspots would
be less than significant and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
TOXIC AIR CONTAMINANTS
CONSTRUCTION
Construction-related activities would result in short-term emissions of diesel particulate matter
(DPM) exhaust emissions from off-road, heavy-duty diesel equipment for site preparation (e.g.,
excavation, grading, and clearing), building construction, and other miscellaneous activities.
DPM was identified as a TAC by CARB in 1998. The potential cancer risk from the inhalation of
DPM, as discussed below, outweighs the potential non-cancer 5 health impacts (CARB 2021).
Generation of DPM from construction typically occurs in a single area for a short period.
Construction of development facilitated by the project would occur over approximately a
decade, but use of diesel-powered construction equipment in any one area would likely occur
for no more than a few years for an individual project and would cease when construction is
completed in that area. It is impossible to quantify risk without identified specific project
details, timelines, and locations.
Projects developed under the proposed HEU would be required to comply with applicable
BAAQMD regulatory requirements and control strategies and the CARB In-Use Off-Road Diesel
Vehicle Regulation, which are intended to reduce emissions from construction equipment and
activities. Additionally, future development facilitated by the proposed HEU would be required
to comply with Mitigation Measure AQ-2a of the 2017 EIR, requiring implementation of
construction emission measures that would reduce construction-related TACs. According to the
OEHHA, construction of individual projects lasting longer than two months or placed within
1,000 feet of sensitive receptors could potentially expose nearby sensitive receptors to
substantial pollutant concentrations and therefore could result in potentially significant risk
impacts (OEHHA 2015). These projects could exceed BAAQMD’s thresholds of an increased
cancer risk of greater than 10.0 in a million and an increased non-cancer risk of greater than 1.0
Hazard Index (Chronic or Acute). Therefore, construction impacts from TAC emissions would be
5 Non-cancer risks include premature death, hospitalizations and emergency department visits for exacerbated chronic heart
and lung disease, including asthma, increased respiratory symptoms, and decreased lung function (CARB 2021a).
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potentially significant. However, future development would be required to comply with
Mitigation Measure AIR-3a of the 2017 EIR, which outlines requirements for the preparation of
health risk assessments (HRA) and the inclusion of best practices, as well as Policy N-5.6 of the
2030 Comprehensive Plan, adopted in compliance with Mitigation Measure AIR-3b of the 2017
EIR, which would ensure compliance with BAAQMD requirements. Therefore, this impact would
be less than significant with mitigation, and would be generally the same as for the 2030
Comprehensive Plan as analyzed in the 2017 EIR. There would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, and further analysis is not
warranted.
OPERATION
In the Bay Area, there are several urban or industrialized communities where the exposure to
TACs is relatively high in comparison to others. The City of Palo Alto is not located in an
impacted community according to BAAQMD CEQA Guidelines. Sources of TACs include, but are
not limited to, land uses such as freeways and high-volume roadways, truck distribution
centers, ports, rail yards, refineries, chrome plating facilities, dry cleaners using
perchloroethylene, and gasoline dispensing facilities (BAAQMD 2017a). Operation of
development facilitated by the project would not involve these uses, and therefore, would not
be considered a source of TACs. In addition, residences do not typically include new stationary
sources onsite, such as emergency diesel generators. However, if a residential project did
include a new stationary source onsite, it would be subject to BAAQMD Regulation 2, Rule 2
(New Source Review) and require permitting. This process would ensure that the stationary
source does not exceed applicable BAAQMD health risk thresholds. Development facilitated by
the project would be required to comply with the residential indoor air quality requirements in
the Title 24 Building Energy Efficiency Standards, which currently require Minimum Efficiency
Reporting Value 13 (or equivalent) filters for heating/cooling systems and ventilation systems in
residences (Section 150.0[m])). Therefore, this impact would be less than significant, and would
be generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
There would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, and further analysis is not warranted.
PROJECT SITING
Development facilitated by the project would occur under the jurisdiction of BAAQMD. CARB
screening methodology for project siting is used in this analysis. In 2005, CARB issued
recommendations to avoid siting new residences within 500 feet of a freeway, urban roads with
100,000 vehicles/day, or rural roads with 50,000 vehicles/day or close to known stationary TAC
sources (CARB 2005). BAAQMD’s average daily traffic (ADT) threshold is lower, at 10,000
vehicles per day (BAAQMD 2017a).
Development facilitated by the project could place sensitive receptors living in housing within
approximately 500 to 1,000 feet of roadways with more than 10,000 annual average daily
traffic (AADT), and highways or freeways. Examples of roadways with over 10,000 vehicles per
day include US 101, SR 82/El Camino Real, I-280, Middlefield Road, Alma Street, Foothill
Expressway/Junipero Serra Boulevard, University Avenue, Embarcadero Road, Oregon
IMPACT ANALYSIS
AIR QUALITY
5 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Expressway/Page Mill Road, Charleston Road/ Arastradero Road, and San Antonio Road. In
addition, portions of Lytton Avenue, Manhattan Avenue, Arboretum Road, Quarry Road,
Pasteur Drive, California Avenue, Fabian Way, and California Street are also identified as high-
volume roadways (City of Palo Alto 2017a). Additionally, development facilitated by the project
could also place sensitive receptors living in housing in proximity to stationary sources of TACs
such as dry cleaners and gasoline-dispensing facilities. The proposed project would facilitate
increased housing compared to the 2017 EIR which could potentially expose an increased
number of residents to sources of TACs and PM2.5. However, future development would be
required to comply with mitigation measures AIR-3c and 3d identified in the 2017 EIR, which
would require the preparation of HRAs for residential and sensitive land use projects or new
ministerial projects located within 1,000 feet of a major source of TAC. Therefore, this impact
would be less than significant with mitigation, generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because here would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
d. Would the project expose sensitive receptors to substantial pollutant concentrations?
During construction activities, heavy equipment and vehicles would emit odors associated with
vehicle and engine exhaust both during normal use and when idling. However, these odors
would be temporary and transitory and would cease upon completion. Therefore, development
facilitated by the project would not generate objectionable odors affecting a substantial
number of people.
BAAQMD includes odor screening distances for land uses with the potential to generate
substantial odor complaints. Those uses include wastewater treatment plants, landfills or
transfer stations, refineries, composting facilities, confined animal facilities, food
manufacturing, smelting plants, and chemical plants. The proposed HEU includes residential
uses which do not typically generate odors. The 2017 EIR included mitigation to address
impacts associated with placing new residential uses in proximity to odor sources. Although the
proposed project would increase the number of residential units compared to the 2017 EIR,
future development would be required to comply with Policy N-5.4 of the 2030 Comprehensive
Plan, adopted in compliance with Mitigation Measure AIR-4 of the 2017 EIR, which would
reduce the potential for residents to be exposed to odors through buffers and other mitigation
methods. Therefore, this impact would be less than significant with mitigation and would be
generally the same as for the 2030 Comprehensive Plan as analyzed in the 2017 EIR. Because
there would be no new or substantially more severe significant impacts than what was analyzed
in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2030 Comprehensive Plan, future development would continue to
implement Mitigation Measures 2a and 2b, 3a and 3c, as well as policies adopted in compliance
with Mitigation Measures AIR-2c and 2d, 3b, and 4, which would reduce air quality impacts to a
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less than significant level. However, similar to the 2017 EIR, the proposed project could
cumulatively contribute to the nonattainment designations (ozone, PM10, and PM2.5) of the
Basin and would have a significant and unavoidable impact by contributing to the regional air
quality problem. Therefore, the project would not result in new or substantially more severe
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted, but impacts would remain significant and unavoidable. This issue does not require
further study in an EIR.
IMPACT ANALYSIS
AIR QUALITY
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4 Biological Resources
Where was
Impact
Analyzed in the
EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Have a substantial
adverse effect, either
directly or through
habitat modifications, on
any species identified as
a candidate, sensitive, or
special status species in
local or regional plans,
policies, or regulations,
or by the California
Department of Fish and
Wildlife or U.S. Fish and
Wildlife Service?
EIR Pages 4.3-6
through 4.3-8
No No No Yes
b. Have a substantial
adverse effect on any
riparian habitat or other
sensitive natural
community identified in
local or regional plans,
policies, or regulations,
or by the California
Department of Fish and
Wildlife or U.S. Fish and
Wildlife Service?
EIR Pages 4.3-8
through 4.3-9
No No No N/A
c. Have a substantial
adverse effect on state
or federally protected
wetlands (including, but
not limited to, marsh,
vernal pool, coastal, etc.)
through direct removal,
filling, hydrological
interruption, or other
means?
EIR Pages 4.3-8
through 4.3-9
No No No N/A
d. Interfere substantially
with the movement of
any native resident or
migratory fish or wildlife
species or with
established native
resident or migratory
wildlife corridors, or
impede the use of native
wildlife nursery sites?
EIR Page 4.3-9 No No No Yes
IMPACT ANALYSIS
BIOLOGICAL RESOURCES
5 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Where was
Impact
Analyzed in the
EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
e. Conflict with any local
policies or ordinances
protecting biological
resources, such as a tree
preservation policy or
ordinance?
EIR Pages 4.3-10
through 4.3-12
No No No Yes
f. Conflict with the
provisions of an adopted
Habitat Conservation
Plan, Natural Community
Conservation Plan, or
other approved local,
regional, or state habitat
conservation plan?
EIR Page 4.3-12
through 4.3-13;
4.9-15 through
4.9-16
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.3, Biological Resources, of the 2017 EIR found that the 2030 Comprehensive Plan
would not have a substantial adverse effect on special-status species; riparian habitats;
sensitive natural communities identified in local or regional plans, policies, or regulations;
federally protected wetlands; or the movement of any native resident or migratory fish or
wildlife species. Additionally, the 2030 Comprehensive Plan would not conflict with local
policies or ordinances protecting biological resources, such as a tree preservation policy, or an
adopted Habitat Conservation Plan or Natural Community Conservation Plan.
PROJECT-SPECIFIC IMPACTS
a. Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as candidate, sensitive, or special status in local or
regional plans, policies, or regulations, or by the California Department of Fish and Wildlife
or the U.S. Fish and Wildlife Service?
The proposed HEU would substantially affect special-status species if it would allow
development that would remove their habitat such as wetlands or riparian vegetation along
non-channelized creeks. Although the proposed HEU would facilitate 665 more residential units
compared to what was analyzed in the 2017 EIR, the proposed HEU would only increase
residential density on non-vacant and underutilized sites in urbanized areas of the city generally
away from open space preserves and non-channelized creeks and would not directly or
indirectly impact the habitat of special-status species. Additionally, implementation of the
proposed HEU would involve disturbance in the same areas as analyzed in the 2017 EIR
(citywide) and the citywide conditions have not substantially changed since the time of the EIR.
Therefore, this impact would be less than significant, and would be generally the same as the
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impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted .
b. Would the project have a substantial adverse effect on any riparian habitat or other
sensitive natural community identified in local or regional plans, policies, or regulations, or
by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
c. Would the project have a substantial adverse effect on federally protected wetlands as
defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal
pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Similar to what was analyzed in the 2017 EIR, the proposed HEU does not propose development
of open space areas, creeks, or wetlands that would result in impacts to these resources. The
proposed HEU would only increase density on non-vacant and underutilized sites in urbanized
areas of the city. Riparian resources are protected by the City’s tree preservation and
management regulations, the Urban Forest Master Plan, and California Fish and Game Code.
Future projects that affect the bed, bank, or channel of a creek or stream where riparian
vegetation is located would require authorization to do so. Wetlands are protected by the
federal Clean Water Act, and impacts to wetlands as a result of future development facilitated
by the proposed HEU would require a permit from the United States Army Corps of Engineers
(USACE) and the Regional Water Quality Control Board (RWQCB). In addition, implementation
of the proposed HEU would involve disturbance in the same areas as analyzed in the 2017 EIR
(citywide) and the citywide conditions have not substantially changed since the time of the EIR.
Therefore, although the proposed HEU would increase the number of residential units by 665
units compared to what was analyzed in the 2017 EIR, with compliance with existing federal,
State, and local regulations, impacts would be less than significant and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive. Because there would
be no new or substantially more severe impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
d. Would the project interfere substantially with the movement of any native resident or
migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
Although the proposed HEU would increase the number of residential units by 665 units
compared to what was analyzed in the 2017 EIR, it would facilitate development only on non-
vacant and underutilized sites in urbanized areas of the city and would not block or remove
wildlife corridors or interfere with fish or wildlife migration or rearing sites. The proposed HEU
does not envision development in open space areas or within the Baylands area of Palo Alto.
Future projects requiring discretionary approval and with the potential to affect wildlife
corridors in Palo Alto would be assessed and mitigated during project-specific review under the
California Environmental Quality Act (CEQA). In addition, future projects that impact creek bed,
bank, or channel would require authorization from federal and State agencies, including the
USACE, United States Fish and Wildlife Service (USFWS), National Oceanic and Atmospheric
Administration (NOAA) Fisheries, California Department of Fish and Wildlife (CDFW), and
IMPACT ANALYSIS
BIOLOGICAL RESOURCES
5 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
RWQCB, as applicable (City of Palo Alto 2017a). Implementation of the proposed HEU would
also involve disturbance in the same areas as analyzed in the 2017 EIR (citywide) and the
citywide conditions have not substantially changed since the time of the EIR. Therefore, this
impact would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
e. Would the project conflict with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or as defined by the City of Palo Alto’s Tree
Preservation Ordinance (Municipal Code Section 8.10)?
Although the proposed HEU does not explicitly propose the removal of trees, development
facilitated under the proposed HEU could result in the removal of existing trees on private or
public properties. Although the proposed HEU would increase the number of residential units
by 665 units compared to buildout assumed in the 2017 EIR, future development would be
required to comply with the City’s Urban Forest Master Plan; Street Tree Management Plan;
Line Clearing Program; Right Tree, Right Place Program; Tree Protection Ordinance Update
adopted on June 6, 2022; and Chapter 8.10 of the PAMC which outlines requirements for tree
and landscape preservation and management. Therefore, this impact would be less than
significant and would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe impacts
than what was analyzed in the 2017 EIR, further analysis is not warranted.
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
As discussed in the 2017 EIR, although Palo Alto is not in the Santa Clara Valley Habitat
Conservation Plan (HCP)/Natural Community Conservation Plan (NCCP), lands in the Baylands
area of Palo Alto have been identified in the Santa Clara Valley HCP/NCCP as suitable mitigation
lands for impacts to the western burrowing owl caused by development in the Santa Clara
Valley HCP/NCCP Plan Area. Additionally, the Stanford HCP identifies four management zones
according to habitat value for Covered Species. However, the proposed HEU does not include
housing sites within the Baylands area of Palo Alto or within the Stanford HCP limits. The
proposed HEU would also facilitate development on non-vacant and underutilized sites in
urbanized areas where species are not present. Therefore, the proposed HEU would not conflict
with the Santa Clara Valley HCP/NCCP or the Stanford HCP. This impact would be less than
significant and would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
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CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to biological resources which would reduce
impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
BIOLOGICAL RESOURCES
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5 Cultural Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Cause a substantial adverse
change in the significance
of a historical resource
pursuant to §15064.5?
EIR Pages
4.4-2 through
4.4-6
No No No Yes
b. Cause a substantial adverse
change in the significance
of an archaeological
resource pursuant to
§15064.5?
EIR Pages
4.4-7 through
4.4-9
No No No Yes
c. Disturb any human
remains, including those
interred outside of formal
cemeteries?
EIR Pages
4.4-9 through
4.4-10
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.4, Cultural Resources, of the 2017 EIR analyzes the 2030 Comprehensive Plan’s
impacts related to cultural resources. The 2017 EIR found that the 2030 Comprehensive Plan
could adversely affect a historic resource listed or eligible for listing on the National and/or
California Register, or listed on the City’s Historic Inventory, since the City’s historical resource
inventory is out of date, and the City’s ordinance does not explicitly prohibit demolition of
historic resources. Therefore, mitigation measure CULT-1 was required and was found to
reduce impacts to a less than significant level.
The 2017 EIR also found that the 2030 Comprehensive Plan could eliminate important examples
of major periods of California history or prehistory since it could result in the demolition or
modification of an historical resource; permittance of inappropriate new construction adjacent
to an historical resource; or result in the demolition, relocation, or alteration of an
archaeological or paleontological resource. Therefore, mitigation measure CULT-2 was required
and was found to reduce impacts to a less than significant level.
The 2017 EIR also found that buildout in accordance with the 2030 Comprehensive Plan could
cause damage to an important archaeological resource as defined in Section 15064.5 of the
CEQA Guidelines without mitigation to address unknown resources that could be uncovered.
Mitigation Measure CULT-3 was required and was found to reduce impacts to a less than
significant level.
The 2017 EIR found that the 2030 Comprehensive Plan would not disturb any human remains,
including those interred outside of formal cemeteries.
Table 12 lists the mitigation measures from the 2017 EIR related to cultural resources.
IMPACT ANALYSIS
CULTURAL RESOURCES
6 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 12 2017 EIR Mitigation Measures: Cultural Resources
Mitigation
Measure # Mitigation Text
Impact CULT-1: Implementation of the proposed Plan could adversely affect a historic resource listed or eligible for listing
on the National and/or California Register, or listed on the City’s Historic Inventory. (Significant and Mitigable)
CULT-1 To ensure the protection of historic resources listed on the National and/or California Register or the
City’s Historic Resource Inventory, the proposed Plan shall include policies that address the following
topics:
The effectiveness of the Historic Preservation Ordinance in preserving historic resources. Periodic
updates to and maintenance of the City’s Historic Resource Inventory.
Process for including potential historic resources in the City’s Historic Resources Inventory.
Protection of archaeological resources.
Impact CULT-2: Implementation of the proposed Plan could eliminate important examples of major periods of California
history or prehistory. (Significant and Mitigable)
CULT-2 Implement Mitigation Measure CULT-1.
Impact CULT-3: Implementation of the proposed Plan could cause damage to an important archaeological resource as
defined in Section 15064.5 of the CEQA Guidelines. (Significant and Mitigable)
CULT-3 Implement Mitigation Measure CULT-1. In addition, to ensure that future development would not
damage archaeological resources, the proposed Plan shall include policies that address the following
topics:
Archaeological surveys and mitigation plans for future development projects.
Developer compliance with applicable regulations regarding the identification and protection of
archaeological and paleontological deposits.
Adequate tribal consultation and consideration of tribal concerns.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project cause a substantial adverse change in the significance of a historical
resource pursuant to §15064.5?
As discussed in the 2017 EIR, there are over 850 structures/sites in Palo Alto that are identified
as historical resources, including four districts (Green Gables, Greenmeadow Units 1 and 2,
Professorville, and Ramona Street). The proposed HEU includes sites in the Professorville
district and the Ramona Street District, as well as along University Avenue, a historic
thoroughfare as described in the 2017 EIR. However, disturbance would occur in the same
areas as analyzed in the 2017 EIR (citywide) and the citywide conditions have not substantially
changed since the time of the EIR. The proposed HEU does not propose any specific
development. It envisions development including the proposed rezoning of sites for the
potential development of additional housing units to meet the City’s RHNA needs on parcels
that may contain buildings that meet the age threshold for potential historical resources
pursuant to CEQA. Development on these parcels could be proposed by a property owner or
project applicant with or without the City’s adoption of the HEU; still, development associated
with the proposed HEU, similar to development under the 2030 Comprehensive Plan on the
same sites, could result in the material impairment of historical resources, which CEQA
Guidelines Section 15064.5(b)(2)(A) defines as the demolition or alteration in an adverse
manner of those characteristics of a historical resource that convey its historical significance
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and that justify its inclusion in, or eligibility for inclusion in, the CRHR or a local register. Future
development requiring discretionary approval would be subject to separate project-level CEQA
review in order to identify potential impacts to a specific historical resource and incorporate
mitigation measures as needed, including City Council consideration of the potential benefits of
the proposed project and potential significant, unavoidable impacts. Modifications to Inventory
resources Downtown and in Professorville historic districts would be subject to PAMC Chapter
16.49. Future development would also be required to implement policies L-7.1 and L-7.15 of
the 2030 Comprehensive Plan EIR, adopted in compliance with Mitigation Measure CULT-1 of
the 2017 EIR, which would ensure the protection of historic resources listed on the National
and/or California Register or the City’s Historic Resource Inventory, as well as applicable
federal, State, and local laws. Therefore, impacts would be less than significant with mitigation,
and would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, and further analysis is not warranted.
b. Would the project cause a substantial adverse change in the significance of an
archaeological resource pursuant to §15064.5?
Similar to what was assumed in the 2017 EIR, although development under the proposed HEU
would occur on non-vacant and underutilized sites in previously disturbed areas, ground-
disturbing activities such as earthmoving and excavation could still potentially damage and/or
destroy unrecorded archaeological resources in subsurface soils within the housing sites.
Implementation of the proposed HEU would involve disturbance in the same areas as analyzed
in the 2017 EIR (citywide) and the citywide conditions have not substantially changed since the
time of the EIR. Further, future development requiring discretionary approval would be subject
to separate project-level CEQA review in order to identify potential impacts to archaeological
resources and incorporate mitigation measures as needed. Future development would also be
required to implement policies L-7.16 through 7.18 of the 2030 Comprehensive Plan EIR,
adopted in compliance with Mitigation Measure CULT-3 of the 2017 EIR, which would ensure
the protection of archaeological, paleontological, and tribal cultural resources. Therefore,
impacts would be less than significant with mitigation, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
c. Would the project disturb any human remains, including those interred outside of formal
cemeteries?
Similar to what was assumed in the 2017 EIR, although development under the proposed HEU
would occur on non-vacant and underutilized sites in previously disturbed areas, ground-
disturbing activities such as earthmoving and excavation could still potentially disturb human
remains. However, implementation of the proposed HEU would involve disturbance in the
same areas as analyzed in the 2017 EIR (citywide) and the citywide conditions have not
substantially changed since the time of the EIR. Future development would be subject to
federal and State regulations, such as the California Health and Safety Code Section 7050.5,
IMPACT ANALYSIS
CULTURAL RESOURCES
6 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Public Resources Code Section 5097.98, and the California Code of Regulations Section
15064.5(e) (CEQA), which state the mandated procedures of conduct following the discovery of
human remains. Therefore, compliance with the mandatory regulatory procedures would
ensure that potential impacts related to the potential discovery or disturbance of any human
remains accidentally unearthed during construction activities would be less than significant and
would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, development would occur in the same areas as those
analyzed in the 2017 EIR. Further, future development would be required to comply with
federal, State, and local regulations pertaining to cultural resources as well as policies adopted
in compliance with Mitigation Measures CULT-1 and CULT-3 from the 2017 EIR, which would
reduce impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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6 Energy
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New or
Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Result in a potentially
significant
environmental impact
due to wasteful,
inefficient, or
unnecessary
consumption of energy
resources, during
project construction or
operation?
EIR Pages
4.14-33
through
4.14-38
No No No N/A
b. Conflict with or obstruct
a state or local plan for
renewable energy or
energy efficiency?
EIR Pages
4.14-33
through
4.14-38
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.14, Utilities and Service Systems, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to energy. At the time the 2017 EIR was prepared, there were no
separate adopted thresholds for energy use under CEQA, although Guidelines Section 15126.4
required that an “EIR shall describe feasible mitigation measures which could minimize
significant adverse impacts, including where relevant, inefficient and unnecessary consumption
of energy,” and Appendix F provided criteria for consideration of energy conservation.
Checklist questions (a) and (b) in this section are now included in CEQA Guidelines Appendix G.
Lead agencies that use Appendix G as a basis for environmental analysis, including the City of
Palo Alto, now consider energy impacts more explicitly during the initial study of a project.
Changes to the CEQA thresholds subsequent to certification of an EIR do not in themselves
constitute a substantial change or new information of substantial importance that requires
major revisions to the EIR unless new significant impacts or a substantial increase in the
severity of a significant impact would occur.
The 2017 EIR concluded that the 2030 Comprehensive Plan would not substantially increase
electrical or natural gas demands to the extent that new local electrical and natural gas supply
facilities would be required. Additionally, future development would be required to comply
with the California Building Standards Code, Chapters 16.14 and 16.17 of the PAMC, and utilize
modern appliances and equipment, in accordance with the 2012 Appliance Efficiency
Regulations, which would conserve energy. Nonetheless, mitigation measure UTIL-17 would be
required to reduce impacts to a less than significant level.
Table 13 lists the mitigation measures from the 2017 EIR related to energy.
IMPACT ANALYSIS
ENERGY
6 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 13 2017 EIR Mitigation Measures: Energy
Mitigation
Measure # Mitigation Text
Impact UTIL-17: The proposed Plan would not result in a substantial increase in natural gas and electrical service demands
that would require the new construction of energy supply facilities and distribution infrastructure or capacity enhancing
alterations to existing facilities. However, without the adoption of policies in support of energy efficiency and
conservation, the proposed Plan would result in a potentially significant impact, requiring mitigation. (Potentially
Significant and Mitigable)
UTIL-17 To ensure that future development would maximize energy efficiency and conservation the proposed
Plan shall include policies that address the following topics:
Maximized conservation and efficient use of energy.
Continued procurement of carbon-neutral energy.
Investment in cost-effective energy efficiency and energy conservation programs.
Provision of public education programs addressing energy conservation and efficiency.
Use of cost-effective energy conservation measures in City projects and practices.
Adherence to State and federal energy efficiency standards and policies.
Consideration of a transition to a carbon-neutral natural gas supply.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACT ANALYSIS
a. Would the project result in a potentially significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
Energy consumption is directly related to environmental quality in that the consumption of
nonrenewable energy resources releases criteria air pollutant and GHG emissions into the
atmosphere. The environmental impacts of air pollutant and GHG emissions associated with the
project’s energy consumption are discussed in detail in Section 3, Air Quality, and Section 8,
Greenhouse Gas Emissions, respectively.
Palo Alto demonstrates its commitment to energy efficiency and renewable energy via
implementation of CALGreen and State-mandated Energy Efficiency Requirements for new
development and retrofits. The proposed HEU would facilitate development of projects to
encourage housing on non-vacant and underutilized sites in urbanized areas. When proposed,
individual projects would be required, pursuant to the requirements of CALGreen, to comply
with the zero-net energy requirements, where new development combines energy efficiency
and renewable energy generation to consume only as much energy as can be produced on-site
through renewable resources over a specified period. However, development under the
proposed HEU would consume energy during construction and operation, using petroleum fuel,
natural gas, and electricity, as discussed below.
CONSTRUCTION
Energy use during construction associated with future development under the proposed HEU
would be in the form of fuel consumption (e.g., gasoline and diesel fuel) to operate heavy
equipment, light-duty vehicles, machinery, and generators for lighting. Temporary grid power
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may also be provided to construction trailers or electric construction equipment. Energy use
during the construction of individual projects would be temporary in nature, and equipment
used would be typical of construction projects in the region. Construction contractors would be
required to demonstrate compliance with applicable CARB regulations that restrict the idling of
heavy-duty diesel motor vehicles and govern the accelerated retrofitting, repowering, or
replacement of heavy-duty diesel on- and off-road equipment. Construction activities
associated with reasonably foreseeable development under the proposed HEU would be
required to utilize fuel-efficient equipment consistent with federal and State regulations and
would comply with State measures to reduce the inefficient, wasteful, or unnecessary
consumption of energy. In addition, individual projects would be required to comply with
construction waste management practices to divert at least 80 percent of construction and
demolition debris pursuant to PAMC Section 16.14.260. These practices would result in efficient
use of energy during construction of future development under the proposed HEU.
Furthermore, in the interest of both environmental awareness and cost efficiency, construction
contractors would not utilize fuel in a manner that is wasteful or unnecessary. Therefore, future
construction activities associated with development under the proposed HEU would not result
in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary
consumption of energy, and impacts would be less than significant.
OPERATIONAL
Long-term operation of future development under the proposed HEU would require permanent
grid connections for electricity to power internal and exterior building lighting, and heating and
cooling systems. Electricity in Palo Alto is supplied by the City of Palo Alto Utilities (CPAU). As
discussed in the 2017 EIR, forecasting and planning by the CPAU will be able to accommodate
expected net annual average increase in electrical service demand of less than one percent with
the implementation of policies N-7.1 and N-7.4 of the 2030 Comprehensive Plan EIR, adopted in
compliance with Mitigation Measure UTIL-17. Although the proposed HEU would facilitate the
development of 665 more residential units, CPAU’s 10-year electric savings increased from 4.8
percent between 2014 and 2023 to 5.7 percent between 2018 and 2027 showing increased
energy efficiency. Additionally, future development would be required to comply with the City’s
most updated Reach Code and All-Electric Mandate which requires all-electric building design
for single-family, low-rise multi-family, and non-residential development (City of Palo Alto
2022a). This would increase demand for electricity but would decrease demand for natural gas.
Electricity provided by CPAU is 100 percent carbon neutral (City of Palo Alto 2022b).
Development facilitated by the proposed HEU would be subject to the energy conservation
requirements of the California Energy Code (Title 24, Part 6 of the California Code of
Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential
Buildings), the California Green Building Standards Code (CALGreen, Title 24, Part 11 of the
California Code of Regulations). The California Energy Code provides energy conservation
standards for all new and renovated commercial and residential buildings constructed in
California. This code applies to the building envelope, space-conditioning systems, and water-
heating and lighting systems of buildings and appliances and provides guidance on construction
techniques to maximize energy conservation. Minimum efficiency standards are given for a
IMPACT ANALYSIS
ENERGY
6 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
variety of building elements, including appliances; water and space heating and cooling
equipment; and insulation for doors, pipes, walls, and ceilings. The code emphasizes saving
energy at peak periods and seasons and improving the quality of installation of energy
efficiency measures. Furthermore, future development would be required to comply with the
PAMC Chapter 16.17, which mandates the implementation of the Building Energy Efficiency
Standards (California Code of Regulations, Title 24, Part 6). Compliance would include
complying with the most updated rooftop solar requirements at the time of construction.
CALGreen sets targets for energy efficiency, water consumption, dual plumbing systems for
potable and recyclable water, diversion of construction waste from landfills, and use of
environmentally sensitive materials in construction and design, including ecofriendly flooring,
carpeting, paint, coatings, thermal insulation, and acoustical wall and ceiling panels. These
standards for new buildings are designed for energy efficient performance, using clean
electricity, so that the buildings do not result in wasteful, inefficient, or unnecessary
consumption of energy.
The housing inventory sites are located within the city’s urbanized and underutilized sites.
These areas are near or adjacent to transportation corridors as well as Class I, II, and III bicycle
lanes, which would reduce trip distances and encourage the use of alternative modes of
transportation such as bicycling and walking, thereby reducing fuel consumption. These factors
would minimize the potential of the proposed project to result in the wasteful or unnecessary
consumption of vehicle fuels.
Future development would also be required to continue to implement policies N-7.1 and N-7.4
of the 2030 Comprehensive Plan EIR, adopted in compliance with Mitigation Measure UTIL-17
to reduce energy impacts to a less than significant level. As a result, operation of development
projects under the proposed HEU would not result in potentially significant environmental
effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts
would be less than significant with mitigation, and generally the same as the impact analyzed in
the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy
efficiency?
Several State plans as well as the City’s adopted 2030 Comprehensive Plan include energy
conservation and energy efficiency strategies intended to enable the State and the city to
achieve GHG reduction and energy conservation goals. A full discussion of the proposed
project’s consistency with GHG reduction plans is included in Section 8, Greenhouse Gas
Emissions. As shown in Table 14, the project would be consistent with applicable State
renewable energy and energy efficiency plans.
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Table 14 Consistency with State Renewable Energy and Energy Efficiency Plans
Renewable Energy or Energy Efficiency Plan Proposed Project Consistency
Assembly Bill 2076: Reducing Dependence on
Petroleum. Pursuant to AB 2076, the CEC and CARB
prepared and adopted a joint-agency report, Reducing
California’s Petroleum Dependence, in 2003. Included
in this report are recommendations to increase the use
of alternative fuels to 20 percent of on-road
transportation fuel use by 2020 and 30 percent by
2030, significantly increase the efficiency of motor
vehicles, and reduce per capita VMT. One of the
performance-based goals of AB 2076 is to reduce
petroleum demand to 15 percent below 2003 demand.
Consistent. Many of the proposed housing inventory sites located
in areas served by transit, are in proximity to jobs and services, or
are near or adjacent to corridors currently served by Class I, II,
and III bicycle lanes such as University Avenue, Bryant Street,
California Avenue, and Bayshore Road. This which would
encourage the use of alternative modes of transportation such as
walking, transit, and bicycling, thereby reducing VMT and
reducing reliance on single-occupancy vehicles. Further, future
development under the proposed HEU would be subject to the
requirements of the most recent iteration of CALGreen and
locally adopted amendments, which include provisions for
electric vehicle charging infrastructure, reducing dependence on
gasoline powered vehicles.
2019 Integrated Energy Policy Report. The 2019 report
highlights the implementation of California’s innovative
policies and the role they have played in establishing a
clean energy economy, as well as provides more detail
on several key energy policies, including decarbonizing
buildings, increasing energy efficiency savings, and
integrating more renewable energy into the electricity
system.
Consistent. Development facilitated by the project would be
required to comply with PAMC Chapter 16.17, which mandates
the implementation of Title 24. Compliance would include
complying with the most updated rooftop solar requirements at
the time of construction. Future development would also be
required to comply with the City’s most updated Reach Code and
All-Electric Mandate which requires all-electric building design for
single-family, low-rise multi-family, and non-residential
development (City of Palo Alto 2022a). Electricity would be
provided by CPAU, which has provided 100 percent carbon
neutral electricity since 2013 (City of Palo Alto 2022b).
California Renewable Portfolio Standard. California’s
RPS obligates investor-owned utilities, energy service
providers, and community choice aggregators to
procure 33 percent total retail sales of electricity from
renewable energy sources by 2020, 60 percent by 2030,
and 100 percent by 2045.
Consistent. Electricity for future development would be provided
by CPAU which has provided 100 percent carbon neutral
electricity since 2013 (City of Palo Alto 2022b).
Energy Action Plan. In the October 2005, the CEC and
CPUC updated their energy policy vision by adding
some important dimensions to the policy areas
included in the original EAP, such as the emerging
importance of climate change, transportation-related
energy issues, and research and development activities.
The CEC adopted an update to the EAP II in February
2008 that supplements the earlier EAPs and examines
the State’s ongoing actions in the context of global
climate change. The nine major action areas in the EAP
include energy efficiency, demand response, renewable
energy, electricity adequacy/reliability/infrastructure,
electricity market structure, natural gas
supply/demand/infrastructure, transportation fuels
supply/demand/infrastructure,
research/development/demonstration, and climate
change.
Consistent. Future development facilitated by the proposed
project would be required to be constructed in accordance with
the latest iteration of CALGreen, the California Energy Code, and
any locally adopted amendments, which include requirements for
the use of energy-efficient design and technologies as well as
provisions for incorporating renewable energy resources into
building design. Electricity for future development would be
provided by CPAU which has provided 100 percent carbon neutral
electricity since 2013 (City of Palo Alto 2022b). Given these
features, the project would facilitate implementation of the nine
major action areas in the EAP.
IMPACT ANALYSIS
ENERGY
6 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Renewable Energy or Energy Efficiency Plan Proposed Project Consistency
AB 1007: State Alternative Fuels Plans. The State
Alternative Fuels Plan assessed various alternative fuels
and developed fuel portfolios to meet California’s goals
to reduce petroleum consumption, increase alternative
fuels use, reduce GHG emissions, and increase in-State
production of biofuels without causing a significant
degradation of public health and environmental quality.
Bioenergy Action Plan, EO S-06-06. The EO establishes
the following targets to increase the production and
use of bioenergy, including ethanol and biodiesel fuels
made from renewable resources: produce a minimum
of 20 percent of its biofuels in California by 2010, 40
percent by 2020, and 75 percent by 2050.
Consistent. The project would not interfere with or obstruct the
production of biofuels in California. Vehicles used by future
residents would be fueled by gasoline and diesel fuels blended
with ethanol and biodiesel fuels as required by CARB regulations.
Pursuant to Section 16.14.420 of the PAMC, new multi-family
residences would be required to provide at least one EVSE Ready
outlet or EVSE installed for each residential unit in the structure
for residential parking, and would be required to provide Conduit
Only, EVSE Ready Outlet, or EVSE installed for at least 25 percent
of guest parking spaces, among which at least 5 percent shall be
EVSE installed. Future development facilitated by the project
would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at the
time of construction.
Title 24, CCR – Part 6 (Building Energy Efficiency
Standards) and Part 11 (CALGreen). The 2019 Building
Energy Efficiency Standards move toward cutting
energy use in new homes by more than 50 percent and
will require installation of solar photovoltaic systems
for single-family homes and multi-family buildings of
three stories and less. The CALGreen Standards
establish green building criteria for residential and
nonresidential projects. The 2019 Standards include the
following: increasing the number of parking spaces that
must be prewired for electric vehicle chargers in
residential development; requiring all residential
development to adhere to the Model Water Efficient
Landscape Ordinance; and requiring more appropriate
sizing of HVAC ducts.
Consistent. Development facilitated by the project would be
required to comply with PAMC Chapter 16.17, which mandates
the implementation of Title 24.
Furthermore, the City’s 2030 Comprehensive Plan and Sustainability and Climate Action Plan
(S/CAP) also contains goals and policies related to energy efficiency and renewable energy. As
discussed under Table 18 in Section 8, Greenhouse Gas Emissions, the proposed project would
be consistent with recommended goals, policies, and actions in the City’s S/CAP related to
energy efficiency and renewable energy. Table 15 summarizes the project’s consistency with
the applicable 2030 Comprehensive Plan policies. As shown therein, the proposed project
would be consistent with the applicable 2030 Comprehensive Plan policies and therefore would
not conflict with or obstruct a State or local plan for renewable energy or energy efficiency, and
impacts would be less than significant and generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
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Table 15 Project Consistency with Applicable 2030 Comprehensive Plan policies
Policies Project Consistency
Natural Environment Element
Policy N-7.4: Maximize the conservation and
efficient use of energy in new and existing
residences and other buildings in Palo Alto.
Consistent: Future development facilitated by the proposed HEU would
be required to be constructed in accordance with the latest iteration of
CALGreen, the California Energy Code, and any locally adopted
amendments, which include green building practices. Future
development would also be required to comply with the City’s most
updated Reach Code and All-Electric Mandate which requires all-electric
building design for single-family, low-rise multi-family, and non-
residential development (City of Palo Alto 2022a).
Policy N-7.5: Encourage energy efficient lighting
that protects dark skies and promotes energy
conservation by minimizing light and glare from
development while ensuring public health and
safety
Consistent: Future development facilitated by the proposed HEU would
be required to incorporate sustainability considerations into project
design such as energy efficient lighting pursuant to PAMC Section
18.24.100(a). Future development would also be subject to PAMC
Section 18.40.250 which outlines requirements for minimizing light
spillover and glare.
Policy N-7.6: Support the maximum economic
use of solar electric (photovoltaic) and solar
thermal energy, both as renewable supply
resources for the Electric Utility Portfolio and as
alternative forms of local power generation.
Consistent: Development facilitated by the proposed HEU would be
required to comply with the PAMC Chapter 16.17, which mandates the
implementation of Title 24. Compliance would include complying with
the most updated rooftop solar requirements at the time of
construction.
Policy N-7.7: Explore a variety of cost-effective
ways to reduce natural gas usage in existing and
new buildings in Palo Alto in order to reduce
associated greenhouse gas emissions.
Consistent: Future development facilitated by the proposed HEU would
also be required to comply with the City’s most updated Reach Code and
All-Electric Mandate which requires all-electric building design for single-
family, low-rise multi-family, and non-residential development (City of
Palo Alto 2022a). Electricity would be provided by City of Palo Alto
Utilities (CPAU), which has provided 100 percent carbon neutral
electricity since 2013 (City of Palo Alto 2022b).
Policy N-7.8: Support opportunities to maximize
energy recovery from organic materials such as
food scraps, yard trimmings and residual solids
from sewage treatment.
Consistent: Future development facilitated by the proposed HEU would
be required to comply with SB 1383 and recycle organic wastes.
Source: City of Palo Alto 2017b
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations as well as policies adopted in compliance with Mitigation
Measure UTIL-17 pertaining to energy, which would reduce impacts to a less than significant
level. Therefore, the project would not result in new significant effects not addressed in the
prior EIR, and no new mitigation measures are warranted. This issue does not require further
study in an EIR.
IMPACT ANALYSIS
ENERGY
7 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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7 Geology and Soils
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New or
Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Directly or indirectly cause
potential substantial
adverse effects, including
the risk of loss, injury, or
death involving:
1. Rupture of a known
earthquake fault, as
delineated on the most
recent Alquist-Priolo
Earthquake Fault
Zoning Map issued by
the State Geologist for
the area or based on
other substantial
evidence of a known
fault?
EIR Pages 4.5-4
through 4.5-6
No No No N/A
2. Strong seismic ground
shaking?
EIR Pages 4.5-4
through 4.5-6
No No No N/A
3. Seismic-related ground
failure, including
liquefaction?
EIR Pages 4.5-4
through 4.5-6
No No No N/A
4. Landslides? EIR Pages 4.5-4
through 4.5-6
No No No N/A
b. Result in substantial soil
erosion or the loss of
topsoil?
EIR Pages 4.5-8
through 4.5-9
No No No Yes
c. Be located on a geologic
unit or soil that is made
unstable as a result of the
project, and potentially
result in on or offsite
landslide, lateral
spreading, subsidence,
liquefaction, or collapse?
EIR Pages 4.5-7
through 4.5-8
No No No N/A
d. Be located on expansive
soil, as defined in Table
18-1-B of the Uniform
Building Code (1994),
creating substantial risks
to life or property?
EIR Pages 4.5-4
through 4.5-6
No No No Yes
IMPACT ANALYSIS
GEOLOGY AND SOILS
7 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New or
Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
e. Have soils incapable of
adequately supporting the
use of septic tanks or
alternative wastewater
disposal systems where
sewers are not available
for the disposal of
wastewater?
N/A No No No N/A
f. Directly or indirectly
destroy a unique
paleontological resource
or site or unique geologic
feature?
EIR Pages 4.4-7
through 4.4-9
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.5, Geology, Soils, and Seismicity, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to geology and soils. The 2017 EIR found that implementation of the
2030 Comprehensive Plan would result in less than significant impacts associated with risk of
loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground
shaking, seismic-related ground failure (including liquefaction), landslides, and expansive soils.
The 2017 EIR also found that implementation of the 2030 Comprehensive Plan would not result
in development located on a geologic unit or on soil that is unstable, or that would become
unstable as a result of the project and potentially result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction, or collapse. The 2030 Comprehensive Plan also determined
that there would be less than significant impacts related to erosion or siltation.
PROJECT-SPECIFIC IMPACTS
a1. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other substantial evidence of a known fault?
The Alquist-Priolo Earthquake Fault Zone associated with the San Andreas Fault is located near
the crest of the Santa Cruz Mountains and just east of the intersection of Page Mill Road and
State Route 35. Similar to what was analyzed in the 2017 EIR, no housing inventory sites are
located near the Alquist-Priolo Earthquake Fault Zone associated with the San Andreas Fault
(City of Palo Alto 2016). The closest active fault is the San Andreas Fault, located approximately
2.5 miles from the southern portion of the city. As a result, the likelihood of surface rupture
occurring from active faulting that would affect future development under the proposed HEU is
remote. This impact would be less than significant and would be generally the same as the
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CITY OF PALO ALTO P a g e | 7 3
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
a2. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving strong seismic ground shaking?
As with any site in the Bay Area region, development under the proposed HEU is susceptible to
strong seismic ground shaking in the event of a major earthquake. Nearby faults include the San
Andreas Fault, the Monte Vista Fault, the Hayward Fault and the Calaveras Fault. These faults
are capable of producing strong seismic ground shaking in the city.
Although nothing can ensure that residences and infrastructure do not fail under seismic stress,
proper engineering can minimize the risk to life and property. Accordingly, building standards
have been developed for construction in areas subject to seismic ground-shaking. Development
facilitated by the proposed HEU would be required to comply with standards established by
PAMC Chapter 16.04 and 16.06, which adopt the California Building Code (CBC) and the
California Residential Code, respectively. The requirements of the California Building Code
ensure that new habitable structures are engineered to withstand the expected ground
acceleration at a given location. Further, CBC Chapter 18 requires that actions recommended in
a site-specific soil investigation are incorporated into the construction of each structure. Future
development would also be required to comply with PAMC Section 16.28.150, which would
require detailed engineering geology reports in areas of suspected geological hazards and
implementation of recommendations and mitigations to reduce hazards from ground shaking
or rupture. Additionally, the project would promote infill development, which may involve
replacing older buildings subject to seismic damage with newer structures built to current
seismic standards that could better withstand the adverse effects of strong ground shaking.
Although the proposed HEU would facilitate development of 665 more housing units compared
to what was analyzed in the 2017 EIR, continued compliance with applicable provisions of the
CBC and the PAMC would ensure that potential impacts from ground-shaking would be
minimized. This impact would be less than significant and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
a3. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving seismic-related ground failure, including
liquefaction?
As shown in Map S-3 of the Safety Element of the 2030 Comprehensive Plan, the northern and
eastern portion of the city lies within a high-liquefaction zone. Although the proposed HEU
would facilitate some development in a high-liquefaction zone adjacent to US 101, future
development would be required to comply with requirements of the CBC pursuant to PAMC
Chapter 16.04, as well as requirements for soils engineering reports and engineering geology
reports pursuant to PAMC Sections 16.28.140 and 16.28.150. Additionally, PAMC Section
18.40.120 imposes requirements in areas that have been identified as having moderate or high
IMPACT ANALYSIS
GEOLOGY AND SOILS
7 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
risk due to seismic activity hazards, including liquefaction, and requires the preparation of
detailed geologic, soils, and engineering studies prior to development. Such reports typically
include recommendations for project design and construction, such as site grading/soil
preparation, and foundation design, as well as quantitative evaluations of liquefaction
susceptibility. The final grading, drainage, and foundation plans are reviewed before
construction to confirm incorporation of the report recommendations. Although the proposed
HEU would facilitate development of 665 more housing units compared to what was analyzed
in the 2017 EIR, continued compliance with all applicable provisions of the California Building
Code and the PAMC would minimize impacts associated with liquefaction to a less than
significant level and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
a4. Would the project expose people or structures to potential substantial adverse effects,
including the risk of loss, injury, or death involving landslides?
c. Would the project be located on a geologic unit or soil that is unstable, or that would
become unstable as a result of the project, and potentially result in on- or off-site landslide,
lateral spreading, subsidence, liquefaction, or collapse?
Earthquakes can trigger landslides that may cause injuries and structural damage. Landslides
are typically a hazard on or near slopes or hillside areas, rather than generally level areas where
HEU housing development is anticipated. The 2017 EIR characterizes most of Palo Alto as
having low topographic relief where the probability of landslides is very low, with the exception
of hilly slopes west of Interstate 280. Similar to what was analyzed in the 2017 EIR, no
development would be facilitated in landslide zones within the city. Furthermore, future
development would be required to comply with PAMC Sections 16.28.140 and 16.28.150, which
outline requirements for soils engineering reports and engineering geology reports, as well as
PAMC Section 18.40.120, which imposes requirements in areas that have been identified as
having moderate or high risk due to seismic activity hazards. Although the proposed HEU would
facilitate development of 665 more housing units compared to what was analyzed in the 2017
EIR, continued compliance with all applicable provisions of the California Building Code and the
PAMC would ensure that potential impacts from landslides would be minimized to a less than
significant level and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
b. Would the project result in substantial soil erosion or the loss of topsoil?
The proposed HEU would include infill development in non-vacant and underutilized sites in
urbanized areas. Demolition and construction activities would be required to comply with CBC,
Appendix Section J110, Erosion Control Standards, pursuant to Chapter 16.04 of the PAMC,
which ensures appropriate erosion and stormwater pollution control during grading and
construction activities.
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Construction activities that occur on more than one acre are required to obtain a National
Pollutant Discharge Elimination System (NPDES) Construction General Permit. NPDES requires
the development of a storm water pollution prevention plan (SWPPP), which includes BMPs to
reduce erosion and topsoil loss from stormwater runoff. BMP examples generally include an
effective combination of erosion and sediment controls, which include barriers such as silt
fences, hay bales, drain inlet protection, or gravel bags.
Future development would also be required to comply with PAMC Chapter 16.28, which
outlines requirements for grading and erosion and sediment control. Examples include
preparation of an interim and a final erosion and sediment control and SWPPP, as well as soils
engineering reports, which would prevent excessive erosion and runoff. Although the proposed
HEU would facilitate development of 665 more housing units compared to what was analyzed
in the 2017 EIR, continued compliance with all applicable federal, State, and local regulations
and the PAMC would ensure that potential impacts from soil erosion would be minimized. This
impact would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform
Building Code (1994), creating substantial direct or indirect risks to life or property?
As discussed in the 2017 EIR, shrink-swell potential in the western and central parts of the city
are generally lower than the northeastern parts, where clay-rich soils and “Bay Mud” sediments
are widespread (City of Palo Alto 2016). The proposed HEU would facilitate some housing
development in the northeastern part of the city, and therefore could potentially locate
housing inventory sites on areas with expansive soils. However, future development would be
required to comply with PAMC Sections 16.28.140 and 16.28.150, which outline requirements
for soils engineering reports and engineering geology reports, as well as PAMC Section
18.40.120, which imposes requirements in areas that have been identified as having moderate
or high risk due to seismic activity hazards. The CBC also includes requirements to address soil-
related hazards. Typical measures to treat hazardous soil conditions involve removal of soil or
fill materials, proper fill selection, and compaction. In cases where soil remediation is not
feasible, the CBC requires structural reinforcement of foundations to resist the forces of
expansive soils. This would ensure that the potential for projects to occur on expansive soils
such that substantial direct or indirect risks to life or property to occur would be reduced.
Although the proposed HEU would facilitate development of 665 more housing units compared
to buildout analyzed in the 2017 EIR, continued compliance with all applicable provisions of the
California Building Code and the PAMC would ensure that potential impacts from soil erosion
would be minimized. This impact would be less than significant and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
IMPACT ANALYSIS
GEOLOGY AND SOILS
7 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
e. Would the project have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
Palo Alto is served by the City’s established wastewater system. The proposed HEU would
facilitate development on non-vacant and underutilized sites which are and would continue to
be served by the City’s wastewater system. The project would not include the use of septic
tanks or alternative wastewater disposal systems. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
f. Would the project directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature?
As discussed in the Geological Setting above, there are known paleontological resource sites
within the city, and the presence of these sites indicates that there are likely undiscovered
paleontological resources. Although the proposed HEU would facilitate development on non-
vacant and already disturbed sites, similar to what was analyzed in the Comprehensive Plan EIR,
development facilitated by the proposed HEU could still potentially impact a unique
paleontological resource or site, or unique geologic feature. However, future development
would be required to comply with applicable federal and State regulations that protect
paleontological resources, as well as implement Mitigation Measure CULT-5 which would
reduce impacts on paleontological resources to a less than significant level. Therefore, this
impact would be less than significant with mitigation, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to geological resources which would reduce
impacts to a less than significant level. Future development would also be required to comply
with applicable federal and State regulations that protect paleontological resources, as well as
implement Mitigation Measure CULT-5 which would reduce impacts on paleontological
resources to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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8 Greenhouse Gas Emissions
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Generate greenhouse
gas emissions, either
directly or indirectly,
that may have a
significant impact on
the environment?
EIR Pages 4.6-10
through 4.6-16
No No No N/A
b. Conflict with any
applicable plan, policy,
or regulation adopted
for the purposes of
reducing the emissions
of greenhouse gases?
EIR Pages 4.6-16
through 4.6-21
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.6, Greenhouse Gas Emissions and Climate Change, of the 2017 EIR analyzed the 2030
Comprehensive Plan’s impacts related to greenhouse gas emissions. The 2017 EIR concluded
that the 2030 Comprehensive Plan would not directly or indirectly generate GHG emissions that
may have a significant impact on the environment since Scenario 6 would result in a decrease in
emissions from existing conditions and would achieve the 2030 performance criteria that would
ensure the City is on a trajectory to achieve the GHG reductions targets of SB 32 for year 2030.
Additionally, the 2030 Comprehensive Plan would not conflict with CARB’s Scoping Plan or
Association of Bay Area Governments (ABAG)/Metropolitan Transportation Commission’s
(MTC) Plan Bay Area. However, the 2017 EIR found that the 2030 Comprehensive Plan would
expose people or structures to the physical effects of climate change, including but not limited
to flooding, extreme temperatures, public health, wildfire risk, or other impacts resulting from
climate change, and mitigation measure GHG-3 would be required to reduce impacts to a less
than significant level.
Table 16 lists the mitigation measures from the 2017 EIR related to greenhouse gas emissions.
IMPACT ANALYSIS
GREENHOUSE GAS EMISSIONS
7 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 16 2017 EIR Mitigation Measures: Greenhouse Gas Emissions
Mitigation
Measure # Mitigation Text
Impact GHG-3: The proposed Plan would expose people or structures to the physical effects of climate change, including
but not limited to flooding, extreme temperatures, public health, wildfire risk, or other impacts resulting from climate
change, requiring mitigation. (Significant and Mitigable)
GHG-3 To address the potential impacts associated with exposing additional people or structures to the effects
of climate change, the proposed Plan shall include policies that address the following topics:
Flooding risks caused by climate change-related changes to precipitation patterns, groundwater
levels, sea level rise, tides, and storm surges.
Cooperative planning with federal, State, regional, and local public agencies on issues related to
climate change (including sea level rise and extreme storms).
Preparation of response strategies to address sea level rise, increased flooding, landslides, soil
erosion, storm events, and other events related to climate change.
Impacts of sea level rise on Palo Alto’s levee system.
Source: City of Palo Alto 2016
THRESHOLDS
In response to climate change, California implemented AB 32, the “California Global Warming
Solutions Act of 2006.” AB 32 requires the reduction of statewide GHG emissions to 1990
emissions levels (essentially a 15 percent reduction below 2005 emission levels) by 2020 and
the adoption of rules and regulations to achieve the maximum technologically feasible and
cost-effective GHG emissions reductions. On September 8, 2016, the Governor signed SB 32
into law, extending AB 32 by requiring the State to further reduce GHG emissions to 40 percent
below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On September
10, 2018, the Governor signed Executive Order (EO) B-55-18, which identifies a new goal of
carbon neutrality by 2045 and supersedes the goal established by EO S-3-05.6 CARB adopted
the 2022 Scoping Plan on November 16, 2022, which provides a framework for achieving
carbon neutrality by 2045 or earlier. The 2022 Scoping Plan extends and expands upon the
three earlier versions of scoping plans with a target of reducing anthropogenic emissions to 85
percent below 1990 levels by 2045.
According to the CEQA Guidelines, projects can tier from a qualified GHG reduction plan, which
allows for project-level evaluation of GHG emissions through the comparison of the project’s
consistency with the GHG reduction policies included in a qualified GHG reduction plan. This
approach is considered by the Association of Environmental Professionals (AEP) in their white
paper, Beyond Newhall and 2020, to be the most defensible approach presently available under
CEQA to determine the significance of a project’s GHG emissions (AEP 2016). Palo Alto does not
currently have a qualified GHG reduction plan and thus this approach is not currently feasible.
6 Executive Order (EO) S-3-05, signed by Governor Arnold Schwarzenegger in 2005, proclaims that California is vulnerable to the
impacts of climate change. It declares that increased temperatures could reduce the Sierra Nevada snowpack, further
exacerbate California’s air quality problems, and potentially cause a rise in sea levels. To combat those concerns, the EO
established total GHG emission targets for the state. Specifically, emissions are to be reduced to the 2000 level by 2010, the
1990 level by 2020, and to 80 percent below the 1990 level by 2050.
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To evaluate whether a project may generate a quantity of GHG emissions that may have a
significant impact on the environment, state agencies have developed a number of operational
bright-line significance thresholds. Significance thresholds are numeric mass emissions
thresholds that identify the level at which additional analysis of project GHG emissions is
necessary. Projects that attain the significance target, with or without mitigation, would result
in less than significant GHG emissions. Since the proposed project would tier from the 2017 EIR,
the BAAQMD GHG 2030 efficiency target applied in the 2017 EIR would be used to inform the
threshold for this analysis. However, to take into account the new State goal of carbon
neutrality by 2045 and the project buildout year of 2031, the BAAQMD GHG 2030 efficiency
target was interpolated to get an adjusted 2031 threshold of 3.74 MTCO2e per service
population per year.7 Therefore, the proposed project’s GHG emissions would be significant if
they would exceed the 2031 interpolated threshold of 3.74 MTCO2e per service population per
year, consistent with EO B-55-18.
PALO ALTO SUSTAINABILITY AND CLIMATE ACTION PLAN
The City of Palo Alto launched its S/CAP in August 2014. In 2020, the city launched an update to
the S/CAP to develop strategies needed to meet their goal of reducing GHG emissions 80
percent below 1990 levels by 2030 (the “80 x 30” goal). In October 2022, the Palo Alto City
Council approved the updated S/CAP Goals and Key Actions that will serve as the City's
roadmap to meeting the "80 x 30" goal and most recent Carbon Neutral by 2030 goal. The
S/CAP Goals and Key Actions includes goals and actions in seven areas: Energy, Mobility,
Electric Vehicles, Water, Climate Adaptation and Sea Level Rise, Natural Environment, and Zero
Waste. The S/CAP is not a qualified CAP under CEQA Guidelines 15183.5(b)(1) since it has not
yet been adopted in a public process following environmental review.
METHODOLOGY
OPERATIONAL EMISSIONS
Long-term emissions relate to area sources, energy use, solid waste, water use, and
transportation. Operational emissions for the proposed HEU were modeled using the California
Emissions Estimator Model (CalEEMod) version 2022.1 and compared to the adjusted BAAQMD
efficiency thresholds used in the 2017 EIR. CalEEMod default settings were used to estimate
emissions associated with the proposed project to apply a high-level and conservative analysis.
AREA SOURCE EMISSIONS
Emissions associated with area sources, including consumer products, landscape maintenance,
and architectural coating were calculated in CalEEMod and utilized default standard emission
rates from CARB, U.S. EPA, and emission factor values provided by the local air district (CAPCOA
2017). Architectural coatings were calculated pursuant to BAAQMD Regulation 8 Rule 3.
7 4.0 MTCO2e (2030 Comprehensive Plan EIR threshold) / 15 years (2030 to 2045 for carbon neutrality) = 0.26 MTCO2e. To find
the 2031 interpolated threshold, 4.0 MTCO2e - 0.26 MTCO2e = 3.74 MTCO2e.
IMPACT ANALYSIS
GREENHOUSE GAS EMISSIONS
8 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
ENERGY USE EMISSIONS
CalEEMod provides operational emissions of CO2, N2O, and CH4. Emissions from energy use
include electricity and natural gas use. The emissions factors for natural gas combustion are
based on EPA’s AP-42 (Compilation of Air Pollutant Emissions Factors) and CCAR. Electricity
emissions are calculated by multiplying the energy use times the carbon intensity of the utility
district per kilowatt hour (CAPCOA 2017). Since the City’s All-Electric Ordinance requires all-
electric construction for future residential uses, it was assumed that the natural gas demand
estimated for the project would instead be supplied by electricity to account for increased
electricity usage. Total annual consumption for natural gas (kBTU/year) was converted to
electricity (kWh/year) and added to the total annual consumption for electricity. CalEEMod
incorporates 2019 Title 24 CALGreen Building Standards.
SOLID WASTE EMISSIONS
Emissions from solid waste generation were also calculated in CalEEMod and are based on the
IPCC’s methods for quantifying GHG emissions from solid waste using the degradable organic
content of waste (CAPCOA 2017). Waste disposal rates by land use and overall composition of
municipal solid waste in California was primarily based on data provided by the California
Department of Resources Recycling and Recovery [CalRecycle] 2019).
WATER AND WASTEWATER USE EMISSIONS
Emissions from water and wastewater usage calculated in CalEEMod were based on the default
electricity intensity from the California Energy Commission’s 2006 Refining Estimates of Water-
Related Energy Use in California using the average values for Northern and Southern California.
The Palo Alto RWQCP was assumed to be 100 percent aerobic since it does not contain
facultative lagoons or septic tanks.
MOBILE SOURCE EMISSIONS
For mobile sources, CO2, CH4, and N2O emissions were quantified in CalEEMod.
REFRIGERANT EMISSIONS
Refrigerants are substances used in equipment for cooling and heating purposes and are mostly
comprised of hydrofluorocarbons (HFC). HFCs are potent GHGs that have high global warming
potential (GWP) values. CalEEMod calculates refrigerant emissions according to equipment
charge sizes and leak rates that have been determined for relevant land uses and equipment
types.
CONSTRUCTION EMISSIONS
Construction of the proposed HEU would generate temporary GHG emissions primarily due to
the operation of construction equipment and truck trips. Site preparation and grading typically
generate the greatest amount of emissions due to the use of grading equipment and soil
hauling. Although construction activity is addressed in this analysis, CAPCOA does not discuss
whether any of the suggested threshold approaches adequately address impacts from
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temporary construction activity. As stated in the CEQA and Climate Change white paper, “more
study is needed to make this assessment or to develop separate thresholds for construction
activity” (CAPCOA 2008). Additionally, the BAAQMD does not have specific quantitative
thresholds for construction activity. Therefore, although estimated in CalEEMod and provided
for informational purposes, construction activity is not included in the total emissions
calculations.
PROJECT-SPECIFIC IMPACTS
a. Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
Proposed construction activities, energy use, daily operational activities, and mobile sources
(traffic) associated with the proposed project would generate GHG emissions. CalEEMod was
used to calculate emissions resulting from construction and long-term operation (see Appendix
B for model output).
CONSTRUCTION EMISSIONS
Emissions generated from construction of full buildout under the proposed HEU are estimated
to be 5,433 MT of CO2e per year.8 However, as the BAAQMD does not have a recommended
threshold for construction-related GHG emissions, emissions associated with construction are
not included in Table 17 and compared to BAAQMD significance thresholds.
OPERATIONAL INDIRECT AND STATIONARY DIRECT EMISSIONS
Long-term emissions relate to area sources, energy use, solid waste, water use, and
transportation. Each of the operational sources of emissions is discussed further below.
MOBILE EMISSIONS
As shown in Table 17 below, the additional 665 units facilitated by the proposed project would
generate approximately 2,921 MTCO2e per year.
AREA SOURCE EMISSIONS
CalEEMod was used to calculate direct sources of air emissions associated with the proposed
project. These include consumer product use and landscape maintenance equipment. Area
emissions are estimated at 42 MTCO2e per year.
ENERGY USE EMISSIONS
Operation of the proposed project would consume both electricity and natural gas. The
generation of electricity through combustion of fossil fuels emits CO2, and to a smaller extent,
N2O and CH4. As discussed under the Methodology section, pursuant to the City’s All-Electric
8 Construction emissions were determined assuming the 1,308 units were built as one continuous project using CalEEMod
defaults. Construction emissions for future projects would be based on the timing and size of individual projects.
IMPACT ANALYSIS
GREENHOUSE GAS EMISSIONS
8 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Ordinance, natural gas was converted to electricity to account for increased electricity usage.
Since CPAU provides electricity to the city, and has supplied 100 percent carbon neutral
electricity since 2013, GHG emissions from energy use are estimated at 0 MTCO2e per year.
WATER USE EMISSIONS
Based on the amount of electricity generated to supply and convey water for the project, the
proposed project would generate an estimated 29 MTCO2e per year.
SOLID WASTE EMISSIONS
Based on the estimate of GHG emissions from project-generated solid waste as it decomposes,
solid waste associated with the proposed project would generate approximately 129 MTCO2e
per year.
REFRIGERANT EMISSIONS
Based on the estimate of GHG emissions from refrigerants used for the project, the proposed
project would generate an estimated 1 MTCO2e per year.
The annual emissions associated with the additional development under the proposed HEU
would total approximately 3,122 MTCO2e per year. As discussed in Section 14, Population and
Housing, the service population from the project would be 1,670 new residents. Therefore, the
MTCO2e per service population for the proposed HEU would be 1.9. These emissions would not
exceed the 2017 EIR’s BAAQMD 2030 efficiency target of 3.74. Therefore, this impact would be
less than significant, and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
Table 17 Operational GHG Emissions
Emissions Source Annual Emissions (MT of CO2e/year)
Mobile 2,921
Area 42
Energy 0
Water 29
Waste 129
Refrigerants 1
Total 3,122
Service Population 1,670
MTCO2e/Service Population 1.9
2017 EIR BAAQMD 2030 Efficiency Target (Adjusted for SB 32) 3.74
Exceeds Threshold? No
See Table 2.5 “Operations Emissions by Sector, Unmitigated” emissions. CalEEMod worksheets in Appendix B.
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b. Would the project conflict with any applicable plan, policy, or regulation adopted for the
purpose of reducing the emissions of greenhouse gases?
The City of Palo Alto has adopted the Sustainability and Climate Action Plan (S/CAP) in 2020 to
develop strategies to meet their goal of reducing GHG emissions 80 percent below 1990 levels
by 2030. The California Air Resources Board (CARB) also updated its Climate Change Scoping
Plan in November 2022. Table 18 shows the proposed project’s compliance with the City’s
S/CAP and CARB Scoping Plan measures.
Table 18 Proposed Project Compliance with Applicable S/CAP Actions
GHG Reduction Goal or Policy Project Consistency
City of Palo Alto S/CAP
Action C3: Complete study to identify any additional Energy,
EV, or Mobility key actions needed to achieve 80% reduction
in greenhouse gas emissions from 1990 levels by 2030, such
as electrification of additional multifamily or commercial end
uses, greater electrification of vehicles, or other emissions
reduction actions not already identified in this Plan.
Consistent. Development facilitated by the project would be
required to comply with the PAMC Chapter 16.17, which
mandates the implementation of Title 24. Compliance would
include complying with the most updated rooftop solar
requirements at the time of construction. Future
development would also be required to comply with the
City’s most updated Reach Code and All-Electric Mandate
which requires all-electric building design for single-family,
low-rise multi-family, and non-residential development (City
of Palo Alto 2022a). Electricity would be provided by CPAU,
which has provided 100 percent carbon neutral electricity
since 2013 (City of Palo Alto 2022b).
Pursuant to Section 16.14.420 of the PAMC, new multi-
family residences would be required to provide at least one
EVSE Ready outlet or EVSE installed for each residential unit
in the structure for residential parking, and would be
required to provide Conduit Only, EVSE Ready Outlet, or
EVSE installed for at least 25 percent of guest parking
spaces, among which at least 5 percent shall be EVSE
installed. Future development facilitated by the project
would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at
the time of construction.
Action E1: Reduce all or nearly all greenhouse gas emissions
in single-family appliances and equipment, including water
heating, space heating, cooking, clothes drying, and other
appliances that use natural gas.
Consistent. Future development would be required to
comply with the City’s most updated Reach Code and All-
Electric Mandate which requires all-electric building design
for single-family, low-rise multi-family, and non-residential
development (City of Palo Alto 2022a).
Action E7: Use codes and ordinances - such as the energy
reach code, green building ordinance, zoning code, or other
mandates - to facilitate electrification in both existing
buildings and new construction projects where feasible.
Consistent. Development facilitated by the project would be
required to comply with the PAMC Chapter 16.17, which
mandates the implementation of Title 24. Compliance would
include complying with the most updated rooftop solar
requirements at the time of construction. Future
development would also be required to comply with the
City’s most updated Reach Code and All-Electric Mandate
which requires all-electric building design for single-family,
low-rise multi-family, and non-residential development (City
of Palo Alto 2022a). Electricity would be provided by CPAU,
which has provided 100 percent carbon neutral electricity
since 2013 (City of Palo Alto 2022b).
IMPACT ANALYSIS
GREENHOUSE GAS EMISSIONS
8 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
GHG Reduction Goal or Policy Project Consistency
Action EV6: Expand access to on-site EV charging for multi-
family residents.
Consistent. Pursuant to Section 16.14.420 of the PAMC, new
multi-family residences would be required to provide at
least one EVSE Ready outlet or EVSE installed for each
residential unit in the structure for residential parking, and
would be required to provide Conduit Only, EVSE Ready
Outlet, or EVSE installed for at least 25 percent of guest
parking spaces, among which at least 5 percent shall be EVSE
installed. Future development facilitated by the project
would be required to comply with the most updated EV
requirements in both the City’s Reach Code and Title 24 at
the time of construction.
Action M7: Continue to implement the City’s Housing
Element of the Comprehensive Plan to improve jobs -
housing balance and reduce vehicle miles traveled (VMT).
Consistent. The proposed project would implement the
2023-2031 Housing Element Update which would facilitate
development within the city’s urbanized and underutilized
sites. These areas are near or adjacent to transportation
corridors currently served by transit or Class I, II, and III
bicycle lanes such as University Avenue, Bryant Street,
California Avenue, and Bayshore Road, which would
encourage the use of bicycles and reduce reliance on single-
occupancy vehicles and VMT.
Action N2: Ensure No Net Tree Canopy Loss for all projects. Consistent. Future development would be required to
comply with the City’s Tree Ordinance pursuant to Title 8 of
the PAMC, which also ensures no net loss of canopy across
all tree removal types.
Action N8: Expand the requirements of the Water Efficient
Landscape Ordinance (WELO) to increase native and
drought-tolerant species composition.
Consistent. Future development would be required to
comply with the most updated requirements of WELO
pursuant to Section 12.32.040 of the PAMC.
Action N9: Phase out gas-powered lawn and garden
equipment, in compliance with California’s AB 1346
Consistent. Future development would be required to
comply with AB 1346 and would be prohibited from using
gas-powered lawn and garden equipment.
Action ZW2: Promote residential food waste reduction. Consistent: Future development facilitated by the proposed
HEU would be required to comply with SB 1383 and recycle
organic wastes.
CARB Scoping Plan Measures
Consider enhanced energy efficiency (high efficiency air
conditioners, light-emitting diode lamps, efficiency
improvements in industrial process cooling and
refrigeration, efficient street lighting).
Consistent. Future development would be required to
comply with the latest CALGreen standards and Building
Energy Efficiency Standards, which would require
implementation of energy-efficient light fixtures and
building materials into the project design, and would ensure
energy efficient performance for new buildings.
Source: City of Palo Alto 2022c, CARB 2017
As shown in Table 18, the project would be consistent with applicable actions from the City’s
S/CAP. Therefore, impacts would be less than significant, and would be generally the same as
for the 2030 Comprehensive Plan as analyzed in the 2017 EIR. There would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, and
further analysis is not warranted.
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CITY OF PALO ALTO P a g e | 8 5
PROJECT CONSISTENCY WITH 2022 SCOPING PLAN
The principal State plans and policies for reducing GHG emissions are AB 32, SB 32, and AB
1279. The quantitative goal of AB 32 is to reduce GHG emissions to 1990 levels by 2020; the
goal of SB 32 is to reduce GHG emissions to 40 percent below 1990 levels by 2030; and the goal
of AB 1279 is to achieve net zero greenhouse gas emissions no later than 2045, and reduce GHG
emissions by 85 percent below 1990 levels no later than 2045. The 2022 Scoping Plan expands
upon earlier plans to include the AB 1279 targets. The 2022 Scoping Plan’s strategies that are
applicable to the proposed project include reducing fossil fuel use and vehicle miles traveled;
decarbonizing the electricity sector, maximizing recycling and diversion from landfills; and
increasing water conservation. The project would be consistent with these goals since future
development would be required to comply with the latest Title 24 Green Building Code and
Building Efficiency Energy Standards, as well as the AB 341 waste diversion goal of 75 percent
and recycle organic wastes pursuant to SB 1383. Future development facilitated by the project
would also be largely located in areas served by transit, such as along El Camino Real, the
California Avenue area, and the Downtown area, and would be near or adjacent to
transportation corridors currently served by transit or Class I, II, and III bicycle lanes such as
University Avenue, Bryant Street, California Avenue, and Bayshore Road. This would reduce
reliance on single-occupancy vehicles and VMT and promote bicycling and walking. Future
development would also be required to comply with the City’s most updated Reach Code and
All-Electric Mandate which requires all-electric building design for single-family, low-rise multi-
family, and non-residential development (City of Palo Alto 2022a). Additionally, future
development would receive electricity from CPAU, which sources 100 percent GHG free
electricity. Therefore, the project would not conflict with the 2022 Scoping Plan and this impact
would be less than significant, generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in emissions exceeding
the 2031 interpolated thresholds, and would be consistent with the City’s S/CAP and CARB
Scoping Plan measures, resulting in less than significant GHG impacts. Therefore, the project
would not result in new significant effects not addressed in the prior EIR, and no new mitigation
measures are warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
GREENHOUSE GAS EMISSIONS
8 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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9 Hazards and Hazardous Materials
Where
was
Impact
Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or
Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Create a significant hazard to the
public or the environment
through the routine transport,
use, or disposal of hazardous
materials?
EIR Pages
4.7-2
through
4.7-3
No No No N/A
b. Create a significant hazard to the
public or the environment
through reasonably foreseeable
upset and accident conditions
involving the release of
hazardous materials into the
environment?
EIR Pages
4.7-3
through
4.7-5
No No No Yes
c. Emit hazardous emissions or
handle hazardous or acutely
hazardous materials, substances,
or waste within 0.25 mile of an
existing or proposed school?
EIR Pages
4.7-5
through
4.7-6
No No No Yes
d. Be located on a site that is
included on a list of hazardous
material sites compiled pursuant
to Government Code Section
65962.5 and, as a result, would it
create a significant hazard to the
public or the environment?
EIR Pages
4.7-6
through
4.7-8
No No No N/A
e. For a project located within an
airport land use plan or, where
such a plan has not been
adopted, within two miles of a
public airport or public use
airport, would the project result
in a safety hazard or excessive
noise for people residing or
working in the project area?
EIR Pages
4.7-9
through
4.7-10;
4.7-11
No No No N/A
f. Impair implementation of or
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
EIR Pages
4.7-10
through
4.7-11
No No No N/A
g. Expose people or structures,
either directly or indirectly, to a
significant risk of loss, injury, or
death involving wildland fires?
EIR Pages
4.7-8
through
4.7-9
No No No N/A
IMPACT ANALYSIS
HAZARDS AND HAZARDOUS MATERIALS
8 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.7, Hazards and Hazardous Materials, of the 2017 EIR analyzed the 2030
Comprehensive Plan’s impacts related to hazards and hazardous materials. The 2017 EIR found
that the 2030 Comprehensive Plan would not create a significant hazard to the public or
environment as a result of the routine transport, use, or disposal of hazardous materials, and
would not involve the release of hazardous materials into the environment through upset and
accident conditions. The 2017 EIR concluded that with compliance with applicable federal,
State, and local regulations regarding the storage, use, and handling of hazardous materials, the
2030 Comprehensive Plan would not result in hazardous emissions or the handling of
hazardous wastes within 0.25 mile of an existing or proposed school, and would not expose
future occupants to contaminated soil and groundwater. The 2017 EIR also found that the 2030
Comprehensive Plan would not impair implementation or interfere with an adopted emergency
response or evacuation plan, or result in a safety hazard from a public airport or private airstrip
for people residing or working within the plan area.
PROJECT-SPECIFIC IMPACTS
a. Would the project create a significant hazard to the public or the environment through the
routine transport, use, or disposal of hazardous materials?
The proposed HEU would include 665 more housing units compared to buildout assumed in the
2017 EIR and therefore would potentially transport, use, or dispose of more hazardous
materials than what was analyzed. However, hazardous materials would be required to be
transported under the United States Department of Transportation (DOT) regulations. Future
development facilitated by the proposed HEU would be subject to regulatory programs such as
those overseen by the RWQCB and the Department of Toxic Substances Control (DTSC). These
agencies require applicants for development of potentially contaminated properties to perform
investigation and cleanup if the site is found to be contaminated with hazardous substances. In
addition, Santa Clara County has substantial regulations concerning hazardous materials under
its Certified Unified Program Agencies (CUPA) jurisdiction and related Unified Programs. This is
further enforced by Palo Alto Fire Department Programs.
The proposed HEU is intended to expand housing capacity and would not facilitate the
establishment of uses that would sell, use, store, transport, or release substantial quantities of
hazardous materials such as industrial, warehouse, auto-service, or manufacturing uses.
Residential uses do not typically use hazardous materials other than small amounts for cleaning
and landscaping. These materials would not be different from household chemicals and
solvents already in wide use throughout Palo Alto. Residents are anticipated to use limited
quantities of products routinely for periodic cleaning, repair, and maintenance or for landscape
maintenance/pest control that could contain hazardous materials. Those using such products
would be required to comply with all applicable regulations regarding the disposal of household
waste.
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Compliance with all applicable federal, State, and local regulations would reduce impacts from
the routine transport, use, or disposal of hazardous materials to a less than significant level.
Therefore, this impact would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
b. Would the project create a significant hazard to the public or the environment through
reasonably foreseeable upset and accident conditions involving the release of hazardous
materials into the environment?
Development under the proposed HEU would facilitate development on sites that are possibly
contaminated and inactive, undergoing evaluation, and/or undergoing corrective action, and
grading or excavation may result in the transport, disposal, and release of hazardous materials
if they are unearthed and removed from the site. However, the amount and type of soil
disturbance would be similar to what was analyzed under the 2017 EIR as development would
be facilitated on previously disturbed soils, and future development under the project would be
subject to regulatory programs such as those overseen by the RWQCB and the DTSC. These
agencies require applicants for development of potentially contaminated properties to perform
investigation and cleanup if the properties are contaminated with hazardous substances above
the applicable environmental screening levels for the site. Future development would also be
required to comply with Chapter 17.16 of the PAMC which requires the preparation of a
hazardous materials management plan (HMMP) demonstrating the suitable storage of
hazardous materials, as well as Chapter 16.11 which requires the implementation of a SWPPP
and stormwater pollution prevention measures. Although the proposed HEU would include 665
more housing units compared to buildout assumed in the 2017 EIR, compliance with all
applicable federal, State, and local regulations would reduce impacts from the release of
hazardous materials to a less than significant level. Therefore, this impact would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous
materials, substances, or waste within 0.25 mile of an existing or proposed school?
Several housing inventory sites are located within 0.25 mile of a school, such as Palo Verde
Elementary School, Fairmeadow Elementary School, Herbert Hoover Elementary School, and
Palo Alto High School. The proposed HEU would not involve new industrial or manufacturing
uses, or involve the use, storage, disposal, or transportation of significant quantities of
hazardous materials. The proposed project is designed to facilitate residential development.
Residential uses may involve use and storage of some materials considered hazardous, though
primarily these would be limited to solvents, paints, chemicals used for cleaning and building
maintenance, and landscaping supplies. These materials would not be different from household
chemicals and solvents already in general and wide use throughout the city. Development
accommodated under the project therefore would not pose a health risk to nearby schools or
IMPACT ANALYSIS
HAZARDS AND HAZARDOUS MATERIALS
9 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
childcare facilities. Additionally, as discussed above under Impacts (a) and (b), future
development would be required to comply with existing applicable federal, State, and local
regulations which govern the routine use, transport, handling, storage, disposal, and release of
hazardous materials. Oversight by the appropriate federal, State, and local agencies and
compliance by new development with applicable regulations related to the handling and
storage of hazardous materials would minimize the risk of the public’s potential exposure to
these substances to a less than significant level. Therefore, this impact would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
d. Would the project be located on a site that is included on a list of hazardous material sites
compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment?
As discussed in the 2017 EIR, a number of hazardous materials sites are listed on databases
compiled pursuant to Government Code Section 65962.5. Most of the sites are listed as closed
and have been remediated to the satisfaction of the lead responsible agency (i.e., RWQCB,
DTSC, Santa Clara County Department of Environmental Health (SCCDEH)) based on land use at
the time of closure. Additionally, several groundwater contaminant plumes underlie certain
areas of the city, which could potentially expose future residents to contamination of soil and
groundwater. The proposed HEU would facilitate 665 more housing units compared to buildout
analyzed in the 2017 EIR, and therefore could potentially facilitate more development on sites
containing hazardous materials in underlying groundwater or soils. However, the amount and
type of soil disturbance would be similar to what was analyzed under the 2017 EIR as
development would be facilitated on previously disturbed soils and on underutilized and non-
vacant sites. Future development would be required to adhere to all applicable federal, State,
and local regulations regarding cleanup and reuse of a site with hazardous materials, as well as
policies within the Safety Element of the 2030 Comprehensive Plan, which would reduce
impacts to a less than significant level. Therefore, this impact would be less than significant, and
would be generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
e. For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project result
in a safety hazard or excessive noise for people residing or working in the project area?
As discussed in the 2017 EIR, the Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport
was adopted in November 2008 by the Santa Clara County Airport Land Use Commission (ALUC)
and the city amended the Comprehensive Plan in 2009 to incorporate the CLUP (Santa Clara
County Airport Land Use Commission 2016). The CLUP includes policies intended to safeguard
the general welfare of the inhabitants within the vicinity of the airport and ensure that new
surrounding uses do not affect the airport’s continued safe operation (City of Palo Alto 2017a).
Unlike Scenario 6 of the 2017 EIR, the proposed HEU would allow residential uses in the ROLM
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 9 1
zone south of US 101. This area is within the Palo Alto Airport’s Airport Influence Area (AIA);
however, this area is not located in the airport’s inner or outer safety zone and is outside of the
aircraft noise contours. Future development in the height restricted areas surrounding the
airport would be subject to Federal Aviation Regulations (FAR) Part 77, Objects Affecting
Navigable Airspace, which establishes imaginary surfaces for airports and runways as a means
to identify objects that are obstructions to air navigation. Any penetrations of the FAR Part 77
surface are subject to review on a case-by-case basis. If a safety problem is found to exist, the
Federal Aviation Administration (FAA) may issue a determination of a hazard to air navigation
(Santa Clara County Airport Land Use Commission 2016). The City of Palo Alto establishes and
enforces height restrictions in these areas.
Therefore, with compliance with existing regulations, the proposed HEU would not interfere
with an airport land use plan or create an airport-related safety hazard, and impacts would be
less than significant. This impact would be less than significant and would be generally the same
as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would
be no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
f. Would the project impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan?
As discussed in the 2017 EIR, the Palo Alto Office of Emergency Services (OES) is responsible for
coordinating agency response to disaster or other large-scale emergencies in Palo Alto with
assistance from the Santa Clara County Operational Area in accordance with the State of
California Standardized Emergency Management System. The Palo Alto Emergency Operations
Plan (EOP) establishes policy direction for emergency planning, mitigation, response, and
recovery activities within the city. The Palo Alto EOP addresses interagency coordination,
procedures to maintain communication with County and State emergency response teams, and
methods to assess the extent of damage and management of volunteers. With participation
from the City of Palo Alto and other local agencies, ABAG created an umbrella Hazard
Mitigation Plan entitled “Taming Natural Disasters.” In addition, the city participated in
development of and has since adopted the Regional Catastrophic Earthquake Mass
Transportation Plan, which is an annex to the San Francisco Bay Area Regional Emergency
Coordination Plan and addresses mass transportation/evacuation issues in response to a major
earthquake (City of Palo Alto 2017a). As discussed in Section 4.13, Public Services and
Recreation, future development in Palo Alto would be required to conform to the latest fire
code requirements, including provisions for emergency access. With adherence to existing
Comprehensive Plan policies and other regulations, implementation of the proposed HEU
would not impair or interfere with an emergency response or evacuation plan. Therefore, this
impact would be less than significant, and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
IMPACT ANALYSIS
HAZARDS AND HAZARDOUS MATERIALS
9 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
g. Would the project expose people or structures, either directly or indirectly, to a significant
risk of loss, injury, or death involving wildland fires?
As shown in Map S-8 of the 2017 EIR, much of the area surrounding Palo Alto west of I-280 is
considered to have a moderate and high risk of wildland fire, whereas all of the urbanized areas
do not have any wildland fire hazards. Since the proposed HEU would facilitate development in
non-vacant and underutilized sites in urbanized areas, wildfire risk to future residents would be
low. Future development would be subject to the CAL FIRE Strategic Plan and the California Fire
Code (CFC), pursuant to Chapter 15.04 of the PAMC. The CFC requires the clearance of debris
and vegetation within a prescribed distance from structures in wildlife hazard areas.
Additionally, future development would be located in proximity to Palo Alto Fire Stations 1, 2,
3, and 4. Cooperative fire service agreements with the Central County Fire Department (CCFD),
City of Menlo Park, City of Mountain View, Woodside Fire Protection District, and Stanford
University would further assist the city in protecting people and structures from potential
wildland fires. Therefore, this impact would be less than significant, and would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to hazards and hazardous materials which would
reduce impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 9 3
10 Hydrology and Water Quality
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Violate any water quality
standards or waste discharge
requirements or otherwise
substantially degrade surface
or ground water quality?
EIR Pages
4.8-11
through
4.8-13
No No No Yes
b. Substantially decrease
groundwater supplies or
interfere substantially with
groundwater recharge such
that the project may impede
sustainable groundwater
management of the basin?
EIR Page
4.8-13
through
4.8-16; 4.8-
20 through
4.8-22
No No No N/A
c. Substantially alter the existing
drainage pattern of the site or
area, including through the
alteration of the course of a
stream or river or through the
addition of impervious
surfaces, in a manner which
would:
(i) Result in substantial
erosion or siltation on- or
off-site;
EIR Pages
4.8-16
through
4.8-17
No No No Yes
(ii) Substantially increase the
rate or amount of surface
runoff in a manner which
would result in flooding on-
or off-site;
EIR Pages
4.8-19
through
4.8-20
No No No Yes
(iii) Create or contribute runoff
water which would exceed
the capacity of existing or
planned stormwater
drainage systems or
provide substantial
additional sources of
polluted runoff; or
EIR Pages
4.8-19
through
4.8-20
No No No Yes
(iv) Impede or redirect flood
flows?
EIR Pages
4.8-22
through
4.8-23
No No No Yes
IMPACT ANALYSIS
HYDROLOGY AND WATER QUALITY
9 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
d. In flood hazard, tsunami, or
seiche zones, risk release of
pollutants due to project
inundation?
EIR Pages
4.8-23
through
4.8-26
No No No N/A
e. Conflict with or obstruct
implementation of a water
quality control plan or
sustainable groundwater
management plan?
N/A No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.8 of the 2017 EIR analyzes impacts to hydrology and water quality. The 2017 EIR
determined that the 2030 Comprehensive Plan could substantially degrade or deplete
groundwater resources or interfere substantially with groundwater recharge since there is a
potential for localized lowering of the shallow aquifer during construction dewatering activities.
However, implementation of mitigation measure HYD-2 would reduce impacts to a less than
significant level. The 2017 EIR found that the 2030 Comprehensive Plan would not violate any
water quality standards or waste discharge requirements with compliance with the NPDES
General Construction Permit (GCP), SWPPP requiring incorporation of BMPs, and Low Impact
Development (LID) treatment measures. The 2017 EIR also states that the 2030 Comprehensive
Plan would not increase the rate of stormwater runoff or alter the existing drainage pattern;
result in stream bank instability; result in new or increased flooding on-or off-site or exceed the
capacity of stormwater drainage systems in local streams; or provide substantial additional
sources of pollutants associated with urban runoff or otherwise substantially degrade surface
or ground water quality. The 2017 EIR determined that the 2030 Comprehensive Plan would
not substantially impede or redirect flood flows through placement of structures within the
100-year flood hazard area with compliance with the National Flood Insurance Program (NFIP)
and Flood Hazard Regulations in the PAMC. Additionally, the 2030 Comprehensive Plan would
not expose people or structures to a significant risk or loss, injury or death involving flooding by
placing housing or other development within a 100-year flood hazard area or a levee or dam
failure inundation area and would not result in impacts from inundation by seiche, tsunami, or
mudflow.
Table 19 lists the mitigation measures from the 2017 EIR related to Hydrology and Water
Quality.
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CITY OF PALO ALTO P a g e | 9 5
Table 19 2017 EIR Mitigation Measures: Hydrology and Water Quality
Mitigation
Measure # Mitigation Text
Impact HYD-2: The proposed Plan could substantially degrade or deplete ground water resources or interfere substantially
with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local
groundwater table level. (Significant and Mitigable)
HYD-2 To reduce potential impacts associated with construction dewatering the proposed Plan shall include
policies that address the following topics:
Impacts of basement construction for single-family homes on adjacent properties, public resources,
and the natural environment.
Conservation of subsurface water resources.
Reduced residential basement dewatering and other excavation activities.
Construction techniques and recharge strategies to reduce subsurface and surface water impacts.
Monitoring of dewatering and excavation projects.
Cooperation with other jurisdictions and regional agencies to protect groundwater.
Protection of groundwater from the adverse impacts of urban use.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project violate any water quality standards or waste discharge requirements?
Similar to what was assumed in the 2017 EIR, although development under the proposed HEU
would occur on non-vacant and underutilized sites in previously disturbed areas, ground-
disturbing activities would still have the potential to cause soil erosion from exposed soil, an
accidental release of hazardous materials used for equipment such as vehicle fuels and
lubricant, or temporary siltation from storm water runoff. If uncontrolled during construction,
soil erosion and water pollutants could have adverse offsite effects on water quality. However,
future development that would disturb one or more acre of land would be required to comply
with the NPDES GCP as well as prepare a SWPPP that requires the incorporation of BMPs to
control sedimentation, erosion, and hazardous materials contamination of runoff during
construction. Additionally, projects that apply for a grading permit must also comply with the
City of Palo Alto’s grading and erosion and sediment control requirements pursuant to PAMC
Chapter 16.28, which require project applicants to submit an erosion and sediment control plan
for review by the City prior to the issuance of grading permits. Pursuant to Chapter 16.11 of the
PAMC, permanent stormwater pollution prevention measures must also be incorporated into
future projects. These may include but are not limited to minimization of impervious surfaces;
construction of sidewalks, walkways, and/or patios with permeable surfaces; and minimization
of disturbances to natural drainages. Furthermore, all new and redevelopment projects that
create or replace 10,000 square feet or more of impervious surface must incorporate site
design, source control, and Low Impact Development (LID) treatment measures to the
maximum extent practicable. Also, all development or redevelopment projects that create or
replace one acre or more of impervious surface and are located in a hydromodification area
must implement hydromodification management measures (i.e., post-project runoff rates shall
not exceed estimated pre-project rates and durations) (City of Palo Alto 2017a).
IMPACT ANALYSIS
HYDROLOGY AND WATER QUALITY
9 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
If groundwater is encountered, future development would be required to comply with the
City’s Construction Dewatering System Policy and Plan Preparation Guidelines, which require
excavation activities that may encounter groundwater to submit a Construction Dewatering
Plan to the City’s Public Works Department (City of Palo Alto 2020). The Public Works
Department would review and permit the dewatering plan prior to commencement of
dewatering as part of the Street Work Permit process. The Construction Dewatering Plan must
comply with the City’s Guidelines that require that water be tested for contaminants prior to
initial discharge and at intervals during dewatering. In the dewatering plan, the applicant must
include provisions for keeping sediment and contaminated groundwater out of the storm drain
system (City of Palo Alto 2017a).
Therefore, with compliance with the NPDES GCP, the Municipal Regional Permit (MRP),
preparation of a SWPPP, and implementation of site design, source control, and LID treatment
control measures for new development would reduce impacts to a less than significant level.
This impact would be less than significant and would be generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project substantially decrease groundwater supplies or interfere substantially
with groundwater recharge such that the project may impede sustainable groundwater
management of the basin?
The proposed HEU would substantially degrade or deplete groundwater resources or interfere
substantially with groundwater recharge if future development would use significant amounts
of groundwater for water supply or would significantly increase impervious surfaces or
construction dewatering. Since the City receives 100 percent of its potable water from the San
Francisco Public Utilities Commission (SFPUC), which obtains its supply from surface water
sources, the proposed HEU would not substantially degrade or deplete groundwater resources.
Implementation of LID measures, which prioritize the use of on-site infiltration, would also
result in some level of groundwater recharge. Although the proposed HEU could potentially
increase impervious surfaces within the city more than what was analyzed under the 2017 EIR,
future development would be facilitated on non-vacant and underutilized sites that are already
built-out. Additionally, future development would be required to comply with Section
18.40.130(f) of the PAMC which lists guidelines for landscaping and pervious paving to
accommodate filtration of stormwater runoff from impervious areas.
As shown in the Palo Alto groundwater dewatering map, construction dewatering sites in 2020
to 2022 were located primarily along the west of Oregon Expressway and Evergreen Park (City
of Palo Alto 2022d). Under the proposed HEU, a few housing sites would be located east of
Oregon Expressway and near the Evergreen Park area. Therefore, impacts would be potentially
significant. However, with compliance with the City’s Construction Dewatering System Policy
and Plan Preparation Guidelines and implementation of policies L-3.5 and N-4.8 of the 2030
Comprehensive Plan EIR, adopted in compliance with Mitigation Measure HYD-2 outlined in the
2017 EIR, impacts associated with construction dewatering would be less than significant.
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 9 7
Therefore, this impact would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
c.(i) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner which would result in substantial erosion or siltation
on- or off-site?
c.(ii) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner which would substantially increase the rate or amount
of surface runoff in a manner which would result in flooding on- or off-site?
c.(iii) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner that would create or contribute runoff water which
would exceed the capacity of existing or planned stormwater drainage systems or provide
substantial additional sources of polluted runoff?
c.(iv) Would the project substantially alter the existing drainage pattern of the site or area,
including through the alteration of the course of a stream or river or through the addition
of impervious surfaces, in a manner which would impede or redirect flood flows?
Similar to Scenario 6 of the 2017 EIR, the proposed HEU would not convert open space areas,
creeks, or wetlands to impervious surfaces or require the alteration of the course of an existing
stream or river. The proposed HEU would facilitate development on non-vacant and
underutilized sites in urbanized areas. Future development would be required to implement
construction phase BMPs as well as post-construction site design measures, source control
measures, and stormwater LID treatment measures. Additionally, future development that
disturbs one or more acre of land would be required to prepare and submit a SWPPP to the
State Water Resources Control Board (SWRCB) that describes the measures to control
discharges from construction sites. Pursuant to PAMC Chapter 16.28, projects that apply for a
grading permit must also comply with the City of Palo Alto’s grading and erosion and sediment
control requirements, which require project applicants to submit an erosion and sediment
control plan for review by the city prior to the issuance of grading permits. Furthermore,
pursuant to Chapter 16.11 of the PAMC, permanent stormwater pollution prevention measures
must also be incorporated into future projects.
MRP-regulated projects would be required to treat 80 percent or more of the volume of annual
runoff for volume-based treatment measures. Projects that create or replace 2,500 square feet
or more, but less than 10,000 square feet, of impervious surface must implement site design
measures to reduce stormwater runoff. All future development that satisfies Provision C.3 of
the Santa Clara Valley Urban Runoff Pollution Prevention Program (SCVURPPP) would be
required to implement post-construction stormwater controls into the design of the project.
New on-site storm drain systems in the city must be designed to convey the stormwater runoff
IMPACT ANALYSIS
HYDROLOGY AND WATER QUALITY
9 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
from a 10-year storm and project applicants must demonstrate that the runoff discharged from
the site to the City’s storm drain system will not exceed its carrying capacity. In addition, the
City’s Department of Public Works requires new development to provide storm drain flow and
detention calculations that compare pre- and post-project flow rates and volumes. The
calculations must be signed and stamped by a registered civil engineer. On-site stormwater
detention may also be required to lessen the project’s impact on the City’s storm drain system.
A final grading and drainage plan must be prepared by a licensed professional that shows the
existing and proposed on-site drainage layout, locations, and elevations and shows the
conveyance of stormwater to the nearest City storm drain system. Existing drainage patterns,
including the accommodation of off-site runoff, must be maintained (City of Palo Alto 2017a).
Therefore, facilitation of development on already built-out sites and compliance with existing
State and local regulations related to stormwater would reduce impacts to a less than
significant level. Therefore, this impact would be less than significant, and would be generally
the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because
there would be no new or substantially more severe significant impacts than what was analyzed
in the 2017 EIR, further analysis is not warranted.
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to
project inundation?
As discussed in the 2017 EIR, only the Baylands area of Palo Alto is within a tsunami inundation
zone and this is a large area of undisturbed marshlands open for recreational access. None of
the housing inventory sites facilitated by the proposed HEU would be located in the Baylands
area. Additionally, mud and debris flows can occur in the southern, mountainous area of Palo
Alto. These areas are maintained as open space and none of the housing inventory sites are
located within areas susceptible to mud or debris flows. The proposed HEU would facilitate
development on flat and urbanized sites away from crests and steep ridges. Therefore, impacts
would be less than significant, and would be generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
e. Would the project conflict with or obstruct implementation of a water quality control plan
or sustainable groundwater management plan?
As discussed under Impact (a), the proposed HEU would not violate water quality or degrade
water quality during construction or operation.
The City of Palo Alto is under the jurisdiction of the San Francisco Bay RWQCB. The San
Francisco Bay RWQCB provides permits for projects that may affect surface waters and
groundwater locally and is responsible for preparing the Water Quality Control Plan for the San
Francisco Bay Basin (Basin Plan). The Basin Plan designates beneficial uses of water in the
region and establishes narrative and numerical water quality objectives. The Basin Plan serves
as the basis for the San Francisco Bay RWQCB’s regulatory programs and incorporates an
implementation plan for achieving water quality objectives (California Water Board 2017). The
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CITY OF PALO ALTO P a g e | 9 9
proposed project would not interfere with the objectives and goals in the Basin Plan. This
impact would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations as well as policies adopted in compliance with Mitigation
Measure HYD-2 pertaining to hydrology and water quality which would reduce impacts to a less
than significant level. Therefore, the project would not result in new significant effects not
addressed in the prior EIR, and no new mitigation measures are warranted. This issue does not
require further study in an EIR.
IMPACT ANALYSIS
HYDROLOGY AND WATER QUALITY
1 0 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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11 Land Use and Planning
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Physically divide an
established community?
EIR Page 4.9-13
through 4.9-15
No No No N/A
b. Cause a significant
environmental impact
due to a conflict with any
land use plan, policy, or
regulation adopted for
the purpose of avoiding
or mitigating an
environmental effect?
EIR Pages 4.9-3
through 4.9-13
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.9, Land Use and Planning, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s
impacts related to land use. The 2017 EIR found that the 2030 Comprehensive Plan could
adversely change the type or intensity of existing or planned land use patterns in the area, and
therefore mitigation measure LAND-1 would be required to guide the change in density and
character in order to avoid or minimize potential impacts to a less than significant level.
Additionally, the 2030 Comprehensive Plan would allow development that could be
incompatible with adjacent land uses or with the general character of the surrounding area,
including density and building height. Therefore, implementation of mitigation measures LAND-
2 would be required to ensure development is compatible with adjacent land uses and that the
general character in Palo Alto is maintained. The 2030 Comprehensive Plan states that the 2030
Comprehensive Plan would not allow development that could conflict with established
residential, recreational, educational, religious, or scientific uses of an area; would not allow
new development that could conflict with any applicable City land use plan, policy or regulation
adopted for the purpose of avoiding or mitigating an environmental effect; and would not
conflict with an applicable habitat conservation plan or natural community plan. However,
Scenario 6 of the 2030 Comprehensive Plan would include transportation improvements at
existing roadways and rail corridors that could potentially physically divide existing
communities. As a result, Mitigation Measure LAND-5 would be required to promote
connectivity and context-sensitive design of infrastructure improvements and to reduce
impacts to a less than significant level.
Table 20 lists mitigation measures related to land use and planning in the 2017 EIR.
IMPACT ANALYSIS
LAND USE AND PLANNING
1 0 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 20 2017 EIR Mitigation Measures: Land Use and Planning
Mitigation
Measure # Mitigation Text
Impact LAND-1: The proposed Plan could adversely change the type or intensity of existing or planned land use patterns in
the area. (Potentially Significant and Mitigable)
LAND-1 To ensure that the intensity of future development would not adversely change the land use patterns or
affect the livability of Palo Alto neighborhoods, the proposed Plan shall include policies that address the
following topics:
Strengthening of residential neighborhoods.
Vitality of commercial areas and public facilities.
High-quality building and site design.
Architectural compatibility of new development.
Promotion of appropriate infill development.
Gradual transitions in the scale of development where residential districts abut more intense uses.
Impact LAND-2: The proposed Plan would allow development that could be incompatible with adjacent land uses or with
the general character of the surrounding area, including density and building height. (Potentially Significant and
Mitigable)
LAND-2 Implement Mitigation Measure LAND-1. In addition, to further reduce potential impacts to visual
character and ensure compatibility with adjacent land uses, the proposed Plan shall include policies that
address the following topic:
Architectural standards that address land use transitions.
Impact LAND-5: The proposed Plan could physically divide an established community. (Potentially Significant and
Mitigable)
LAND-5 To avoid potential impacts from physically dividing an established community, the proposed Plan shall
include policies that address the following topics:
Enhanced connections to and from parks, schools, and community facilities for all users.
Safe and convenient pedestrian, bicycle, and transit connections between residential areas and
commercial centers.
Cooperation with other agencies to improve circulation connections.
Grade separation of rail crossings.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project physically divide an established community?
The proposed HEU would not divide a community; rather, it is designed to meet the City’s
RHNA and includes implementation programs that would promote the development of existing
non-vacant, underdeveloped, or underutilized sites, thereby locating people closer to existing
employment, goods and services within an established community. Unlike Scenario 6 of the
2017 EIR, which included changes to transportation infrastructure, the proposed HEU would
not involve the construction of barriers, such as new roads or other linear development or
infrastructure, that would divide the existing communities or neighborhoods. Existing roadways
would not be permanently blocked, and temporary construction would not limit access to a
community or restrict movement within a community. Nonetheless, future development would
continue to implement policies T-1.17 and T-1.19 of the 2030 Comprehensive Plan EIR, adopted
in compliance with Mitigation Measure LAND-5 from the 2017 EIR, which would further reduce
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 1 0 3
impacts to a less than significant level. Therefore, this impact would be less than significant
with mitigation, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
b. Would the project conflict with any applicable land use plan, policy, or regulation of an
agency with jurisdiction over the project (including but not limited to the general plan,
specific plan, local coastal program, or zoning ordinance) adopted for the purpose of
avoiding or mitigating an environmental effect?
The proposed HEU would provide a framework for introducing new housing at all levels of
affordability that is within access to transit, jobs, services, and open spaces. Through its
identification of sites for future development and implementation of housing programs, the
project would encourage development of up to 6,695 new residential units, which would
address the City’s fair share housing needs as quantified in the RHNA plus buffer. As shown in
Table 2, with entitled and proposed development, ADUs, underutilized sites with no rezoning
required, and rezoning to meet the RHNA, a total of 6,807 units can be accommodated, which is
more than the RHNA plus 10 percent buffer of 6,695 units.
The proposed HEU would also include zoning ordinance and zoning map amendments to
increase permitted density, floor area, and height in the RM-20, RM-30, CN, CC, and CS zones,
and permit residential development in the ROLM and GM zones. Although the proposed HEU
would allow residential development in the ROLM and GM zones, the corresponding
Research/Office Park Comprehensive Plan land use designations for these zones already permit
multi-family residential uses and mixed use.
The following analysis discusses the project’s consistency with relevant and applicable plans
and regulations, including Plan Bay Area 2050 and the 2030 Comprehensive Plan. Consistency
with Plan Bay Area is presented in Table 21, and consistency with the Comprehensive Plan is
presented in Table 22. The project is determined to be either “consistent” or “inconsistent”
with the identified goals and policies.
PLAN BAY AREA 2050
As shown in Table 21, the project would be consistent with the key goals and strategies of Plan
Bay Area 2050. Therefore, the project would not conflict with Plan Bay Area 2050 and impacts
would be less than significant.
IMPACT ANALYSIS
LAND USE AND PLANNING
1 0 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 21 Project Consistency with Plan Bay Area 2050
Measure Proposed HEU Project Consistency
Housing. Spur Housing Production for Residents of all Income Levels
H1. Further strengthen renter protections
beyond state law. Building upon recent tenant
protection laws, limit annual rent increases to the
rate of inflation, while exempting units less than
10 years old.
Consistent. The HEU analyzes housing needs for present and future
residents. The City’s Regional Housing Needs Assessment (RHNA)
allocation is 6,086 units, which are distributed across over four income
levels. The units would be distributed as is over the four income levels:
1,556 extremely low and very low units, 896 low units, 1,013 moderate
units, and 2,621 above moderate units. The allocation described would
be protected and not altered. Furthermore, Policy 4.3 of the proposed
HEU encourages new high-quality rental housing and Program 6.6
ensures fair housing by instituting tenant protections to prevent anti-
displacement and requiring a 90-day notice for rent increases of 6
percent instead of the State’s 10 percent threshold for noticing.
H2. Preserve existing affordable housing. Acquire
homes currently affordable to low and middle-
income residents for preservation as permanently
deed-restricted affordable housing.
H4. Build adequate affordable housing to ensure
homes for all. Construct enough deed-restricted
affordable homes to fill the existing gap in housing
for the unhoused community and to meet the
needs of low-income households.
Consistent. As described above, the Housing Element Update is
required to provide 1,556 extremely low and very low units, 896 low
units, and 1,013 moderate units. Affordable housing would be
preserved for these income levels. HEU Goal 2.0 Affordable Housing
and policies and programs under this goal would ensure housing
affordability in Palo Alto especially for people at the lowest income
levels.
H3. Allow a greater mix of housing densities and
types in Growth Geographies. Allow a variety of
housing types at a range of densities to be built in
Priority Development Areas, select Transit-Rich
Areas and Select High-Resource Areas.
Consistent. As shown in Figure 2-3 of the Project Description (Housing
Element Update Sites Inventory Locations), many of the housing
inventory sites are generally located in areas near major transportation
corridors such as along El Camino Real or in transit-accessible Priority
Development Areas (PDAs) such as the California Avenue area and the
Downtown area, as well as near existing residential and commercial
development. HEU Policies 3.1, 3.3, and 4.4 also aim to promote
transit-oriented new construction and encourage construction of new
high-density housing on major transit corridors in proximity to transit
stations.
H5. Integrate affordable housing into all major
housing projects. Require a baseline of 10-20% of
new market-rate housing developments of five
units or more to be affordable to low-income
households.
Consistent. Pursuant to the City’s Below Market Rate (BMR) Housing
Purchase Program, the city requires that developers for new
development with three or more residential units to contribute at least
15 percent of those units at below market rates, and projects with
seven or more units are required to provide one or more BMR units
within the development (City of Palo Alto 2023). Additionally, HEU Goal
2.0 Affordable Housing aims to ensure Palo Alto residents have access
to quality housing at a range of housing options and prices.
EN4. Maintain urban growth boundaries. Using
urban growth boundaries and other existing
environmental protections, focus new
development within the existing urban footprint
or areas otherwise suitable for growth, as
established by local jurisdictions.
Consistent. The proposed HEU would facilitate development of
housing on underutilized sites in urbanized areas of the city, which
would reduce pressure to develop open space areas. By placing
residents close to jobs, commercial services, and alternative methods
of transportation, the project would reduce greenhouse gas emissions
and other criteria pollutants associated with vehicle use to help
communities stay healthy and safe.
Source: ABAG 2021
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CITY OF PALO ALTO 2030 COMPREHENSIVE PLAN
As shown in Table 22, the project would be consistent with the goals, policies, and actions
within the 2030 Comprehensive Plan. As noted under Government Code Section 65589.5(a),
the Legislature has concluded that “the lack of housing, including emergency shelters, is a
critical problem that threatens the economic, environmental, and social quality of life in
California.” More specifically, the Legislature’s stated intent is “to assure that counties and
cities recognize their responsibilities in contributing to the attainment of the state housing
goal…to assure that counties and cities will prepare and implement housing elements
which…will move toward attainment of the state housing goal” (Government Code Section
65581). The project would help meet the city’s RHNA allocation, as well as efficiently utilize
non-vacant, underutilized, and underdeveloped lots within the city to increase the supply of
housing. The project would encourage development of housing, which is supportive of the city’s
goal and policies.
Table 22 Project Consistency with Relevant 2030 Comprehensive Plan Goals and Policies
Comprehensive Plan Policy Proposed HEU Project Consistency
Land Use Element
Policy L-1.2: Limit future urban development to
currently developed lands within the urban service
area. The boundary of the urban service area is
otherwise known as the urban growth boundary.
Retain undeveloped land west of Foothill Expressway
and Junipero Serra as open space, with allowances
made for very low-intensity development consistent
with the open space character of the area. Retain
undeveloped land northeast of Highway 101 as open
space.
Consistent. Most of the housing inventory sites are located in
areas near major transportation and commercial corridors such as
along El Camino Real or in transit-accessible PDAs such as the
California Avenue area and the Downtown area, or are located in
commercial areas such as GM/ROLM zones. None of the housing
inventory sites are located in areas designated as open space.
Policy L-2.4: Use a variety of strategies to stimulate
housing, near retail, employment, and transit, in a
way that connects to and enhances existing
neighborhoods.
Consistent. As shown in Figure 3of the Project Description
(Housing Element Update Sites Inventory Locations), most of the
housing inventory sites are located in areas near major
transportation and commercial corridors such as along El Camino
Real or in transit-accessible PDAs such the California Avenue area
and the Downtown area, as well as near existing residential and
commercial development. The proposed HEU would also
encourage residential uses in areas shown on Figure 4 and
Figure 5. These areas are located near existing services. The
addition of housing in the GM/ROLM zones shown on Figure 4
would place housing near services (including those in Mountain
View) and on underutilized commercial parcels. Overall, the
proposed HEU would create walkable neighborhoods and increase
transit ridership.
Policy L-2.8: When considering infill redevelopment,
work to minimize displacement of existing residents.
Consistent. The proposed HEU would facilitate development on
non-vacant and underutilized sites. Program 6.6 of the HEU
ensures tenant protections and prevents anti-displacement.
Policy L-2.9: Facilitate reuse of existing buildings. Consistent. The proposed HEU would not hinder reuse of existing
buildings by facilitating development on non-vacant and
underutilized sites in urbanized areas.
IMPACT ANALYSIS
LAND USE AND PLANNING
1 0 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Comprehensive Plan Policy Proposed HEU Project Consistency
Policy L-1.3: Infill development in the urban service
area should be compatible with its surroundings and
the overall scale and character of the city to ensure a
compact, efficient development pattern.
Policy L-3.1: Ensure that new or remodeled structures
are compatible with the neighborhood and adjacent
structures.
Policy L-6.1: Promote high-quality design and site
planning that is compatible with surrounding
development and public spaces.
Policy L-6.2: Use the Zoning Ordinance, design review
process, design guidelines and Coordinated Area
Plans to ensure high quality residential and
commercial design and architectural compatibility.
Consistent. Development facilitated by the proposed HEU would
be subject to the City’s Major Architectural Review which includes
a hearing and recommendation by the Architectural Review Board
on whether the individual project is consistent with the findings for
Architectural Review outlined in PAMC Section 18.76.020. This
process aims to promote orderly and harmonious development in
the city and promote visual environments that are of high
aesthetic quality and variety and which, at the same time, are
considerate of each other. Additionally, future development in
locations within specific area plans would be required to adhere to
development guidelines outlined within the respective
coordinated area plans, such as the North Ventura Coordinated
Area Plan following its adoption. If projects qualify for streamlined
review, multifamily projects would be subject to objective design
standards that aim to create high-quality design and compatibility
with surrounding uses and character.
Transportation Element
Policy T-1.3: Reduce GHG and pollutant emissions
associated with transportation by reducing VMT and
per-mile emissions through increasing transit options,
supporting biking and walking, and the use of zero-
emission vehicle technologies to meet City and State
goals for GHG reductions by 2030.
Consistent. As shown in Figure 3 (Housing Element Update Sites
Inventory Locations), most of the housing inventory sites are
located in areas near major transportation corridors such as along
El Camino Real, or in transit-accessible PDAs such as the California
Avenue area and the Downtown area, as well as near existing
residential and commercial development. HEU Policies 3.1, 3.3, and
4.4 also aim to promote transit-oriented new construction and
encourage construction of new high-density housing on major
transit corridors in proximity to transit stations. The addition of
housing in the GM/ROLM zones shown on Figure 4 would place
housing near services (including those in Mountain View) and on
underutilized commercial parcels. Pursuant to Section 16.14.420 of
the PAMC, new multi-family residences would be required to
provide at least one EVSE Ready outlet or EVSE installed for each
residential unit in the structure for residential parking, and would
be required to provide Conduit Only, EVSE Ready Outlet, or EVSE
installed for at least 25 percent of guest parking spaces, among
which at least 5 percent shall be EVSE installed. Future
development facilitated by the project would be required to
comply with the most updated EV requirements in both the City’s
Reach Code and Title 24 at the time of construction.
Source: City of Palo Alto 2017b
As shown in Table 21 and Table 22, the proposed HEU would not conflict with applicable goals
and policies in Plan Bay Area 2050 or the 2030 Comprehensive Plan. Therefore, impacts would
be less than significant, and would be generally the same as the impact analyzed in the 2017 EIR
for the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not physically divide an
established community or conflict with any applicable land use plan, policy, or regulation, and
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impacts would be less than significant with mitigation. Therefore, the project would not result
in new significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
LAND USE AND PLANNING
1 0 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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12 Mineral Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Result in the loss of
availability of a known
mineral resource that would
be of value to the region and
the residents of the state?
EIR Pages 7-2
through 7-3
No No No N/A
b. Result in the loss of
availability of a locally
important mineral resource
recovery site delineated on a
local general plan, specific
plan, or other land use plan?
EIR Pages 7-2
through 7-3
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The City’s Comprehensive Plan EIR analyzes mineral resources in Chapter 7, CEQA-Mandated
Sections, and found that no impacts related to mineral resources would occur.
PROJECT-SPECIFIC IMPACTS
a. Would the project result in the loss of availability of a known mineral resource that would be
of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource
recovery site delineated on a local general plan, specific plan, or other land use plan?
According to the 2017 EIR, most of the city is classified as MRZ-1 9, MRZ-3 10, or MRZ-411,
meaning that no significant mineral deposits are present or data does not exist to identify the
significance of mineral deposits (City of Palo Alto 2017a). Therefore, there would be no impacts
regarding mineral resources, generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because here would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
9 MRZ-1: Adequate information indicates that no significant mineral deposits are present or likely to be present.
10 MRZ-3: The significance of mineral deposits cannot be determined from the available data.
11 MRZ-4: There is insufficient data to assign any other MRZ designation.
IMPACT ANALYSIS
MINERAL RESOURCES
1 1 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
CONCLUSION
As with what was analyzed under the 2017 EIR, there would be no impacts related to mineral
resources. Therefore, the project would not result in new significant effects not addressed in
the prior EIR, and no new mitigation measures are warranted. This issue does not require
further study in an EIR.
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13 Noise
Where was
Impact
Analyzed
in the EIR?
Could
Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project result in:
a. Generation of a substantial
temporary or permanent
increase in ambient noise levels
in the vicinity of the project in
excess of standards established
in the local general plan or
noise ordinance, or applicable
standards of other agencies?
EIR Pages
4.10-2
through
4.10-18;
4.10-21
through
4.10-26
No No No Yes
b. Generation of excessive
ground-borne vibration or
groundborne noise levels?
EIR Pages
4.10-18
through
4.10-21
No No No N/A
c. For a project located within the
vicinity of a private airstrip or
an airport land use plan or,
where such a plan has not been
adopted, within two miles of a
public airport or public use
airport, would the project
expose people residing or
working in the project area to
excessive noise levels?
EIR Pages
4.10-26
through
4.10-28
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.10, Noise, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts related to
on-site operational noise, traffic noise, and construction noise. The 2017 EIR found that impacts
related to long-term non-transportation, operational noise would be potentially significant due
to zoning changes for commercial and residential uses, and mitigation measure NOISE-1a would
be required to reduce impacts to a less than significant level. The 2017 EIR also found that
transportation noise impacts related to aircraft and railway noise sources would be potentially
significant due to encroachment of land uses near aircraft facilities, along with unknown future
operations patterns, which could potentially result in unacceptable aircraft-related noise
environments from one or both of these Palo Alto-based facilities (Stanford University Hospital
helipad and the Palo Alto Airport). Therefore, mitigation measures NOISE-1b and NOISE-1c
would be required to reduce impacts to a less than significant level. Additionally, the 2030
Comprehensive Plan would have the potential to result in noise level increases such that Ldn
would increase by three dB, causing the Ldn in existing residential areas to exceed 60 dBA.
Implementation of mitigation measures NOISE-2 and NOISE-3 would be required to reduce
IMPACT ANALYSIS
NOISE
1 1 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
impacts from long-term operational noise as well as transportation noise related to aircraft and
railway noise to a less than significant level.
The 2017 EIR determined that the 2030 Comprehensive Plan would have the potential to result
in indoor noise levels for residential development to exceed 45 dB Ldn, and mitigation measures
NOISE-4a and NOISE-4b would be required to reduce indoor noise impacts to a less than
significant level. Furthermore, the 2030 Comprehensive Plan would have the potential to
expose persons to or generate excessive ground-borne vibration or ground-borne noise levels,
and therefore impacts related to temporary construction-related vibration, long-term
operational vibration, and railway-related vibration could be potentially significant, requiring
implementation of mitigation measures NOISE-5a and NOISE-5b to reduce vibration impacts to
a less than significant level. The 2017 EIR also concluded that the 2030 Comprehensive Plan
would have the potential to expose people to noise levels in excess of established State
standards and standards established in the local General Plan or noise ordinance since previous
Comprehensive Plan policies do not require acoustical analyses to demonstrate compliance
with applicable interior or exterior noise compatibility standards. Therefore, implementation of
mitigation measures NOISE-6 and NOISE-7 would be required to ensure that pertinent exterior
and interior noise environments would comply with City guidelines and State standards.
Additionally, the 2030 Comprehensive Plan could result in a potentially substantial temporary
or periodic increase in ambient noise levels in the project vicinity above levels existing without
the project since certain construction activities may lead to substantial temporary or periodic
increases to ambient noise levels. Mitigation measure NOISE-8 would be required to reduce
impacts to a less than significant level.
The 2017 EIR found that the 2030 Comprehensive Plan would not expose people residing or
working within an airport land use plan or within two miles of a public airport to excessive noise
levels since all areas of Palo Alto are miles outside of the pertinent 65 dBA CNEL noise contour
of medium or large airports including the Moffett Federal Airfield (KNUQ), San Carlos Airport
(KSQL), San Jose International Airport (SJC), San Francisco International Airport (SFO), and
Oakland International Airport (OAK). Additionally, since only airport property and the golf
course – neither of which are noise-sensitive land uses – are within the Palo Alto Airport’s 60
dBA CNEL noise contours, within-city public airport noise impacts would also be less than
significant.
Table 23 lists mitigation measures related to noise in the 2017 EIR.
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Table 23 2017 EIR Mitigation Measures: Noise
Mitigation
Measure # Mitigation Text
Impact NOISE-1: Implementation of the proposed Plan would have the potential to cause the average 24-hour noise level
(Ldn) to increase by 5.0 decibels (dB) or more in an existing residential area, even if the Ldn would remain below 60 dB.
(Potentially Significant and Mitigable)
NOISE-1a To ensure that average 24-hour noise levels associated with long term operational noise would not
increase by 5.0 decibels (dB) or more in an existing residential area, the proposed Plan shall include
policies that address the following topics:
Location of land uses in areas with compatible noise environments.
Use of the guidelines in the “Land Use Compatibility for Community Noise Environment” table to
evaluate the compatibility of proposed land uses with existing noise environments.
Clear guidelines for maximum outdoor noise levels in residential areas.
Adherence to the interior noise requirements of the State of California Building Standards Code (Title
24) and the Noise Insulation Standards (Title 25).
Inclusion of a noise contour map in the proposed Plan.
Reduction of noise impacts of development on adjacent properties.
Updating for clarity the Noise Ordinance to make enforcement easier.
NOISE-1b To ensure that aircraft noise would not increase average 24-hour noise levels by 5.0 decibels (dB) or more
in an existing residential area, the proposed Plan shall include policies that address the following topics:
Compliance with the airport-related land use compatibility standards for community noise
environments.
Prohibition of incompatible land use development within the 60 dBA CNEL noise contours of the Palo
Alto airport, as established in the adopted County of Santa Clara Airport Land Use Commission
Comprehensive Land Use Plan (CLUP) for the Palo Alto Airport.
NOISE-1c To ensure that railway noise would not increase average 24-hour noise levels by 5.0 decibels (dB) or more
in an existing residential area, the proposed Plan shall include policies that address the following topics:
Noise spillover from rail-related activities into adjacent noise-sensitive areas.
Reduction of impacts from noise and ground borne vibrations associated with rail operations.
Guidelines for interior noise levels.
Requirements for vibration impact analysis for future development projects.
Impact NOISE-2: Implementation of the proposed Plan would not cause the Ldn to increase by three dB or more in an
existing residential area, thereby causing the Ldn in the area to exceed 60 dB. (Significant and Mitigable)
NOISE-2 Implement Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
Impact NOISE-3: Implementation of the proposed Plan would have the potential to cause an increase of three dB or more
in an existing residential area where the Ldn currently exceeds 60 dB. (Potentially Significant and Mitigable)
NOISE-3 Implement Mitigation Measures NOISE-1a, NOISE-1b, and NOISE-1c.
Impact NOISE-4: Implementation of the proposed Plan would have the potential to result in indoor noise levels for
residential development to exceed an Ldn of 45 dB. (Potentially Significant and Mitigable)
NOISE- 4a Implement Mitigation Measure NOISE-1a.
NOISE-4b The Land Use Noise Compatibility Guidelines established in the current Comprehensive Plan shall be
maintained under all six scenarios.
IMPACT ANALYSIS
NOISE
1 1 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Mitigation
Measure # Mitigation Text
Impact NOISE-5: Implementation of the proposed Plan would have the potential to expose persons to or generate
excessive ground-borne vibration or ground-borne noise levels.(Potentially Significant and Mitigable)
NOISE-5a To ensure that future development would not result in significant construction-related vibration impacts,
the proposed Plan shall include policies that address the following topics:
Requirements for construction and operations vibration impact analysis, to be prepared by a qualified
acoustical consultant for development projects.
Requirements for vibration mitigation plans to ensure compliance with the pertinent industry
standards and City guidelines for projects that would experience vibration impacts during construction
or operations.
Limits for construction and operations vibration around vibration-sensitive receptors.
NOISE-5b Implement Mitigation Measure NOISE-1c.
Impact NOISE-6: Implementation of the proposed Plan would have the potential to expose people to noise levels in excess
of established State standards. (Potentially Significant and Mitigable)
NOISE-6 Implement Mitigation Measures NOISE-4a and NOISE-4b
Impact NOISE-7: Implementation of the proposed Plan would have the potential to result in the exposure of persons to or
generation of noise levels in excess of standards established in the local General Plan or noise ordinance, or applicable
standards of other agencies. (Potentially Significant and Mitigable)
NOISE-7 Implement Mitigation Measures NOISE-1a, NOISE-1b, NOISE-1c, NOISE-4a, and NOISE-4b.
Impact NOISE-8: Implementation of the proposed Plan could result in a potentially substantial temporary or periodic
increase in ambient noise levels in the project vicinity above levels existing without the project. (Potentially Significant
and Mitigable)
NOISE-8 To ensure that future development would not result in significant impacts to sensitive receptors from
construction noise, the proposed Plan shall include policies that address the following topics:
Construction noise limits around sensitive receptors.
Monitoring and reporting plans for construction noise levels of larger development projects.
Noise control measures to ensure compliance with the noise ordinance.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project result in generation of a substantial temporary or permanent increase in
ambient noise levels in the vicinity of the project in excess of standards established in the
local general plan or noise ordinance, or applicable standards of other agencies?
Standards for interior noise in Palo Alto are currently determined primarily through the Land
Use Noise Compatibility Guidelines and interior noise standards set by Title 24 of the State
Building Code, while standards for exterior noise are currently determined primarily through
the City’s Noise Ordinance, or PAMC Chapter 9.10, and PAMC Section 18.42.190 which outlines
requirements for noise and vibration. Although the proposed HEU would include 665 more
residential units compared to buildout analyzed in the 2017 EIR and could therefore result in an
increased amount of noise in excess of established standards, future development requiring
discretionary approval would be required to conduct project-level acoustical analysis pursuant
to Section 18.42.190 of the PAMC to demonstrate consistency with applicable land use
compatibility requirements and noise standards.
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CONSTRUCTION NOISE IMPACTS
Noise from increased construction could also temporarily or periodically increase ambient noise
levels within the city. Engine noise reduction technology, including silencers, continues to
improve, but heavy construction equipment still generates noise exceeding ambient levels that
could cause intermittent annoyance to nearby receivers. Even with adherence to the city’s
allowed construction hours of 8 a.m. through 6 p.m. on Monday to Friday and 9 a.m. through 6
p.m. on Saturday, as well as maximum construction noise levels of 110 dBA at a distance of 25
feet pursuant to PAMC Section 9.10.060, it is likely that in certain cases these and other
available methods to reduce noise would be inadequate to prevent a significant impact.
Therefore, future development would also be required to comply with Policy N-6.11 of the
2030 Comprehensive Plan, adopted in compliance with Mitigation Measure NOISE-8 of the
2017 EIR which would reduce noise impacts to a less than significant level. Therefore, this
impact would be less than significant with mitigation, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
TRANSPORTATION-RELATED NOISE IMPACTS
AIRPORT/HELIPORT NOISE
As discussed in the 2017 EIR, because Palo Alto has only one heliport at Stanford University
Hospital, and one airport, the Palo Alto Airport, notable increases in ambient noise levels from
air traffic are not anticipated. However, encroachment of land uses near these aircraft facilities,
along with unknown future operations patterns, could potentially result in unacceptable
aircraft-related noise environments from one or both of these Palo Alto-based facilities. Aircraft
operations may cause the Ldn to increase by five DB or more in an existing residential area. The
proposed HEU does not envision housing inventory sites in proximity to the Stanford University
Hospital helipad, and the closest housing inventory site from the Palo Alto Airport would be
located approximately three miles southeast. As with the 2017 EIR, future development would
be required to comply with policies L-10.3 and N-6.12 of the 2030 Comprehensive Plan, adopted
in compliance with Mitigation Measure NOISE-1b, which would reduce impacts from airport or
heliport noise to a less than significant level, generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
RAILWAY NOISE
As discussed in the 2017 EIR, with only one single railway alignment through the city, railway
operations (primarily Caltrain pass-bys) are not anticipated to notably increase community
noise levels, except in the immediate vicinity of the rail lines. However, the 2017 EIR
determined that since a definitive assessment of operations increases cannot be determined,
future railway operations could potentially cause the Ldn to increase by five dB or more in an
existing residential area. Since the proposed HEU would facilitate an increased number of units
IMPACT ANALYSIS
NOISE
1 1 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
along Alma Street where Caltrain runs parallel, impacts could potentially be significant.
However, future development would be required to comply with policies N-6.11 and N-6.14 of
the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measure NOISE-1c,
which would reduce impacts from railway noise to a less than significant level, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive. Because there would
be no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
OPERATIONAL NOISE IMPACTS
As discussed in the 2017 EIR, development would have the potential to receive noise from both
highways and major arterials, and certain areas would require special noise-insulating features
or construction techniques. Project-level acoustical analyses, at a minimum, would need to
examine portions of individual housing sites nearest to major transportation corridors to
measure current, 24-hour ambient noise levels and determine appropriate site design and/or
construction techniques for noise attenuation. Future development facilitated by the proposed
HEU would be required to conduct project-level acoustical analysis pursuant to Section
18.42.190 of the PAMC, and would be required to comply with policies N-6.1, 6.2, and 6.6 of
the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measure NOISE-1a of the
2017 EIR, which would reduce impacts on interior noise to a less than significant level, generally
the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
The project allows for higher density/intensity land uses in some areas of Palo Alto than
currently permitted, leading to additional vehicle trips on area roadways. Under full buildout of
the project, an estimated 665 new units compared to buildout in the 2030 Comprehensive Plan
would be added to Palo Alto. By generating new vehicle trips, new development would
incrementally increase the exposure of land uses along roadways to traffic noise. Development
facilitated by the project would increase vehicle trips in Palo Alto, depending on the location
and intensity of individual projects. As discussed under Section 3, Air Quality, the proposed HEU
would increase residential vehicle trips from 2015 conditions by 16.2 percent. It is unlikely that
a vehicle trip growth of 16.2 percent would result in a 100 percent increase in traffic volumes
on a given roadway segment. When analyzing roadway vehicle trips, a three dBA increase in
noise is considered noticeable. A 40 percent increase in trips equates to a noise increase of less
than 1.5 decibels. A 1.5 dBA increase in noise would not be perceptible, and the increase in
traffic volumes on any given roadway segment is expected to be below 40 percent. A doubling
of traffic volumes would be required to reach the threshold of noticeability (a 3-dba increase in
noise levels). A doubling of traffic volumes on a roadway (i.e., a 100 percent increase) is not
anticipated under the project, considering trips are only anticipated to increase by 16.2
percent. Traffic volumes on streets would not increase by 40 percent on average, and therefore
increases in traffic noise would be less than perceptible. Increases in roadway noise would be
less than significant generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
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LONG-TERM OPERATIONAL NOISE IMPACTS
As discussed in the 2017 EIR, zoning changes could result in noise level increases such that Ldn
would increase by three dB, causing the Ldn in a residential area to exceed 60 dBA Ldn. The
proposed rezoning that would occur under the proposed HEU would allow for increased
residential density in RM-20, RM-30, CN, CC, and CS zones, and would allow for residential uses
in non-residential zones such as ROLM and GM zones. Therefore, as with the 2017 EIR, impacts
would be potentially significant. However, future development would be required to comply
with policies N-6.1, 6.2, and 6.6 of the 2030 Comprehensive Plan, adopted in compliance with
Mitigation Measures NOISE-2 and NOISE-3 of the 2017 EIR, which would reduce impacts from
long-term operational noise to a less than significant level, generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project result in generation of excessive groundborne vibration or groundborne
noise levels?
As discussed in the 2017 EIR, groundborne vibration can be related to short-term impacts from
construction activities, on-going impacts related to operation, or on-going impacts related to
rail pass-bys.
CONSTRUCTION VIBRATION IMPACTS
Since the proposed HEU would include 665 more residential units compared to Scenario 6 of
the 2017 EIR, vibration resulting from construction activities could occur more frequently;
however, the intensity of vibration would be similar as analyzed previously as the type of
equipment anticipated would be similar. Overall, vibration impacts related to construction
would be short-term, temporary, and generally restricted to the areas in the immediate vicinity
of active construction equipment. Methods to reduce vibration during construction would
include the use of smaller equipment, use of well-maintained equipment, use of static rollers
instead of vibratory rollers, and drilling of piles as opposed to pile driving. Methods to reduce
human impacts of vibration from construction include limitations on construction hours and/or
guidelines for the positioning of vibration-generating construction equipment. Construction
would be localized and would occur intermittently for varying periods of time. Because specific,
project-level information is not available at this time, it is not possible to quantify construction-
related vibration impacts at specific sensitive receptors. Future development requiring
discretionary approval would be required to undergo individual review to ensure construction
vibration impacts are reduced. Nonetheless, vibration impacts could be potentially significant
and construction of future development would be required to comply with policies N-6.3, 6.11,
and 6.14 of the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measures
NOISE-5a and NOISE-5b of the 2017 EIR, which would reduce construction-related vibration
impacts to a less than significant level, generally the same as the impact analyzed in the 2017
EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
IMPACT ANALYSIS
NOISE
1 1 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
OPERATIONAL VIBRATION IMPACTS
Future development would have a significant environmental effect involving operational
vibration if it would increase the risk of harm to surrounding properties from such vibrational
hazards. Since operation of residential housing development would not involve activities that
would result in substantial vibration levels, such as use of heavy equipment or machinery, the
project would not have any known environmental impact involving operational vibration.
Additionally, future development would be required to comply with Section 18.42.190 of the
PAMC which contains restrictions regarding the generation of vibration that is perceptible
without instruments at the lot line of the receiving property. Therefore, impacts would be
generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
RAILWAY PASS-BY VIBRATION IMPACTS
CEQA is concerned with the impacts of a project on the environment, and not the impacts of
the environment on a project. A project would not have a significant environmental effect
involving railway pass-by vibration, unless the project would increase the risk of harm to
surrounding properties from such vibrational hazards. Therefore, the project would not have
any known environmental impact involving railway pass-by vibration.
Even if CEQA were concerned with impacts of the environment on projects, the impact would
be less than significant. The 2017 EIR states that Scenario 6 may result in long-term vibration
impacts if sensitive land uses were allowed to be developed in proximity to existing railways.
Since the proposed HEU would include 665 more residential units compared to Scenario 6 of
the 2017 EIR, it would place more sensitive receptors in proximity to existing railways. These
additional receptors would be exposed to similar vibration levels as considered in the 2017 EIR.
While vibration impacts related to rail pass-bys would be short-term, temporary, and generally
restricted to the areas in the immediate vicinity of a railway, vibration effects from on-going rail
pass-bys could be objectionable. These vibration effects can range from no perceptible effects
at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate
levels, to slight structural damage at the highest levels. Vibration from rail pass-bys rarely
reaches the levels that can damage structures, but groundborne vibration and groundborne
noise can reach perceptible and audible levels in buildings that are close to railways. As such,
appropriate setbacks, buffers, and/or other measures can largely eliminate these impacts since
these basic techniques are particularly effective approaches to avoid vibration impacts.
However, individual project review would still be needed to ensure appropriately reduced
vibration impacts arising from rail pass-bys. Future development would also be required to
comply with policies N-6.3, 6.11, and 6.14 of the 2030 Comprehensive Plan, adopted in
compliance with Mitigation Measures NOISE-5a and NOISE-5b of the 2017 EIR, which would
reduce railway pass-by vibration impacts to a less than significant level, generally the same as
the impact for the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new
or substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
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CITY OF PALO ALTO P a g e | 1 1 9
c. For a project located within the vicinity of a private airstrip or an airport land use plan or,
where such a plan has not been adopted, within two miles of a public airport or public use
airport, would the project expose people residing or working in the project area to excessive
noise levels?
As discussed in the 2017 EIR, the City of Palo Alto owns and operates the Palo Alto Airport
(KPAO), a relatively small public air facility which primarily serves single-engine, general aviation
(GA) aircraft. At the nearest points within city limits, Palo Alto is located approximately 2.6
miles to the west of Moffett Federal Airfield (KNUQ), 6 miles to the southeast of San Carlos
Airport (KSQL), 10 miles to the northwest of the San Jose International Airport (SJC), 15 miles to
the southeast of San Francisco International Airport (SFO), and 17 miles to the south of Oakland
International Airport (OAK) (City of Palo Alto 2017a). As shown in Figure 5 of the Palo Alto
Airport CLUP, none of the housing inventory sites are located within the airport’s 55 to 70 CNEL
noise contours, and therefore would not exceed the “Normally Acceptable” noise levels for
compatibility for those land uses. Nonetheless, as with the 2017 EIR, future development would
be required to comply with policies L-10.3 and N-6.12 of the 2030 Comprehensive Plan,
adopted in compliance with Mitigation Measure NOISE-1b, which would reduce impacts from
airport or heliport noise to a less than significant level. Therefore, impacts would be less than
significant with mitigation, and would be generally the same as the impact for the 2017 EIR for
the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would result in less than significant
impacts regarding noise and vibration with implementation of policies adopted in compliance
with Mitigation Measures NOISE-1a through NOISE-1c, NOISE-2, NOISE-3, NOISE-4a and NOISE-
4b, and 5a and 5b of the 2017 EIR. Therefore, the project would not result in new significant
effects not addressed in the prior EIR, and no new mitigation measures are warranted. This
issue does not require further study in an EIR.
IMPACT ANALYSIS
NOISE
1 2 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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14 Population and Housing
Where was
Impact
Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Induce substantial unplanned
population growth in an area,
either directly (e.g., by
proposing new homes and
businesses) or indirectly (e.g.,
through extension of roads or
other infrastructure)?
EIR Pages
4.11-5
through
4.11-10
No No No Yes
b. Displace substantial numbers
of existing people or housing,
necessitating the construction
of replacement housing
elsewhere?
EIR Pages
4.11-10
through
4.11-13
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.11, Population and Housing, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s
impacts related to population and housing growth. The 2017 EIR found that Scenario 6 of the
2030 Comprehensive Plan could increase the total population from 65,685 persons in 2014 to
79,765 persons in 2030, resulting in an addition of 2,665 persons or a 3.34 percent increase
from ABAG projections. However, the 2017 EIR concluded that the exceedance of ABAG
projections is intended to help to lower the jobs-to employed-resident ratio by providing more
local housing opportunities, thereby helping to alleviate the need for workers to commute to
Palo Alto from other areas of the region. Therefore, the 2030 Comprehensive Plan would not
directly or indirectly induce substantial population growth and impacts would be less than
significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would not displace a substantial
number of existing housing or people or necessitate the construction of replacement housing
elsewhere since the 2015-2023 Housing Element included policies and programs that protect
existing residents, neighborhoods, and housing. Additionally, the 2030 Comprehensive Plan
would not create a substantial imbalance between employed residents and jobs, and impacts
would be less than significant.
IMPACT ANALYSIS
POPULATION AND HOUSING
1 2 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
PROJECT-SPECIFIC IMPACTS
a. Would the project induce substantial unplanned population growth in an area, either
directly (for example, by proposing new homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)?
For the purposes of this analysis, buildout under the proposed HEU would add up to 6,665 new
residential units in the city by the year 2031, or approximately 665 residential units more than
what was analyzed under Scenario 6 of the Comprehensive Plan EIR. Based on the estimated
number of 2.51 residents per household, the additional 665 units compared to Scenario 6
would lead to an increase of approximately 1,670 new residents during the housing element
cycle 2023 to 2031 assuming all of the estimated 665 units are built (DOF 2022).
Although the proposed HEU would increase residential units compared to Scenario 6, the State
requires that all local governments adequately plan to meet the housing needs of their
communities. Given that the State is currently in an ongoing housing crisis due to an insufficient
housing supply, the additional units under the proposed project would further assist in
addressing the existing crisis and meeting the housing needs of the City’s communities.
Furthermore, the proposed HEU would first be submitted to the HCD for review and approval
to ensure that it would adequately address the housing needs and demands of the city.
Approval by the HCD would ensure that population and housing growth under the proposed
HEU would not be substantial or unplanned.
Additionally, growth under the proposed HEU would be concentrated in locations where such
development is encouraged by adopted plans due to their proximity to transit and
transportation corridors as well as located near commercial uses and services and on
underutilized sites. The proposed HEU would facilitate infill growth, promote housing in close
proximity to employment opportunities, and support regional planning efforts.
Lastly, this analysis is conservative because it assumes a maximum buildout scenario. The
project’s actual contribution to population growth may be less than estimated. In addition, the
project would not involve the extension of roads or other infrastructure that could indirectly
lead to population growth. The city is mostly developed and is supported by existing public
services and infrastructure which are sufficient to serve the additional housing units. Therefore,
the project would not result in substantial unplanned population growth, either directly or
indirectly, and impacts would be less than significant, generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project displace substantial numbers of existing people or housing, necessitating
the construction of replacement housing elsewhere?
“Substantial” displacement would occur if the proposed project would displace more
residences than would be accommodated through growth facilitated by the project. The goal of
the proposed project is to accommodate and encourage new residential development in Palo
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CITY OF PALO ALTO P a g e | 1 2 3
Alto. A portion of the housing units would be developed at a density range that could
accommodate low and very low-income housing as required to meet the 6th Cycle RHNA.
Development under the proposed HEU would result in 665 more residential units compared to
Scenario 6 of the 2017 EIR. The proposed buildout, in addition to existing and planned housing
projects, would result in an overall increase in available housing which exceeds the City’s RHNA
requirements. Therefore, overall, the proposed HEU would add to the City’s housing stock to
meet housing goals.
On an individual site basis, it is possible that some redevelopment projects could result in
displacement of current residents. However, the proposed HEU includes policies and programs
to reduce displacement impacts. For example, Program 2.2 addresses the potential loss of
rental housing and displacement of lower- and moderate-income households due to new
development and ensures the retainment of a stock of affordable housing through a Below
Market Rate (BMR) Program, while Program 6.6 of the proposed HEU aims to provide fair
housing and Implementing Objective 6 serves to institute tenant protections to prevent anti-
displacement.
Therefore, although the proposed HEU would provide additional housing in excess of RHNA
requirements and Scenario 6, there are policies and programs in place to reduce displacement
resulting from the proposed project, and impacts would be less than significant, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not induce substantial unplanned
population growth or displace substantial numbers of existing people and housing, and impacts
would be less than significant. Therefore, the project would not result in new significant effects
not addressed in the prior EIR, and no new mitigation measures are warranted. This issue does
not require further study in an EIR.
IMPACT ANALYSIS
POPULATION AND HOUSING
1 2 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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15 Public Services
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes Involve
New or
Substantially More
Severe Impacts?
Do New
Circumstances
Result in New or
Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address and/or
Resolve
Impacts?
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered
governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could
cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for any of the public services:
a. Fire protection? EIR Page
4.12-9
through
4.12-11
No No No N/A
b. Police protection? EIR Page
4.12-13
through
4.12-14
No No No N/A
c. Schools? EIR Page
4.12-2
through
4.12-7
No No No N/A
d. Parks? EIR Pages
4.12-17
through
4.12-20
No No No N/A
e. Other public
facilities?
EIR Pages
4.12-22
through
4.12-24
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.12, Public Services and Recreation, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to public services. The 2017 EIR states that the 2030 Comprehensive Plan
would not result in an adverse physical impact associated with the construction of additional
school facilities, fire protection facilities, police facilities, and libraries. Impacts would be less
than significant. However, the 2017 EIR found that the 2030 Comprehensive Plan could result in
an adverse physical impact from the construction of additional parks and recreation facilities
since Scenario 6 would require new parkland to accommodate new development and meet the
City’s parkland standard. Therefore, implementation of mitigation measure PS-7 would be
required to reduce impacts to a less than significant level.
Table 24 lists mitigation measures related to public services and recreation in the 2017 EIR.
IMPACT ANALYSIS
PUBLIC SERVICES
1 2 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 24 2017 EIR Mitigation Measures: Public Services and Recreation
Mitigation
Measure # Mitigation Text
Impact PS-7: Implementation of the proposed Plan would result in an adverse physical impact from the construction of
additional parks and recreation facilities in order to maintain acceptable performance standards. (Significant and
Mitigable)
PS-7 To address the potential physical impacts of park construction/improvement, the Comprehensive Plan
Update and/or the Parks, Trails, Natural Open Space and Recreation Master Plan shall incorporate policies
addressing the following topic:
Evaluation and mitigation of construction impacts associated with park and recreational facility
creation and expansion.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered fire protection facilities, or the need for new or
physically altered fire protection facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times or
other performance objectives?
To meet increased demand under the 2030 Comprehensive Plan, the 2017 EIR found that the
City of Palo Alto Fire Department (PAFD) would likely increase staffing for EMS delivery and new
apparatus and fire station improvements or expansions, but would not anticipate the need to
construct a new station, as development would be located in existing urbanized areas already
served by existing PAFD stations. Furthermore, the city’s approved infrastructure plan includes
the replacement of two fire stations (City of Palo Alto 2017a). Fire Station 3 was replaced in
March 2020 to meet the most current California Building Codes (CBC), Essential Services
Building Seismic Safety Act, American with Disabilities Act (ADA), National Fire Protection
Association (NFPA), and OSHA standards, and Fire Station 4 is currently underway and will be
completed in December 31, 2025 (City of Palo Alto 2022e).
Although the proposed HEU would increase the number of residential units by 665 compared to
Scenario 6 of the 2017 EIR, future development would be facilitated on non-vacant and
underutilized sites in urbanized areas such as along El Camino Real, the California Avenue area,
the Downtown area, and in the GM/ROLM zones which are already served by existing fire
stations. Future remodeling or expansion of PAFD facilities to accommodate new equipment
would not be needed to specifically to serve the additional residential units, which would be
added incrementally in various locations in the city and served by more than one fire station.
Therefore, impacts would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
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CITY OF PALO ALTO P a g e | 1 2 7
b. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered police protection facilities, or the need for new or
physically altered police protection facilities, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios, response
times or other performance objectives?
Police protection in the city is provided by the Palo Alto Police Department (PAPD). As discussed
under Impact (a), although the proposed HEU would increase the number of residential units by
665 compared to Scenario 6 of the 2017 EIR, future development would be facilitated on non-
vacant and underutilized sites in urbanized areas such as El Camino Real, the California Avenue
area, the Downtown area, and in the GM/ROLM zones, which are already served by an existing
police station. The PAPD has already indicated that the existing police station is inadequate to
accommodate current and future needs, and the city is currently constructing a new Public
Safety Building (PSB) at 250 Sherman Avenue which will serve as the new headquarters of the
Police Department, the Fire Department and the Office of Emergency Services and house the
city's dispatch operation. Future construction or expansion of the PAPD facility would not be a
result specifically of the additional residential units and would be subject to separate project-
level CEQA review in order to identify potential environmental impacts and mitigation
measures as needed. As such, with the new police station, police services would be adequate to
accommodate current and future needs of the city. Although additional units would result in
varying amounts of housing, population, and employees, the HEU identifies sizes for rezoning
and directs new housing construction to sites and areas of Palo Alto that are already urbanized,
all of which are currently served by the PAPD and within the city limit of Palo Alto. Therefore,
impacts would be less than significant, and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
c. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered schools, or the need for new or physically altered
schools, the construction of which could cause significant environmental impacts, in order
to maintain acceptable service ratios or other performance objectives?
Palo Alto is served by the Palo Alto Unified School District (PAUSD), which consists of 12
primary schools, three middle schools, two high schools, and an adult school. In general,
kindergarten enrollment has been increasing within PAUSD, however, projections forecast a
decline in enrollment district-wide across a 10-year period based upon historical enrollment
trends and projected new development (DecisionInsite 2021).
As discussed in the 2017 EIR, Scenario 6 would result in enrollment that would exceed the
capacity of existing PAUSD elementary schools, middle schools, and high schools. Since the
proposed HEU would include 665 more units compared to Scenario 6, the proposed HEU would
also result in enrollment that would exceed the capacity of existing PAUSD schools. Although
the increased enrollment would add stress to schools in PAUSD, this growth would occur over a
period of approximately 8 years from 2023 to 2031, resulting in a gradual increase in demand
for school service in PAUSD. Additionally, in order to offset a project’s potential impact to
IMPACT ANALYSIS
PUBLIC SERVICES
1 2 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
schools, school impact fees would be charged to new residential and commercial development
that occurs under the proposed project consistent with State law. Government Code 65995 (b)
establishes the base amount of allowable developer fees a school district can collect from
development projects located within its boundaries. The fees obtained by school districts that
serve Palo Alto are used for construction or reconstruction of school facilities. Future
development facilitated by the proposed project would be required to pay school impact fees
which, pursuant to Section 65995 (3) (h) of the California Government Code (Senate Bill 50,
chaptered August 27, 1998), are “deemed to be full and complete mitigation of the impacts of
any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or
development of real property, or any change in governmental organization or reorganization.”
Facility expansions in the PAUSD would require project-specific environmental analysis under
CEQA to address site-specific environmental concerns. Therefore, existing laws and regulations
that require funding for the provision or expansion of new school facilities would offset impacts
from new residential development, and impacts would be less than significant, and would be
generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
d. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered parks, or the need for new or physically altered parks,
the construction of which could cause significant environmental impacts, in order to
maintain acceptable service ratios or other performance objectives?
Refer to Section 16, Recreation.
e. Would the project result in substantial adverse physical impacts associated with the
provision of other new or physically altered public facilities, or the need for other new or
physically altered public facilities, the construction of which could cause significant
environmental impacts, in order to maintain acceptable service ratios, response times or
other performance objectives?
The 2017 EIR states that while an overall increase in residents is expected, the growth would
occur incrementally throughout the 15-year time horizon; therefore, potential impacts from
increased demand from library services would not occur in the immediate future. Similarly,
growth induced from the proposed HEU would occur incrementally over eight years from 2023
to 2031. Pursuant to Chapter 16.58 of the PAMC, future development would be required to
contribute impact fees to offset potential impacts from increased demand in library facilities
and to ensure library facilities remain adequate. Therefore, impacts would be less than
significant, and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
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CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in the construction of
new or physically altered public facilities, and impacts would be less than significant. Therefore,
the project would not result in new significant effects not addressed in the prior EIR, and no
new mitigation measures are warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
PUBLIC SERVICES
1 3 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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16 Recreation
Where was
Impact
Analyzed
in the EIR?
Could
Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Increase the use of existing
neighborhood and regional
parks or other recreational
facilities such that substantial
physical deterioration of the
facility would occur or be
accelerated?
EIR Page
4.12-17
through
4.12-20
No No No Yes
b. Include recreational facilities or
require the construction or
expansion of recreational
facilities which might have an
adverse physical effect on the
environment?
EIR Page
4.12-17
through
4.12-20
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR analyzes recreation in Section 4.12, Public Services and Recreation, and impacts
are summarized above under Section 14, Public Services. The Comprehensive Plan EIR
concludes that impacts regarding public services would be significant but mitigable with
incorporation of mitigation measure PS-7, which would include new policies and programs
addressing funding, community input, and environmental review for property acquisition and
park construction/improvement.
PROJECT-SPECIFIC IMPACTS
a. Would the project increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical deterioration of the facility would occur
or be accelerated?
b. Does the project include recreational facilities or require the construction or expansion of
recreational facilities which might have an adverse physical effect on the environment?
The City of Palo Alto has adopted a policy of 4 acres of neighborhood and district parkland for
every 1,000 residents and a parkland dedication standard of 5 acres of parkland (including open
space) for every 1,000 residents. Based on the existing 2022 population of 67,473 and the
adopted parkland standard, Palo Alto should currently provide 269.9 acres of neighborhood
IMPACT ANALYSIS
RECREATION
1 3 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
and district parkland.12 There is an existing total of 173.4 acres of neighborhood and district
parkland, 96.5 acres below the adopted policy.
The proposed HEU would increase the number of residential units by 665 compared to Scenario
6 of the 2017 EIR, and would therefore increase the demand for parks and recreational facilities
and would require more acres of new parkland to meet the city’s requirement that new
residential development provide 5 acres of parkland per 1,000 residents. As noted above, the
city currently provides less parkland than required to meet its adopted policy for neighborhood
and district parkland. Nonetheless, future development would be required to comply with
Chapter 21.50 of the PAMC which outlines requirements for parkland dedication or in lieu fees
payment, and the ongoing master planning effort for the parks, trails, and open space system
would develop strategies for the addition and improvement of park land. Because the exact
locations of future residential or parkland development are not known at this time, it would be
speculative to assess the physical environmental impacts associated with the construction of
future park facilities. However, given the need to new parkland under the proposed HEU,
construction or expansion of new parks or recreation facilities would be expected and the
impact would be potentially significant. However, future development would be required to
comply with Policy N-1.13 of the 2030 Comprehensive Plan, adopted in compliance with
Mitigation Measure PS-7 of the 2017 EIR, which would address the potential physical impacts of
park construction and improvement and reduce impacts to a less than significant level,
generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
Because there would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in the substantial
deterioration of existing neighborhood and regional parks. The proposed HEU could result in
the construction or expansion of new parks or recreational facilities and this impact could be
potentially significant. However, Policy N-1.13 adopted in compliance with Mitigation Measure
PS-7 would reduce impacts to a less than significant level. Therefore, the project would not
result in new significant effects not addressed in the prior EIR, and no new mitigation measures
are warranted. This issue does not require further study in an EIR.
12 67,473 (existing population) / 1,000 = 67.473 x 4 (number of acres per 1,000 residents of parkland) = 269.89
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17 Transportation
Where was
Impact
Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Conflict with a program, plan,
ordinance or policy addressing
the circulation system,
including transit, roadway,
bicycle and pedestrian
facilities?
EIR Pages
4.13-38
through
4.13-48
No No No No
b. Conflict or be inconsistent with
CEQA Guidelines section
15064.3, subdivision (b)?
EIR Pages
4.13-18
through
4.13-30
No No No No
c. Substantially increase hazards
due to a geometric design
feature (e.g., sharp curves or
dangerous intersections) or
incompatible use (e.g., farm
equipment)?
EIR Pages
4.13-49
through
4.13-51
No No No No
d. Result in inadequate
emergency access?
EIR Pages
4.13-51
through
4.13-52
No No No No
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.13, Transportation and Traffic, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to traffic and the circulation system. The 2017 EIR analyzes
transportation impacts using the level of service (LOS) methodology and found that impacts
would be significant and unavoidable since there would be six intersections with a substandard
LOS and there would be a significant impact during at least one of the peak hours. Although
implementation of mitigation measures TRANS-1a through 1e would mitigate the projected
impact to a less than significant level, Scenario 6 would still result in some impacted
intersections, both because of growth in Palo Alto and regional growth. Therefore, the
mitigation measures would reduce, but not eliminate, impacts at five of the six study
intersections analyzed in the 2017 EIR. Additionally, the 2030 Comprehensive Plan was found to
cause a freeway segment or ramp to drop below its level of service standard, or deteriorate
operations that already operate at a substandard level of service since mitigation measures
TRANS-1a and TRANS-3b would reduce but not eliminate the impact under Scenario 6 on four
freeway segments. Although mitigation measures TRANS-3a and 3b would be required, impacts
would remain significant and unavoidable. The 2017 EIR found that the 2030 Comprehensive
Plan would not cause a roadway segment to drop below its level of service standard or
deteriorate operations that already operate at a substandard level of service.
IMPACT ANALYSIS
TRANSPORTATION
1 3 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
The 2017 EIR concluded that the 2030 Comprehensive Plan would not impede the function of
planned bicycle or pedestrian facilities since compliance with existing City regulations and
procedures would maintain existing and may improve the function of planned bicycle and
pedestrian facilities. Furthermore, the 2030 Comprehensive Plan would not increase demand
for pedestrian and bicycle facilities as well as transit services that cannot be met by existing or
planned facilities or services. The 2030 Comprehensive Plan would also not result in inadequate
emergency access and impacts would be less than significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would create the potential
demand for through traffic to use local residential streets and would create an operational
safety hazard since growth under Scenario 6 could result in increased congestion, increasing the
potential for drivers to divert onto local streets and therefore causing a potential for increase in
accidents onto local streets. Therefore, mitigation measures TRANS-8 and TRANS-9 would be
required to reduce impacts to a less than significant level.
Table 25 lists the 2017 EIR’s mitigation measures related to transportation. Pursuant to Public
Resource Code, Section 21099 (b)(2), traffic congestion, while potentially an inconvenience to
drivers, is not itself an environmental impact. Therefore, issues related solely to traffic
congestion are outside the scope of CEQA analysis.
Table 25 2017 EIR Mitigation Measures: Transportation and Traffic
Mitigation
Measure # Mitigation Measure Text
Impact TRANS-1: Implementation of the project would cause an intersection to drop below its motor vehicle level of
service standard, or deteriorate operations at representative intersections that already operate at a substandard level of
service. (Significant and Unavoidable)
TRANS-1a Adopt a programmatic approach to reducing traffic with the goal of achieving no net increase in peak
period motor vehicle trips from new development, with an exception for uses that directly contribute to
the neighborhood character and diversity of Palo Alto (such as ground floor retail and below market rate
housing). The program should, at a minimum:
Require new development projects to prepare and implement a Transportation Demand Management
(TDM) Plan to achieve the following reduction in peak period motor vehicle trips from the rates
included in the Institute of Transportation Engineers’ Trip Generation Manual for the appropriate land
use category. These reductions are deemed aggressive, yet feasible, for the districts indicated.
45 percent reduction in the Downtown district
35 percent reduction in the California Avenue area
30 percent reduction in the Stanford Research Park
30 percent reduction in the El Camino Real Corridor
20 percent reduction in other areas of the city.
TDM Plans must be approved by the City and monitored by the property owner on an annual basis.
The Plans must contain enforcement mechanisms or penalties that accrue if targets are not met.
Require new development projects to pay a Transportation Impact Fee which will be partially used to
reduce peak period motor vehicle trips citywide.
TRANS-1b Study the feasibility of unbundled parking for office, commercial and multi-family residential
development (including senior housing developments) that are well-served by transit and demonstrated
walking and biking connections, including senior housing developments.
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Mitigation
Measure # Mitigation Measure Text
TRANS-1c Include policies in the Comprehensive Plan to ensure collaboration with regional agencies and
neighboring jurisdictions, and identification and pursuit of funding for rail corridor improvements and
grade separation. Policies shall support grade separation of rail crossings along the rail corridor as a City
priority and encourage studies and outreach necessary to advance grade separation of Caltrain to
become a “shovel ready” project.
TRANS-1d Engage in regional transportation planning and advocate for specific transit improvements and
investments, such as Caltrain service enhancements and grade separations, Dumbarton Express service,
enhanced bus service on El Camino Real with queue jumping and curbside platforms, and additional VTA
bus service.
TRANS-1e Encourage the PAUSD to analyze decisions regarding school assignments to reduce peak period motor
vehicle trips to and from school sites.
Impact TRANS-3: Implementation of the project would cause a freeway segment or ramp to drop below its level of service
standard, or deteriorate operations that already operate at a substandard level of service. (Significant and Unavoidable)
TRANS-3a The City shall require new development projects to prepare and implement TDM programs, as described
in TRANS-1a. TDM programs for worksites may include measures such as private bus services and free
shuttle services to transit stations geared towards commuters.
TRANS-3b Include policies in the Comprehensive Plan that advocate for efforts by Caltrans and the Valley
Transportation Authority to reduce congestion and improve traffic flow on existing area freeway facilities
consistent with Statewide GHG emissions reduction initiatives.
Policies shall support the application of emerging freeway information, monitoring, and control systems
that provide non-intrusive driver assistance and reduce congestion.
Policies shall support, where appropriate, the conversion of existing traffic lanes to exclusive bus and
high-occupancy vehicle (HOV) lanes on freeways and expressways, including the Dumbarton Bridge, and
the continuation of an HOV lane from Redwood City to San Francisco.
Impact TRANS-8: Implementation of the project would create the potential demand for through traffic to use local
residential streets. (Significant and Mitigable)
TRANS-8 Include policies in the Comprehensive Plan to identify specific improvements that can be used to
discourage non-local drivers from using local, neighborhood streets to bypass traffic congestion on
arterials.
Impact TRANS-9: Implementation of the project would create an operational safety hazard. (Significant and Mitigable)
TRANS-9 Implement Mitigation Measure TRANS-8.
Source: City of Palo Alto 2016
REGULATORY SETTING
SENATE BILL 743 AND VEHICLE MILES TRAVELED
Senate Bill (SB) 743 was signed into law by Governor Brown in 2013 and directed the State
Office of Planning and Research (OPR) to establish new criteria for determining the significance
of transportation impacts under the California Environmental Quality Act (CEQA). SB 743
requires the new criteria to “promote the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses.” It also states
that alternative measures of transportation impacts may include “vehicle miles traveled, vehicle
miles traveled per capita, automobile trip generation rates, or automobile trips generated.”
In January 2018, OPR transmitted its proposed CEQA Guidelines implementing SB 743 to the
California Natural Resources Agency for adoption, and in January 2019 the Natural Resources
IMPACT ANALYSIS
TRANSPORTATION
1 3 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Agency finalized SB 743 updates to the CEQA Guidelines. SB 743 changed the way that public
agencies evaluate the transportation impacts of projects under CEQA, recognizing that roadway
congestion, while an inconvenience to drivers, is not itself an environmental impact (Public
Resource Code, § 21099 (b)(2)). In addition to new exemptions for projects consistent with
specific plans, the CEQA Guidelines replaced congestion-based metrics, such as auto delay and
level of service (LOS), with VMT as the basis for determining significant impacts, unless the
Guidelines provide specific exceptions.
The 2017 EIR examined program-level transportation impacts using the level of service (LOS)
methodology and found that all such impacts would be significant and unavoidable. Although
the 2017 EIR analyzes VMT, VMT was not the basis for a standard of significance used and no
impact finding regarding VMT was made. Nonetheless, Scenario 6 was found to result in the
lowest VMT per capita (including employment and residential VMT) of 30.8 compared to other
scenarios.
PROJECT-SPECIFIC IMPACTS
This analysis is based upon the VMT Analysis prepared for the HEU by Hexagon Transportation
Consultants, Inc. (Hexagon) in January 2023 (Appendix A).
IMPACT ANALYSIS
a. Would the project conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities?
The 2017 EIR used level of service (LOS) as its performance criteria while analyzing the city’s
roadway system. However, to implement SB 743, the CEQA Guidelines have been updated to
change the criteria for determining what constitutes a significant traffic related environmental
impact to rely upon quantification of VMT instead of LOS. The proposed HEU would be
consistent with the Transportation Element of the 2030 Comprehensive Plan since it would
place housing near transit, services, and jobs, which would reduce the usage of single-
occupancy vehicles and encourage walking, bicycling, and using alternative modes of
transportation.
Bicycling would be encouraged through the Bicycle and Pedestrian Transportation Plan which
aims to improve bicycling and pedestrian conditions and increase bicycling and walking rates
within Palo Alto (City of Palo Alto 2012). Future residents would be able to benefit from goals,
policies, and improvements associated with the Bicycle and Pedestrian Transportation Plan
which would reduce VMT and reliance on single-occupancy vehicles.
Future development proposals for individual projects would be subject to adopted
development guidelines, including standards that govern VMT, transportation, GHG, and
associated issues. Impacts identified for development facilitated by the plan would be
addressed through the project approval process, including Planning and Transportation
Commission (PTC) review as well as design review specific to potential impacts of that project.
Because the proposed HEU does not include modifications to the existing transportation
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network and individual future developments must be designed consistent with applicable
bicycle and pedestrian facility requirements, the proposed HEU would not conflict with the
City’s existing circulation, bicycle, or pedestrian plans. Impacts to transit, roadway, bicycle, and
pedestrian facilities would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3,
subdivision (b)?
CEQA Guidelines Section 15064.3(b) requires specific consideration of a plan or project’s
transportation impacts based on VMT. This implements SB 743, which eliminates level of
service as a basis for determining significant transportation impacts under CEQA and requires a
different performance metric: VMT. With this change, the State shifted the focus from
measuring a plan or project’s impact upon drivers (LOS) to measuring the impact of driving
(VMT) on achieving its goals of reducing GHG emissions, encouraging infill development, and
improving public health through active transportation.
Hexagon Transportation Consultants, Inc. prepared a VMT Analysis (Appendix A) for the
proposed HEU to determine whether it would generate a significant VMT impact. The City
adopted a VMT threshold for residential projects on June 15, 2020. A residential project that
exceeds a level of 15 percent below existing (baseline) County home-based VMT per resident
may indicate a significant transportation impact.
The City of Palo Alto Travel Forecasting Model (PA model) was used to estimate VMT for the
proposed project. According to the PA model, the countywide average VMT per resident for
residential development is 12.90 miles. Based on the Palo Alto VMT Criteria, a project
generating a VMT that is 15 percent or more below this value, or 10.97 daily vehicle miles per
resident, would have a less-than-significant VMT impact. Based on the results of the PA model,
as shown in Table 26, the project would have a projected VMT rate of 9.28 miles per resident,
lower than the significance threshold of 10.97 miles, since the proposed project would
concentrate new residential units in urbanized areas in proximity to transit, jobs, and services
compared to other parts of the County. Therefore, this impact would be less than significant,
and further analysis is not warranted.
Table 26 Vehicle Miles Traveled Analysis Summary
VMT Metric
Baseline
VMT Rate
Significance
Threshold
Project
VMT Rate Resulting Significance
VMT per resident (Countywide baseline) 12.90 10.97 9.28 Less than significant
Sources: Hexagon Transportation Consultants, Inc 2023; Appendix A
IMPACT ANALYSIS
TRANSPORTATION
1 3 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
c. Would the project substantially increase hazards due to a geometric design feature (e.g.,
sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)?
In the absence of specific project applications to review, analyzing impacts based on project
design features would be wholly speculative. CEQA does not require public agencies to
speculate. Adoption of the proposed HEU analyzes the amount of new housing units the City
will accommodate during the 2023-2031 planning period and sets goals and policies for how
this housing is implemented. It does not grant entitlements for any specific project or future
development. Thus, the plan for new housing and the goals and policies needed to achieve that
housing do not have a specific transportation safety impact or hazard. The proposed project
would not include hazardous geometric design features or incompatible uses. Each housing
application would be evaluated at the project specific level and undergo design review which
would ensure design features would be in accordance with all applicable City standards to
minimize design hazards. Furthermore, future projects facilitated would be infill projects or
would include increasing density and height of existing sites, and therefore would not involve
the creation of new roadways or intersections or incompatible uses within Palo Alto. While new
intersections of existing local streets with proposed new streets internal to these sites may be
created if these sites would be developed, they would be subject to the project-level review
processes described above to ensure hazards from design features or incompatible uses are not
created. Therefore, impacts from hazardous design features or incompatible uses would be less
than significant and would be generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan as analyzed in the 2017 EIR. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
d. Would the project result in inadequate emergency access?
Similar to Scenario 6 as discussed in the 2017 EIR, traffic increases would contribute to
congestion on freeway segments, which could contribute to cumulative traffic conditions that
have the potential to impede emergency vehicle access on US 101. However, isolated instances
of emergency vehicles being impeded vary on a case-by-case basis and more information would
be needed to determine the precise problem causing a particular event. It would be speculative
to try to determine how future traffic associated with development in Palo Alto would
cumulatively contribute to such events. In addition, approximately 15 percent of the traffic
signals maintained by the City of Palo Alto are equipped with emergency vehicle preemption
devices. The city will continue to install traffic signal preemption devices where appropriate.
Emergency vehicles have the right to use lights and sirens to allow them to bypass congestion,
and all other vehicles are required by State law to pull over to allow emergency vehicles to
pass. Additionally, future development would be required to comply with comply with basic
building designs and standards for residential buildings as mandated by the Palo Alto Fire Code
pursuant to PAMC Chapter 15.04. Future projects would be required to incorporate all
applicable design and safety requirements as set forth in the most current adopted building
codes and fire and life safety standards. Additionally, as discussed under Section 9, Hazards and
Hazardous Materials, the proposed HEU would not impair implementation of or physically
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CITY OF PALO ALTO P a g e | 1 3 9
interfere with an adopted emergency response plan or emergency evacuation plan. Therefore,
impacts would be less than significant and would be generally the same as the impact analyzed
in the 2017 EIR for the 2030 Comprehensive Plan as analyzed in the 2017 EIR. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not conflict with a program, plan,
ordinance or policy addressing the circulation system; result in a significant VMT impact;
substantially increase hazards due to a geometric design feature or incompatible use; or result
in inadequate emergency access. Therefore, the project would not result in new significant
effects not addressed in the prior EIR, and no new mitigation measures are warranted. This
issue does not require further study in an EIR.
IMPACT ANALYSIS
TRANSPORTATION
1 4 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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18 Tribal Cultural Resources
Where was
Impact
Analyzed in
the EIR?
Could
Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of
the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that
is:
a. Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register
of historical resources as
defined in Public Resources
Code Section 5020.1(k)?
EIR Pages
4.4-2
through
4.4-5
No No No Yes
b. A resource determined by the
lead agency, in its discretion and
supported by substantial
evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public
Resources Code Section 5024.1?
EIR Pages
4.4-7
through
4.4-9
No No No Yes
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR does not specifically discuss impacts to tribal cultural resources or compliance
with Assembly Bill 52 (AB 52), which was signed into law in 2014. AB 52 expanded CEQA by
defining a new resource category, “tribal cultural resources,” and requires lead agencies to
complete consultation with California Native American Tribes regarding proposed projects,
because it became effective after the issuance of the Notice of Preparation for 2017 EIR.
However, as described in Section 5, Cultural Resources, of this Addendum, the 2017 EIR
incorporated required mitigation measures CULT-1 and CULT-3 for procedures in the event
archaeological resources, tribal resources, and human remains are discovered during
construction.
ASSEMBLY BILL 52 OF 2014
AB 52 establishes that “A project with an effect that may cause a substantial adverse change in
the significance of a tribal cultural resource is a project that may have a significant effect on the
environment” (PRC Section 21084.2). It further states that the lead agency shall establish
measures to avoid impacts that would alter the significant characteristics of a tribal cultural
resource, when feasible (PRC Section 21084.3).
PRC Section 21074 (a)(1)(A) and (B) defines tribal cultural resources as “sites, features, places,
cultural landscapes, sacred places, and objects with cultural value to a California Native
American tribe” and are:
IMPACT ANALYSIS
TRIBAL CULTURAL RESOURCES
1 4 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
1. Listed or eligible for listing in the California Register of Historical Resources, or in a local register
of historical resources as defined in Public Resources Code section 5020.1(k), or
2. A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying these criteria, the lead agency shall consider the significance of
the resource to a California Native American tribe.
AB 52 also establishes a formal consultation process for California tribes regarding those
resources. The consultation process must be completed before a CEQA document can be
certified. Under AB 52, lead agencies are required to “begin consultation with a California
Native American tribe that is traditionally and culturally affiliated with the geographic area of
the proposed project.” Native American tribes to be included in the process are those that have
requested notice of projects proposed within the jurisdiction of the lead agency.
The requirements of AB 52 do not apply to the proposed project because it falls under a
previously certified EIR. Nonetheless, the City of Palo Alto conducted tribal consultation in
accordance with AB 52 as well as in accordance with Senate Bill 18. The City sent out letters via
certified mail on September 29, 2022, to the following eight Native American Tribes that that
were identified by the NAHC as being traditionally and culturally affiliated with the geographic
area:
Amah Mutsun Tribal Band
Amah Mutsun Tribal Band of Mission San Juan Bautista
Indian Canyon Mutsun Band of Costanoan
Muwekma Ohlone Indian Tribe of the SF Bay Area
Northern Valley Yokuts Tribe
The Ohlone Indian Tribe
Wuksache Indian Tribe/Eshom Valley Band
Tamien Nation
Under AB 52, Native American tribes typically have 30 days to respond and request further
project information and formal consultation. Under SB 18, Native American tribes have 90 days
to respond and request further project information and request formal consultation. To date,
the City of Palo Alto has not received responses requesting consultation under AB 52 or SB 18
from the Tribes. AB 52 and SB 18 correspondence is included in Appendix C.
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IMPACT ANALYSIS
a. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource as defined in Public Resources Code Section 21074 that is listed or eligible for
listing in the California Register of Historical Resources, or in a local register of historical
resources as defined in Public Resources Code Section 5020.1(k)?
b. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource as defined in Public Resources Code 21074 that is a resource determined by the
lead agency, in its discretion and supported by substantial evidence, to be significant
pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1?
No specific tribal cultural resources were identified in the City of Palo Alto as a result of
consultation with the Tribes. Similar to what was assumed in the 2017 EIR, although
development under the proposed HEU would occur on non-vacant and underutilized sites in
previously disturbed areas, ground-disturbing activities such as earthmoving and excavation
could still potentially damage and/or destroy unrecorded tribal cultural resources in subsurface
soils within the housing sites. Adherence to the requirements of AB 52 would require Tribal
consultation with local California Native American Tribes prior to implementation of project
activities subject to CEQA. AB 168 would require Tribal consultation with local California Native
American Tribes prior to implementation of project activities subject to SB 35. In compliance
with AB 52, a determination of whether project-specific substantial adverse effects on tribal
cultural resources would occur along with identification of appropriate project-specific
avoidance, minimization, or mitigation measures would be required. Due to the programmatic
nature of the proposed HEU it is not possible to fully determine impacts of specific projects on
specific sites; however, no tribal cultural resources were identified during consultation. Future
projects subject to CEQA and SB 35 would require project-specific tribal cultural resource
identification and consultation, and the appropriate avoidance, minimization, or mitigation
would be incorporated. Project-specific tribal cultural resource consultation will occur when
specific projects are implemented, and consultation conducted pursuant to the requirements of
AB 52. Future development would also be required to comply with policies L-7.16 through 7.18
of the 2030 Comprehensive Plan, adopted in compliance with Mitigation Measure CULT-3 of
the 2017 EIR, which would reduce impacts on tribal cultural resources to a less than significant
level. Because there would be no new or substantially more severe significant impacts than
what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, development would occur in the same areas as those
analyzed in the 2017 EIR. Further, future development would be required to comply with
federal, State, and local regulations pertaining to tribal cultural resources as well as policies
adopted in compliance with Mitigation Measure CULT-3 from the 2017 EIR, which would reduce
impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
TRIBAL CULTURAL RESOURCES
1 4 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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19 Utilities and Service Systems
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Require or result in the
relocation or construction of
new or expanded water,
wastewater treatment or
storm water drainage,
electric power, natural gas, or
telecommunications facilities,
the construction or relocation
of which could cause
significant environmental
effects?
EIR Pages
4.14-2
through
4.14-7; 4.14-
14 through
4.14-15;
4.14-18
through
4.14-19;
4.14-25
through
4.14-28;
4.14-33
through
4.14-38
No No No N/A
b. Have sufficient water supplies
available to serve the project
and reasonably foreseeable
future development during
normal, dry and multiple dry
years?
EIR Pages
4.14-2
through
4.14-4
No No No N/A
c. Result in a determination by
the wastewater treatment
provider which serves or may
serve the project that it has
adequate capacity to serve
the project’s projected
demand in addition to the
provider’s existing
commitments?
EIR Pages
4.14-10
through
4.14-16
No No No N/A
d. Generate solid waste in
excess of State or local
standards, or in excess of the
capacity of local
infrastructure, or otherwise
impair the attainment of solid
waste reduction goals?
EIR Pages
4.14-25
through
4.14-28
No No No N/A
e. Comply with federal, state,
and local management and
reduction statutes and
regulations related to solid
waste?
EIR Pages
4.14-28
through
4.14-30
No No No N/A
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 4 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.14, Utilities and Service Systems, of the 2017 EIR analyzed the 2030 Comprehensive
Plan’s impacts related to utilities and service systems. The 2017 EIR found that sufficient water
supplies from existing entitlements would be available to serve Scenario 6 and the increased
demand in water would not result in the substantial physical deterioration of a water utility
facility. Additionally, the 2030 Comprehensive Plan would not prompt a need to expand
treatment facilities or regional water system conveyance and storage facilities in order to meet
its demand. New or expanded local water distribution facilities would require permitting and
review in accordance with CEQA, which would ensure environmental impacts are disclosed and
mitigated. Therefore, impacts would be less than significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would not exceed wastewater
treatment requirements of the RWQCB or wastewater treatment capacity of the Regional
Water Quality Control Plant (RWQCP). Furthermore, the 2030 Comprehensive Plan would not
result in substantial physical deterioration of the RWQCP or adverse physical impacts from new
or expanded wastewater utility facilities since the existing RWQCP would provide adequate
capacity to meet dry weather and maximum month flows through at least 2035 and beyond.
Therefore, impacts would be less than significant.
The 2017 EIR found that the 2030 Comprehensive Plan would not require or result in the
construction of new stormwater facilities or expansion of existing facilities since development
would be required to comply with Provision C.3 of the MRP, as well as the City’s post-
construction site design measures, source control measures, and stormwater treatment
measures. The 2030 Comprehensive Plan would not result in a substantial physical
deterioration of stormwater facilities with compliance with existing State, regional, and local
regulations. Therefore, impacts would be less than significant.
The 2017 EIR determined that the 2030 Comprehensive Plan would be served by 17 different
landfills with sufficient permitted capacity to accommodate the increased waste disposal needs.
However, the 2017 EIR found that the 2030 Comprehensive Plan could potentially fall out of
compliance with federal, State, and local statutes and regulations related to solid waste, and
mitigation measure UTIL-15 would be required to reduce impacts to a less than significant level.
The 2017 EIR also analyzes impacts to energy supply and efficiency which is discussed in Section
6, Energy, of this document.
Table 27 lists the mitigation measures from the 2017 EIR related to utilities and service systems.
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Table 27 2017 EIR Mitigation Measures: Utilities and Service Systems
Mitigation
Measure # Mitigation Text
Impact UTIL-15: Without the adoption of policies to promote recycling and conservation, the proposed Plan could
potentially fall out of compliance with federal, State, and local statutes and regulations related to solid waste. (Potentially
Significant and Mitigable)
UTIL-15 To ensure that future development under Scenarios 2, 3, and 4 would comply with applicable solid
waste regulations, the proposed Plan shall include policies that address the following topics:
Substantial landfill diversion by 2030, and ultimately zero waste.
Reduced solid waste generation.
Use of reusable, returnable, recyclable, and repairable goods.
Enhanced recycling and composting programs for all waste generators.
Source: City of Palo Alto 2016
PROJECT-SPECIFIC IMPACTS
a. Would the project require or result in the relocation or construction of new or expanded
water, wastewater treatment or storm water drainage, electric power, natural gas, or
telecommunications facilities, the construction or relocation of which could cause
significant environmental effects?
WATER
As discussed under Threshold Question (b) below, water supply and demand for the proposed
HEU would be similar to that of Scenario 6 of the 2017 EIR. The City receives 100 percent of its
potable water from the SFPUC. The City does not own or operate a water treatment plant
(WTP). The water purchased from the SFPUC may be treated at one or more WTPs operated by
SFPUC. SFPUC treats water to meet all applicable drinking water standards. SFPUC periodically
makes improvements to its WTPs in order to improve system reliability and accommodate
projected growth in its regional service areas. For example, the Water System Improvement
Program (WSIP) includes capacity expansion and other improvements in order to upgrade
SFPUC’s regional and local water systems. The WSIP also includes many projects to improve the
Regional Water System distribution lines and storage reservoirs (City of Palo Alto 2017a).
Although existing local distribution lines within the city could potentially be undersized for
future projects and improvements under the proposed HEU could require replacement with
larger diameter pipes, potential environmental impacts that could result from pipeline
improvements would be project specific. New or expanded local water distribution facilities
would require permitting and review in accordance with CEQA, which would ensure
environmental impacts are disclosed and addressed in the environmental analysis. Therefore,
similar to Scenario 6, the proposed HEU would not result in the expansion or construction of
new treatment facilities or regional water system conveyance and storage facilities in order to
meet its demand and this impact would be less than significant, generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 4 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
WASTEWATER
As discussed under Threshold Question (c), the existing RWQCP facilities would provide
adequate capacity to meet dry weather and maximum month flows through at least 2035 and
beyond, and that new or expanded facilities would not be needed as a result of the proposed
HEU. Some aging facilities will need to be replaced, based on the treatment processes design
criteria and historical performance. However, these facility upgrades and replacements are
anticipated based on existing planning documents and would not be necessitated as a result of
the proposed HEU. In addition, the LRFP anticipates that the existing RWQCP facilities will
provide adequate capacity to meet dry weather and maximum month flows through at least
2035, assuming the same level of treatment is required. Therefore, similar to Scenario 6, the
proposed HEU would not result in the expansion or construction of new wastewater facilities
and this impact would be less than significant, generally the same as the impact analyzed in the
2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or substantially
more severe significant impacts than what was analyzed in the 2017 EIR, further analysis is not
warranted.
STORMWATER
Although the proposed HEU would increase the number of residential units by 665 compared to
Scenario 6 of the 2017 EIR, new future development would be required to comply with the C.3
provisions of the MRP and implement BMPs and LID features to minimize stormwater runoff
impacts. In particular, during construction, future projects would be required to implement
flow control BMPs to minimize potential impacts. Similar to Scenario 6, the proposed HEU does
not propose the conversion of open space areas, creeks, or wetlands to impervious surfaces
and would not alter the course of a stream or river. The City’s Department of Public Works
requires all new development projects to provide storm drain flow and detention calculations,
including pre-project and post-project conditions and flow rates. On-site stormwater detention
is also required as per the C.3 provisions of the MRP. In addition, per section C.3.j, future
applicants would be required to complete and implement a Green Infrastructure Plan for the
inclusion of low impact development drainage design into storm drain infrastructure on public
and private lands, including streets, roads, storm drains, parking lots, building roofs, and other
storm drain infrastructure elements (City of Palo Alto 2017a). Compliance with State and local
stormwater regulations would reduce impacts to a less than significant level, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
TELECOMMUNICATIONS
The proposed HEU would require connections to existing adjacent utility infrastructure to meet
the needs of future residents. Similar to Scenario 6 of the 2017 EIR, the proposed HEU would
only facilitate development on non-vacant and underutilized sites in urbanized areas. Based on
the availability of existing telecommunications infrastructure, construction of new telephone
and cable lines would not be required, and all future development would be able to connect to
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existing infrastructure. Development facilitated by the project would be required to adhere to
applicable laws and regulations related to the connection to existing telecommunication
infrastructure. Therefore, there would be adequate telecommunications facilities to serve the
development facilitated by the project, and impacts would be less than significant, generally
the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because
there would be no new or substantially more severe significant impacts than what was analyzed
in the 2017 EIR, further analysis is not warranted.
ELECTRICITY AND NATURAL GAS
As discussed in the 2017 EIR, Scenario 6 would result in a long-term increase in electrical service
energy demand ranging from 10 percent to 11 percent over 2014 baseline levels within the
CPAU’s service territory for electrical service. This average incremental increase in electrical
service demand would be less than a one percent increase per year. Although the proposed
HEU would increase the number of residential units by 665 compared to Scenario 6 of the 2017
EIR, it would not include non-residential uses and therefore electricity demand would be similar
to that of Scenario 6 and would result in less than a one percent increase per year. Since the
proposed HEU would also facilitate development in non-vacant and underutilized sites with
existing infrastructure, it is not anticipated that the construction of new electrical transmission
and distribution lines would be required. Therefore, the proposed HEU would not result in the
relocation or construction of new or expanded electrical facilities and impacts would be less
than significant, generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
Similarly, for the same reasons described above, the proposed HEU would not substantially
increase natural gas demand compared to Scenario 6 and future development would also be
subject to the City’s most updated Reach Code and All-Electric Mandate which requires all-
electric building design for single-family, low-rise multi-family, and non-residential
development (City of Palo Alto 2022a). Therefore, the proposed HEU would not result in the
relocation or construction of new or expanded natural gas facilities and impacts would be less
than significant, generally the same as the impact analyzed in the 2017 EIR for the 2030
Comprehensive Plan. Because there would be no new or substantially more severe significant
impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
b. Would the project have sufficient water supplies available to serve the project and
reasonably foreseeable future development during normal, dry and multiple dry years?
As discussed in the 2017 EIR, the increased water demand for Scenario 6 would be
approximately 13,767 acre-feet per year (AFY), and the city’s Individual Supply Guarantee
through 2035 is 19,118 AFY. As shown on Table 28, the additional 665 units facilitated by the
proposed HEU compared to the 2017 EIR would increase water demand by approximately
43,225 gallons per day (gpd) or 48.4 acre-feet per year (AFY) in 2031 assuming full buildout.
According to the city’s 2020 Urban Water Management Plan (UWMP), by 2030, the city would
have a water demand of 11,394 AFY and an Individual Supply Guarantee of 18,579 AFY.
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 5 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Therefore, the proposed project would increase Palo Alto’s estimated 2030 normal-year water
demand by approximately 0.4 percent.
Table 28 Estimated Water Use for the Proposed HEU
Potential Buildout
Development/Land Use
Water Generation
Factor (gpd/unit) 1
Projected Number
of Housing Units
Projected Water
Demand in 2031 (gpd)
Projected Water
Demand in 2031 (AFY)
Multi-family residential 65 665 43,225 48.4
1 Per unit water demand factors from Palo Alto are not available, therefore, this analysis is based water use factors provided by the
East Bay Municipal Utilities District, 65 gpd/unit for a low-rise apartment.
gpd =gallons per day. AFY = acre-feet per year
According to the city’s 2020 UWMP, the City of Palo Alto analyzed three different hydrological
conditions to determine the reliability of water supplies for the City: average/normal water
year, single dry water year, and multiple dry water year period. In each of the three
hydrological conditions, the projected water demand was calculated taking into account growth
in billing data, water conservation efforts, and demographics. The UWMP states that the City of
Palo Alto can reliably meet the projected water demand in normal years. However, there would
be a potable water supply shortfall for single dry year and multiple dry years. Under these
conditions, residents would be required to reduce water usage by 30 to 50 percent depending
on the length of the dry year. The San Francisco Public Utilities Commission (SFPUC) and Bay
Area Water Supply and Conservation Agency (BAWSCA) are also evaluating alternative water
supplies during and seeking water supplies and solutions for drought years. In addition, the City
of Palo Alto has formed partnerships such as the one with Valley Water and is embarking on a
One Water plan which will have dry year water supply reliability as a central tenet (City of Palo
Alto 2021). The City of Palo Alto also offers many resources to help residents use water wisely,
including free water surveys, conservation devices, educational programs, and rebates for
appliance or landscape upgrades (City of Palo Alto 2017a). The City presents drought updates to
the Utilities Advisory Commission monthly and has held numerous public meetings to update
the community on the drought, responses by the State and the City, and available resources.
Therefore, sufficient water supplies would be available to serve the proposed HEU during
normal, single- and multiple-dry years, and impacts would be less than significant, generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
c. Would the project result in a determination by the wastewater treatment provider which
serves or may serve the project that it has adequate capacity to serve the project’s
projected demand in addition to the provider’s existing commitments?
As discussed in the 2017 EIR, Scenario 6 would increase wastewater generation by 631,032
gallons per day (GPD) and this estimated worst-case increase in water flow would represent
less than four percent of the existing excess dry flow capacity of 18 million gallons per day
(MGD) available at the RWQCP. The Long Range Facilities Plan (LRFP) also further estimates that
the RWQCP would have at least 5 MGD of excess capacity in 2062. Assuming that wastewater
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generation is 80 percent of water use, the proposed HEU would increase wastewater
generation by approximately 34,580 gpd.13 This would constitute approximately 0.2 percent of
the RWQCP’s excess dry flow capacity and therefore the RWQCP would have sufficient capacity
to accommodate the 665 additional units proposed under the HEU. Although some aging
facilities will need to be replaced, based on the treatment processes design criteria and
historical performance, the LRFP anticipates that the existing RWQCP facilities would l provide
adequate capacity to meet dry weather and maximum month flows through at least 2035,
assuming the same level of treatment is required. Projected dry weather flows are anticipated
to be between 28 and 34 MGD in the year 2062, which is below the dry weather flow design
capacity of the plant (39 MGD). Therefore, the RWQCP’s existing capacity would be sufficient to
accommodate the anticipated residential development under the proposed HEU. Development
facilitated by the proposed project would not result in the need to expand the capacity of the
RWQCP. This impact would be less than significant and generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
d. Would the project generate solid waste in excess of State or local standards, or in excess of
the capacity of local infrastructure, or otherwise impair the attainment of solid waste
reduction goals?
e. Would the project comply with federal, state, and local management and reduction
statutes and regulations related to solid waste?
As discussed in the 2017 EIR, Scenario 6 would generate an approximate increase of 15,315
tons per year of solid waste over baseline at buildout. Additionally, the city’s disposal rate per
resident in 2014 was 3.6 pounds per day (PPD), which was below the CalRecycle target of 7.1
PPD per resident. The city’s disposal rates for both residents and employees have been below
target rates since 2007 (City of Palo Alto 2017a).
CalRecycle estimates that multi-family residential uses generate an average of four pounds of
solid waste per unit per day (CalRecycle 2023). As shown in Table 29, prior to implementation
of State-mandated diversion requirements, development associated with the proposed HEU
would generate an estimated 2,660 pounds per day of solid waste, which equates to 1.3 tons or
11.8 cubic yards per day. In accordance with California’s Integrated Waste Management Act of
1989 (AB 939), cities and counties are required to divert 50 percent of all solid wastes from
landfills. Additionally, pursuant to AB 341 adopted in 2012, all businesses that generate four
cubic yards or more of commercial solid waste per week including multi-family dwelling that
consists of five units or more would be required to divert 75 percent of all solid wastes. The City
of Palo Alto has achieved a diversion rate of 82 percent, which substantially exceeds AB 939
State requirement (City of Palo Alto 2018). Assuming that this diversion rate continues to apply
to new development on the project sites, implementation of the project would generate
approximately 0.2 tons or 2.1 cubic yards per day of solid waste for disposal at landfills.
13 43,225 gpd times 0.8 = 34,580 gpd
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 5 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
Table 29 Estimated Solid Waste Generation
Potential Buildout
Development/ Land
Use Quantity Units Generation Rate1
Solid Waste
(pounds per day)
Solid Waste
(tons per day)
Solid Waste
(cubic yards
per day)2
Residential 665 dwelling
units
4 pounds/unit/day 2,660 1.3 11.8
Total Assuming 82% Diversion Rate 479 0.2 2.1
1 CalRecycle 2023
2 RecycleMania/USEPA 2022, assumes 225 pounds per cubic yard of residential waste
In 2019, CalRecycle reported that the overall total of 47,023 tons of solid waste from Palo Alto
was disposed at 17 different landfills. The majority (42,252 tons) were disposed at three
landfills: Kirby Canyon Landfill, Corinda Los Trancos Landfill (Ox Mountain), and Monterey
Peninsula Landfill (CalRecycle 2022). The Kirby Canyon Landfill has a closure year of 2059 and a
remaining capacity of 16,191,600 cubic yards (CalRecycle 2022b); the Ox Mountain Landfill has
a closure year of 2034 and a remaining capacity of 22,180,000 cy (CalRecycle 2022c); and the
Monterey Peninsula Landfill has a closure year of 2107 and a remaining capacity of 48,560,000
(CalRecycle 2022d). With development facilitated by the proposed HEU, it is estimated that the
665 units would generate approximately 2.1 cubic yards of solid waste per day, or 767 cubic
yards of solid waste per year for disposal at landfills. This represents 0.00004 percent of the
current total remaining landfill capacity at the Kirby Canyon Landfill. The projected closure
years and remaining capacities of these three main landfills currently accepting solid waste
from the city would be able to accommodate the projected increase in solid waste under
Scenario 6 and the proposed HEU. There are also 14 more landfills that received waste from
Palo Alto in 2019. If one or more of these landfills were unavailable in the future, it is likely Palo
Alto’s solid waste volume could be increased at one or more of the other landfills that already
serve Palo Alto. Moreover, the city has ongoing and planned measures to divert increasing
amounts of Palo Alto’s solid waste away from landfills. Future development would be required
to comply with PAMC Section 16.14.260 which requires an 80 percent diversion of construction
and demolition debris, and preparation of a Waste Management Plan for on-site sorting of
construction debris, which is submitted to the City for approval, in order to ensure that the
covered project meets the diversion requirement for reused or recycled construction and
demolition debris. Development facilitated by the proposed HEU would also be required to
comply with applicable federal, State, and local statutes and regulations related to solid waste
such as AB 939, which requires the City to divert 50 percent of solid waste from landfills, as well
as SB 1838, which would require mandatory organic waste recycling for future residents.
Furthermore, future development would be required to comply with policies S-3.8, 3.9, and
3.11 of the 2030 Comprehensive EIR, adopted in compliance with Mitigation Measure UTIL-15
of the 2017 EIR, which would ensure waste diversion and increased recycling. Therefore, the
existing landfills would be able to accommodate development under the proposed HEU, and
the proposed HEU would comply with federal, State, and local regulations related to solid
wastes. Impacts would be less than significant with mitigation and generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
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new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not result in the construction or
expansion of utilities facilities, and existing infrastructure would be sufficient to accommodate
the increased residential units. Therefore, the project would not result in new significant effects
not addressed in the prior EIR, and no new mitigation measures are warranted. This issue does
not require further study in an EIR.
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 5 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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20 Wildfire
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a. Substantially impair an
adopted emergency response
plan or emergency evacuation
plan?
N/A No No No N/A
b. Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks and thereby
expose project occupants to
pollutant concentrations from
a wildfire or the uncontrolled
spread of a wildfire?
EIR Pages
4.7-8
through
4.7-9
No No No N/A
c. Require the installation or
maintenance of associated
infrastructure (such as roads,
fuel breaks, emergency water
sources, power lines or other
utilities) that may exacerbate
fire risk or that may result in
temporary or ongoing impacts
to the environment?
N/A No No No N/A
d. Expose people or structures to
significant risks, including
downslopes or downstream
flooding or landslides, as a
result of runoff, post-fire slope
instability, or drainage
changes?
EIR Pages
4.7-8
through
4.7-9
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
The 2017 EIR does not directly address the issue area of wildfire, but discusses wildfire impacts
in Section 4.7, Hazards and Hazardous Materials, of the 2017 EIR. As discussed in the 2017 EIR,
much of the area surrounding Palo Alto west of I-280 is considered to have a moderate and
high risk of wildland fire, whereas all of the urbanized areas of Palo Alto do not have any
wildland fire hazards. The 2017 EIR found that there would be less than significant impacts
related to wildfire.
IMPACT ANALYSIS
WILDFIRE
1 5 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
IMPACT ANALYSIS
a. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project substantially impair an adopted emergency response plan
or emergency evacuation plan?
b. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project, due to slope, prevailing winds, and other factors,
exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations
from a wildfire or the uncontrolled spread of a wildfire?
c. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts
to the environment?
d. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project expose people or structures to significant risks, including
downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
As shown in the CAL FIRE Fire Hazard Severity Zone Map, only the area west of I-280 is located
in a High Fire Hazard Severity Zone (HFHSZ) while the rest of the city east of I-280 is located in
an area with low wildfire risk. Similar to what was analyzed in the 2017 EIR, the proposed HEU
would facilitate development in non-vacant and underutilized sites in urbanized areas of the
city, and would not facilitate development in locations near the HFHSZ. New development
would also be located in proximity to Fire Stations 1, 2, 3, and 4 which would protect future
residents from wildfire hazards. Additionally, future development would be required to comply
with the CAL FIRE Strategic Plan and the CFC pursuant to PAMC Chapter 15.04. The CFC requires
the clearance of debris and vegetation within a prescribed distance from structures in wildlife
hazard areas. The proposed HEU would facilitate residential development primarily on infill
sites in urbanized areas, and would not require the construction of additional roads, power
lines, or other utilities that would exacerbate existing fire risk. Housing sites that require utility
connections would likely install underground connections, and development within
underground utility districts would be required to install new utility connections underground.
Therefore, the project would not impair an adopted emergency response or evacuation plan
related to wildfire; exacerbate wildfire risks; or expose people to post-fire risks related to
runoff, flooding, or landslides. Impacts would be less than significant and generally the same as
the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be
no new or substantially more severe significant impacts than what was analyzed in the 2017
EIR, further analysis is not warranted.
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CONCLUSION
Although the proposed HEU would facilitate the development of 665 more residential units
than analyzed under the 2017 EIR, future development would not impair an adopted
emergency response or evacuation plan related to wildfire; exacerbate wildfire risks; or expose
people to post-fire risks related to runoff, flooding, or landslides. Therefore, the project would
not result in new significant effects not addressed in the prior EIR, and no new mitigation
measures are warranted. This issue does not require further study in an EIR.
IMPACT ANALYSIS
WILDFIRE
1 5 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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21 Cumulative Impacts
CEQA defines “cumulative impacts” as two or more individual impacts that, when considered
together, are substantial or will compound other environmental impacts. Cumulative impacts
are the combined changes in the environment that result from the incremental impact of
development of the proposed project and other nearby projects. For example, noise impacts of
two nearby projects may be less than significant when analyzed separately but could have a
significant impact when analyzed together. Cumulative impact analysis provides a reasonable
forecast of future environmental conditions and can more accurately gauge the effects of a
series of projects.
This analysis is cumulative in nature in that it analyzes future development under the proposed
HEU throughout Palo Alto and takes into consideration the effects associated with
development of multiple projects in the housing element cycle through 2031. For analyses that
may have more localized or neighborhood implications (aesthetics, agriculture, biological
resources, cultural resources, geology and soils, hazards and hazardous materials, hydrology
and water quality, land use and planning, mineral resources, noise, public services, recreation,
utilities, tribal cultural resources, wildfire), the geographic scope for cumulative impacts
includes the city of Palo Alto. For these issue areas, generally, impacts are site specific and
cumulative impacts would not be significant. Therefore, the proposed project would not result
in a cumulatively considerable contribution to the above-mentioned issue areas. Future
development projects would be reviewed by the City pursuant to CEQA to identify potential
impacts to on a project-by-project basis. While there is the potential for significant cumulative
impacts, it is anticipated that potential impacts associated with individual development projects
would be addressed on a case-by-case basis and would be subject to the mitigation measures
outlined in this Addendum, City policies, and State and local regulations regarding the
protection of such resources. With compliance with the existing policies and regulations, and
mitigation measures, future development would be required to avoid or mitigate impacts.
Therefore, the proposed project’s incremental contribution to cumulative impacts associated
with aesthetics, agriculture, biological resources, cultural resources, geology and soils, hazards
and hazardous materials, hydrology and water quality, land use and planning, mineral
resources, noise, public services, recreation, utilities, tribal cultural resources, and wildfire
would not be cumulatively considerable, and cumulative impacts would be less than significant.
Some analyses including air quality, energy, greenhouse gas emissions, transportation, and
population and housing, rely on much larger geographic areas such as the Bay Area region. For
issues that may have regional cumulative implications, the cumulative impact analysis is based
on Plan Bay Area 2050, the Bay Area’s most recent Regional Transportation Plan/Sustainable
Communities Strategy (RTP/SCS).
As discussed in Section 3, Air Quality, the project would be consistent with the 2017 Clean Air
Plan control measures as development facilitated by the project would comply with the latest
Title 24 regulations and would increase density in urban areas in proximity to transit, allowing
for greater use of alternative modes of transportation. Additionally, the increase in VMT would
not exceed the projected population increase per the BAAQMD CEQA Air Quality Guidelines for
IMPACT ANALYSIS
CUMULATIVE IMPACTS
1 6 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
operational emissions from plans. Discussion of these impacts considers the cumulative nature
of criteria pollutants in the region. Therefore, the project would not result in a cumulatively
considerable contribution to an air quality impact.
As discussed in Section 6, Energy, development facilitated by the project would not result in a
wasteful, inefficient, or unnecessary consumption of energy, and operation of the new
residential structures would not result in potentially significant environmental effects due to
the wasteful, inefficient, or unnecessary consumption of energy. Development facilitated by the
project would be consistent with the energy-related goals, policies, and actions of the
Statewide plans and the City’s 2030 Comprehensive Plan; therefore, the project would not
make a cumulatively considerable contribution to a significant cumulative impact with respect
to consistency with renewable energy and energy efficiency plans. Projects throughout the Bay
Area are required to adhere to applicable renewable energy and energy efficiency laws,
programs, and policies such as California’s RPS, AB 2076, and Title 24 standards to avoid the
wasteful, inefficient, or unnecessary consumption of energy.
As discussed in Section 8, Greenhouse Gas Emissions, the impact of GHG emissions generated
by development facilitated by the proposed HEU is inherently cumulative. GHG emissions from
one project cannot, on their own, result in changes in climatic conditions; therefore, the
emissions from any project must be considered in the context of their contribution to
cumulative global emissions, which is the basis for determining a significant cumulative impact.
This is determined through the project’s consistency with applicable GHG emission thresholds
and applicable plans, policies, or regulations adopted for the purpose of reducing the emissions
of GHGs. GHG emissions from development facilitated by the project would not exceed the
BAAQMD interpolated 2031 plan-level threshold. In addition, development facilitated by the
project would be consistent with the 2022 Scoping Plan, Plan Bay Area 2050, 2030
Comprehensive Plan, and the City’s S/CAP. Therefore, the project would not result in a
significant cumulative impact related to GHG emissions.
As discussed in Section 14, Population and Housing, the proposed HEU would result in an
increase of 665 more housing units compared to Scenario 6 of the 2017 EIR. However, the
proposed project would be consistent with State requirements for the RHNA and would further
assist in addressing the existing housing crisis and meeting the housing needs of the City’s
communities. Therefore, the project would not result in a cumulatively considerable
contribution to a population and housing impact.
As discussed in Section 17, Transportation, the proposed HEU would not result in a significant
cumulative VMT impact. Therefore, the project would not result in a cumulatively considerable
contribution to a transportation impact.
Therefore, with continued implementation of mitigation measures from the 2017 EIR, impacts
of the proposed HEU would not be cumulatively considerable. Impacts would be generally the
same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there
would be no new or substantially more severe significant impacts than what was analyzed in
the 2017 EIR, further analysis is not warranted.
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22 Other CEQA Required Discussions
The proposed HEU would not substantially change the discussion and findings presented for the
2030 Comprehensive Plan in Section 7, CEQA-Mandated Sections, of the 2017 EIR. These other
required discussions include impacts found not to be significant, growth-inducing impacts, and
irreversible changes. As with the 2017 EIR, the proposed HEU would not directly induce growth
because it would not extend services to an undeveloped area. The proposed HEU would direct
growth to specific areas that are already urbanized and underutilized and would improve
mobility while not making new areas within or outside of Palo Alto easier to develop. Although
employment growth that occurs during the life of the proposed HEU could indirectly induce
additional growth by contributing to an increased demand for housing, similar to the 2017 EIR,
future development would be required to comply with policies within the 2030 Comprehensive
Plan to ensure growth occurs in a sustainable manner. All potential impacts associated with
population and housing growth would be mitigated to less than significant levels. Given that the
State is currently in an ongoing housing crisis due to an insufficient housing supply, the
additional units under the proposed project would further assist in addressing the existing crisis
and meeting the housing needs of the City’s communities, and would allow the city to satisfy its
fair share of RHNA.
The proposed HEU would allow land uses largely consistent with current land uses and
redevelopment would occur in areas that are already urbanized, which would not result in
irreversible land use changes. Additionally, as discussed in Section 9, Hazards and Hazardous
Materials, of this Addendum, compliance with federal, State, and local hazardous materials
regulations and local emergency plans would ensure that irreversible changes to the physical
environment from the accidental release of hazardous materials are less than significant. As
with the 2017 EIR, the proposed HEU would irretrievably commit non-renewable resources for
the construction and maintenance of buildings and infrastructure. These non-renewable
resources include mined materials such as sand, gravel, steel, lead, copper, and other metals.
Buildout of the proposed HEU would also result in a long-term commitment to the consumption
of fossil fuels, natural gas, and gasoline. Increased energy demands would be used for
construction, lighting, heating, and cooling of residences, and transportation of people within,
to, and from the housing inventory sites. However, the proposed project would place residents
in proximity to transit, services, and jobs, which would reduce consumption of fossil fuels
through the reduced reliance on single-occupancy vehicles and promote bicycling and walking.
Additionally, future development would be required to include an all-electric design pursuant
to the City’s Reach Code and would utilize 100 percent carbon neutral electricity supplied by
CPAU. Therefore, by facilitating residential development that would maximize conservation,
energy efficiency, and solar energy generation, impacts would be less than significant.
As described above in Sections 1 through 20, the proposed project would not result in new or
substantially more severe significant direct, indirect, or cumulative impacts beyond those
identified in the 2017 EIR for the 2030 Comprehensive Plan. Therefore, the proposed project
would also result in no new or substantially more severe significant impacts found not to be
IMPACT ANALYSIS
OTHER CEQA REQUIRED DISCUSSIONS
1 6 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
significant, growth-inducing impacts, and irreversible changes beyond those previously
discussed in the 2017 EIR.
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 1 6 3
CONCLUSION
As demonstrated in the discussions above regarding the potential effects of the proposed HEU,
substantial changes are not proposed to the 2030 Comprehensive Plan nor have substantial
changes in circumstances occurred that would require major revisions to the 2017 EIR prepared
for the 2030 Comprehensive Plan. Significant impacts beyond those identified and analyzed in
the 2017 EIR would not be expected to occur as a result of the proposed project. Overall, the
proposed HEU would result in no new information of substantial importance that would have
new, more severe impacts, or new mitigation measures from what was identified in the 2017
EIR. As such, the proposed project would not result in conditions identified in State CEQA
Guidelines Section 15162, and a Subsequent or Supplemental EIR is not required for the
proposed project. Again, it should be noted that the proposed project would be subject to all
previously required mitigation measures from the 2017 EIR, as applicable. The MMRP adopted
for the 2030 Comprehensive Plan would continue to be applicable to the proposed project.
Based on the above analysis, this Addendum to the 2017 EIR for the 2030 Comprehensive Plan
has been prepared in accordance with Section 15164 of the State CEQA Guidelines.
CONCLUSION
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CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 1 6 5
REFERENCES
BIBLIOGRAPHY
Association of Bay Area Governments (ABAG). 202. Plan Bay Area 2050.
https://www.planbayarea.org/sites/default/files/documents/Plan_Bay_Area_2050_October_20
21.pdf
BAAQMD. 2017a. California Environmental Quality Act: Air Quality Guidelines. San Francisco, CA. May
2017. http://www.baaqmd.gov/~/media/files/planning-and-
research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en
______. 2017b. Final 2017 Clean Air Plan. April 19, 2017.
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-
plan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en
California Air Resources Board (CARB). 2005. Air Quality and Land Use handbook: A Community Health
Perspective. https://sfmohcd.org/sites/default/files/20%20-
%20CARB%2C%20Air%20Quality%20and%20Land%20Use%20Handbook%202005.pdf
______. 2017. 2017 Climate Change Scoping Plan.
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf
______. 2021. Overview: Diesel Exhaust & Health. https://ww2.arb.ca.gov/resources/overview-diesel-
exhaust-and-health
California Department of Conservation (DOC). 2002. California Geomorphic Provinces.
https://www.conservation.ca.gov/cgs/Documents/Publications/CGS-Notes/CGS-Note-36.pdf
CalRecycle. 2022a. Jurisdiction Disposal and Alternative Daily Cover (ADC) Tons by Facility.
https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility
______. 2022b. Kirby Canyon Landfill.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1370?siteID=3393
______. 2022c. Corinda Los Trancos Landfill (Ox Mountain).
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223
______. 2022d. Monterey Peninsula Landfill.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2642?siteID=1976
______. 2023. Estimated Solid Waste Generation Rates.
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates
DecisionInsite. 2021. Annual Enrollment Projection Report Palo Alto Unified School District.
https://go.boarddocs.com/ca/pausd/Board.nsf/files/C29PNR646AA6/$file/20210420Attachmen
t4DecisionInsiteEnrollmentProjectionReport.pdf
Department of Finance (DOF). 2022. E-5 Population and Housing Estimates for Cities, Counties, and the
State 2020-2022. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-
housing-estimates-for-cities-counties-and-the-state-2020-2022/
REFERENCES
1 6 6 | P a g e Addendum to the 2030 Comprehensive Plan EIR
IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the
Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte,
V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M. I. Gomis,
M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu
and B. Zhou (eds.)] Cambridge University Press.
https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf
Office of Emergency Services. 2017. Santa Clara County Operational Area Hazard Mitigation Plan.
https://emergencymanagement.sccgov.org/sites/g/files/exjcpb261/files/For%20Partners/Local-
Hazard-Mitigation-Plan-LHMP-Vol-1.pdf
Palo Alto, City of. 2005. Palo Alto Single-Family Individual Review Guidelines. Adopted June 10, 2005.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/file-
migration/current-planning/forms-and-guidelines/individual-review-ir-guidelines.pdf
______. 2012. City of Palo Alto Bicycle and Pedestrian Transportation Plan.
https://www.cityofpaloalto.org/files/assets/public/transportation/projects/bicycle-pedestrian-
transportation-plan_adopted-july-2012.pdf
______. 2016. City of Palo Alto Comprehensive Plan Draft EIR Volume 1. Adopted February 5, 2016.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/paloaltocompplandeir_vol1_web-1.pdf
______. 2017a. City of Palo Alto Comprehensive Plan Update Supplement to the Draft EIR.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/paloalto_compplanupdate_suppeir_feb2017.pdf
______. 2017b. City of Palo Alto Comprehensive Plan. Adopted November 13, 2017.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/full-comp-plan-2030_with-june21-amendments.pdf
______. 2018. City of Palo Alto Zero Waste Plan. Adopted August 2018.
https://www.cityofpaloalto.org/files/assets/public/zero-waste/zero-waste-website-files/2018-
zero-waste-plan.pdf
______. 2020. Regulations for Groundwater Dewatering during Construction of Below Ground
Structures. https://www.cityofpaloalto.org/files/assets/public/public-works/engineering-
services/webpages/forms-and-permits/regulations-for-groundwater-dewatering-during-
construction-of-below-ground-structures-2021.pdf
______. 2021. 2020 Urban Water Management Plan and Water Shortage Contingency Plan.
https://www.cityofpaloalto.org/files/assets/public/utilities/uwmp/2020-uwmp_final-
submission-to-dwr.pdf
______. 2022a. Green Building Code Requirements. https://www.cityofpaloalto.org/City-
Hall/Sustainability/Green-Building-Code-Requirements
______. 2022b. Carbon Neutral Electricity and Natural Gas.
https://www.cityofpaloalto.org/Departments/Utilities/Sustainability/Carbon-Neutral-Electricity-
and-Natural-Gas
______. 2022c. 2022 Sustainability and Climate Action Plan Goal and Key Actions. Adopted October 3,
2022. https://www.cityofpaloalto.org/files/assets/public/sustainability/policies-and-plans/2022-
scap-goals-and-key-actions.pdf
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 1 6 7
______. 2022d. Dewatering Sites.
https://www.google.com/maps/d/viewer?mid=14ztztkt6te1yanSaxzUhuJONY-
E&ll=37.43630527807649%2C-122.13162251821232&z=14
______. 2022e. Fire Station No. 4 Replacement Project.
https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-Services/Engineering-
Projects/Fire-Station-No.-4-Replacement-Project
______. 2023. Below Market Rate Housing. https://www.cityofpaloalto.org/Departments/Planning-
Development-Services/Long-Range-Planning/Housing-Policies-and-Programs/Below-Market-
Rate-Housing
Santa Clara County Airport Land Use Commission. 2016. Comprehensive Land Use Plan Santa Clara
County Palo Alto Airport. Amended November 16, 2016.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/aluc_pao_clup_2017.pdf
United States Environmental Protection Agency (US EPA). 2021. Overview of Greenhouse Gases.
https://www.epa.gov/ghgemissions/overview-greenhouse-gases
LIST OF PREPARERS
Rincon Consultants, Inc. prepared this Addendum under contract to the City of Palo Alto.
Persons involved in data gathering analysis, project management, and quality control include
the following:
RINCON CONSULTANTS, INC.
Abe Leider, AICP CEP, Principal in Charge
Karly Kaufman, MESM, Project Manager
Heather Dubois, Senior Air Quality Specialist
Bill Vosti, Program Manager – Air Quality, GHG Emissions, and Noise
Nichole Yee, Environmental Planner
Gina Gerlich, GIS Analyst
Debra Jane Seltzer, Publishing Specialist
Yaritza Ramirez, Publishing Specialist
REFERENCES
1 6 8 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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Appendix A
Vehicle Miles Traveled Analysis
Technical Memorandum
Date: April 10, 2023
To: Karly Kaufman
From: At van den Hout
Subject: VMT Analysis for the Palo Alto Housing Element Update (HEU)
Hexagon Transportation Consultants, Inc. has conducted a CEQA transportation VMT analysis for the
proposed residential developments under the Palo Alto Housing Element. This memorandum presents a
summary of the vehicle miles traveled (VMT) methodology and analysis findings.
Project Description
The proposed Housing Element would amend the City of Palo Alto’s 2030 Comprehensive Plan by replacing
the current Housing Element with the proposed 2023-2031 Housing Element. The proposed Housing
Element identifies 289 sites that could provide 6,668 additional housing units within the City of Palo Alto.
Most sites are located throughout Palo Alto’s Downtown and South of the Forest Area in districts that allow
for a mix of residential and commercial uses near transit and services.
Senate Bill 743
Based on revisions in State law to implement Senate Bill (SB) 743, public agencies in California
are mandated to use vehicle miles traveled (VMT) as the metric for CEQA transportation
analyses starting July 1, 2020. The CEQA Guidelines now identify VMT as the most appropriate metric for
evaluating a project’s transportation impacts. With the California Natural Resources Agency’s certification
and adoption of the changes to the CEQA Guidelines, automobile delay, and congestion, as measured by
level of service (LOS) and other similar metrics, no longer constitutes a significant environmental effect
under CEQA. However, LOS is used outside the CEQA document to evaluate other non-CEQA transportation
impacts of development projects, such as congestion, circulation, and safety issues and concerns.
Palo Alto Vehicle Miles Traveled Policy
On June 15, 2020, Palo Alto City Council established a VMT policy by adopting a resolution updating the
City’s transportation analysis methodology under CEQA to comply with California Senate Bill 743. In
addition, City Council adopted a local transportation impact analysis policy to evaluate level of service and
other local roadway impacts. The VMT policy contains screening criteria to identify projects that can be
presumed to have a less than significant transportation impact. The Governor’s Office of Planning and
Research (OPR) recommends that agencies use screening criteria to identify projects known to reduce VMT
or be low VMT generators and that are thus expected to have a less than significant VMT impact. These
projects would then be exempt from performing a quantitative VMT analysis. The use of screening criteria
streamlines analysis for projects already presumed to have a less than significant impact on VMT. Palo
Alto’s Comprehensive Plan policies encourage housing developments to protect local-serving
retail, and to reduce traffic on the roadway network. Therefore, projects aligned with City policies do not
have to procure costly and redundant transportation analyses that will show they are low-VMT
generators under CEQA. If a project meets the screening criteria, a quantitative VMT analysis
Palo Alto Housing Element VMT Analysis April 10, 2023
P a g e | 2
would not be required; however, the CEQA analysis would still include a qualitative assessment of
VMT, discussing the site(s) and location characteristics.
The City of Palo Alto has established the following VMT screening criteria to determine land use
development projects that may be exempt from additional VMT analysis under the City’s VMT guidelines:
• Small Projects: Projects that generate fewer than 110 trips per day. This may equate to non-
residential projects of 10,000 sq. ft. or less and residential projects of 20 units or less.
• Projects in Low VMT Areas: Residential and office projects located in low-VMT areas1 with similar
features (i.e., density, a mix of uses, transit accessibility) as existing developments in these areas.
• Projects in Proximity to Major Transit Stops: Projects that are located within a half mile of an
existing or planned high-quality transit corridor or major transit stations and meet the following
additional criteria:
(1) is high density (minimum floor area ratio of 0.75),
(2) does not exceed parking requirements,
(3) is consistent with Plan Bay Area, and
(4) does not replace affordable units with smaller numbers of moderate- or above moderate-
income units.
• Affordable Housing: 100% affordable housing projects in infill locations.
• Local Serving Retail: Retail projects of 50,000 sq. ft. or less.
Thresholds of Significance
Land use projects not screened out will require quantitative VMT analyses, and their VMTs must be below
pre-determined thresholds to be considered as having a less-than-significant impact. Consistent with State
CEQA Guidelines Section 15064.3, the City of Palo Alto has adopted the thresholds of significance for
residential projects. A residential project that exceeds a level of 15% below existing (baseline) County
home-based VMT per resident may indicate a significant transportation impact.
VMT Analysis Methodology and Findings
When applying the above thresholds for residential projects, VMT is compared to a threshold based on the
countywide (2015) baseline VMT value, which is the home-based VMT per resident. Home-based VMT per
resident is defined as the number of all home-based automobile vehicle trips traced back to the residence
multiplied by the vehicle distance. This home-based VMT is then divided by the population to calculate
home-based VMT per resident.
1 Residential projects located in areas where baseline VMT is 15% below the existing county average per resident,
and office projects located in areas where baseline VMT is 15% below the existing regional average per employee
could be considered to be in low-VMT areas and presumed to have a less than significant VMT impact.
Palo Alto Housing Element VMT Analysis April 10, 2023
P a g e | 3
Travel Forecasting Model
The VMT calculations are done with the recently completed Palo Alto Travel Forecasting Model (PA model).
The PA model is a refinement of Santa Clara Valley Transportation Authority’s (VTA’s) Bi-County Travel
Forecasting Model (VTA model)2. The PA model is the best available tool to simulate travel in Palo Alto and
serves as the primary forecasting tool for the City. The model is a mathematical representation of travel in
the nine Bay Area counties and Santa Cruz, San Benito, Monterey, and San Juaquin counties, focusing on
travel within the City of Palo Alto. The model has four main components: 1) trip generation, 2) trip
distribution, 3) mode choice, and 4) trip assignment. The model uses socioeconomic inputs (i.e., population,
income, employment) aggregated into geographic areas, called transportation analysis zones (TAZs), to
estimate travel within the modeled area. There are 110 TAZs within the model that represent the City of
Palo Alto, and the 289 Housing Element sites are spread out over 44 TAZs.
Scenarios Analyzed
In addition to evaluating VMT for the Housing Element, VMT associated with Scenario 6 of the City’s
Comprehensive Plan was also analyzed. The PA model's land use assumptions and transportation networks
were updated to reflect the year 2031 conditions. The year 2031 land use data outside Palo Alto was
interpolated between VTA’s 2015 and 2040 land use assumptions. Palo Alto’s two future land use scenarios
reflect the increases in households and employment proposed for the Comprehensive Plan and the Housing
Element, respectively. The following scenarios are addressed in the VMT analysis.
• Baseline (2015) Conditions: The baseline (2015) PA model is used to determine the baseline home-
based VMT per resident for the TAZs in Palo Alto and the countywide average VMT per resident, and
the 85 percentile of the countywide average VMT per resident.
• Comprehensive Plan (2031) Conditions: This scenario includes the proposed land uses assumed for
Scenario 6 of Palo Alto’s Comprehensive Plan. Scenario 6 contains 6,000 additional housing units
and 8,868 jobs.
• Housing Element (2031) Conditions: This scenario includes the proposed land uses assumed in the
Housing Element. The Housing Element has 6,668 additional housing units and 8,868 jobs.
Figures 1 and 2 present the growth in housing units for the TAZs assumed for the Comprehensive Plan and
the Housing Element Plan, respectively. The increase in jobs, which is assumed to be the same for both the
Comprehensive Plan and the Housing Element Plan, is shown on Figure 3.
2 Documentation of the Palo Alto Travel Forecasting Model Update is summarized in a Technical Memorandum: Palo Alto
Model Update and Validation Results, March 20, 2023.
Figure 1
Increase in Housing Units by Palo Alto TAZ for the Comprehensive Plan
City of Palo Alto
13
12
14
5
1
6
6
3
1
1
3
4
5
6
7
7
8
7
2
4
6
12
16
6
4
7
97
4
11
13
17
13
6
222
3
9
33
47
4
30
235
78
18
194
19
896
108
75
20
53
11
863
52
223
13
128
18
33
400
224
174
38
19
31
259
19
13
170
118
10
123
81
114
148
155
117
63
134
72
103
68
676868
8673
Legend
Increase in the Number of Housing Units
0
1 - 50
51 - 200
201 - 500
501 - 896
Figure 2
Increase in Housing Units by Palo Alto TAZ for the Housing Element
City of Palo Alto
3
5
43
35
51
278
58
93
52
9
37
31
56
55
45
54
173
23
11
229
10
1909
542
15
330
40 13
237
305
62
74
916
17
197
104
91
29
15
54
67
687
64
Legend
Increase in the Number of Housing Units
0 - 1
2 - 50
51 - 200
201 - 500
501 - 1909
44
38
40
74
38
323
29
39
320
364
87
70
51
9
79
80
60
19
128
19
133
47
23
62
182
74
1710
63
99
115
195
75
90
178
266
93
74
39
1899
19
306
355
58
27
24
24
8564
22
58
546943
5853
222
Legend
Increase in the Number of Jobs
0 - 1
2 - 100
101 - 200
201 - 500
501 - 1899 Figure 3
Increase in Employment by Palo Alto TAZ
Palo Alto Housing Element VMT Analysis April 10, 2023
P a g e | 7
Residential VMT Analysis
The PA model was used to estimate the 2015 baseline countywide VMT, the VMT for the Comprehensive
Plan, and the Housing Element. Table 1 below shows the residential VMT, the number of housing units, the
population, and the VMT per resident for Santa Clara County and three Palo Alto scenarios. The county
average VMT per resident for residential development is 12.90, and the threshold of significance is 85
percent of 12.90 or 10.97 daily vehicle miles per resident. As a whole, the Comprehensive Plan and the
Housing Element have a residential VMT of 9.02 and 9.28, respectively, which is less than 85 percent of the
county average VMT per resident. Thus, the VMT per resident for the Housing Element (and also for the
Comprehensive Plan) as a whole would be below the threshold of 10.97 VMT per resident. Therefore,
implementing the Housing Element would result in a less-than-significant VMT impact on transportation.
Table 1: VMT Projections for Palo Alto and Santa Clara County
Site-Specific VMT Analysis
The 289 Housing Element sites are spread out over 44 TAZs. A VMT analysis for each of the 44 TAZs shows
that the Housing Element sites in three TAZs have a VMT per resident higher than the threshold of 85
percent of the countywide average, but these VMTs are still lower than the county average of 12.90. A
summary of the VMT data for those three TAZs is shown in Table 2. A map of the VMT per resident for the
Housing Element TAZs is shown on Figure 4. The sites in the other 41 TAZs have VMT per resident values
less than 85 percent of the county average.
Table 2
Housing Sites in TAZs with VMTs Higher than 85 Percent of the County Average
Individual housing development projects located at sites in these three TAZs are subject to mitigate VMT
impacts. A list of TDM strategies to mitigate VMT impacts can be found in Appendix G of the document “SB
743 Implementation Decisions for Palo Alto” at this link.
Area Scenario Residential
VMT 1
Housing
Units Population VMT per
Resident 2
2015 643,912 27,771 69,537 9.26
2031 Comp 763,463 33,771 84,597 9.02
2031 HEU 801,073 34,439 86,277 9.28
Santa Clara County 2015 23,897,059 627,249 1,852,178 12.90
1 Residential VMT = Home-Based Trip Productions * Travel Distance
2 VMT per Resident = Residential VMT / Population
City of Palo Alto
TAZ
Residential
VMT 1
Total Housing
Units Population
VMT per
Resident 2
HEU Housing
Units
477 28,129 916 2,299 12.23 916
496 8,071 327 626 12.89 17
533 15,605 677 1,314 11.88 62
Total 995
1 Residential VMT = Home-Based Trip Productions * Travel Distance
2 VMT per Resident = Residential VMT / Population
Note: The threshold of significance is 85 percent of the county average, or 11.0 daily miles per resident
Figure 4
Home-Based VMT per Resident for the Housing Element TAZs
City of Palo Alto
8.64
8.1
10.05
9.36
9.53
3.68
8.85
10.72
8.62
9.94
6.31
5.99
10.86
8.01
9.97
7.95
10.84
10.58
9.87
8.74
12.94
5.77
7.23
5.82
8.02
6.19 6.57
10.39
10.95
9.06
12.3
12.23
9.13
5.49
6.63
10.91
10.01
8.94
8.9
4.51
5.75
7.52
5.02
7.86
Legend
VMT is less than 85% of the County Average
VMT is between 85% and 100 % of the County Average
XX.XX = Home-based VMT per Resident
Appendix B
Greenhouse Gas Emissions Modeling Results
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
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Palo Alto HEU - GHG Emissions Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
3. Construction Emissions Details
3.1. Demolition (2023) - Unmitigated
3.3. Site Preparation (2023) - Unmitigated
3.5. Grading (2023) - Unmitigated
3.7. Building Construction (2023) - Unmitigated
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
2 / 53
3.9. Building Construction (2024) - Unmitigated
3.11. Building Construction (2025) - Unmitigated
3.13. Building Construction (2026) - Unmitigated
3.15. Paving (2026) - Unmitigated
3.17. Architectural Coating (2025) - Unmitigated
3.19. Architectural Coating (2026) - Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.2. Unmitigated
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
4.5. Waste Emissions by Land Use
Palo Alto HEU - GHG Emissions Detailed Report, 2/14/2023
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4.5.2. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
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5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
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5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
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5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Palo Alto HEU - GHG Emissions
Lead Agency —
Land Use Scale Plan/community
Analysis Level for Defaults County
Windspeed (m/s)4.20
Precipitation (days)18.8
Location Palo Alto, CA, USA
County Santa Clara
City Palo Alto
Air District Bay Area AQMD
Air Basin San Francisco Bay Area
TAZ 1726
EDFZ 1
Electric Utility City of Palo Alto
Gas Utility City of Palo Alto Ultilities
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft)Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
Population Description
Apartments Mid Rise 665 Dwelling Unit 17.5 638,400 0.00 0.00 1,669 —
1.3. User-Selected Emission Reduction Measures by Emissions Sector
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No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.4.77 46.2 39.8 38.9 0.06 1.81 19.8 21.6 1.66 10.1 11.8 —9,373 9,373 0.43 0.48 24.5 9,549
Daily,
Winter
(Max)
——————————————————
Unmit.3.57 46.1 27.4 35.5 0.04 1.20 5.25 5.74 1.10 1.25 1.70 —9,011 9,011 0.33 0.50 0.64 9,168
Average
Daily
(Max)
——————————————————
Unmit.2.54 27.7 18.1 24.6 0.03 0.76 4.50 5.26 0.70 1.82 2.52 —6,362 6,362 0.22 0.34 7.40 6,477
Annual
(Max)
——————————————————
Unmit.0.46 5.05 3.31 4.49 0.01 0.14 0.82 0.96 0.13 0.33 0.46 —1,053 1,053 0.04 0.06 1.22 1,072
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
——————————————————
2023 4.77 4.01 39.8 37.1 0.06 1.81 19.8 21.6 1.66 10.1 11.8 —8,639 8,639 0.43 0.46 24.5 8,813
2024 3.47 2.95 15.1 35.4 0.04 0.52 4.46 4.98 0.48 1.07 1.55 —8,533 8,533 0.29 0.46 23.0 8,701
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2025 3.79 46.2 15.2 38.9 0.04 0.49 5.25 5.74 0.45 1.25 1.70 —9,373 9,373 0.30 0.48 24.5 9,549
2026 3.46 46.0 14.3 37.1 0.04 0.43 5.25 5.68 0.40 1.25 1.65 —9,246 9,246 0.30 0.48 22.2 9,420
Daily -
Winter
(Max)
——————————————————
2023 3.56 3.01 27.4 34.0 0.04 1.20 4.46 5.04 1.10 1.07 1.60 —8,324 8,324 0.33 0.47 0.64 8,474
2024 3.40 2.87 15.6 32.5 0.04 0.52 4.46 4.98 0.48 1.07 1.55 —8,225 8,225 0.32 0.47 0.59 8,374
2025 3.57 46.1 15.7 35.5 0.04 0.49 5.25 5.74 0.45 1.25 1.70 —9,011 9,011 0.32 0.50 0.64 9,168
2026 3.40 45.8 14.8 34.0 0.04 0.43 5.25 5.68 0.40 1.25 1.65 —8,892 8,892 0.32 0.50 0.58 9,048
Average
Daily
——————————————————
2023 2.54 2.14 18.1 20.0 0.03 0.76 4.50 5.26 0.70 1.82 2.52 —4,092 4,092 0.16 0.12 2.37 4,134
2024 2.42 2.05 11.0 23.0 0.03 0.38 3.16 3.53 0.35 0.75 1.10 —5,921 5,921 0.22 0.34 7.07 6,035
2025 2.48 27.7 10.9 24.6 0.03 0.34 3.61 3.95 0.32 0.86 1.18 —6,362 6,362 0.22 0.34 7.40 6,477
2026 1.43 18.8 6.56 14.5 0.02 0.21 2.04 2.25 0.19 0.49 0.68 —3,689 3,689 0.13 0.19 3.77 3,752
Annual ——————————————————
2023 0.46 0.39 3.31 3.65 0.01 0.14 0.82 0.96 0.13 0.33 0.46 —677 677 0.03 0.02 0.39 685
2024 0.44 0.37 2.01 4.21 < 0.005 0.07 0.58 0.64 0.06 0.14 0.20 —980 980 0.04 0.06 1.17 999
2025 0.45 5.05 1.99 4.49 < 0.005 0.06 0.66 0.72 0.06 0.16 0.22 —1,053 1,053 0.04 0.06 1.22 1,072
2026 0.26 3.43 1.20 2.64 < 0.005 0.04 0.37 0.41 0.03 0.09 0.12 —611 611 0.02 0.03 0.62 621
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Un/Mit.TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.14.1 30.9 12.8 113 0.23 0.64 7.54 8.18 0.64 1.33 1.97 324 27,711 28,035 23.5 0.97 44.0 28,954
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——————————————————Daily,
Winter
(Max)
Unmit.10.4 27.2 13.4 71.0 0.22 0.63 7.54 8.17 0.62 1.33 1.95 324 26,464 26,788 23.6 1.04 5.59 27,692
Average
Daily
(Max)
——————————————————
Unmit.10.7 27.9 6.46 81.8 0.17 0.11 7.16 7.28 0.11 1.26 1.37 324 17,642 17,966 23.3 0.96 20.7 18,854
Annual
(Max)
——————————————————
Unmit.1.96 5.10 1.18 14.9 0.03 0.02 1.31 1.33 0.02 0.23 0.25 53.6 2,921 2,974 3.86 0.16 3.43 3,122
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Mobile 9.92 9.24 5.85 72.7 0.19 0.10 7.54 7.64 0.09 1.33 1.42 —19,279 19,279 0.72 0.73 39.4 19,554
Area 4.21 21.6 6.91 40.7 0.04 0.54 —0.54 0.55 —0.55 0.00 8,432 8,432 0.16 0.02 —8,441
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————101 0.00 101 0.35 0.22 —176
Waste ———————————222 0.00 222 22.2 0.00 —778
Refrig.————————————————4.57 4.57
Total 14.1 30.9 12.8 113 0.23 0.64 7.54 8.18 0.64 1.33 1.97 324 27,711 28,035 23.5 0.97 44.0 28,954
Daily,
Winter
(Max)
——————————————————
Mobile 9.59 8.88 6.85 68.2 0.18 0.10 7.54 7.64 0.09 1.33 1.42 —18,133 18,133 0.81 0.80 1.02 18,393
Area 0.77 18.4 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
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Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————101 0.00 101 0.35 0.22 —176
Waste ———————————222 0.00 222 22.2 0.00 —778
Refrig.————————————————4.57 4.57
Total 10.4 27.2 13.4 71.0 0.22 0.63 7.54 8.17 0.62 1.33 1.95 324 26,464 26,788 23.6 1.04 5.59 27,692
Average
Daily
——————————————————
Mobile 9.00 8.34 6.12 63.1 0.17 0.09 7.16 7.26 0.09 1.26 1.35 —17,387 17,387 0.73 0.73 16.2 17,640
Area 1.72 19.6 0.33 18.7 < 0.005 0.02 —0.02 0.02 —0.02 0.00 255 255 0.01 < 0.005 —256
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————101 0.00 101 0.35 0.22 —176
Waste ———————————222 0.00 222 22.2 0.00 —778
Refrig.————————————————4.57 4.57
Total 10.7 27.9 6.46 81.8 0.17 0.11 7.16 7.28 0.11 1.26 1.37 324 17,642 17,966 23.3 0.96 20.7 18,854
Annual ——————————————————
Mobile 1.64 1.52 1.12 11.5 0.03 0.02 1.31 1.32 0.02 0.23 0.25 —2,879 2,879 0.12 0.12 2.68 2,921
Area 0.31 3.57 0.06 3.42 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 0.00 42.2 42.2 < 0.005 < 0.005 —42.3
Energy 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Water ———————————16.8 0.00 16.8 0.06 0.04 —29.2
Waste ———————————36.8 0.00 36.8 3.68 0.00 —129
Refrig.————————————————0.76 0.76
Total 1.96 5.10 1.18 14.9 0.03 0.02 1.31 1.33 0.02 0.23 0.25 53.6 2,921 2,974 3.86 0.16 3.43 3,122
3. Construction Emissions Details
3.1. Demolition (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
3.39 2.84 27.3 23.5 0.03 1.20 —1.20 1.10 —1.10 —3,425 3,425 0.14 0.03 —3,437
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
3.39 2.84 27.3 23.5 0.03 1.20 —1.20 1.10 —1.10 —3,425 3,425 0.14 0.03 —3,437
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.46 0.39 3.75 3.22 < 0.005 0.16 —0.16 0.15 —0.15 —469 469 0.02 < 0.005 —471
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.08 0.07 0.68 0.59 < 0.005 0.03 —0.03 0.03 —0.03 —77.7 77.7 < 0.005 < 0.005 —77.9
Demolitio
n
——————0.00 0.00 —0.00 0.00 ———————
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Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.06 0.06 0.05 0.71 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —134 134 0.01 < 0.005 0.61 136
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.06 0.05 0.06 0.61 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —124 124 < 0.005 0.01 0.02 125
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —17.1 17.1 < 0.005 < 0.005 0.04 17.4
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.84 2.84 < 0.005 < 0.005 0.01 2.88
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.3. Site Preparation (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
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Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
4.70 3.95 39.7 35.5 0.05 1.81 —1.81 1.66 —1.66 —5,295 5,295 0.21 0.04 —5,314
Dust
From
Material
Movement
——————19.7 19.7 —10.1 10.1 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.39 0.32 3.27 2.92 < 0.005 0.15 —0.15 0.14 —0.14 —435 435 0.02 < 0.005 —437
Dust
From
Material
Movement
——————1.62 1.62 —0.83 0.83 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.07 0.06 0.60 0.53 < 0.005 0.03 —0.03 0.02 —0.02 —72.1 72.1 < 0.005 < 0.005 —72.3
Dust
From
Material
Movement
——————0.29 0.29 —0.15 0.15 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
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——————————————————Daily,
Summer
(Max)
Worker 0.07 0.06 0.05 0.83 0.00 0.00 0.14 0.14 0.00 0.03 0.03 —156 156 0.01 0.01 0.71 159
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.01 0.01 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —12.0 12.0 < 0.005 < 0.005 0.03 12.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.99 1.99 < 0.005 < 0.005 < 0.005 2.02
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.5. Grading (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
4.43 3.72 37.3 31.4 0.06 1.59 —1.59 1.47 —1.47 —6,598 6,598 0.27 0.05 —6,621
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———————3.653.65—9.209.20——————Dust
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Road
Equipment
0.91 0.76 7.66 6.45 0.01 0.33 —0.33 0.30 —0.30 —1,356 1,356 0.05 0.01 —1,360
Dust
From
Material
Movement
——————1.89 1.89 —0.75 0.75 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.17 0.14 1.40 1.18 < 0.005 0.06 —0.06 0.06 —0.06 —224 224 0.01 < 0.005 —225
Dust
From
Material
Movement
——————0.35 0.35 —0.14 0.14 ———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.08 0.07 0.06 0.95 0.00 0.00 0.17 0.17 0.00 0.04 0.04 —178 178 0.01 0.01 0.81 181
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.02 0.01 0.01 0.17 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —34.3 34.3 < 0.005 < 0.005 0.07 34.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —5.68 5.68 < 0.005 < 0.005 0.01 5.76
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.7. Building Construction (2023) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.50 1.26 11.8 13.2 0.02 0.55 —0.55 0.51 —0.51 —2,397 2,397 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.50 1.26 11.8 13.2 0.02 0.55 —0.55 0.51 —0.51 —2,397 2,397 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Average
Daily
——————————————————
Off-Road
Equipment
0.32 0.27 2.50 2.78 < 0.005 0.12 —0.12 0.11 —0.11 —507 507 0.02 < 0.005 —508
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.06 0.05 0.46 0.51 < 0.005 0.02 —0.02 0.02 —0.02 —83.9 83.9 < 0.005 < 0.005 —84.2
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.93 1.77 1.44 22.6 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,268 4,268 0.21 0.16 19.4 4,339
Vendor 0.20 0.07 2.70 1.29 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,974 1,974 0.12 0.29 5.12 2,068
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.86 1.68 1.76 19.5 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,951 3,951 0.12 0.17 0.50 4,004
Vendor 0.19 0.07 2.85 1.32 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,975 1,975 0.12 0.29 0.13 2,064
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.39 0.35 0.34 4.07 0.00 0.00 0.83 0.83 0.00 0.19 0.19 —844 844 0.02 0.04 1.77 857
Vendor 0.04 0.01 0.59 0.28 < 0.005 0.01 0.10 0.11 0.01 0.03 0.03 —417 417 0.03 0.06 0.47 437
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.07 0.06 0.06 0.74 0.00 0.00 0.15 0.15 0.00 0.04 0.04 —140 140 < 0.005 0.01 0.29 142
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Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —69.1 69.1 < 0.005 0.01 0.08 72.3
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.9. Building Construction (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.44 1.20 11.2 13.1 0.02 0.50 —0.50 0.46 —0.46 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.44 1.20 11.2 13.1 0.02 0.50 —0.50 0.46 —0.46 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
1.03 0.86 8.04 9.39 0.02 0.36 —0.36 0.33 —0.33 —1,717 1,717 0.07 0.01 —1,723
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.19 0.16 1.47 1.71 < 0.005 0.07 —0.07 0.06 —0.06 —284 284 0.01 < 0.005 —285
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.84 1.67 1.29 21.0 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,186 4,186 0.07 0.16 17.8 4,252
Vendor 0.20 0.07 2.58 1.23 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,949 1,949 0.12 0.29 5.12 2,043
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.77 1.60 1.62 18.1 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,877 3,877 0.11 0.17 0.46 3,929
Vendor 0.19 0.07 2.72 1.27 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,950 1,950 0.12 0.29 0.13 2,039
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 1.26 1.14 1.05 12.8 0.00 0.00 2.80 2.80 0.00 0.66 0.66 —2,807 2,807 0.07 0.12 5.49 2,850
Vendor 0.14 0.05 1.91 0.89 0.01 0.02 0.36 0.37 0.02 0.10 0.12 —1,396 1,396 0.09 0.21 1.58 1,462
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.23 0.21 0.19 2.33 0.00 0.00 0.51 0.51 0.00 0.12 0.12 —465 465 0.01 0.02 0.91 472
Vendor 0.03 0.01 0.35 0.16 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 —231 231 0.01 0.03 0.26 242
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.11. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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Off-Road
Equipment
1.35 1.13 10.4 13.0 0.02 0.43 —0.43 0.40 —0.40 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.35 1.13 10.4 13.0 0.02 0.43 —0.43 0.40 —0.40 —2,398 2,398 0.10 0.02 —2,406
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.96 0.80 7.46 9.31 0.02 0.31 —0.31 0.28 —0.28 —1,713 1,713 0.07 0.01 —1,719
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.18 0.15 1.36 1.70 < 0.005 0.06 —0.06 0.05 —0.05 —284 284 0.01 < 0.005 —285
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.75 1.59 1.16 19.6 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,103 4,103 0.07 0.16 16.2 4,168
Vendor 0.18 0.07 2.46 1.19 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,918 1,918 0.11 0.28 5.08 2,008
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.58 1.53 1.47 16.8 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,801 3,801 0.10 0.17 0.42 3,853
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Vendor 0.18 0.07 2.58 1.21 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,919 1,919 0.11 0.28 0.13 2,004
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 1.11 1.08 0.94 11.8 0.00 0.00 2.79 2.79 0.00 0.65 0.65 —2,745 2,745 0.06 0.11 5.00 2,784
Vendor 0.13 0.05 1.82 0.86 0.01 0.02 0.35 0.37 0.02 0.10 0.12 —1,370 1,370 0.08 0.20 1.57 1,432
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.20 0.20 0.17 2.15 0.00 0.00 0.51 0.51 0.00 0.12 0.12 —454 454 0.01 0.02 0.83 461
Vendor 0.02 0.01 0.33 0.16 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 —227 227 0.01 0.03 0.26 237
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.13. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
1.28 1.07 9.85 13.0 0.02 0.38 —0.38 0.35 —0.35 —2,397 2,397 0.10 0.02 —2,405
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
1.28 1.07 9.85 13.0 0.02 0.38 —0.38 0.35 —0.35 —2,397 2,397 0.10 0.02 —2,405
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
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Average
Daily
——————————————————
Off-Road
Equipment
0.50 0.41 3.82 5.02 0.01 0.15 —0.15 0.13 —0.13 —929 929 0.04 0.01 —932
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.09 0.08 0.70 0.92 < 0.005 0.03 —0.03 0.02 —0.02 —154 154 0.01 < 0.005 —154
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 1.55 1.51 1.02 18.3 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —4,026 4,026 0.07 0.16 14.7 4,089
Vendor 0.18 0.06 2.34 1.15 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,885 1,885 0.11 0.28 4.59 1,974
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 1.50 1.34 1.33 15.6 0.00 0.00 3.96 3.96 0.00 0.93 0.93 —3,730 3,730 0.10 0.17 0.38 3,782
Vendor 0.17 0.05 2.47 1.16 0.01 0.03 0.50 0.53 0.03 0.14 0.16 —1,886 1,886 0.11 0.28 0.12 1,971
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.57 0.51 0.45 5.97 0.00 0.00 1.52 1.52 0.00 0.35 0.35 —1,461 1,461 0.03 0.06 2.46 1,482
Vendor 0.07 0.02 0.94 0.45 0.01 0.01 0.19 0.20 0.01 0.05 0.06 —730 730 0.04 0.11 0.77 764
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.10 0.09 0.08 1.09 0.00 0.00 0.28 0.28 0.00 0.06 0.06 —242 242 0.01 0.01 0.41 245
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Vendor 0.01 < 0.005 0.17 0.08 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 —121 121 0.01 0.02 0.13 127
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.15. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.91 0.76 7.12 9.94 0.01 0.32 —0.32 0.29 —0.29 —1,511 1,511 0.06 0.01 —1,516
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.91 0.76 7.12 9.94 0.01 0.32 —0.32 0.29 —0.29 —1,511 1,511 0.06 0.01 —1,516
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.11 0.10 0.90 1.25 < 0.005 0.04 —0.04 0.04 —0.04 —190 190 0.01 < 0.005 —191
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
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Off-Road
Equipment
0.02 0.02 0.16 0.23 < 0.005 0.01 —0.01 0.01 —0.01 —31.5 31.5 < 0.005 < 0.005 —31.6
Paving —0.00 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.05 0.05 0.03 0.57 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —126 126 < 0.005 < 0.005 0.46 128
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.05 0.04 0.04 0.49 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —117 117 < 0.005 0.01 0.01 118
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.01 0.01 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 —14.9 14.9 < 0.005 < 0.005 0.03 15.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —2.46 2.46 < 0.005 < 0.005 < 0.005 2.50
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.17. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
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Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.15 0.13 0.88 1.14 < 0.005 0.03 —0.03 0.03 —0.03 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.09 0.08 0.52 0.68 < 0.005 0.02 —0.02 0.01 —0.01 —79.2 79.2 < 0.005 < 0.005 —79.4
Architect
ural
Coatings
—25.5 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.02 0.01 0.10 0.12 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —13.1 13.1 < 0.005 < 0.005 —13.2
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Architect
Coatings
—4.65 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.35 0.32 0.23 3.91 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —821 821 0.01 0.03 3.24 834
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.32 0.31 0.29 3.36 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —760 760 0.02 0.03 0.08 771
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.18 0.18 0.16 1.96 0.00 0.00 0.46 0.46 0.00 0.11 0.11 —456 456 0.01 0.02 0.83 462
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.03 0.03 0.03 0.36 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —75.4 75.4 < 0.005 < 0.005 0.14 76.5
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
3.19. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Road
Equipment
0.15 0.12 0.86 1.13 < 0.005 0.02 —0.02 0.02 —0.02 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Off-Road
Equipment
0.15 0.12 0.86 1.13 < 0.005 0.02 —0.02 0.02 —0.02 —134 134 0.01 < 0.005 —134
Architect
ural
Coatings
—42.9 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Off-Road
Equipment
0.06 0.05 0.35 0.46 < 0.005 0.01 —0.01 0.01 —0.01 —54.6 54.6 < 0.005 < 0.005 —54.8
Architect
ural
Coatings
—17.6 ————————————————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Off-Road
Equipment
0.01 0.01 0.06 0.08 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —9.04 9.04 < 0.005 < 0.005 —9.07
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————————————————3.21—Architect
ural
Coatings
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.31 0.30 0.20 3.65 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —805 805 0.01 0.03 2.94 818
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Daily,
Winter
(Max)
——————————————————
Worker 0.30 0.27 0.27 3.12 0.00 0.00 0.79 0.79 0.00 0.19 0.19 —746 746 0.02 0.03 0.08 756
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Average
Daily
——————————————————
Worker 0.12 0.11 0.10 1.26 0.00 0.00 0.32 0.32 0.00 0.07 0.07 —308 308 0.01 0.01 0.52 313
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Annual ——————————————————
Worker 0.02 0.02 0.02 0.23 0.00 0.00 0.06 0.06 0.00 0.01 0.01 —51.1 51.1 < 0.005 < 0.005 0.09 51.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
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4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
9.92 9.24 5.85 72.7 0.19 0.10 7.54 7.64 0.09 1.33 1.42 —19,279 19,279 0.72 0.73 39.4 19,554
Total 9.92 9.24 5.85 72.7 0.19 0.10 7.54 7.64 0.09 1.33 1.42 —19,279 19,279 0.72 0.73 39.4 19,554
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
9.59 8.88 6.85 68.2 0.18 0.10 7.54 7.64 0.09 1.33 1.42 —18,133 18,133 0.81 0.80 1.02 18,393
Total 9.59 8.88 6.85 68.2 0.18 0.10 7.54 7.64 0.09 1.33 1.42 —18,133 18,133 0.81 0.80 1.02 18,393
Annual ——————————————————
Apartme
nts
Mid Rise
1.64 1.52 1.12 11.5 0.03 0.02 1.31 1.32 0.02 0.23 0.25 —2,879 2,879 0.12 0.12 2.68 2,921
Total 1.64 1.52 1.12 11.5 0.03 0.02 1.31 1.32 0.02 0.23 0.25 —2,879 2,879 0.12 0.12 2.68 2,921
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
Annual ——————————————————
Apartme
nts
Mid Rise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Daily,
Winter
(Max)
——————————————————
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Apartme
Mid Rise
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Annual ——————————————————
Apartme
nts
Mid Rise
0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 —0.00 0.00 —0.00 —0.00 0.00 0.00 0.00 —0.00
4.3. Area Emissions by Source
4.3.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Hearths 0.77 0.38 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
Consum
er
Products
—13.7 ————————————————
Architect
ural
Coatings
—4.31 ————————————————
Landsca
pe
Equipme
nt
3.44 3.26 0.35 37.9 < 0.005 0.01 —0.01 0.02 —0.02 —101 101 < 0.005 < 0.005 —101
Total 4.21 21.6 6.91 40.7 0.04 0.54 —0.54 0.55 —0.55 0.00 8,432 8,432 0.16 0.02 —8,441
Daily,
Winter
(Max)
——————————————————
Hearths 0.77 0.38 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
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Consum
Products
—13.7 ————————————————
Architect
ural
Coatings
—4.31 ————————————————
Total 0.77 18.4 6.56 2.79 0.04 0.53 —0.53 0.53 —0.53 0.00 8,331 8,331 0.16 0.02 —8,340
Annual ——————————————————
Hearths < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 0.00 34.0 34.0 < 0.005 < 0.005 —34.0
Consum
er
Products
—2.49 ————————————————
Architect
ural
Coatings
—0.79 ————————————————
Landsca
pe
Equipme
nt
0.31 0.29 0.03 3.41 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —8.24 8.24 < 0.005 < 0.005 —8.26
Total 0.31 3.57 0.06 3.42 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 0.00 42.2 42.2 < 0.005 < 0.005 —42.3
4.4. Water Emissions by Land Use
4.4.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————101 0.00 101 0.35 0.22 —176
Total ———————————101 0.00 101 0.35 0.22 —176
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Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————101 0.00 101 0.35 0.22 —176
Total ———————————101 0.00 101 0.35 0.22 —176
Annual ——————————————————
Apartme
nts
Mid Rise
———————————16.8 0.00 16.8 0.06 0.04 —29.2
Total ———————————16.8 0.00 16.8 0.06 0.04 —29.2
4.5. Waste Emissions by Land Use
4.5.2. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————222 0.00 222 22.2 0.00 —778
Total ———————————222 0.00 222 22.2 0.00 —778
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
———————————222 0.00 222 22.2 0.00 —778
Total ———————————222 0.00 222 22.2 0.00 —778
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Annual ——————————————————
Apartme
nts
Mid Rise
———————————36.8 0.00 36.8 3.68 0.00 —129
Total ———————————36.8 0.00 36.8 3.68 0.00 —129
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————————4.57 4.57
Total ————————————————4.57 4.57
Daily,
Winter
(Max)
——————————————————
Apartme
nts
Mid Rise
————————————————4.57 4.57
Total ————————————————4.57 4.57
Annual ——————————————————
Apartme
nts
Mid Rise
————————————————0.76 0.76
Total ————————————————0.76 0.76
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4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
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Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
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Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual)
Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Avoided ——————————————————
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Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Annual ——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
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5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description
Demolition Demolition 2/7/2023 4/18/2023 5.00 50.0 —
Site Preparation Site Preparation 4/19/2023 5/31/2023 5.00 30.0 —
Grading Grading 6/1/2023 9/14/2023 5.00 75.0 —
Building Construction Building Construction 9/15/2023 7/17/2026 5.00 740 —
Paving Paving 7/31/2026 10/3/2026 5.00 46.0 —
Architectural Coating Architectural Coating 3/4/2025 7/28/2026 5.00 366 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38
Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40
Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40
Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40
Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
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Building Construction Cranes Diesel Average 1.00 7.00 367 0.29
Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20
Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45
Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36
Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Demolition ————
Demolition Worker 15.0 11.7 LDA,LDT1,LDT2
Demolition Vendor —8.40 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck ——HHDT
Site Preparation ————
Site Preparation Worker 17.5 11.7 LDA,LDT1,LDT2
Site Preparation Vendor —8.40 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck ——HHDT
Grading ————
Grading Worker 20.0 11.7 LDA,LDT1,LDT2
Grading Vendor —8.40 HHDT,MHDT
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Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck ——HHDT
Building Construction ————
Building Construction Worker 479 11.7 LDA,LDT1,LDT2
Building Construction Vendor 71.1 8.40 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck ——HHDT
Paving ————
Paving Worker 15.0 11.7 LDA,LDT1,LDT2
Paving Vendor —8.40 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck ——HHDT
Architectural Coating ————
Architectural Coating Worker 95.8 11.7 LDA,LDT1,LDT2
Architectural Coating Vendor —8.40 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck ——HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 2,542,752 847,584 0.00 0.00 —
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5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy)Material Exported (cy)Acres Graded (acres)Material Demolished (sq. ft.)Acres Paved (acres)
Demolition 0.00 0.00 0.00 ——
Site Preparation ——45.0 0.00 —
Grading ——225 0.00 —
Paving 0.00 0.00 0.00 0.00 —
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Land Use Area Paved (acres)% Asphalt
Apartments Mid Rise —0%
5.8. Construction Electricity Consumption and Emissions Factors
kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2023 0.00 0.00 0.00 0.00
2024 0.00 0.00 0.00 0.00
2025 0.00 0.00 0.00 0.00
2026 0.00 0.00 0.00 0.00
5.9. Operational Mobile Sources
5.9.1. Unmitigated
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Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
Apartments Mid Rise 3,618 3,265 2,720 1,255,235 27,403 24,733 20,603 9,508,239
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 339
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 326
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft)Residential Exterior Area Coated (sq ft)Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area Coated
(sq ft)
Parking Area Coated (sq ft)
2542752 847,584 0.00 0.00 —
5.10.3. Landscape Equipment
Season Unit Value
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Snow Days day/yr 0.00
Summer Days day/yr 180
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr)
Land Use Electricity (kWh/yr)CO2 CH4 N2O Natural Gas (kBTU/yr)
Apartments Mid Rise 7,837,103 0.00 0.0000 0.0000 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year)Outdoor Water (gal/year)
Apartments Mid Rise 47,436,451 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year)Cogeneration (kWh/year)
Apartments Mid Rise 164 0.00
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg)Operations Leak Rate Service Leak Rate Times Serviced
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10.02.502.50< 0.0052,088R-410AApartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
Apartments Mid Rise Household refrigerators
and/or freezers
R-134a 1,430 0.12 0.60 0.00 1.00
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr)Daily Heat Input (MMBtu/day)Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
——
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
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Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year)Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG
emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 11.8 annual days of extreme heat
Extreme Precipitation 4.05 annual days with precipitation above 20 mm
Sea Level Rise 0.00 meters of inundation depth
Wildfire 10.7 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed
historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full
day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider different
increments of sea level rise coupled with extreme storm events. Users may select from four model simulations to view the range in potential inundation depth for the grid cell. The four simulations make
different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature
possibilities (MIROC5). Each grid cell is 50 meters (m) by 50 m, or about 164 feet (ft) by 164 ft.
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Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate,
vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make
different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature
possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest
exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the
greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score
Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
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Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest
exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the
greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 10.6
AQ-PM 15.6
AQ-DPM 54.0
Drinking Water 38.1
Lead Risk Housing 68.1
Pesticides 0.00
Toxic Releases 28.4
Traffic 30.2
Effect Indicators —
CleanUp Sites 73.7
Groundwater 91.9
Haz Waste Facilities/Generators 51.9
Impaired Water Bodies 23.9
Solid Waste 0.00
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Sensitive Population —
Asthma 0.66
Cardio-vascular 4.54
Low Birth Weights 36.4
Socioeconomic Factor Indicators —
Education 3.87
Housing 22.1
Linguistic 24.8
Poverty 8.07
Unemployment 29.4
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 95.14949313
Employed 43.98819453
Median HI 99.29423842
Education —
Bachelor's or higher 99.60220711
High school enrollment 100
Preschool enrollment 73.48902862
Transportation —
Auto Access 68.11240857
Active commuting 83.57500321
Social —
2-parent households 94.40523547
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Voting 96.57384833
Neighborhood —
Alcohol availability 81.20107789
Park access 81.35506224
Retail density 46.32362376
Supermarket access 56.22994996
Tree canopy 94.4180675
Housing —
Homeownership 63.76235083
Housing habitability 86.19273707
Low-inc homeowner severe housing cost burden 41.33196458
Low-inc renter severe housing cost burden 96.25304761
Uncrowded housing 87.19363531
Health Outcomes —
Insured adults 99.75619145
Arthritis 0.0
Asthma ER Admissions 96.2
High Blood Pressure 0.0
Cancer (excluding skin)0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 97.7
Cognitively Disabled 80.8
Physically Disabled 96.9
Heart Attack ER Admissions 93.0
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Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 19.6
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 95.8
Children 64.0
Elderly 25.8
English Speaking 76.2
Foreign-born 51.5
Outdoor Workers 79.5
Climate Change Adaptive Capacity —
Impervious Surface Cover 86.7
Traffic Density 34.0
Traffic Access 87.4
Other Indices —
Hardship 0.9
Other Decision Support —
2016 Voting 98.7
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7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a)7.00
Healthy Places Index Score for Project Location (b)99.0
Project Located in a Designated Disadvantaged Community (Senate Bill 535)No
Project Located in a Low-Income Community (Assembly Bill 1550)No
Project Located in a Community Air Protection Program Community (Assembly Bill 617)No
a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Land Use Pursuant to DOF 2.51 residents per household, consistent with Pop and Housing
Construction: Construction Phases Architectural coating occurs simultaneously as building construction
Construction: Architectural Coatings BAAQMD Regulation 8 Rule 3, Nonflat Coating
Operations: Architectural Coatings BAAQMD Regulation 8 Rule 3, Nonflat Coating
Operations: Energy Use Pursuant to Palo Alto's All-Electric Ordinance, natural gas converted to electricity
Operations: Water and Waste Water WTP 100% aerobic
Appendix C
Native American Tribal Correspondence
September 29, 2022
Amah Mutsun Tribal Band
Valentin Lopez, Chairperson
PO Box 5272
Galt, California 95632
Via Email: vlopez@amahmutsun.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Lopez:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your name
as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the proposed
project. The input of the Amah Mutsun Tribal Band is important to the City of Palo Alto’s planning process and we
invite you to engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and
Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have regarding
Native American cultural resources located in or near the proposed project area that may be affected by project
activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
September 29, 2022
Amah Mutsun Tribal Band of Mission San Juan Bautista
Irene Zwierlein, Chairperson
3030 Soda Bay Road
Lakeport, California 95453
Via email: amahmutsuntribal@gmail.com
Dear Chairperson, Zwierlein:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Amah Mutsun Tribal Band of Mission San Juan Bautista is important to the City of
Palo Alto’s planning process and we invite you to engage in scoping consultation pursuant to Government Code
§65352.4 (Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide
any information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
September 29, 2022
Indian Canyon Mutsun Band of Costanoan
Kanyon Sayers-Roods, MLD Contact
1615 Pearson Court
San Jose, California 95122
Via email: kanyon@kanyonkonsulting.com
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Sayers-Roods:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of Indian Canyon Mutsun Band of Costanoan is important to the City of Palo Alto’s
planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
September 29, 2022
Indian Canyon Mutsun Band of Costanoan
Ann Marie Sayers, Chairperson
P.O. Box 28
Hollister, California 95024
Via email: ams@indiancanyons.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Marie Sayers:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Indian Canyon Mutsun Band of Costanoan is important to the City of Palo Alto’s
planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
September 29, 2022
Muwekma Ohlone Indian Tribe of the SF Bay Area
Monica Arellano, Vice Chairwoman
20885 Redwood Road, Suite 232
Castro Valley, California 94546
Via email: marellano@muwekma.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Arellano:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Muwekma Ohlone Indian Tribe of the SF Bay Area is important to the City of Palo
Alto’s planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
September 29, 2022
The Ohlone Indian Tribe
Andrew Galvan
P.O. Box 3388
Fremont, California 94539
Via email: chochenyo@AOL.com
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Galvan:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Ohlone Indian Tribe is important to the City of Palo Alto’s planning process and
we invite you to engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and
Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have
regarding Native American cultural resources located in or near the proposed project area that may be affected by
project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
September 29, 2022
Wuksache Indian Tribe/Eshom Valley Band
Kenneth Woodrow, Chairperson
1179 Rock Haven Ct.
Salinas, California 93906
Via email: kwood8934@aol.com
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Woodrow:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development(HCD) that the City’s Housing Element has identified
adequate land use capacity and implementing policies to accommodate its Regional Housing Needs Allocation (RHNA)
in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017 Comprehensive Plan
anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the addition of 3,545 to 4,420.
Although no development is specifically proposed as part of the Housing Element Update, the City’s CEQA analysis
will evaluate the potential buildout of these housing units within the boundaries of the City of Palo Alto. The Housing
Element will also identify a list of Housing Inventory Sites which reflect the sites within the City as the highest likelihood
of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions boundaries as well as a list
of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your
name as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the
proposed project. The input of the Wuksache Indian Tribe/Eshom Valley Band is important to the City of Palo Alto’s
planning process and we invite you to engage in scoping consultation pursuant to Government Code §65352.4
(Assembly Bill 52) and Government Code § 65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any
information you have regarding Native American cultural resources located in or near the proposed project area
that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 289-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
June 21, 2022
Tamien Nation
Quirina Luna Geary, Chairperson
P.O. Box 8053
San Jose, California 95155
Via email: qgeary@tamien.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson Geary:
The City of Palo Alto, acting as the lead agency in accordance with the California Environmental Quality Act, is
preparing a Supplemental EIR for its 2023-31 Housing Element Update. The proposed project consists of a complete
update to the Housing Element and related edits to the City’s Comprehensive Plan Land Use Element and Palo Alto
Municipal Code.
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development (HCD) that the City’s Housing Element has
identified adequate land use capacity and implementing policies to accommodate its Regional Housing Needs
Allocation (RHNA) in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017
Comprehensive Plan anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the
addition of 3,545 to 4,420. Although no development is specifically proposed as part of the Housing Element Update,
the City’s CEQA analysis will evaluate the potential buildout of these housing units within the boundaries of the City
of Palo Alto. The Housing Element will also identify a list of Housing Inventory Sites which reflect the sites within the
City as the highest likelihood of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions
boundaries as well as a list of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your name
as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the proposed
project. The input of the Tamien Nation is important to the City of Palo Alto’s planning process and we invite you to
engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and Government Code §
65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have regarding Native American
cultural resources located in or near the proposed project area that may be affected by project activities.
In accordance with AB 52 your tribes have 30 days from receipt of this letter to respond in writing if you wish to
consult on the proposed project. Under the provisions of SB 18, your tribe has 90 days from receipt of this letter to
respond in writing if you wish to consult on the proposed project. Therefore, the City respectfully requests receipt of
any questions or comments on this project within 90 days of receipt of this letter. If you require any additional
information or have any questions, please contact me at (650) 329-2493 or via e-mail at tim.wong@cityofpaloalto.org.
Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
Tamien Nation September 29, 2022
Johnathan Wasaka Costillas, THPO
P.O. Box 866
Clearlake Oaks, California 94523
Via email: thpo@tamien.org
RE: Assembly Bill 52 and Senate Bill 18 Consultation, City of Palo Alto 2023-31 Housing Element
Update, Palo Alto, California
Dear Chairperson, Costillas:
The Housing Element is one of the seven state-mandated elements of the local Comprehensive Plan and is required
to be updated every eight years. The City of Palo Alto is preparing the 2023-2031 Housing Element Update to comply
with the legal mandate that requires each local government to identify adequate sites for housing to meet the existing
and projected housing needs for varying income-levels in the community. It is intended to provide the city with a
comprehensive strategy for promoting the production of safe, decent and affordable housing, and affirmatively
furthering fair housing during the housing cycle. The Housing Element Update establishes goals, policies, and actions
to address the existing and projected housing needs in Palo Alto. Overall, the City’s zoning and other land use
regulations must accommodate at least 6,695 new units during the 8-year planning period in order to demonstrate
to the State Department of Housing and Community Development (HCD) that the City’s Housing Element has
identified adequate land use capacity and implementing policies to accommodate its Regional Housing Needs
Allocation (RHNA) in addition to the identified “buffer” of 10 percent above its RHNA. By comparison, the 2017
Comprehensive Plan anticipated—and the Comprehensive Plan Environmental Impact Report evaluated—the
addition of 3,545 to 4,420. Although no development is specifically proposed as part of the Housing Element Update,
the City’s CEQA analysis will evaluate the potential buildout of these housing units within the boundaries of the City
of Palo Alto. The Housing Element will also identify a list of Housing Inventory Sites which reflect the sites within the
City as the highest likelihood of housing redevelopment in order to accommodate the RHNA. A map of the jurisdictions
boundaries as well as a list of the draft Housing Inventory Sites is attached.
The City of Palo Alto is sending this letter because the Native American Heritage Commission has provided your name
as a representative of a tribe that is traditionally and culturally affiliated with the geographic area of the proposed
project. The input of the Tamien Nation is important to the City of Palo Alto’s planning process and we invite you to
engage in scoping consultation pursuant to Government Code §65352.4 (Assembly Bill 52) and Government Code §
65352.3– 65352.4 (Senate Bill 18) or to confidentially provide any information you have regarding Native American
cultural resources located in or near the proposed project area that may be affected by project activities.
If you wish to engage in consultation under AB 52 (California Public Resources Code § 21080.3.1) for this or future
projects, you may submit a written request for notification of proposed projects. In accordance with AB 52 your tribe
has 30 days from receipt of this letter to respond in writing if you wish to consult on the proposed project. Under the
provisions of SB 18, your tribe has 90 days from receipt of this letter to respond in writing if you wish to consult on
the proposed project. Therefore, the City respectfully requests receipt of any questions or comments on this project
within 90 days of receipt of this letter. If you require any additional information or have any questions, please contact
me at (650) 329-2493 or via e-mail at tim.wong@cityofpaloalto.org. Thank you for your assistance.
Sincerely,
Tim Wong
Senior Planner
City of Palo Alto, Planning and Development Services Department
Enclosure:
Regional Location Map
*NOT YET APPROVED*
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0160103_20230427_ay16
RESOLUTION NO. _____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALO ALTO, APPROVING AN
ADDENDUM TO THE 2017 COMPREHENSIVE PLAN FINAL ENVIRONMENTAL IMPACT REPORT,
AND ADOPTING A COMPREHENSIVE PLAN AMENDMENT TO REPEAL THE 2015-2023
HOUSING ELEMENT AND ADOPT THE HOUSING ELEMENT OF THE COMPREHENSIVE PLAN
FOR THE PERIOD OF 2023-2031 IN COMPLIANCE WITH STATE HOUSING ELEMENT LAW.
RECITALS
A. California Government Code Section 65300 et seq. requires every city and county in
California to adopt a General Plan, known in Palo Alto as its Comprehensive Plan, for its
long-range development, and further, to periodically to update that plan to reflect current
issues and conditions; and
B. On November 13, 2017, the City Council for the City of Palo Alto (City) certified a Final
Environmental Impact Report (EIR) for the City of Palo Alto Comprehensive Plan 2030
through Resolution No. 9720, made findings in relation to the Final EIR, adopted a mitigation
monitoring and report plan (MMRP), and adopted a statement of overriding considerations
through Resolution No. 9721 and adopted the City of Palo Alto Comprehensive Plan 2030
through Resolution No. 9722; and
C. Government Code Section 65302 mandates that every city and county shall include a
Housing Element in its General Plan, and that the Housing Element be updated regularly on
a schedule set forth in the law to reflect current conditions and legal requirements; and
D. State Housing Element Law (Government Code Sections 65580 et seq.) requires that the
City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate
the City of Palo Alto (City) regional housing need allocation (RHNA) of 6,086 housing units,
comprised of 1,556 very-low income units, 896 low-income units, 1,013 moderate-income
units, and 2,621 above moderate-income units; and
E. To comply with State Housing Element Law, the City has prepared the Housing Element
2023-2031 (the Housing Element) in compliance with State Housing Element Law and has
identified sites that can accommodate housing units meeting the City’s RHNA; and
F. As provided in Government Code Section 65350 et. seq., adoption of the Housing Element
constitutes a General Plan Amendment and also qualifies as a project under the California
Environmental Quality Act (CEQA); and
G. Pursuant to the provisions and requirements of CEQA and CEQA Guidelines Section 15164,
the City as lead agency, prepared an Addendum to the 2017 Comprehensive Plan Final EIR
(the Addendum) to analyze the potential environmental impacts resulting from adopting the
2023-2031 Housing Element, which Addendum is attached hereto as Exhibit E and
incorporated by this reference; and
*NOT YET APPROVED*
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0160103_20230427_ay16
H. The Addendum analyzes the environmental impacts of the 2023-2031 Housing Element and
the Addendum, in conjunction with the 2017 Comprehensive Plan Final EIR, is the
environmental document upon which adoption of the 2023-2031 Housing Element is
predicated; and
I. As provided in Government Code sections 65352 – 65352.5 the City mailed a public notice to
all California Native American tribes provided by the Native American Heritage Commission
and to other entities listed; and
J. No California Native American tribe requested consultation; and
K. The City conducted extensive community outreach in multiple languages over the past two
years including fifteen meetings of the Housing Element Working Group, eight meetings of
the City Council Housing Element Ad Hoc Committee, two community workshops,
dissemination of a housing survey, numerous meetings with special interest groups such as
the Palo Alto Renters Association, Housing Choices, and Ability Path, four meetings of the
Planning and Transportation Commission (PTC), three meetings of the City Council, and two
joint meetings of the PTC and City Council; and
L. In accordance with Government Code Section 65585 (b), on November 7, 2022, the City
posted the draft Housing Element and requested public comment for a 30-day review
period, and on December 23, 2022, after responding to public comments, the City
submitted the draft Housing Element to the State Department of Housing and Community
Development (HCD or Department) for its review; and
M. On March 8, 2023, the PTC held a duly and properly noticed public hearing to consider a
draft of the Addendum and the initial draft of the 2023-2031 Housing Element, and
unanimously recommended that the City Council adopt the draft 2023-2031 Housing
Element, subject to refinement following formal comment by HCD.
N. In February 2023, prior to receiving HCD’s formal findings regarding the draft Housing
Element, the City contacted HCD discuss preliminary comments on the adequacy of the
draft Housing Element; and
O. On March 23, 2023, the City received a letter from HCD, attached as Exhibit B to this
Resolution, providing its findings regarding the draft Housing Element, and based upon this,
City staff and consultants revised the draft Housing Element to include additional
information and data; and
P. On April 27, 2023, the City published a revised draft Housing Element responding to HCD’s
findings and requested public comment on the draft; and
*NOT YET APPROVED*
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0160103_20230427_ay16
Q. On May 8, 2022, the PTC held a duly and properly noticed joint public hearing with the City
Council and recommended that the City Council adopt the Housing Element; and
R. On May 8, 2022, the City Council conducted a duly and properly joint noticed public hearing
with the PTC to take public testimony, consider the 2017 Comprehensive Plan EIR and EIR
Addendum, reviewed the Housing Element and all pertinent maps, documents and exhibits,
including HCD’s findings, the City’s response to HCD’s findings, the staff report, and all
attachments, and oral and written public comments.
NOW, THEREFORE, BE IT RESOLVED, that the City Council hereby finds that, based on substantial
evidence in the record:
1. The foregoing recitals are true and correct and are incorporated by reference into this action.
2. The record of proceedings upon which the City Council bases its decision herein includes, but is
not limited to: (1) the Addendum and the 2017 Comprehensive Plan Final EIR including all
appendices and attachments cited and/or relied upon therein; (2) the staff reports, City files and
records and other documents prepared for and/or submitted to the City relating to the 2017
Comprehensive Plan Final EIR, the Addendum, and the 2023-2031 Housing Element; (3) the
evidence, facts, findings, and other determinations set forth in this Resolution; (4) the 2017
Comprehensive Plan; (5) all studies, data, and correspondence submitted by the City in
connection with the Addendum and the 2023-2031 Housing Element; (6) all documentary and
oral evidence received at public workshops, meetings, and hearings; (7) all other matters of
common knowledge to City decisionmakers, including City, state, and federal laws, policies,
rules, and regulations, reports, records, and projections related top development within the City
of Palo Alto and its surrounding areas. The location and custodian of records is the City Clerk of
the City of Palo Alto, 250 Hamilton Avenue, Palo Alto, CA 94305.
3. Based on the record of proceedings as a whole, the City Council approves the Addendum to the
2017 Comprehensive Plan Final EIR and makes the following findings and declarations:
a. That the 2023-2031 Housing Element represents only incremental change over the
conditions studied in the 2017 Comprehensive Plan Final EIR.
b. The MMRP adopted in conjunction with the 2017 Comprehensive Plan included all
mitigation measures necessary to mitigate the most impactful scenarios contemplated
in the 2017 Comprehensive Plan EIR.
c. None of the conditions described in CEQA Guidelines Section 15162 calling for the
preparation of a Subsequent EIR or Supplemental EIR are present, as set forth in the
Addendum.
d. Any modifications to the 2023-2031 Housing Element directed by the City Council on
May 8, 2023 do not change the conclusions of the Addendum and the 2017
Comprehensive Plan Final EIR.
e. The Addendum has been prepared in accordance with CEQA and the State CEQA
Guidelines and reflects the independent judgment of the City as lead agency.
*NOT YET APPROVED*
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0160103_20230427_ay16
f. All mitigation measures included in the MMRP for the 2017 Comprehensive Plan Final
EIR will continue to be required, as part of the adoption of the 2023-2031 Housing
Element.
4. Based on the record of proceedings as a whole, the City Council makes the following findings
and declarations regarding the 2023-2031 Housing Element, as shown in Exhibit A to this
Resolution, incorporated herein:
a. Adoption of the 2023-2031 Housing Element is in the public interest. The 2023-2031
Housing Element promotes the production of the City’s share of regional housing need
for all segments of the community, which is in the interest of the City, the region, and
the state.
b. The 2023-2031 Housing Element is internally consistent and consistent with the rest of
the Comprehensive Plan. As an integrated set of goals, policies, programs, and timelines,
and quantified objectives, the 2023-2031 Housing Element does not approve any
specific development projects; it acknowledges land use and zoning changes that will be
required and therefore it creates no inconsistencies with the Comprehensive Plan.
c. The 2023-2031 Housing Element was developed through diligent effort by the City to
achieve public participation of all segments of the community, as described in Chapter 1
of the 2023—2031 Housing Element.
d. The 2023-2031 Housing Element substantially complies with all requirements of Housing
Element Law, as provided in Government Code 65580 et seq., and contains all provisions
required by State Housing Element Law, as shown in Exhibit D to this Resolution,
incorporated herein.
5. Based on substantial evidence in the record, including, but not limited to, the analyses provided
in Chapters 3 and 4 of the 2023-2031 Housing Element, the City’s experience with the
redevelopment of non-vacant and commercially developed sites for housing, strong expressed
interest from property owners and developers, and the numerous policies and programs in
Chapter 5 of the 2023-2031 Housing Element aimed at reducing constraints to housing
development and otherwise increasing housing supply, the existing uses on the non-vacant sites
identified in the site inventory to accommodate the RHNA are likely to be integrated with new
residential uses or discontinued during the planning period and therefore do not constitute an
impediment to planned residential development on the site during the planning period.
6. As required by Government Code Section 65585(e), the City Council has considered the findings
made by the Department of Housing and Community Development included in the
Department’s letter to the City dated March 23, 2023, consistent with Government Code
Section 65585(f), and as described in Exhibit C to this Resolution, incorporated herein, the City
Council has changed the Housing Element in response to the findings of the Department to
substantially comply with the HCD’s interpretation of the requirements of State Housing
Element Law.
7. The 2015-2023 Housing Element is hereby repealed in its entirety, and the 2023-2031 Housing
Element is adopted.
*NOT YET APPROVED*
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0160103_20230427_ay16
8. The City Council intends to complete the HCD review process to obtain an HCD findings of
substantial compliance and certification and hereby directs and authorizes the Director of
Planning and Development Services: a) to file all necessary material with the HCD for the
Department to find that the Housing Element is in conformance with State Housing Element
Law; and b) to make all non-substantive changes to the Housing Element to make it internally
consistent or to address any non-substantive changes or amendments requested by the
Department to achieve certification.
9. The Director of Planning and Development Services is hereby directed to ensure that the
adopted Housing Element, including any additional amendments, is posted to the City’s website,
and a link emailed to all individuals and organizations that have previously requested notices, at
least seven days prior to submission to HCD.
10. The Director of Planning and Development Services and City Clerk are hereby directed to
distribute copies of the Housing Element in the manner provided in Government Code Sections
65357 and 65589.7.
11. This Resolution shall become effective upon adoption by the City Council.
INTRODUCED and PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Attorney City Manager
____________________________
Director of Planning and
Development Services
*NOT YET APPROVED*
6
0160103_20230427_ay16
Exhibit A: 2023-2031 Housing Element
Exhibit B: HCD Finding Letter, dated March 23, 2023
Exhibit C: Response to HCD Findings
Exhibit D: Housing Element Statutory Provisions Checklist
Exhibit E: Addendum to the 2017 Comprehensive Plan Final EIR
*NOT YET APPROVED*
Exhibit A
Not included in this draft for brevity. To be replaced with Attachment A to Council Report #2304-1372,
as revised.
*NOT YET APPROVED*
Exhibit B
Not included in this draft for brevity. To be replaced with Attachment D to Council Report 2304-1372.
*NOT YET APPROVED*
Exhibit C
Not included in this draft for brevity. To be replaced with Attachment F to Council Report 2304-1372.
*NOT YET APPROVED*
Exhibit D
This exhibit will be provided with the agenda packet published on May 4, 2023
Exhibit E
Not included in this draft for brevity. To be replaced with Attachment B to Council Report 2304-1372.
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
DATE 23, 2023
Jonathon Lait, Planning Director
Department of Planning and Development
City of Palo Alto
250 Hamilton Avenue, Fifth Floor
City of Palo Alto, CA 94301
Dear Jonathon Lait:
RE: City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element
Thank you for submitting the City of Palo Alto’s (City) draft housing element received for
review on December 23, 2022. Pursuant to Government Code section 65585,
subdivision (b), the California Department of Housing and Community Development
(HCD) is reporting the results of its review. HCD considered comments from
David Kellogg, Greenbelt Alliance; Stuart L. Klein, Ian Faucher, Rob Neilson,
Scott O’Neil and Robert Chun, Palo Alto Moving Forward; Salim Damerdji,
Sidharth Kapur, Steve Levy, Greg Schmid, Kelsey Banes, Emily Ramos, and the
League of Women Voters; pursuant to Government Code section 65585, subdivision
(c).
The draft element addresses many statutory requirements; however, revisions will be
necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).
The enclosed Appendix describes the revisions needed to comply with State Housing
Element Law.
As a reminder, the City’s 6th cycle housing element was due January 31, 2023. As of
today, the City has not completed the housing element process for the 6th cycle. The
City’s 5th cycle housing element no longer satisfies statutory requirements. HCD
encourages the City to revise the element as described above, adopt, and submit to
HCD to regain housing element compliance.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if
a local government fails to adopt a compliant housing element within 120 days of the
statutory deadline (January 31, 2023), then any rezoning to make prior identified sites
available or accommodate the regional housing needs allocation (RHNA) shall be
completed no later than one year from the statutory deadline pursuant to Government
Code sections 65583, subdivision (c) (1) and 65583.2, subdivision (c). Otherwise, the
local government’s housing element will no longer comply with State Housing Element
Erin Morris, Planning Director
Page 2
Law, and HCD may revoke its finding of substantial compliance pursuant to
Government Code section 65585, subdivision (i). Please be aware, if the City fails to
adopt a compliant housing element within one year from the statutory deadline, the
element cannot be found in substantial compliance until these rezones are completed.
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. Throughout the housing element
process, the City should continue to engage the community, including organizations that
represent lower-income and special needs households, by making information regularly
available and considering and incorporating comments where appropriate. Please be
aware, any revisions to the element must be posted on the local government’s website
and to email a link to all individuals and organizations that have previously requested
notices relating to the local government’s housing element at least seven days before
submitting to HCD.
Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s
Affordable Housing and Sustainable Communities programs; and HCD’s Permanent
Local Housing Allocation consider housing element compliance and/or annual reporting
requirements pursuant to Government Code section 65400. With a compliant housing
element, the City meets housing element requirements for these and other funding
sources.
For your information, some general plan element updates are triggered by housing
element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html
HCD appreciates the commitment and cooperation of the housing element update team
during the update and our review. We are committed to assisting the City in addressing
all statutory requirements of State Housing Element Law. If you have any questions or
need additional technical assistance, please contact Irvin Saldana, of our staff, at
Irvin.Saldana@hcd.ca.gov.
Sincerely,
Melinda Coy
Proactive Housing Accountability Chief
Enclosure
City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element Page 1
March 23, 2023
APPENDIX
CITY OF PALO ALTO
The following changes are necessary to bring the City’s housing element into compliance with
Article 10.6 of the Government Code. Accompanying each recommended change, we cite the
supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at
https://www.hcd.ca.gov/planning-and-community-development/hcd-memos Among other resources,
the housing element section contains HCD’s latest technical assistance tool, Building Blocks for
Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-
community-development/housing-elements/building-blocks and includes the Government Code
addressing State Housing Element Law and other resources.
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress
in implementation, and reflect the results of this review in the revised element. (Gov. Code,
§ 65588 (a) and (b).)
Special Housing Needs: The element must provide an evaluation of the cumulative
effectiveness of past goals, policies, and related actions in meeting the housing needs
of special needs populations (e.g., elderly, persons with disabilities, large households,
female-headed households, farmworkers, and persons experiencing homelessness)
and revise programs as appropriate. In addition to evaluating progress or effectiveness
of programs to address special needs groups, the element can also discuss the results,
success, or lack of, challenges and opportunities from outreach, coordination,
application for funding, incentives or other activities and then discuss potential
strategies set forth in the current element to meet the need.
B. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with
Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in
the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Fair Housing Enforcement and Capacity: While the housing element includes a
summary of fair housing enforcement and outreach capacity at the county level, it must
also quantify and evaluate complaints at the City level. In addition, the element should
discuss how the City complies with existing fair housing laws and regulations, any past
fair housing lawsuits, consent decrees or other related legal matters.
Patterns and Trends: While the element reports general information and data, it must
analyze this data for trends over time, patterns across census tracts, and coincidence
with other components of the assessment of fair housing. Moreover, the element must
supplement existing data with local data and knowledge and other relevant factors were
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applicable. Lastly, the element provides an evaluation of fair housing data on a regional
basis that is generally limited, comparing only a few fair housing topics within Santa
Clara County and providing no analysis to the surrounding South Bay region. Once
complete, the assessment of fair housing must include appropriate programmatic
responses to encourage housing mobility and promote new affordable housing
opportunities throughout the City, regardless of the regional housing need allocation
(RHNA).
Racially Concentrated Areas of Poverty (R/ECAPs): The element mentions that there
are no racially concentrated areas of poverty within City; however, the element does
provide analysis on distinct areas of poverty/lower income; and identifies two census
tracts with 10-40 percent of the population below the poverty line. The analysis should
include local data and knowledge to further evaluate patterns and changes overtime at
a local (e.g., neighborhood to neighborhood) level and provide appropriate
programmatic responses to address ongoing patterns and trends.
Racially Concentrated Areas of Affluence (RCAA): The element identified a total of 10
census tracts within City that qualified as RCAA; however, and as mentioned above,
element provides limited analysis on the factors that contribute to this outcome. This
analysis should utilize local data and knowledge and other relevant factors to achieve a
comprehensive analysis. For example, the element could examine past land use
practices, investments, quality of life relative to the rest of the City and region and then
formulate appropriate programs to promote more inclusive communities and equitable
quality of life. For example, the City should consider additional actions (not limited to the
RHNA) to promote housing mobility and improve new housing opportunities throughout
the City.
Disparities in Access to Opportunity: The element provides datapoints and a general
analysis on accesses opportunity including, education, economic, transportation and
environmental outcomes; however, the element should analyze these data points for
trends and patterns throughout the City, and any concentrations or coincidences with
other components of the fair housing analysis. A complete analysis should revise and or
provide additional policies and programs that meet the need of each of the components
mentioned above.
Disproportionate Housing Needs including Displacement: The element provides some
analysis on overcrowding, overpayment, substandard housing, homelessness, and
displacement risk; however, the element must analyze the data for local and regional
patterns for overcrowding, overpayment, and substandard housing including any
identified trends and coincidence with other components of the fair housing
assessment. In addition, the element briefly mentions persons experiencing
homelessness, but should provide additional information on the need, including, impacts
and patterns within the City. For instance, the element should examine disproportionate
impacts on protected characteristics (e.g., race, disability) and patterns of need,
including access to transportation and services. Lastly, the element must describe
characteristics of existing “sensitive communities” found on figures C-45 and 46 of the
element.
City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element Page 3
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Identified Sites and Affirmatively Furthering Fair Housing (AFFH): The element must
include data on the location of regional housing need allocation (RHNA) sites by income
group relative to all fair housing components. The analysis should address the isolation
of the RHNA by income group, specifically in the GM and ROLM zones (p. C-86)
magnitude of the impact on existing concentrations of socio-economic characteristics
and discuss how the sites improve fair housing conditions. The analysis should be
supported by local data and knowledge and other relevant factors and programs should
be added or modified as appropriate to promote inclusive and equitable communities.
Local Data and Knowledge and Other Relevant Factors: As noted in the prior findings,
the element must supplement the analysis and complement state and federal data with
local data and knowledge to capture emerging trends and issues, including utilizing
knowledge from local and regional advocates, public comments, and service providers.
Contributing Factors: The element identifies many contributing factors to fair housing
issues but must prioritize these factors to better formulate policies and programs and
carry out meaningful actions to AFFH.
2. Include an analysis and documentation of household characteristics, including level of
payment compared to ability to pay, housing characteristics, including overcrowding,
and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Analyze any special housing needs such as elderly; persons with disabilities, including a
developmental disability; large families; farmworkers; families with female heads of
households; and families and persons in need of emergency shelter. (Gov. Code,
§ 65583, subd. (a)(7).)
Housing Conditions: The element provides some information on age of the housing
stock. However, it must estimate the number of units in need of rehabilitation and
replacement. For example, the analysis could include estimates from a recent
windshield survey or sampling, estimates from the code enforcement agency, or
information from knowledgeable organizations.
Special-Needs Populations: While the element identifies the number of persons
experiencing homelessness using a past point in time count (PIP) survey, (pp. 2-72) of
the element mentions a more recent PIP conducted on January 24, 2023. The elements
analysis and corresponding figures should be updated to reflect the most recent PIP.
3. An inventory of land suitable and available for residential development, including vacant
sites and sites having realistic and demonstrated potential for redevelopment during the
planning period to meet the locality’s housing need for a designated income level, and
an analysis of the relationship of zoning and public facilities and services to these sites.
(Gov. Code, § 65583, subd. (a)(3).)
Progress toward the RHNA: As you know, the City’s RHNA may be reduced by the
number of new units built since June 30, 2022; however, the element must demonstrate
the affordability of units in the planning period based on actual sales price, rent level, or
other mechanisms ensuring affordability (e.g., deed restrictions). While the element
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includes some information related units in the pipeline listed on Table 3-2 (pp. 3-6, 3-7),
it divides the units between below market rate and market rate rather than indicating the
actual affordability category (very-low-, low-, moderate-, above moderate- income). In
addition, several projects which have units assigned in the below market rate category
indicate that there is no restriction. For these projects, the element must indicate how
affordability was determined. The element must also discuss availability or likelihood the
units will be built in the planning period and should account for any barriers to
development, phasing, anticipated build out horizons, market conditions and other
relevant factors to demonstrate their availability in the planning period.
Realistic Capacity: While realistic capacity assumptions are generally conservative and
based on existing or approved residential developments and development trends in the
surrounding region, the elements realistic capacity assumptions must still account for all
land use controls and site improvements. In addition, residential capacity calculations
should account for the likelihood of residential development in zones where 100 percent
nonresidential uses are allowed. These assumptions should also go beyond recent
approved development and consider additional factors such as, nonresidential
performance standards that require residential use, incentives for residential use,
market demand, efforts to attract and assist developers, the allowance of 100 percent
residential development in nonresidential zones, and local or regional residential
development trends in the same nonresidential zoning districts. The element should
enhance existing policies and programs based on a complete analysis.
Nonvacant Sites: The element provides several factors that demonstrate the
redevelopment potential of nonvacant sites, including factors such as, current, and past
development trends, improvement to land value ratios, existing use vs zone use, age of
structure, floor area ratio (FAR), proximity to transit, TCAC/HCD designations, and
community interest. However, the element must provide additional information on
nonvacant sites related to existing uses that may constitute an impediment to additional
residential development, past experiences converting existing uses to higher density
residential development, current market demand for the existing use, existing leases or
contracts that would perpetuate the existing use or prevent additional residential
development or other relevant information to demonstrate the potential for redevelopment
such as expressed owner and developer interest. Based on a complete analysis the
element may need to add or revise programs to facilitate redevelopment. In addition, HCD
received several public comment letters regarding the possible existence of additional
units on several sites included in the City’s site inventory. The City must review and
consider the possibility that existing units on nonvacant sites were undercounted. Once
complete, existing capacity totals must be adjusted to accurately reflect existing units on
identified nonvacant sites.
Finally, if the housing element relies upon nonvacant sites to accommodate more than 50
percent of the RHNA for lower income households, the housing element must demonstrate
that the existing use is not an impediment to additional residential development in the
planning period (Gov. Code, § 65583.2, subd. (g)(2).). This can be demonstrated by
providing substantial evidence that the existing use is likely to be discontinued during the
planning period (Gov. Code, § 65583.2, subd. (g)(2).
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Environmental Constraints: While the element generally describes environmental
conditions within the City (pp. 4-77), it must describe any other known environmental
constraints or conditions within the City that could preclude development on identified
sites in the planning period (e.g., airport compatibility and related land use controls,
shape, contamination, easements, overlays).
AB 725: For jurisdictions that are considered Metropolitan, the element must identify at
least 25 percent of the remaining moderate and above moderate RHNA on sites that
allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2,
subd. (c)(4)).
City-Owned sites: While a brief analysis on city-owned parking lots (pp. 3-43) is
included in the element, the analysis should discuss the status, anticipated steps for
development including disposition, any known barriers to development and other
relevant factors to development in the planning period. Based on a complete analysis,
the element should add or modify programs to comply with the Surplus Land Act,
commit to numerical objectives, including affordability, aligned with assumptions in the
inventory and a schedule of actions to facilitate development. A schedule of actions may
include coordination with appropriate entities, including potential developers, disposition
of the land, zoning, funding, facilitating other entitlements and issuing permits. Lastly,
the program should identify and make alternative sites with zoning of equivalent
capacity and density by a specified date if sites are not made available by a date early
in the planning period.
Availability of Infrastructure: While the element describes minor upgrades to water and
sewer hookups may be required to support development of select sites, it should clarify
sufficient existing or planned water and sewer capacity to accommodate the City’s
regional housing need. Currently, the analysis on (pp. 3-57) is unclear.
For your information, water and sewer service providers must establish specific
procedures to grant priority water and sewer service to developments with units
affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are
required to immediately deliver the housing element to water and sewer service
providers. HCD recommends including a cover memo describing the City’s housing
element, including the City’s housing needs and regional housing need. For additional
information and sample cover memo, see the Building Blocks at
https://www.hcd.ca.gov/planning-and-community-development/housing-
elements/building-blocks/priority-water-and-sewer.
Electronic Sites Inventory: For your information, pursuant to Government Code section
65583.3, the City must submit an electronic sites inventory with its adopted housing
element. The City must utilize standards, forms, and definitions adopted by HCD.
Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-
development/housing-element/index.shtml#element for a copy of the form and
instructions. The City can reach out to HCD at sitesinventory@hcd.ca.gov for technical
assistance.
City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element Page 6
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Zoning for a Variety of Housing Types:
• Emergency Shelters: The element currently identifies the Research, Office, and
Limited Manufacturing-Embarcadero (ROLM(E)) district as suitable to
accommodate emergency shelters. However, the element should clarify if
emergency shelters are allowed in this zone by-right and without discretionary
action. In addition, the element should list development standards and identify
reuse, and redevelopment opportunity. Lastly, the element should provide an
analysis of proximity to transportation and services for these sites, hazardous
conditions, and any conditions appropriate for human habitability.
For your information, Chapter 654, Statutes of 2022 (AB 2339), adds additional
specificity on how cities and counties plan for emergency shelters and ensure
sufficient and suitable capacity. Future submittals of the housing element may
need to address these statutory requirements. For additional information and
timing requirements, please see HCD’s memo at
https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/ab2339-
notice.pdf.
• Accessory Dwelling Units (ADU): Please refer to HCD’s letter related to ADU
requirements sent on December 21, 2022.
• Transitional and Supportive Housing: Transitional housing and supportive
housing must be permitted as a residential use in all zones allowing residential
uses and only subject to those restrictions that apply to other residential
dwellings of the same type in the same zone. Currently, the element mentions
that supportive and transitional housing will be allowed in additional zones (pp. 4-
36, 4-37); however referencing (Table 4-3A) on (pp. 4-22) the City has several
additional zones (i.e., AMF, MUO) that would also have to allow transitional and
supportive housing as a residential use and subject only to those restrictions that
apply to residential dwelling of the same type in the same zone.
• By-Right Permanent Supportive Housing (AB 2162): Supportive housing shall be
a use by-right in zones where multifamily and mixed uses are permitted,
including nonresidential zones permitting multifamily uses pursuant to
Government Code section 65651. The element must demonstrate compliance
with these requirements and include programs as appropriate.
• Manufactured Housing: Manufactured homes that are built on a permanent foundation
must be allowed in the same manner and in the same zones as conventional or stick-
built structures. Specifically, manufactured homes on a permanent structure should only
be subject to the same development standards as a conventional single-family
residential dwelling. The element must demonstrate consistency with this requirement
or add or modify programs as appropriate.
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• Farmworker Housing: Section 17021.6 requires employee housing consisting of no
more than 12 units or 36 beds to be permitted in the same manner as other agricultural
uses in the same zone. Currently, the element is unclear on whether the City complies
with state law in accordance to Health and Safety Code 17021.6. In addition while the
element mentions amending the City’s code to comply with 17021.6, Program 6.5 fails
to mention commitments to do so during the planning period .For additional information
and sample analysis, see the Building Blocks at https://www.hcd.ca.gov/planning-and-
community-development/housing-elements/building-blocks/farmworkers.
4. An analysis of potential and actual governmental constraints upon the maintenance,
improvement, or development of housing for all income levels, including the types of
housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as
identified in the analysis pursuant to paragraph (7), including land use controls, building
codes and their enforcement, site improvements, fees and other exactions required of
developers, and local processing and permit procedures... (Gov. Code, § 65583, subd.
(a)(5).)
Land Use Controls: The element must identify and analyze the impact of all relevant
land use controls as potential constraints on a variety of housing types in all zones that
allow residential uses. The analysis should analyze land use controls independently and
cumulatively with other land use controls. The analysis should address any impacts on
cost, supply, housing choice, feasibility, timing, approval certainty and ability to achieve
maximum densities and include programs to address identified constraints. The analysis
must specifically describe and analyze, minimum lot area coverage, height limits,
setbacks, and floor area ratios (FAR). Lastly, the element must describe and analyze
parking requirements in all zones that allow residential uses.
Fees and Exaction: While the element describes required fees for single family and
multifamily housing developments, including impact fees, on (pp. 4-66) the element
states that impact fees/capacity fees are considered the highest in the County. In
addition, on (pp. 4-67) the City recognizes that current planning/permitting and
development fees add substantial cost to residential development. The element should
provide a comprehensive analysis assessing all required fees and their proportion to the
development costs for both single family and multifamily housing. In addition, the
element could also provide information on how the city provides financial assistance to
affordable housing developments. Based on a complete analysis, the City should
provide additional policy and programs to mitigate the cost and impact of required fees
on residential development.
Density Bonus Law: The element must clarify compliance with current State Density
Bonus Law (SDBL) including amendments enacted January 1, 2023. In addition, the
element must list and analyze fees associated to SDBL as a potential constraint on
housing.
Zoning and Fee Transparency: The element must clarify its compliance with new
transparency requirements for posting all zoning and development standards for each
parcel on the jurisdiction’s website pursuant to Government Code section 65940.1(a)(1).
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Local Processing and Permit Procedures: HCD has received several public comments
related to the local permit process that have indicated a complex, untimely, and
cumbersome process with little certainty to applicants. While the element includes
information on permit process and processing time frames that range from 90 to 365
days, a complete analysis must evaluate the processing and entitlement procedures for
potential constraints on housing supply, cost, timing, financial feasibility, approval
certainty and ability to achieve maximum densities. Specifically, the element must
describe the procedures for a typical single-family and multifamily development. As
most projects require discretionary approvals, the analysis must describe the decision-
making framework for discretionary approvals related to all permits and entitlements,
including but not limited to building permits, major architectural review board, conditional
use permits (CUPs), context-based design criteria, rezone procedures, planned home
zoning, site plans, environmental review, etc. The analysis must include the approval
bodies, the number of public hearings, the actual approval findings, and all relevant
information. Based on the outcomes of a complete analysis, the element must add or
modify programs as appropriate.
Finally, the element should discuss compliance with the Permit Streamlining Act and
intersections with CEQA and timing requirements, including streamlining determinations
and add or modify programs as appropriate.
On/Off-Site Improvements: The element must identify subdivision level improvement
requirements, such as minimum street widths (e.g., 40 foot minimum street width), and
analyze their impact as potential constraints on housing supply and affordability.
Codes and their Enforcement: While the element describes the City’s current building
code, it must describe the City’s building and zoning code enforcement processes and
procedures, including whether code enforcement is targeted or complaint based, and
analyze their impact as potential constraints on housing supply and affordability.
Local Ordinances: The element must specifically analyze locally adopted ordinances
such as inclusionary ordinances or short-term rental ordinances that directly impact the
cost and supply of residential development. In addition, the element should further
analyze the Retail Preservation Ordinance and clarify whether any sites in the element
are currently with the boundaries of the ordinance. Lastly, HCD received public
comment on the City’s Tree Protection Ordinance, the element must provide analysis on
this recently adopted ordinance (July 21, 2022) and should evaluate any impacts on the
development of housing and the City’s ability to meet the RHNA.
5. An analysis of potential and actual nongovernmental constraints upon the maintenance,
improvement, or development of housing for all income levels, including… …requests to
develop housing at densities below those anticipated in the analysis required by subdivision (c)
of Government Code section 65583.2, and the length of time between receiving approval for a
housing development and submittal of an application for building permits for that housing
development that hinder the construction of a locality’s share of the regional housing need in
accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).)
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Developed Densities and Permit Times: The element must be revised to include
analysis of requests to develop housing at densities below those anticipated, and the
length of time between receiving approval for a housing development and submittal of
an application for building permits that potentially hinder the construction of a locality’s
share of the regional housing need.
6. Analyze existing assisted housing developments that are eligible to change to non-low-
income housing uses during the next 10 years due to termination of subsidy contracts,
mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd.
(a)(9) through 65583(a)(9)(D).)
Table 2-39 on (pp. 2-100) of the element identifies the total number of units at-risk of
conversation during the planning period. However, according to HCD records received
from the California Housing Partnership (http://www.chpc.net) additional properties may
be at-risk including Oak Park Manor (630 Los Robles Ave) and California Park
Apartments (2301 Park Blvd). If units are identified as at-risk, the analysis must include
the following:
• Listing of each development by project name and address.
• Type of governmental assistance received and the earliest date of change from
low-income use.
• Total number of units for senior vs. nonsenior residents.
• Estimated total cost for producing, replacing, and preserving the at-risk units.
• Identification of public and private nonprofit corporations known to the City to
have the legal and managerial capacity to acquire and manage at-risk units.
• Identification and consideration of use of federal, state, and local financing and
subsidy programs.
C. Housing Programs
1. Include a program which sets forth a schedule of actions during the planning period,
each with a timeline for implementation, which may recognize that certain programs are
ongoing, such that there will be beneficial impacts of the programs within the planning
period, that the local government is undertaking or intends to undertake to implement
the policies and achieve the goals and objectives of the Housing Element... (Gov. Code,
§ 65583, subd. (c).)
To have a beneficial impact in the planning period and achieve the goals and objectives
of the housing element, programs must have discrete timing (e.g., at least annually or
by 2025) and specific commitment to housing outcomes and refrain from language such
as “consider” while also having discrete timing (e.g., at least annually or by
January 2024).
Examples of programs to be revised with discrete timing include Program 1.5 (Stanford
University Lands), Program 3.1 (Monitor constraints on housing), 2.1 (Affordable
Housing developments), Program 3.5 (Pedestrian and Transit Oriented Development),
City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element Page 10
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Program 3.8 (Objective Design Standards for SOFA), Program 6.1 (Housing for Special
Needs) Program 6.2 (Multi-Family Housing & Large Units).
Examples of programs to revised with specific commitments Program 1.4 (City Owned
Land Lots), Program 1.6 (Lot Consolidation), Program 3.1 (Fee Waivers and
Adjustments), Program 3.3 (Affordable housing development incentives), Program 3.4
(Housing Incentives Program (HIP)), Program 3.6 (Accessory Dwelling Unit Facilitation),
Program 3.7 (Expedited Project Review), 4.2 (Housing and Neighborhood
Preservation), Program 4.3 (Home Rehabilitation), Program 5.1 (At Risk Preservation,
Program 5.2 (Funding Partnerships), Program 6.3 (Mixed use Development) Program
6.5 (Alternative Housing) Program 6.6 (Affirmatively Furthering Fair Housing).
2. Identify actions that will be taken to make sites available during the planning period with
appropriate zoning and development standards and with services and facilities to
accommodate that portion of the city’s or county’s share of the regional housing need
for each income level that could not be accommodated on sites identified in the
inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and
to comply with the requirements of Government Code section 65584.09. Sites shall be
identified as needed to facilitate and encourage the development of a variety of types of
housing for all income levels, including multifamily rental housing, factory-built housing,
mobilehomes, housing for agricultural employees, supportive housing, single-room
occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583,
subd. (c)(1).)
As noted in Finding B3, the element does not include a complete site analysis,
therefore, the adequacy of sites and zoning were not established. Based on the results
of a complete sites inventory and analysis, the City may need to add or revise programs
to address a shortfall of sites or zoning available to encourage a variety of housing
types.
In addition, Program 6.5 (Alternative Housing) should specifically commit to allowing
emergency shelters without discretionary action, with appropriate development
standards in compliance with statutory requirements.
3. The Housing Element shall contain programs which assist in the development of
adequate housing to meet the needs of extremely low-, very low-, low- and moderate-
income households. (Gov. Code, § 65583, subd. (c)(2).)
Several actions commit to “partner”, “explore”, “encourage” housing. While these efforts
are important and meaningful, these efforts should be complimented by additional steps
that lead to housing outcomes. For example, Program 6.2 (Multi-Family Housing and
Large Units) should set forth clear commitments in implementing incentives for larger
units. This is only one example of several programs that will need to include clear and
specific commitment to identify affordable development opportunities, grant incentives,
assist with funding, and process entitlements on an annual basis. Programs should also
commit to a numerical target and evaluate and adjust efforts as necessary every other
year.
City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element Page 11
March 23, 2023
4. Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with
disabilities. The program shall remove constraints to, and provide reasonable
accommodations for housing designed for, intended for occupancy by, or with
supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding B4 and B5, the element requires a complete analysis of potential
governmental and nongovernmental constraints. Depending upon the results of that
analysis, the City may need to revise or add programs and address and remove or
mitigate any identified constraints. In addition, the element should be revised as follows:
• Program 3.4 (Housing Incentives Program): The Program should specifically commit
to reduce parking requirements and establish creative alternatives (beyond aligning
parking requirements with required State Density Bonus Law requirements).
• Program 6.5 (Alternative Housing): The Program should clearly commit to allow
group homes for seven or more persons in all residential zones. For your
information, zoning should simply implement a barrier-free definition of family
instead of subjecting, potentially persons with disabilities, to special regulations such
as the number of persons, population types and licenses. Please refer to HCD’s
Group Home Technical Advisory
https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/group-
home-technical-advisory-2022.pdf.
5. Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race, religion,
sex, marital status, ancestry, national origin, color, familial status, or disability, and other
characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding B1, the element must include a complete analysis of AFFH. The
element must be revised to add goals and actions based on the outcomes of a complete
analysis. The element must add, and revise programs based on a complete analysis
and listing and prioritization of contributing factors to fair housing issues.
Goals, Priorities, Metrics, and Milestones: Goals and actions must significantly seek to
overcome contributing factors to fair housing issues and must include quantifiable
metrics and milestones for evaluating progress on programs, actions, and fair housing
results. Goals and actions must specifically respond to the analysis and to the identified
and prioritized contributing factors to fair housing issues and must be significant and
meaningful enough to overcome identified patterns and trends. Actions must have
specific commitment, milestones, geographic targeting and metrics or numeric
objectives and, as appropriate, must address housing mobility enhancement, new
housing choices and affordability in high opportunity areas, place-based strategies for
community preservation and revitalization and displacement protection.
D. Quantified Objectives
City of Palo Alto’s 6th Cycle (2023-2031) Draft Housing Element Page 12
March 23, 2023
1. Establish the number of housing units, by income level, that can be constructed,
rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd.
(b)(1 & 2).)
The element must include quantified objectives for new construction, rehabilitation, and
conservation by income group. In addition, conservation objectives should not be limited to at-
risk preservation and can include broader efforts to conserve the existing housing stock such
as code enforcement programs, rental assistance or housing choice vouchers, weatherization,
tenant protections, and mobile home park preservation ordinances.
Draft Housing Element – December 2022
Summary of Public Comments and City Responses Submitted to HCD
Comment Theme Responses
1. Concerns relating to
the Site Inventory and the
future availability of
identified properties.
RHNA is a State mandate and the City must comply with State law
by planning for future residential development through the
identification of sites that can accommodate the assigned RHNA.
Development of the City’s Site Inventory is detailed more in
Chapter 4, and occurred through the identification of site
selection strategies, which were developed through input
provided by the Housing Element Working Group. Housing
Element Working Group members completed group
walking/drive by tours of the sites. Once complete, the Site
Inventory was fully vetted by the Housing Element Working
Group, the Planning and Transportation Commission and the City
Council. The City undertook a number of additional engagement
efforts related to the Site Inventory. A map of all identified sites
has been available on the City’s Housing Element website since
April 2022. The City also reached out to all property owners via a
direct mail (USPS) marketing campaign. The City honored all
requests from property owners who asked that their property(s)
be removed from the Site Inventory. Moreover, the City
communicated with various land owners whose sites were
contemplated for inclusion or placed in the site inventory,
including one prominent land owner where the City is proposing
changes to the GM/ROLM zoning district.
2. Concerns relating to
environmental and
infrastructure constraints
such as traffic,
intersection safety, and
bicycle and pedestrian
safety.
Development of the sites inventory for RHNA took into
consideration potential environmental constraints. Future
development projects may be required to assess environmental
impacts in CEQA documentation prepared for the specific project.
3. Programs should be
objective and
quantifiable.
Changes have been made to a number of programs to address this
comment. Most notably, Program 6.6 (Fair Housing) has been
significantly expanded to include more action items related to fair
housing constraints, quantified objectives, and implementation
timeframes for each.
Comment Theme Responses
4. City’s existing zoning
and development
standards create
constraints to housing
and do not allow for
financially feasible
projects.
Changes to the City’s Zoning Ordinance are planned to support
development of housing and to comply with recently approved
State legislation. The following are a selection of programs that
aim to reduce constraints and improve project feasibility:
•Program 1.5: Initiate discussions with Stanford University
regarding zoning modifications to support future
residential development within the Stanford Research
Park.
•Program 1.6: Develop lot consolidation provisions for
affordable housing projects.
•Program 3.3: Amend the residential floor area ratios and
height requirements for projects taking advantage of the
affordable housing overlay regulations.
•Program 3.6: Amend Zoning Ordinance to maintain
compliance with State legislation pertaining to ADUs.
•Program 3.7: Limit multi-family housing projects to two
hearings before the City’s ARB.
•Program 3.8: Create objective design standards for the
SOFA area to streamline future development.
•Program 3.9: Compliance with State legislation.
•Program 6.2: Explore zoning changes to support larger
units.
•Program 6.5: Encourage innovative housing structures
through zoning regulations and address State legislation
pertaining to low barrier navigation centers, emergency
shelters, supportive and transitional housing, and
employee housing.
5. Application processing
timeframes can create a
constraint to residential
development if they are
lengthy, as is the case in
Palo Alto. The City should
work to reduce
application processing
timeframes.
With the implementation of Program 3.7 the City will explore
opportunities to improve the efficiency of the development
review process, including expedited project review. This program
will also limit multi-family projects to two hearings before the
City’s ARB. Furthermore, with the recently adopted objective
design standards in 2022, the City created a streamlined review
process for compliant projects that only requires one study
session with the City’s ARB.
6. Public participation
should be fair and
equitable to all.
The City has provided a detailed summary of the public
engagement program implemented for this project in Chapter 1.
This program included a number of study sessions with PTC
Comment Theme Responses
and/or City Council, a dedicated website, and online survey, and
multiple community workshops that were advertised in multiple
languages. In addition, the City formed a Housing Element
Working Group, comprised of 15 members and 2 alternates.
Group members included homeowners and renters, Stanford
employees, members of Palo Alto’s young adult and minority
communities, an affordable housing developer (staff), and a
member of the unhoused community. All meetings were open to
the public (virtually) and the group took and responded to public
comments at all meetings.
7. Strengthen the efforts
to enhance affordability
by providing fee waivers,
securing new funding
sources, expediting
project review, and
developing standards
supportive of higher
densities.
All these efforts are included in the Draft Housing Element.
Specific programs include: Program 2.2: Continuation and
expansion of the program to promote affordability. Program 3.1:
The City will waive staff costs associated with affordable housing
planning applications. Program 3.7: The City will explore
opportunities to improve the efficiency of the development
review process, including expedited project review. Program 3.8;
The City will create objective design standards for the SOFA area.
Program 5.1: Preservation of at-risk housing.
8. Expand support for
programs that combat
homelessness
Program 6.4 addresses the City’s efforts to combat homelessness.
Expansion of the City’s Safe Parking Program is included.
9. Accessory Dwelling
Units assumptions are too
aggressive and do not
appropriately address
affordability of these
types of units in the City.
ADU assumptions are detailed in Chapter 3 of the Housing
Element and are based on actual ADU permitting trends for the
2019-2021 time period. That said, current trends from 2022
demonstrate an increase in ADU permitting in the City. Through
these natural increases, and the implementation of Program 3.6,
the City is confident that the ADU production numbers presented
for the next 8 years can be realized. Affordability assumptions
were based on the HCD approved technical guidance prepared by
ABAG, as discussed in Chapter 3. The City does not have control
over the rental market and the affordability of non-deed
restricted units although the action items outlined in Program 3.6
support the program as a whole.
10. Tenant protection
policies should be
strengthened. The City
Tenant protection strategies have been further expanded across
Program 6.6. Specifically: Program 6.6.I: Includes implementation
for additional anti-displacement measures including relocation
Comment Theme Responses
amended the Tenant
Relocation Assistance
requirements in January
2022.
assistance, eviction reduction, security deposit limits and right to
counsel. Program 6.6.J: Includes consideration of a Fair Chance
Ordinance.
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Attachment F
Meeting Date: May 8, 2023
City Response Matrix to HCD Comment Letter
This attachment reflects the City responses to the HCD comments with reference to the
respective pages in the Strikeout/Underlined Draft 2023-31 Housing Element version.
This attachment is being finalized and will be provided on May 4 with next week’s Council
report packet.