HomeMy WebLinkAboutStaff Report 2310-21159.Public Hearing: Adoption of Resolution Amending the Land Use Element of the Palo Alto
Comprehensive Plan and an Ordinance Implementing Program 1.1A and 1.1B of the
Housing Element, Including: 1) New Chapter 18.14: Housing Incentives, and 2)
Modifications to Base Zoning Districts Throughout Title 18. CEQA Status: An Addendum to
the City’s Comprehensive Plan Environmental Impact Report was Prepared for the Subject
Comp Plan and Municipal Code Amendments. Public Comments Presentation
City Council
Staff Report
From: City Manager
Report Type: ACTION ITEMS
Lead Department: Planning and Development Services
Meeting Date: November 13, 2023
Report #:2310-2115
TITLE
Public Hearing: Adoption of Resolution Amending the Land Use Element of the Palo Alto
Comprehensive Plan and an Ordinance Implementing Program 1.1A and 1.1B of the Housing
Element, Including: 1) New Chapter 18.14: Housing Incentives, and 2) Modifications to Base
Zoning Districts Throughout Title 18. CEQA Status: An Addendum to the City’s Comprehensive
Plan Environmental Impact Report was Prepared for the Subject Comp Plan and Municipal Code
Amendments.
RECOMMENDATION
Staff recommends that Council:
1. Adopt a resolution amending the Palo Alto Comprehensive Plan Land Use Element
(Attachment A); and,
2. Adopt an ordinance amending Title 18 (Zoning) of the Palo Alto Municipal Code (PAMC)
(Attachment B) to implement Program 1.1A and 1.1B of the Housing Element regarding
the Adequate Sites Inventory.
EXECUTIVE SUMMARY
Program 1.1 in the recently adopted Housing Element necessitates certain amendments to the
Land Use Element of the Comprehensive Plan and Zoning Ordinance. The proposed zoning
amendments include a new chapter in Title 18 to consolidate existing and proposed housing
incentive programs. Consistent with Program 1.1, the proposed zoning amendments rezone
certain Housing Element opportunity sites to modify densities and other development
standards that support multifamily housing at capacities identified in the Housing Element.
Program 1.1A also includes higher-density site-specific zoning regulations for Stanford-owned
properties along El Camino Real near Page Mill Road, and at Pasteur Drive and Sand Hill Road.
According to Housing Element Law, the rezonings in Program 1.1A to meet the RHNA must be
completed within one year of the required Housing Element adoption date (i.e., by January 31,
2024). According to the adopted Housing Element, the City is also committed to completing
Program 1.1B (GM and ROLM rezonings) by January 2024.
Attachment B represents amendments to Title 18 in the form of a new chapter, 18.14: Housing
Incentives and revisions to base district regulations throughout Title 18. Changes include
rezonings to allow multifamily housing as a permitted use, increases in residential density/FAR,
and modifications to other development standards, as specified in the Housing Element to
meet the RHNA and sites inventory estimates. These proposed amendments necessitate
changes to base district regulations in existing zoning chapters (18.12, 18.13, 18.16, 18.18,
18.20, and 18.28); these changes are shown in underline/strikeout.
Additionally, the report and ordinance suggest expanding the policy recommendation for
Program 1.1A to extend proposed rezoning on El Camino Real to create an expanded Focus
Area on El Camino Real between Page Mill Road and Matadero Avenue. These proposed
changes would be formalized during the next revision to the Housing Element but are being
advanced as part of these zoning amendments given the January 31, 2024 deadline.
For expediency, to meet the state-mandated timeline for adoption, the proposed housing Focus
Area on El Camino Real does not include additional sites either further south or on the east side
of El Camino Real as was commented upon at the October 4, 2023 Council study session
meeting. Council may direct further study in this regard if there is interest to do so.
BACKGROUND
Housing Element Adoption & HCD Review
On May 8, 2023, the City Council adopted the 2023-2031 Housing Element. The Element aims to
implement State Housing Element law, including meeting the RHNA and fulfilling AFFH
objectives. More information about the Housing Element can be found at the project website:
www.paloaltohousingelement.com.
The City sent the adopted Housing Element to HCD for review on June 7, 2023. On August 3,
2023, the City received a comment letter from HCD requesting modifications to the Housing
Element prior to HCD certification. In particular, members of the public and HCD have called for
additional analysis of the Sites Inventory to ensure and demonstrate that sites are viable for
redevelopment during the 8-year planning cycle, including that existing uses are likely to cease.
To address these comments, City staff and the Housing Element consultant are exploring
changes to the Sites Inventory, including adding sites to the inventory and increasing densities.
Given the deadline for this rezoning effort, City staff are daylighting these proposed changes as
part of the Program 1.1 rezoning task. The next version of the Housing Element will formalize
updates to the Sites Inventory, Program 1.1, and additional analysis to demonstrate viability of
these sites. The PTC can expect to review the revised Element before the end of the year.
Housing Element Program 1.1
Program 1.1 represents the City’s rezoning program to meet the "Adequate Sites Inventory”
required under State law and is excerpted below. This program necessitates amendments to
the Zoning Ordinance to modify density and other development standards.
These rezonings must accommodate multifamily housing at the capacity levels prescribed in the
Housing Element. In summary, Program 1.1 requires the following zoning amendments on
Housing Element opportunity sites:
•Rezoning opportunity sites in the R-1, ROLM, RP, GM, and PF districts to allow multiple-
family housing as a permitted use;
•Up-zoning opportunity sites to increase residential densities and/or FARs, including on
Stanford Lands;
•Modifications to other development standards on opportunity sites to ensure that
development is feasible at current and planned densities (e.g., landscape coverage);
and,
•Statutory requirements that residential uses occupy at least 50 percent of the total floor
area of a mixed-use project on an opportunity site
Program 1.1 calls for specific zoning regulations for three Stanford University-owned
properties. On these sites, the Housing Element inventory targeted specific unit counts and
called for higher FAR and taller height limits in order to fulfill those targets (see excerpt from
the Housing Element Program 1.1A in Figure 1). As noted above, the geographic reach of
Program 1.1 is proposed for expansion on El Camino Real to create a targeted Focus Area for
rezoning.
Palo Alto Housing Element (June 2023), Excerpt from Program 1.1A, p. 5-5
Planning & Transportation Commission Review
The PTC held a study session on September 13, 20231,2 to review the draft Comprehensive Plan
and Zoning Ordinance amendments. Based on the PTC’s feedback, City staff and consultants
revised the draft Zoning Ordinance. On October 11, 20233 the PTC reviewed the revised
ordinance and made a recommendation to the City Council to approve the Comprehensive Plan
and Zoning Ordinance amendments.
The PTC generally supported the staff comprehensive plan and zoning ordinance
recommendations making a few discrete motions that resulted in the following additional
recommendations:
•For the El Camino Real Housing Focus Area, require a 20-foot setback adjacent to the R-
1 zoning district and extend the height transition zone to 35’ height within 100 feet of
the R-1 property line and 45’ height between 100’ and 150’, (5-1, Hechtman).
o NOTE: The attached ordinance has been updated to reflect the PTC
recommendation, however, a representative of the Creekside Inn site noted
concerns about doubling the existing ten foot setback and the modification to
the transitional height. Staff continues to support a transitional height that
would allow buildings to reach 35 feet in height within 75 feet of an R-1 zoned
property and 45 feet between 75 and 150 feet from the R-1 zoned property,
while also maintaining a ten foot setback. If the Council concurs with staff’s
perspective, a modification to the attached ordinance would be required.
•Modify a state-mandated requirement in new Chapter 18.14 (Housing Incentives) to
increase the minimum residential floor area requirement from 50% to 65% for mixed
use projects on opportunity sites identified as meeting lower income households, (4-3,
Hechtman, Lu, Templeton).
o NOTE: The attached ordinance has been updated to reflect the PTC
recommendation with a slight adjustment changing 65% to two-thirds (66%) to
be consistent with the threshold used for housing accountability projects; the
PTC recommendation and its slight staff adjustment do not conflict with state
law. Notwithstanding this change to the ordinance. The PTC argument in favor of
the change is that these are sites where we are anticipating housing and by
increasing the threshold that focus is reinforced and, if developed, may have
reduce the jobs/housing imbalance. An argument against the change is that
1 PTC staff report, dated September 13, 2023: https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-
minutes-reports/agendas-minutes/planning-and-transportation-commission/2023/ptc-09.13-Study-Session.pdf.
2 PTC summary meeting minutes, dated September 13, 2023:
https://www.cityofpaloalto.org/files/assets/public/v/2/agendas-minutes-reports/agendas-minutes/planning-and-
transportation-commission/2023/ptc-9.13.2023-summary-2.pdf.
3 PTC staff report, dated October 11, 2023: https://www.cityofpaloalto.org/files/assets/public/v/1/agendas-
minutes-reports/agendas-minutes/planning-and-transportation-commission/2023/ptc-10.11-title-18-
amendments.pdf.
commercial floor area can be used to fund housing projects and the higher
threshold may discourage a property owner from redeveloping an existing
commercial site toward housing. Staff does not have a strong opinion about this
modification but generally supports retention of the state-established 50%
residential floor area threshold. To restore the 50% threshold, a change to the
attached ordinance would be required.
•The PTC requested staff to research minimum density standards to discourage
townhome development within the GM and ROLM zoning districts in favor of higher
density apartment buildings (4-3, Summa, Lu, Templeton).
o NOTE: Staff previously increased the minimum density for these sites from 20 to
25. Based on the PTC’s feedback, staff has adjusted the minimum density
standard to 40, to address this concern.
•The PTC expressed concern about the potential loss of property tax revenues for
Stanford-owned properties if developed for affiliate housing and lost revenues are not
accounted through some other funding mechanism to support impacts on the City,
school district and other services (5-1, Hechtman).
o NOTE: This request requires more analysis than can be accommodated within
the timeline to complete these amendments, however, staff has modified the
attached ordinance to prohibit Stanford affiliate housing on the housing
opportunity sites adjacent to El Camino Real. The Pasteur site was previously
identified in the adopted Housing Element as designated for affiliate housing.
Accordingly, there is no restriction in the attached ordinance about affiliate
housing for that location.
There were other non-substantive refinements to the ordinance requested by the PTC that
were incorporated into the attached ordinance.
City Council Review
On October 4, 2023, the City Council received a preview of the draft ordinance, in particular to
review the idea of a Focus Area on El Camino Real between Page Mill Road and Matadero
Avenue, where higher densities and heights could be achieved.
The Council had little time to consider to the staff report, which was released shortly before the
meeting but there were some initial comments expressed by more than one councilmember
including:
•Support for creek protection at the Creekside Inn site;
•Interest in careful site planning at adjacencies to the R-1 zoning district;
•Concern about a potential lack of property tax revenue at Stanford affiliate housing;
•Desire for transportation demand management measures and bicycle parking
requirements to balance the proposed reduction in minimum parking requirements; and
•Interest in extending the development standards proposed in the El Camino Real Focus
Area to the opposite side of the street.
Regarding the last two comments, staff appreciates there may be an opportunity to extend the
El Camino Real Housing Focus Area south and potentially to the east side of the street. Staff has
even been approached by interested property owners since the Council’s study session.
However, given the state-mandated timeline to complete the subject zoning amendments by
January 31, 2024, staff recommends completing the attached ordinance and, if there is Council
interest, provide direction to staff to revisit further expansions of the Focus Area after
certification of the Housing Element. Moreover, staff anticipates bringing the North Ventura
Coordinated Area Plan to Council for final adoption in spring next year. Changes to direction
already received would further delay that work, cost more money to pay for plan revisions and
may require the City to repay the grant money received for NVCAP project.
The interest in transportation demand management measures is also a distinct effort to codify
specific standards that balance the reduction in parking requirements for these Focus Area
sites. However, staff has included in the attached ordinance, subsequent to the PTC’s review, a
requirement for a transportation demand management plan if Focus Area sites are developed
with less parking than would typically be required by the municipal code (outside of the Focus
Area). As an initial step, until a more specific program can be presented to the PTC and Council,
staff has included a requirement for free transit passes for residents, when parking is reduced
by 50% or more (compared to otherwise applicable citywide parking requirements) and a
provision for 20% of the required bicycle parking spaces to have outlets appropriately spaced
for e-bike charging.
The City Council will have an opportunity to direct staff to focus on these two initiatives when it
has its priority setting discussion and reviews Council objectives for the next fiscal year.
ANALYSIS
Comprehensive Plan Amendments
The recently adopted Housing Element of the Palo Alto Comprehensive Plan identifies planned
changes to uses and densities which must be updated in the Land Use Element of the
Comprehensive Plan to ensure consistency within the Comprehensive Plan and between the
Comprehensive Plan and proposed zoning. Attachment A annotates proposed amendments to
the Land Use Element of the Comprehensive Plan to update FAR ranges and allow multi-family
uses, consistent with the Housing Element and proposed changes to the Zoning Ordinance.
Zoning Ordinance Amendments
The rezonings in Program 1.1A to meet the RHNA must be completed within one year of the
required Housing Element adoption date (i.e., by January 31, 2024). According to the adopted
Housing Element, the City is also committed to completing Program 1.1B (GM and ROLM
rezonings) by January 31, 2024. Attachment B aims to codify Program 1.1A and 1.1B in the
Zoning Ordinance. It also consolidates a range of housing programs that will support
implementation of the Housing Element into a single chapter. Basic contents of the ordinance
are described below.
Section 18.14.020: Housing Opportunity Sites
This section modifies base district development standards on Housing Element opportunity
sites. Regulations for these sites are those specified in the base district regulations, except as
modified by this proposed chapter. In zones that regulate residential density, primarily the RM
zones, these modifications increase maximum residential density limits consistent with
Appendix D of the Housing Element (Attachment C). All zoning districts regulate FAR, so
amendments also modify FAR limits.
This section also modifies other development standards that were identified as constraints to
development in Chapter 4 of the Housing Element (see excerpt in Attachment D). For most
districts, this includes modifications to the landscape coverage standard which generally
requires landscape planting on the ground-floor. As stated in the adopted Housing Element,
despite the well-meaning value of enabling trees, shrubs and groundcover, this often
represents a constraint to development by shrinking the building footprint. Therefore,
proposed modifications to this standard allow it to be met above the ground-floor, permitting a
larger building footprint, while still enabling planted areas for residents.
In the employment districts (i.e., ROLM, GM, RP), the Housing Element specifies much higher
densities compared to what the existing base district regulations allow. As a result, the Housing
Element identified additional standards that would represent constraints to development (see
Attachment D excerpt) at higher densities. The zoning amendments therefore modify standards
for lot coverage, parking, and building height, in addition to increasing FAR and reducing
landscape coverage requirements.
Finally, this subsection includes site specific zoning regulations including Program 1.1A
standards for Stanford-owned properties as well as a proposed idea for an El Camino Real Focus
Area. These specific locations are discussed further below.
Section 18.14.030: Housing Incentive Program (HIP)
This section is a placeholder location to consolidate regulations pursuant to the existing HIP and
amendments proposed as part of Program 3.4 of the Housing Element. This ordinance does not
include changes to the HIP at this time.
Section 18.14.040: Affordable Housing Incentive Program (AHIP)
This section is a placeholder location to relocate existing 18.32 AHIP regulations into this
consolidated chapter of housing incentives. This ordinance does not include amendments to
this program at this time.
Base Districts
The ordinance amends several of the base zoning districts for two main purposes:
1. To allow multifamily as a permitted use on Housing Element opportunity sites, where
otherwise not allowed; and
2. To provide a cross-reference to modified development standards for opportunity sites in
the new Section 18.14.040.
Proposed Development Standards for Opportunity Sites and Focus Areas
Table 1 and Table 2 summarizes proposed changes to the standards for density, intensity, and
landscape coverage in the residential and commercial mixed-use districts, and mixed use
employment districts, respectively. In terms of FAR, as a baseline, the draft ordinance allows at
least 1.25:1 FAR, which generally accommodates three stories of development with fairly low
lot coverages of 45%. Notably, 1.25:1 FAR is currently the minimum standard required under
State law for small projects with 8-10 units and is codified accordingly in the City’s RM districts.
From this baseline, FARs range up to 2:1 in Downtown (CD-C) and 2.5:1 in the GM/ROLM areas
shown in the West Bayshore area (see Figure 1 below). Maximum density standards, if they are
proposed for change at all, are as specified in the Housing Element.
Landscape coverage is revised for most zoning district, as stated in Chapter 4 of the Housing
Element (Attachment D). The draft ordinance generally does not propose to change the
landscape coverage requirement (e.g., 20% or 30%). Instead, the draft ordinance allows more
flexibility regarding where the requirement can be met—not just at the ground-level, but on
above-grade on courtyard or rooftop (if permitted by the district). In the GM and ROLM zones
and Focus Area, the draft ordinance proposes two changes that would have opposite effects:
first, to add a landscape coverage requirement for the GM, where one currently does not exist,
and second to modestly reduce the requirement in the ROLM zone, from 30% to 20%.
Table 1: Existing vs. Proposed Development Standards for Opportunity Sites, by Residential
and Mixed-Use Zoning Districts
Maximum FAR
Maximum
Site/Landscape
Coverage
Maximum Density
(du/ac)
Zoning Existing Proposed Existing Proposed Existing Proposed
CC(2)
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.6 (other)
Total: 2.0
Residential:
1.5
Total: 2.0 20%
above the
ground-
floor None None
CC
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.15 (other)
Total: 1.0
Residential:
1.25
Total: 1.25 30%
above the
ground-
floor None None
CS (El Camino
Real) None None
CS (Other)
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.6 (other)
Total: 1.0
Residential:
1.25
Total: 1.25
30%
above the
ground-
floor 30 30-40
CN (El Camino
Real)
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.5 (other)
Total: 1.0-1.25 None None
CN (Other)
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.5 (other)
Total: 0.9-1.25
Residential:
1.25
Total: 1.25
35%
30%
above the
ground-
floor 15-20 30-40
CD-C
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
1.0 (other)
Total: 2.0 (3.0 w/
TDR)
Residential:
2.0
Total: 2.0
(3.0 w/ TDR) 20%
above the
ground-
floor None None
CD-N
Residential
1.25 (8-10 units)
1.0 (3-7 units) 1.5 35%
above the
ground-
floor 50 50
0.5 (other)
Total: 0.9-1.25 (2.0
w/TDR)
RM-40
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
1.0 (other) 1.5 20%
above the
ground-
floor 40 40-50
RM-30
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.6 (other) 1.25 30%
above the
ground-
floor 30 30-50
RM-20
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.5 (other) 1.25 35%No change 20 20-50
RP
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.5 (other)
Total: 0.5-1.25 1.25 35%No change 20-30 None
PF (California
Ave.)
See CC(2)
standards
above
See CC(2)
standards
above
See CC(2)
standards
above
PF
(Downtown)
None
See CD(C)
standards
above
None
See CD(C)
standards
above
None
See CD(C)
standards
above
Figure 1: GM/ROLM Housing Element Focus Area
The higher densities approved for the GM and ROLM employment districts necessitate other
modifications to development standards. These are specified in the Housing Element excerpt in
Attachment D and proposed to be codified as shown in Table 2. This results in taller height
limits, increased lot coverage and landscape coverage requirements, and reduced parking
requirements, in addition to changes to FAR limits. Table 2 distinguishes between three tiers of
standards for these zones: (1) the highest proposed densities within the GM/ROLM Focus Area,
(2) moderate proposed densities for other GM/ROLM Housing Element opportunity sites
outside the Focus Area; and (3) existing densities which will remain for other GM/ROLM sites
that do not fall under either of the first two categories.
Table 2: Existing vs. Proposed Development Standards for Opportunity Sites and Focus Areas
(GM and ROLM Districts)
Zoning Maximum FAR
Maximum
Landscape
Coverage
Maximum
Lot
Coverage
Min.
Density
(du/ac)
Maximum
Density
(du/ac)
Max.
Height Min. Parking
Ratios
GM
Residential: N/A
Total: 0.5 None None None None 50 N/AE
X
I
S
T
I
N
G
ROLM
Residential:
1.25 (8-10 units)
1.0 (3-7 units)
0.6 (other)
Total: 1.0-1.25 30%40%16 30 35
1 per
studio/1-
bed; 2.0 per
2+ bed
GM
(Focus
Area)2.5
20% above
the ground-
floor 70%40
None; 90
anticipated 60
1 per
studio/1-
bed; 1.5
per 2+ bed
GM
(Other
Opp
Site)1.5
30% above
the ground-
floor 70%25
None; See
HE
Appendix D
for
anticipated
densities
No
change No change
ROLM
(Focus
Area)2.5
20% above
the ground-
floor 70%40
None; 90
anticipated 60
1 per
studio/1-
bed; 1.5
per 2+ bed
P
R
O
P
O
S
E
D
ROLM
(Other
Opp
Site)1.5
above the
ground-
floor 70%25
None; 50
anticipated 45 No change
Notably, raising the “base” density standards for these sites will have implications for the use of
State Density Bonus Law. It would effectively raise the “floor” upon which density bonuses are
calculated. This would generate more below- market rate housing units within a State Density
Bonus Law-compliant project, but would also allow additional density bonus, which could result
in taller and larger buildings than are currently permitted by the Zoning Ordinance.
El Camino Real & Page Mill Focus Area
The draft ordinance proposes higher density standards for a specific segment of El Camino Real
to create a housing Focus Area between Page Mill Road and Matadero Avenue, as shown in
Figure 2. Program 1.1A already identified three sites on this segment higher density
development standards; this proposal extends the geographic reach. The North Ventura
Coordination Area Plan process is devising standards for the opposite side of El Camino Real, so
no changes to the east side of the corridor are proposed as part of this process.
Figure 2: El Camino Real Focus Area
There are several reasons for this expanded proposal:
1.Neighborhood Context & Services: This location has excellent access to services,
shopping, California Avenue, jobs, Stanford, and transit. It is also primary
surrounding by commercial uses, with only one interface with a lower density
residential neighborhood with 1- and 2-story homes at Matadero Avenue. The
proposed development standards aim to mitigate this adjacency through required
height transitions and daylight planes. At Palo Alto Square, there already exists taller
buildings than what are proposed here, with two ~140-foot tall office buildings
already located near the Page Mill Road intersection.
2.Community & Decision-Maker Input. Second, and in part for the aforementioned
reasons, the Housing Element Working Group, City Council Housing Ad Hoc
Committee, and the Planning & Transportation Commission have previously
discussed creating a cohesive plan for this area as part of the Housing Element.
3.Motivated Property Owners: Over the past several months, four separate property
owners/lessees along this corridor have expressed interest in residential or mixed-
use development or submitted preliminary or formal planning applications. In the
case of the applications, project proposals have included density bonuses under
State Density Bonus law that far exceed base district regulations due to requests for
waivers and concessions (see images below.)
Proposal for 3150 El Camino Real: 380 units, 84 feet, 4.1 FAR
Proposal for 3400 El Camino Real: 185 units, 75 feet, 1.9 FAR
The owner of Palo Alto Square, the largest site at the corner of Page Mill Rd., has expressed
interest in adding housing to some of the existing parking pads but has not filed any
applications. Because Palo Alto Square is subject to a Planned Community zone ordinance, an
amendment to that ordinance would be required to allow multifamily housing at these
densities. This would also provide the City with an opportunity to weigh on site planning,
access, drive aisles, etc. Although conceptually, this site is an integral part of the Focus Area
concept, it is not included in the City’s Sites Inventory at this time. Note that the Parmani Hotel
is included in the proposed rezoning but has not expressed interest in redevelopment into
housing.
Draft Standards
The draft ordinance proposes a series of standards that would modify base district regulations
on the Stanford sites and the El Camino Real Focus Area. Notably, these regulations are
optional to the base district regulations and provided as an alternative to State Density Bonus
Law. In other words, developers could choose whether to propose a Density Bonus project
relying on base district regulations or to use these higher standards in lieu of State law. These
standards are shown in Table 3.
To balance the reduction in parking requirements at these sites, the City can create objective
transportation demand management measures. For example, these could include:
•A requirement to provide free transit passes for residents at these sites
•A minimum % requirement for large at-grade bicycle parking spaces to accommodate
cargo bikes, trailers, and heavier e-bikes
•A minimum % requirement for bicycle parking spaces that have outlets for e-bike
charging
As noted above, the attached ordinance contains some of these provisions, with the
expectation that a future ordinance could adopt a more fully developed program.
Table 3 Site-Specific Development Standards for El Camino Real Focus Area
Location El Camino Real Focus Area (Figure 2)
Minimum Setbacks See base district regulations
For sites with a property line abutting a low density
residential district (RE, R2, RMD) or R1 single family
residential district: 20 feet
Maximum FAR 4.0 (Total)
Maximum Site/Landscape Coverage Allowed above the ground-floor
Maximum Lot Coverage 70%
Maximum Density (du/ac) None
Maximum Height 85
Daylight Plane See base district regulations for standards for
daylight planes
Height Transitions Within 100 ft of a low density residential district
(RE, R2, RMD) or R1 single family residential district
property line: 35 ft.
Between 100 and 150 ft a low density residential
district (RE, R2, RMD) or R1 single family residential
district property line: 45 ft.
Upper Story Step Back El Camino Real frontage: maximum height of 55
feet within 20 feet of the El Camino Real property
line
Open Space 100 sq. ft/unit (any combination of common
and/or private)
Minimum Residential Parking 1 space/unit
(Per AB2097: 0 space/unit within ½ mile of
Caltrain)
Other Development Standards See base district regulations
Design Criteria/Standards Architectural Review and compliance with either
Objective Design Standards pursuant to Chapter
18.24 or Context-Based Design Criteria pursuant to
base district regulations.
Other Proposed Regulations and Potential Impacts Related to the Focus Area
Architectural Review. Projects in the Focus Area would be required to go through Architectural
Review (2 to 3 hearings with the Architectural Review Board) and would need to meet either
the Objective Design Standards or Context-Based Design Criteria.
20% Inclusionary Requirement. The City typically requires that projects set-aside 15% of units
for below-market rate housing at moderate income levels. Rental projects are permitted to pay
a fee in lieu of this requirement. However, to take advantage of these standards in the Focus
Area, developers would need to provide 20% below-market rate housing at up to 80% AMI and
would not have the opportunity to pay a fee in-lieu. (The Pasteur Dr. Site is an exception and
may pay the in-lieu fee payment, since it is intended for Stanford affiliates.) As a result of this
draft regulation, the Focus Area could achieve more below-market rate units within mixed
income developments. However, at least one developer has suggested that a 20% BMR
requirement at 80% of AMI is challenging.
Potential Development. Importantly, not all sites can achieve the standards identified in the
draft ordinance. In particular, the Creekside Inn site at 3400 El Camino Real is constrained by
the creek, required creek setbacks, hotel buildings to be retained, and by the height transition
requirements where the site abuts an R-1 zoning district. Similarly, the 3300 El Camino Real site
has an approved entitlement for an office project, at 0.4 FAR, and a no-build PG&E easement
that constrains a significant portion of the site. Notably, due to these constraints, the next
iteration of the Housing Element will reduce the Sites Inventory’s realistic capacity for this site
from 200 units to approximately 100 units.
Palo Alto Square has high-density office buildings and uses proposed to remain and therefore
any new residential floor area would be additive. The 3150 El Camino Real site is the least
constrained, since it anticipates complete redevelopment, and is therefore the most likely to
utilize the maximum standards achievable. To create consistency between these sites and
simplify implementation in the code for City staff and decision-makers, a consistent set of
standards is applied across the Focus Area.
The two projects that have submitted formal applications to the City propose standards in line
what is being proposed here; these applications total approximately 560 units. Taking a
proactive approach to rezoning allows the City to set standards that are in line with market
demands, but that establish the City’s priorities (e.g., stepbacks, height transitions, on-site
affordable housing, Architectural Review, etc.) rather than allow waivers and concessions under
State law to drive architectural design. If the City did not move forward with this Focus Area
concept, it would need to remove these sites from the Sites Inventory and find alternate sites
that could accommodate lower-income households.
Traffic Operations. In addition to an analysis of potential vehicle miles traveled (VMT) impacts
under CEQA (see discussion below), the City will also need to analyze operational traffic
impacts. This will include traditional level of service (LOS) analysis, which would describe any
necessary improvements such as signal timing or signal warrants.
Precedential effect. It should be noted that this proposed concept is likely not replicable in
many other parts of the city. As noted at the outset of this section, this particular segment of El
Camino Real is well suited for higher density development based on existing services, transit
access, height context, and lack of sensitive adjacent uses.
Pasteur Drive & Sand Hill Road Property
Separate from Stanford’s El Camino Real properties, Program 1.1A of the Housing Element also
calls for site-specific standards for Pasteur Drive at Sand Hill Road (see Figure 3). This property
is proposed to have similar standards as the El Camino Real Focus Area, but different
authorizing regulations givens the population served and context of the site.
As required by Senate Bill (SB) 330, a project at this site is required to replace the existing 150
units at Welch Road Apartments. Housing Element Program 1.1 envisions approximately 450
units for the site.
This site context is central to Stanford campus, primarily the medical school. There are no
abutting residential neighbors that are not affiliated with the university. The housing would
only be occupied by Stanford affiliates, including medical school residents, faculty, staff, and
postdoctoral fellows. The City Council and Planning & Transportation Commission have
expressed concerns about how this could prevent the project site from paying property taxes
that would fund school district and other city and county services. Notably, the existing Welch
Road apartments are already limited to Stanford affiliates. As previously noted, the adopted
Housing Element identifies this site for affiliate housing and, therefore, no restrictions are
proposed in the attached ordinance for this site. Other Stanford-owned housing opportunities
are required to be made available to the general public.
Figure 3: Pasteur Dr. & Sand Hill Rd. (Welch Rd. Apartments and Construction Yard)
At this property, a development project would be able to pay the affordable housing fee in-lieu
of providing on-site below-market rate housing. The City can leverage these funds to build
stand-alone affordable housing projects elsewhere in the city. Moreover, Stanford’s policy is to
rent to affiliates at rates that are discounted from the market to assist with affordability—
typically this represents a 20% reduction.
A project on the Pasteur Drive site would need to meet Objective Design Standards, with
modifications proposed in the draft ordinance, and therefore could be eligible for Streamlined
Review. Proposed development standards are shown in Table 4.
Table 4: Pasteur Drive & Welch Road Site-Specific Development Standards
Location Pasteur Dr. & 1100 Welch Rd. (Figure 3)
Minimum Front Setback 15 feet
Maximum FAR 3.5 (Total)
Maximum Site/Landscape
Coverage
Allowed above the ground-floor
Maximum Lot Coverage 60%
Maximum Density (du/ac) None
Maximum Height 85
Daylight Plane Sand Hill Rd. frontage only: initial height 60 feet
above grade at the Sand Hill Rd. setback line and a
45-degree angle
Height Transitions n/a
Upper Story Step Back None
Open Space 100 sq. ft/unit (any combination of common and/or
private)
Minimum Residential Parking 0.5 spaces/unit
Other Development Standards See base district regulations: 18.13.040
Design Criteria/Standards Compliance with Objective Design Standards
pursuant to Chapter 18.24
FISCAL/RESOURCE IMPACT
The recommendation in this report does not have any significant fiscal impacts that cannot be
absorbed by the City’s department budget allocations.
STAKEHOLDER ENGAGEMENT
Preparation of the Housing Element included a range of community outreach methods,
including surveys, Working Group meetings, community workshops, and public hearings.
Hundreds of community members have participated in the Housing Element update over the
course of the project. To announce the release of the Public Review draft, an email blast was
sent to over 400 recipients with information about the Public Review draft release.
Meetings included a November 16, 2022 Community Meeting, a November 28, 2022 joint City
Council/PTC meeting, a March 8, 2023 PTC hearing, and the May 8, 2023 joint City Council/PTC
hearing. The City’s Housing Element website, www.paloaltohousingelement.com, serves as the
library for draft and final documents, past and upcoming meetings.
ENVIRONMENTAL REVIEW
Consultants prepared an Addendum to the Comprehensive Plan Environmental Impact Report
(EIR) to analyze the potential environmental impacts of the 2023-2031 Draft Housing Element.
This includes the implementation of Program 1.1 and the associated increase in housing
production including and beyond what was projected by the RHNA and Housing Element sites
inventory.
The City Council considered a previous version of this Addendum before adopting the Housing
Element in June 2023. The revised Addendum analyzes modifications to the Adopted Housing
Element’s Sites Inventory, which includes additional site locations and unit yields. It also
analyzes the expanded Program 1.1 rezoning (i.e., the El Camino Real Focus Area). The revised
Addendum demonstrates similar findings and no new impacts compared to the previous
Addendum.
ATTACHMENTS
Attachment A: Amendments to the Land Use Element of the Comprehensive Plan
Attachment B: Ordinance Adopting Amendments to Title 18 to Implement Housing Element
Program 1.1
Attachment C: Housing Element Program 1.1: Adequate Sites Inventory
Attachment D: Excerpt from Chapter 4 of the Adopted Housing Element (Site Tests)
Attachment E: Addendum to the Comprehensive Plan EIR (November 2023)
APPROVED BY:
Jonathan Lait, Planning and Development Services Director
2LAN D U SE AND
CO MMUN ITY DESIG N
VISION: Palo Alto’s land use decisions shall balance our future
growth needs with the preservation of our neighborhoods,
address climate protection priorities through sustainable
development near neighborhood services and enhance the
quality of life of all neighborhoods.
L.
INTRODUCTION
The Land Use and Community Design Element sets the foundation for future
preservation, growth and change in Palo Alto and serves as the blueprint for the
development of public and private property in the city. It includes policies and
programs intended to balance natural resources with future community needs in a
way that makes optimal use of available land, to create attractive buildings and
public spaces that reinforce Palo Alto’s sense of place and community, to preserve
and enhance quality of life in Palo Alto neighborhoods, to support thriving
commercial areas that meet the needs of local residents, and to maintain Palo Alto's
role in the success of the surrounding region.
This Element meets the State-mandated requirements for a Land Use Element. It
defines categories for the location and type of public and privates uses of land under
the City's jurisdiction; it recommends standards for population density and building
intensity on land covered by the Comprehensive Plan; and it includes a Land Use
Map (Map L-6) and Goals, Policies and Programs to guide land use distribution in
the city. By satisfying these requirements, the Land Use and Community Design
Element lays out the basic guidelines and standards upon which all of the other
Comprehensive Plan elements rely and build. Other elements of the Plan
correspond with the land use categories and policy direction contained in this
Element, while providing more specialized guidance focused on particular topics,
such as transportation or conservation.
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L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
CONNECTIONS TO OTHER ELEMENTS
The Land Use and Community Design Element is replete with direct connections to
all of the other elements of the Comprehensive Plan. Its guidance for land uses is
strongly linked to the Housing Element’s prescriptions for residential development,
even though the Housing Element is cyclically updated on a separate State-
mandated timetable. The inextricable tie between land use and transportation is
clearly apparent both in this Element and the Transportation Element, as the co-
location of land uses significantly affects the ability of transit, walking and biking to
replace vehicle travel, in addition to capitalizing on the presence of rail service in
Palo Alto. The success of programs in the Natural Environment and Safety Elements
are largely dependent on land uses decisions that protect the environment as well as
people and property. The Land Use Element dovetails with both the quality of life
initiatives in the Community Services and Facilities Element, and the prosperity
objectives of the Business and Economics Element.
PLANNING CONTEXT
N ATURAL E NVIRONMENT
With a backdrop sweeping from forested hills to the Bay, Palo Alto is framed by
natural beauty. Views of the foothills contribute a sense of enclosure and a reminder
of the close proximity of open space and nature. Views of the baylands provide a
strong connection to the marine environment and the East Bay hills. Together with
the city’s marshland, salt ponds, sloughs, creeks and riparian corridors, these natural
resources, clearly visible in the aerial photograph in Map L-1, are a major defining
feature of Palo Alto’s character.
Preserving the city’s attractive and valuable natural features is important for a
number of reasons. Ecologically, these areas provide key habitat for wildlife, create a
buffer from developed areas and act as a natural filtration system for storm water
runoff. For the community, they represent an important facet of the look and feel of
Palo Alto, contributing to a sense of place both through direct public access to
natural areas and the views that establish Palo Alto’s local scenic routes.
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E
S A N
F R A N C I S C O
B A YRedwood City
East Palo Alto
Atherton
£¤
101Menlo Park
Stanford
University
PALO
ALTO
§¨¦280
Stanford
Lands
Mountain View
Los AltosLos Altos Hills
·|}þ
85
§¨¦280
Sunnyvale
Railroads
City Boundary
Sphere of Influence,0 1 2 Miles
Source: City of Palo Alto, 2013; ESRI, 2016; PlaceWorks, 2016.
M A P L - 1
P A L O A L T O A E R I A L V I E W
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
R EGIONAL P LANNING
Palo Alto cooperates with numerous regional partners on a range of issues of
common interest. Regional planning partners include the California Department of
Transportation (Caltrans) and other State agencies, Metropolitan Transportation
Commission and Association of Bay Area Governments, Santa Clara Valley
Transportation Authority, San Mateo County Transit District, Santa Clara County, San
Mateo County and neighboring cities. The City of Palo Alto works together with the
cities of East Palo Alto and Menlo Park on a variety of shared programs relating to
economic development, social services, education, public safety and housing.
Palo Alto also works with Mountain View, Los Altos and Los Altos Hills on joint
ventures such as fire protection and water quality control. In addition, Palo Alto
elected officials and staff participate in numerous countywide and regional planning
efforts, including via both advisory and decision-making boards and commissions.
Palo Alto also maintains a strong relationship with Stanford University. Although the
campus lies outside of the city limits, as shown in Map L-2, important Stanford-
owned lands are within Palo Alto, including Stanford Shopping Center, Stanford
Research Park and the Stanford University Medical Center. The City, Santa Clara
County and Stanford maintain an inter-jurisdictional agreement regarding
development on unincorporated Stanford lands and collaborate on selected land use
and transportation projects.
CITY EVOLUTION
E ARLY H ISTORY
There is evidence in the archaeological record of people living along San
Francisquito Creek as far back as 4000 BC, and the first widely recognized inhabitants
are the Costanoan people starting in about 1500 BC. The Costanoan are Ohlone-
speaking Native Americans who lived near the water from San Francisco Bay to
Carmel. Costanoan and earlier artifacts have been identified in the city, particularly
along the banks of San Francisquito Creek. Preservation of these resources is a high
priority for the City and essential to defining the character of the community.
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E
S A N
F R A N C I S C O
B A YRedwood City
East Palo Alto
Atherton
£¤
101Menlo Park
Stanford
University
§¨¦280
Stanford
Lands
Mountain View^_
Los AltosLos Altos Hills
·|þ}
85
§¨¦280
Sunnyvale
City Limit
Sphere of Influence
Stanford Academic Growth Boundary
Railroads^_Potential Future School Site
Stanford University Land Use Designations
Academic Campus
Campus Residential - Low Density
Campus Residential - Moderate Density
Open Space and Field Research
Campus Open Space
Special Conservation
Lake/Reservoir
Urban Service Boundary
|! Caltrain Stations012 Miles
Source: City of Palo Alto, 2013; USGS, 2010; NHD 2013; ESRI, 2010; Tiger Lines, 2010; Stanford University, 2000; PlaceWorks, 2014.
M A P L - 2
S P H E R E O F I N F L U E N C E , U R B A N S E R V I C E A R E A , A N D S T A N F O R D U N I V E R S I T Y L A N D S
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
CITY D EVELOPMENT
From its earliest days, Palo Alto has been a world-class center of knowledge and
innovation. The city incorporated in 1894 on land purchased with the specific intent
of serving the newly established Stanford University. Originally centered on
University Avenue, Palo Alto grew south and east, incorporating the older town of
Mayfield and its California Avenue district in 1925. By the 1970s, the city had almost
doubled in size, stretching into the foothills and south to Mountain View, with
commercial centers along Middlefield Road in Midtown and El Camino Real through
formerly unincorporated Barron Park, and research and development areas at the
city’s outskirts.
Today, Palo Alto covers almost 26 square miles (16,627 acres) of land, about a third
of which is open space, including 34 city-owned parks and 1,700 acres of protected
baylands. Ensuring that activities in and around the baylands, including airport
operations, occur with minimal environmental impacts is of major importance to the
City and region.
COMPACT D EVELOPMENT
Palo Alto was an early adopter of compact development principles, as embodied in
the Urban Service Area designated to manage growth in the current Comprehensive
Plan. Through this strategy, the City has endeavored to direct new development into
appropriate locations—such as along transit corridors and near employment centers—
while protecting and preserving neighborhoods as well as the open space lands that
comprise about half of the city.
S USTAINABILITY AND RESILIENCE
Palo Alto is regarded as a leader in sustainability, having adopted its first Climate
Action Plan in 2007 and continuing through the City’s multi-faceted efforts to
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
eliminate the community’s dependence on fossil fuels and adapt to the potential
effects of climate change. Through the direct provision of public utility services by the
City to the community, Palo Alto is able to achieve truly outstanding energy efficiency
and water conservation. The City and community also are leaders in promoting non-
automobile transportation, waste reduction and diversion and high-quality, low-
impact development.
In addition to efficiency and conservation, the City sees an adequate housing supply
as a fundamental component of a sustainable and equitable community. As of the
adoption of this Comprehensive Plan, renting or owning a home in Palo Alto is
prohibitively expensive for many. The housing affordability crisis in Palo Alto and in
the Bay Area more broadly has a number of negative consequences, including
diminished socioeconomic diversity and increased traffic congestion as local workers
commute from distant places where housing is cheaper. In response, this Element
lays out a multi-faceted strategy to both preserve existing housing and create new
housing in a variety of types and sizes. Most new housing is anticipated to be multi-
family housing on redeveloped infill sites near housing. These policies and programs
work hand-in-hand with Housing Element programs and focus change along transit
corridors, while preserving the character of established single-family neighborhoods.
Together, all of these efforts make Palo Alto a more resilient community, able to
adjust behaviors and actions in an effort to protect and preserve environmental
resources.
CITY STRUCTURE
COMPONENTS
The city is composed of unique neighborhoods and distinct but connected
commercial centers and employment districts. Understanding how these different
components of the city structure support one another and connect to the region can
help inform land use planning. By reflecting the existing structure in its policies, Palo
Alto will ensure that it remains a community that encourages social contact and
public life and also maintains quality urban design.
R ESIDENTIAL N EIGHBORHOODS
Palo Alto’s 35 neighborhoods are characterized by housing, parks and public
facilities. Their boundaries are based on land use and street patterns and community
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
perceptions. Most of the residential neighborhoods have land use classifications of
single-family residential with some also including multiple-family residential, and
transitions in scale and use often signify neighborhood boundaries.
Each neighborhood is a living reminder of the unique blend of architectural styles,
building materials, scale and street patterns that were typical at the time of its
development. These characteristics are more intact in some neighborhoods than in
others. The City strives to complement neighborhood character when installing
streets or public space improvements and to preserve neighborhoods through
thoughtful development review to ensure that new construction, additions and
remodels reflect neighborhood character.
Neighborhoods built prior to the mid-1940s generally have a traditional pattern of
development with relatively narrow streets, curbside parking, vertical curbs and street
trees between the curb and sidewalk. Many homes are oriented to the street with
parking often located to the rear of the lot.
Many later neighborhoods were shaped by Modernist design ideas popularized by
builder Joseph Eichler. The houses are intentionally designed with austere facades
and oriented towards private backyards and interior courtyards, where expansive
glass walls “bring the outside in.” Curving streets and cul-de-sacs further the sense of
house as private enclave, and flattened curbs joined to the sidewalk with no planting
strip create an uninterrupted plane on which to display the house. Some
neighborhoods built during this period contain other home styles such as California
ranch.
Both traditional and modern Palo Alto neighborhoods have fine examples of multi-
unit housing that are very compatible with surrounding single-family homes,
primarily because of their high-quality design characteristics, such as entrances and
gardens that face the street rather than the interior of the development. Examples
include duplexes and small apartment buildings near Downtown, as well as second
units and cottage courts in other areas of the city.
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L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
COMMERCIAL C ENTERS
Centers are commercial and mixed use areas that serve as focal points of community
life. These commercial centers are distributed throughout the city, within walking or
bicycling distance of virtually all Palo Alto residents, as shown in Map L-3. There are
three basic types of Centers in Palo Alto:
h Regional Centers include University Avenue/Downtown and Stanford
Shopping Center. These areas are commercial activity hubs of citywide and
regional significance, with a mix of shopping, offices and some housing.
Downtown is characterized by two- and three-story buildings with ground
floor shops. Downtown Palo Alto is widely recognized for its mix of culture,
architecture and atmosphere of innovation, which make it a uniquely special
place. Trees, benches, outdoor seating areas, sidewalks, plazas and other
amenities make the streets pedestrian-friendly. Transit is highly accessible and
frequent. Downtown plays a key role in concentrating housing, employment,
shopping and entertainment near each other and regional rail and other
transit, exemplifying and supporting citywide sustainability and resiliency.
However, a recent cycle of economic growth has brought increased pressure
for additional office space in Downtown Palo Alto. In recent years, the
demand has become so strong that other important uses that contribute to
Downtown’s vitality, such as storefront retail, are at risk of being pushed out.
This Element includes policies and programs to preserve ground floor-retail
uses Downtown and sustain its role as a gathering place. Programs are also
included to convert some unused development potential from commercial to
residential potential in the future.
Stanford Shopping Center has evolved from its original auto-oriented design
into a premier open-air pedestrian environment known for extensive
landscaped areas surrounded by retail and dining.
h Multi-Neighborhood Centers, including California Avenue, Town and
Country Village and South El Camino Real, are retail districts that serve more
than one neighborhood with a diverse mix of uses including retail, office and
residential. They feature one- to three-story buildings with storefront windows
and outdoor seating areas that create a pedestrian-friendly atmosphere.
These centers also contain retail uses clustered around plazas and parks that
provide public gathering spaces. They can be linked to other city Centers via
transit.
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h Neighborhood Centers, such as Charleston Shopping Center, Edgewood
Plaza and Midtown Shopping Center, are small retail areas drawing customers
from the immediately surrounding area. These centers are often anchored by
a grocery or drug store and may include a variety of smaller retail shops and
offices oriented toward the everyday needs of local residents. Adjacent streets
provide walking, biking and transit connections.
E MPLOYMENT D ISTRICTS
Palo Alto’s employment districts, such as Stanford Research Park, Stanford Medical
Center, East Bayshore and San Antonio Road/Bayshore Corridor, represent a
development type not found in other parts of the city. These Districts are
characterized by large one- to four-story buildings, with some taller buildings,
separated by parking lots and landscaped areas. The Districts are accessed primarily
by automobile or employer-supported transit, though future changes in land use and
tenancy could support a shift toward transit, pedestrian and bicycle travel.
GROWTH MANAGEMENT
The pace of non-residential growth and development in Palo Alto has been
moderated by a citywide cap on non-residential development first adopted by the
City Council in 1989. Based on the demonstrated and continuous strength of the
city’s economy, and recent changes in the approach to growth management
throughout California, this Plan presents an updated cumulative growth
management and monitoring system. This system moderates the overall amount of
new office/R&D development and monitors its impacts on Palo Alto’s livability.
This updated approach uses 2015 as the baseline from which to monitor new
development and establishes a cumulative, citywide cap on office/R&D uses,
including conversions of existing square footage to office/R&D space. It also
establishes clear guidance to address what the City should do as the cap is
approached.
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P A L O A L T O G E N E R A L P L A N U P D A T E
L A N D U S E E L E M E N T
S A N
F R A N C I S C O
B A Y
East Palo Alto
Ø
1
3Menlo Park Ø
2Ø £¤
101
2 1
Ø
2 Ø23
Ø
1 4Stanford
University
2 Ø
1
1 Ø
3Stanford
Lands
Commercial Districts
Regional CentersØ"
1. University Avenue/Downtown
2. Stanford Shopping CenterØ"Multi-Neighborhood Centers
1. California Avenue
2. Town & Country Village
3. South El Camino Real
ØLos A "Neighborhood CentersLos Altos Hills 1. Charleston Center
2. Edgewood Plaza
3. Midtown
³³ Mixed Use Areas
1. South of Forest Area (SOFA)
2. California Avenue
×lo
§¨¦3. Alma Village280
Employment DistrictslEmployment Centers
1. Stanford Research Park
2. Stanford Medical Center
3. East Bayshore
4. San Antonio Road/Bayshore Corridor
|!Caltrain Stations
Sphere of Influence
City Boundary
Railroads
Park/Open Space
0 0.5 1 Miles
Source: City of Palo Alto, 2013; USGS, 2010; NHD 2013; ESRI, 2010; Tiger Lines, 2010; PlaceWorks, 2014.
M A P L - 3
C I T Y S T R U C T U R E
P A L O A L T O G E N E R A L P L A N U P D A T E
L A N D U S E E L E M E N T
S A N
F R A N C I S C O
B A Y
Redwood City
East Palo Alto
Atherton
Menlo Park
£¤
101
Stanford
University
Stanford
Lands§¨¦280
Mountain View
Los AltosLos Altos Hills
·|}þ
85
§¨¦280
Major View Corridors
k Primary Gateways
Scenic Routes in Palo Alto
Caltrain Stations
Railroads
! !
|!
Park/Open Space
City Boundary
Sphere of Influence012 Miles
Source: City of Palo Alto, 2013; USGS, 2010; NHD 2013; ESRI, 2010; Tiger Lines, 2010; PlaceWorks, 2014.
M A P L - 4
C O M M U N I T Y D E S I G N F E A T U R E S
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
URBAN DESIGN
The look and feel of Palo Alto is shaped by urban design, which encompasses the
wide variety of features that together form the visual character of the city. These
elements range from aesthetic to functional and include the design of buildings, the
historic character of structures and places, public spaces where people gather,
gateways or entrances to the city, street trees lining neighborhoods, art decorating
public spaces, as well as parking lots and essential infrastructure. Key community
design features are illustrated on Map L-4.
B UILDINGS
Palo Alto has many buildings of outstanding architectural merit representing a variety
of styles and periods. The best examples of these buildings are constructed with
quality materials, show evidence of craftsmanship, fit with their surroundings and
help make neighborhoods comfortable and appealing. To help achieve quality
design, the Architectural Review Board reviews buildings and site design for
commercial and multi-family residential projects. Palo Alto’s commercial and
residential buildings have received regional and national design recognition. Design
issues in residential neighborhoods include sympathetic restoration and renovation
of homes, protection of privacy if second stories are added, and efforts to make
streets more inviting to pedestrians.
H ISTORIC R ESOURCES
Palo Alto has a rich stock of historic structures and places that are important to the
city’s heritage and preserving and reusing these historic resources contributes to the
livability of Palo Alto. The City’s Historic Inventory lists approximately 400 buildings of
historical merit, with more than a dozen buildings on the National Register of
Historic Places, as well as three historic districts (Green Gables, Greenmeadow and
Professorville) and one architectural district (Ramona Street). Map L-5 illustrates
historic resources in Palo Alto.
Historic sites include the El Palo Alto Redwood, believed to be the site of a 1776
encampment of the Portola Expedition and one of 19 California Points of Historical
Interest in the city. The garage at 367 Addison that was the birthplace of Hewlett-
Packard is one of seven sites or structures listed on the California Register of Historic
Landmarks. The length of El Camino Real from San Francisco to San Diego, including
the section that passes through Palo Alto, is a State Historic Landmark. Many historic
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L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
buildings in the city have been rehabilitated and adaptively reused as office or
commercial spaces, including former single-family homes in and near downtown.
P UBLIC S PACES , S TREETS AND P ARKING
Throughout Palo Alto are a variety of public spaces from parks and schools to plazas
and sidewalks, to cultural, religious and civic facilities. Each of these can increasingly
serve as centers for public life with gathering places, bicycle and pedestrian access,
safety-enhancing night-time lighting and clear visual access, and, in some cases,
small-scale retail uses such as cafes.
Well-designed streets also invite public use and enhance quality of life. Palo Alto’s
reputation as a gracious residential community is due not only to its fine street trees
and attractive planting areas, but also to appropriate street width for neighborhood
character, accommodation of pedestrians and bicycles, height and setbacks of
buildings and color and texture of paving materials. These components help to
ensure that streets are pleasant and safe for all travelers.
Parking lots occupy large amounts of surface area in the city. Well-designed parking
lots make efficient use of space while contributing positively to the appearance of the
surrounding area. A parking lot can provide an opportunity for open space and
outdoor amenities rather than just a repository for cars. Many parking lots in Palo
Alto include trees, landscaping and public art.
G ATEWAYS
Community identity is strengthened when the entrances to the city are clear and
memorable. In Palo Alto, these entrances or gateways include University Avenue, El
Camino Real, Middlefield Road, Oregon Expressway/Page Mill Road, San Antonio
Road and Embarcadero Road and the Palo Alto Transit Center and California Avenue
Caltrain station. Well-designed gateways are defined by natural and urban landmarks
that complement the character and identity of the neighborhood.
24
P A L O A L T O G E N E R A L P L A N U P D A T E
L A N D U S E E L E M E N T
Atherton
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Architectural District
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Professorville
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Los AltosLos Altos Hills
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0 1 2 Miles
Source: PlaceWorks, 2016; The City of Palo Alto, 2013.
*Cultural and historic resources include Historic Structures on the City of Palo Alto Historic Inventory
(categories I, II, III, or IV), and/or Buildings on the National Register of Historic Places, and/or California
Registered Historic Landmarks, and/or Points of Historical Interest.
This map is for illustrative purposes only and does not depict the full inventory of historic
structures, landmarks, or other cultural resources in Palo Alto. For a more complete listing,
please refer to the content of the Palo Alto Comprehensive Plan and the
Cultural or historic resource*
Highways
!
City Limit associated environmental review documents.MꢀAꢀP Lꢀ-ꢀꢁ
H I S T O R I C R E S O U R C E S
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
U RBAN F OREST
Palo Alto’s urban forest—including both public and privately owned trees—is a key
part of the community’s history, identity and quality of life. It offers enormous social,
environmental and financial benefits and is a fundamental part of Palo Alto’s sense
of place. Regular spacing of trees that are similar in form and texture provides order
and coherence and gives scale to the street. A canopy of branches and leaves
provides shade for pedestrians and creates a sense of enclosure and comfort. On the
city’s most memorable streets, trees of a single species extend historic character to
the corners of blocks, reducing the apparent width of streets and intersections and
defining the street as a continuous space. Protecting, maintaining and enhancing the
urban forest, as called for in the 2015 Urban Forest Master Plan, is among the most
effective ways to preserve Palo Alto’s character.
P UBLIC A RT
Public art helps create an inviting atmosphere for gathering, fosters economic
development and contributes to vital public spaces. Palo Alto’s public art program
reflects the City’s tradition of enriching public spaces with works of art, ranging from
the subtle inclusion of handcrafted artifacts into building architecture to more
traditional displays of sculpture at civic locations. The Municipal Code requires both
public and private projects to incorporate public art.
U TILITIES AND INFRASTRUCTURE
A city is supported by its infrastructure—features such as paving, signs and utilities.
These features represent substantial public investments and are meant to serve all
community members. Infrastructure improvements must meet current needs and
keep pace with growth and development. While the purpose of infrastructure is
usually utilitarian or functional, attention to design details can add beauty or even
improve urban design. For example, replacing a sidewalk can provide an opportunity
to create larger tree wells and provide new street trees.
State law (California Government Code Section 65302.10) requires the City to
address potential regional inequity and infrastructure deficits within disadvantaged
unincorporated communities (DUCs) in this Element. There are no DUCs within the
Palo Alto Sphere of Influence (SOI) with public services or infrastructure needs or
deficiencies.
26
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
PALO ALTO AIRPORT
Palo Alto Airport (PAO) is a general aviation airport owned and operated by the City
of Palo Alto. PAO occupies 102 acres of land east of Highway 101 in the baylands
and has one paved runway. The airport functions as a reliever to three Bay Area
airports. PAO facilities include an air traffic control tower operated by the Federal
Aviation Administration and a terminal building. Flight clubs and fixed base operators
operate on-site, offering fuel sales, flight lessons, pilot training and aircraft sales,
rentals, maintenance and repair. From 1967 to 2015, PAO was operated by Santa
Clara County under a lease agreement. Operations and control have since been
transferred to the City and key challenges ahead include addressing deterioration of
runway conditions, addressing noise impacts and hours of operation and the
relationship between the Airport and the Baylands Master Plan.
LAND USE MAP AND LAND USE DESIGNATIONS
Map L-6 shows each land use designation within the city of Palo Alto. The land use
designations translate the elements of city structure into a detailed map that presents
the community’s vision for future land use development and conservation on public
and private land in Palo Alto through the year 2030. Residential densities are
expressed in terms of dwelling units per acre. Population densities per acre are not
absolute limits.
Building intensities for non-residential uses are expressed in terms of floor area ratio
(FAR), which is the ratio of gross building floor area (excluding areas designated for
parking, etc.) to net lot area, both expressed in square feet. FAR does not regulate
building placement or form, only the spatial relationship between building size and
lot size; it represents an expectation of the overall intensity of future development.
27
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
The maximums assigned to the land use designations below do not constitute
entitlements, nor are property owners or developers guaranteed that an individual
project, when tested against the General Plan’s policies, will be able or permitted to
achieve these maximums.
L AND U SE D EFINITIONS
OPEN SPACE
Publicly Owned Conservation Land : Open lands whose primary purpose is the
preservation and enhancement of the natural state of the land and its plants and
animals. Only resource management, recreation and educational activities
compatible with resource conservation are allowed.
Publi c Park: Open lands whose primary purpose is public access for active
recreation and whose character is essentially urban. These areas, which may have
been planted with non-indigenous landscaping, may provide access to nature within
the urban environment and require a concerted effort to maintain recreational
facilities and landscaping.
Streamside Open Space: This designation is intended to preserve and enhance
corridors of riparian vegetation along streams. Hiking, biking and riding trails may be
developed in the streamside open space. The corridor will generally vary in width up
to 200 feet on either side of the center line of the creek. However, along San
Francisquito Creek between El Camino Real and the Sand Hill Road bridge over the
creek, the open space corridor varies in width between approximately 80 and 310
feet from the center line of the creek. The aerial delineation of the open space in this
segment of the corridor, as opposed to other segments of the corridor, is shown to
approximate scale on the Proposed Land Use and Circulation Map.
Open Space/Controlle d Development : Land having all the characteristics of open
space but where some development may be allowed on private properties. Open
space amenities must be retained in these areas. Residential densities range from 0.1
to 1 dwelling unit per acre but may rise to a maximum of 2 units per acre where
second units are allowed, and population densities range from 1 to 4 persons per
acre. Other uses such as agricultural, recreational and non-residential uses may be
allowed consistent with the protection and preservation of the inherent open space
characteristics of the land.
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P A L O A L T O G E N E R A L P L A N U P D A T E
L A N D U S E E L E M E N T
Baylands Master Plan
SOFA I CAP
SOFA II CAP
S A N
F R A N C I S C O
B A YEast Palo Alto Byxbee
Park
Menlo Park
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101
Baylands
Preserve
|!
|!|ÿ82Stanford
University
Mountain View
§¨¦
Los Altos
S A N
F R A N C I S C O
B A YLos Altos Hills
0 0.125 0.25 0.5 0.75 1
Miles
Comprehensive Plan Land Use Designations
Residential Other Campus Open Space
Special Conservation
Lake/Reservoir
Single Family Res SOFA II CAP
Multi-Family Res
Mixed Use
SOFA I CAP
School District Land |Caltrain Stations
Urban Service Area
City Boundary
Commercial Major Institution/Special Facility
Streamside Open Space
Public Park
Hotel Commercial
Service Commercial Sphere of Influence
RailroadsNeighborhood Commercial
Regional/Community Commercial
Open Space/Controlled Development
Public Conservation Land
Business/Industrial Stanford University Land Use Designations
Academic CampusLight Industrial
Research/Office Park Campus Residential - Low Density
Campus Residential - Moderate Density
Open Space/Field Research
Source: ESRI, 2010; Tiger Lines, 2010; USGS, 2010; NHD, 2013; City of Palo Alto, 2013; PlaceWorks, 2015.
M A P L - 6
C O M P R E H E N S I V E P L A N L A N D U S E D E S I G N A T I O N S
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
Multiple-Family uses may
be permitted on Housing
Element opportunity sites.
R ESIDENTIAL
Single-Family Residential: This designation applies to residential neighborhoods
primarily characterized by detached single-family homes, typically with one dwelling
unit on each lot. Private and public schools and churches are conditional uses
requiring permits. Accessory dwelling units or duplexes are allowed subject to certain
size limitations and other development standards and duplexes may be allowed in
select, limited areas where they would be compatible with neighborhood character
and do not create traffic and parking problems. The net density in single family areas
will range from 1 to 7 units per acre, but rises to a maximum of 14 units on parcels
where second units or duplexes occur. Population densities will range from 1 to 30
persons per acre.
, except on
Housing
Element
opportunity
sites, for which
higher density
standards may
be specified in
the Zoning
Ordinance .
Multiple-Family Residential: The permitted number of housing units will vary by
area, depending on existing land use, proximity to major streets and public transit,
distance to shopping and environmental problems. Net densities will range from 8 to
40 units and 8 to 90 persons per acre. Density should be on the lower end of the
scale next to single-family residential areas. Densities higher than what is permitted
, except on
Housing
Element
opportunity
sites, for which
higher density
standards may may be allowed where measurable community benefits will be derived, services andbe specified in
the Zoning
Ordinance .
facilities are available, and the net effect will be consistent with the Comprehensive
Plan. Population densities will range up to 2.25 persons per unit by 2030.
Village Residential: Allows residential dwellings that are designed to contribute to
the harmony and pedestrian orientation of a street or neighborhood. Housing types
include single-family houses on small lots, second units, cottage clusters, courtyard
housing, duplexes, fourplexes and small apartment buildings. Design standards will
be prepared for each housing type to ensure that development successfully
contributes to the street and neighborhood and minimizes potential negative
impacts. Net densities will range up to 20 units per acre. Population densities will
range up to 2.25 persons per unit by 2030.
Transit-Oriented Residential: Allows higher density residential dwellings in the
University Avenue/Downtown and California Avenue commercial centers within a
walkable distance, approximately 2,500 feet, of the City’s two multi-modal transit
stations. The land use category is intended to generate residential densities that
support substantial use of public transportation and especially the use of Caltrain.
Design standards will be prepared to ensure that development successfully
contributes to the street and minimizes potential negative impacts. Individual project
requirements will be developed, including parking, to ensure that a significant
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
portion of the residents will use alternative modes of transportation. Net density will
range up to 50 units per acre, with minimum densities to be considered during
development of new City zoning regulations. Population densities will range up to
2.25 per person per unit by 2030.
C OMMERCIAL
Neighborhood Commercial: Includes shopping centers with off-street parking or a
cluster of street-front stores that serve the immediate neighborhood. Examples
include Charleston Center, Edgewood Center and Midtown. Typical uses include
supermarkets, bakeries, drugstores, variety stores, barber shops, restaurants, self-
service laundries, dry cleaners and hardware stores. In locations along El Camino
Real and Alma Street, residential and mixed use projects may also locate in this
category. Non-residential FARs will range up to 0.4. Consistent with the
Comprehensive Plan’s encouragement of housing near transit centers, higher density
multi-family housing may be allowed in specific locations. , generally within 1/2 mile of
high quality transit.
Regional/Community Commercial: Larger shopping centers and districts that have
a wider variety of goods and services than the neighborhood shopping areas. They
rely on larger trade areas and include such uses as department stores, bookstores,
furniture stores, toy stores, apparel shops, restaurants, theaters and non-retail
services such as offices and banks. Examples include Stanford Shopping Center,
Town and Country Village and University Avenue/Downtown. Non-retail uses such as
medical and dental offices may also locate in this designation; software development
may also locate Downtown. In some locations, residential and mixed use projects
may also locate in this category. Non-residential FARs range from 0.35 to 2.0.
Consistent with the Comprehensive Plan’s encouragement of housing near transit, generally withincenters, higher density multi-family housing may be allowed in specific locations.1/2 mile of high
quality transit.
Service Commercial: Facilities providing citywide and regional services and relying
on customers arriving by car. These uses do not necessarily benefit from being in
high volume pedestrian areas such as shopping centers or Downtown. Typical uses
include auto services and dealerships, motels, lumberyards, appliance stores and
restaurants, including fast service types. In almost all cases, these uses require good
automobile and service access so that customers can safely load and unload without
impeding traffic. In some locations, residential and mixed-use projects may be
appropriate in this land use category. Examples of Service Commercial areas include
San Antonio Road, El Camino Real and Embarcadero Road northeast of the Bayshore
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
Freeway. Non-residential FARs will range up to 0.4. Consistent with the
Comprehensive Plan’s encouragement of housing near transit centers, higher density
, generally within 1/2 mile
of high quality transit.multi-family housing may be allowed in specific locations.
Mixed Use: The Mixed Use designation is intended to promote pedestrian-oriented
places that layer compatible land uses, public amenities and utilities together at
various scales and intensities. The designation allows for multiple functions within
the same building or adjacent to one another in the same general vicinity to foster a
mix of uses that encourages people to live, work, play and shop in close proximity.
Most typically, mixed-use developments have retail on the ground floor and
residences above. This category includes Live/Work, Retail/Office, Residential/Retail
and Residential/Office development. FARs will range up to 1.15, although
development located along transit corridors or near multi-modal centers will range
up to 2.0 FAR with up to 3.0 FAR possible where higher FAR would be an incentive
to meet community goals such as providing affordable housing. The FAR above 1.15
must be used for residential purposes. FAR between 0.15 and 1.15 may be used for
residential purposes. As of the adoption of this Comprehensive Plan, the Mixed Use
designation is currently only applied in the SOFA area. Consistent with the
Comprehensive Plan’s encouragement of housing near transit centers, higher density, generally within 1/2 mile of
high quality transit.multi-family housing may be allowed in specific locations.
Commercial Hotel: This category allows facilities for use by temporary overnight
occupants on a transient basis, such as hotels and motels, with associated
conference centers and similar uses. Restaurants and other eating facilities, meeting
rooms, small retail shops, personal services and other services ancillary to the hotel
are also allowed. This category can be applied in combination with another land use
category. FAR currently ranges up to 2.0 for the hotel portion of the site. An
implementation program indicates that the City will explore increasing this FAR.
Research/Office Park: Office, research and manufacturing establishments whose
operations are buffered from adjacent residential uses. Stanford Research Park is an
example. Other uses that may be included are educational institutions and child care
facilities. Compatible commercial service uses such as banks and restaurants and
residential or mixed-uses that would benefit from the proximity to employment
centers, will also be allowed. Additional uses, including retail services, commercial
recreation, churches and private clubs may also be located in Research/Office Park
areas, but only if they are found to be compatible with the surrounding area through
33
P A L O A L T O C O M P R E H E N S I V E P L A N On Housing Element
opportunity sites, FAR will
typically range from 1.25
to 2.5, as specified in the
Zoning Ordinance. Higher
FARs may be feasible
within 1/2-mile of high
quality transit.
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
the conditional use permit process. In some locations, residential and mixed-use
projects may also locate in this category. Maximum allowable FAR ranges from 0.3 to
0.5, depending on site conditions. Consistent with the Comprehensive Plan, multi-
family housing may be allowed in specific locations.
Light Industrial: Wholesale and storage warehouses and the manufacturing,
processing, repairing and packaging of goods. Emission of fumes, noise, smoke, or
other pollutants is strictly controlled. Examples include portions of the area south of
Oregon Avenue between El Camino Real and Alma Street that historically have
included these land uses, and the San Antonio Road industrial area. Compatible
residential and mixed use projects may also be located in this category. FAR will
range up to 0.5. Consistent with the Comprehensive Plan’s encouragement of
housing near transit centers, higher density multi-family housing may be allowed inOn Housing Element
opportunity sites, FAR will
typically range from 1.5 to specific locations. , generally within 1/2 mile of high quality transit.2.5, as specified in the
Zoning Ordinance. Higher
FARs may be feasible
within 1/2-mile of high
quality transit.
I NSTITUTIONAL
School District Lands: Properties owned or leased by public school districts and
used for educational, recreational, or other non-commercial, non-industrial purposes.
FAR may not exceed 1.0.
Major Institution/Special Facilities: Institutional, academic, governmental and
community service uses and lands that are either publicly owned or operated as
non-profit organizations. Examples are hospitals and City facilities. Consistent with
the Comprehensive Plan’s encouragement of housing near transit centers, higher
density multi-family housing may be allowed in specific locations.
Major Institution/University Lands: Academic and academic reserve areas of
Stanford University. Population density and building intensity limits are established
by conditional use permit with Santa Clara County. These lands are further
designated by the following sub-categories of land use:
h Major Institution/University Lands/Campus Single-Family Residential:
Single-family areas where the occupancy of the units is significantly or totally
limited to individuals or families affiliated with the institution.
h Major Institution/University Lands/Campu s Multiple Family Residential:
Multiple family areas where the occupancy of the units is significantly or totally
limited to individuals or families affiliated with the institution.
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
h Major Institution/University Lands/Campus Educational Facilities:
Academic lands with a full complement of activities and densities that give
them an urban character. Allowable uses are academic institutions and
research facilities, student and faculty housing and support services. Increases
in student enrollment and faculty/staff size must be accompanied by
measures that mitigate traffic and housing impacts.
h Major Institution/University Lands/Academic Reserve and Open Space:
Academic lands having all the characteristics of open space but upon which
some academic development may be allowed provided that open space
amenities are retained. These lands are important for their aesthetic and
ecological value as well as their potential for new academic uses.
35
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
GOALS, POLICIES AND PROGRAMS
G ROWTH M ANAGEMENT
GOAL L-1 A compact and resilient city providing residents and visitors with attractive neighborhoods,
work places, shopping districts, public facilities and open spaces.
C ONCENTRATING D EVELOPMENT W ITHIN THE U RBAN S ERVICE A REA
Policy L-1.1 Maintain and prioritize Palo Alto’s varied residential neighborhoods while sustaining the vitality of its commercial
areas and public facilities.
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.
Policy L-1.3
Policy L-1.4
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.
Commit to creating an inventory of below market rate housing for purchase and rental. Work with neighbors,
neighborhood associations, property owners and developers to identify barriers to infill development of below
market rate and more affordable market rate housing and to remove these barriers, as appropriate. Work with
these same stakeholders to identify sites and facilitate opportunities for below market rate housing and housing
that is affordable.
R EGULATING L AND U SE
Policy L-1.5
Policy L-1.6
Regulate land uses in Palo Alto according to the land use definitions in this Element and Map L-6.
Encourage land uses that address the needs of the community and manage change and development to benefit
the community.
Program L1.6.1 Review regulatory tools available to the City and identify actions to enhance and preserve the
livability of residential neighborhoods and the vitality of commercial and employment
districts, including improved code enforcement practices.
Policy L-1.7 Use coordinated area plans to guide development, such as to create or enhance cohesive neighborhoods in
areas of Palo Alto where significant change is foreseeable. Address both land use and transportation, define the
desired character and urban design traits of the areas, identify opportunities for public open space, parks and
recreational opportunities, address connectivity to and compatibility with adjacent residential areas; and include
broad community involvement in the planning process.
36
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
R EGIONAL C OOPERATION
Policy L-1.8 Maintain an active engagement with Santa Clara County, San Mateo County, neighboring cities, other public
agencies including school districts and Stanford University regarding land use and transportation issues.
Program L1.8.1 Maintain and update as appropriate the 1985 Land Use Policies Agreement that sets forth the
land use policies of the City, Santa Clara County and Stanford University with regard to
Stanford unincorporated lands.
Policy L-1.9 Participate in regional strategies to address the interaction of jobs, housing balance and transportation issues.
G ROWTH MANAGEMENT AND M ONITORING
Policy L-1.10 Maintain a citywide cap of 1.7 million new square
feet of office/R&D development, exempting medical
office uses in the Stanford University Medical
Center (SUMC) vicinity. Use January 1, 2015 as the
baseline and monitor development towards the cap
on an annual basis. Require annual monitoring to
assess the effectiveness of development
requirements and determine whether the cap and
the development requirements should be adjusted.
Continue to exempt medical, governmental and
institutional uses from the cap on office/R&D
development.
Program L1.10.1 Reevaluate the cumulative cap when the amount of new office/R&D square footage entitled
since January 1, 2015 reaches 67 percent of the allowed square footage, or 1,139,000 square
feet. Concurrently consider removal or potential changes to the cap and/or to the amount of
additional development permitted by the City’s zoning ordinance.
Policy L-1.11
Policy L-1.12
Hold new development to the highest development standards in order to maintain Palo Alto’s livability and
achieve the highest quality development with the least impacts.
The City will monitor key community indicators on a regular basis to determine whether the policies of this plan
and the efforts of Palo Alto residents and businesses are effective at promoting livability. Suggested indicators
and monitoring frequency are listed in Table L-1.
37
P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
TABLE L-1 COMMUNITY METRICS
Measure Metric Recommended Monitoring Frequency
Annually as part of Earth Day Report80% below 1990 emissions by 2030 (S/CAP
goal)Greenhouse Gas Emissions
Vehicle Miles Traveled (VMT) per Capita Decrease year over year
Jobs/Housing Balance (Expressed as a
Ratio of Jobs to Employed Residents)
Annually as part of Earth Day Report
Every 4 yearsRatio of jobs to employed residents
Annually as part of report to California
Department of Housing and Community
Development (HCD)
Below Market Rate (BMR) Units Number of units
Annual Report to State Housing and
Community Development Department
Change in PM peak hour traffic volumes at
10 representative local intersections
Percent of residents who live within ½-mile
of a city park
Progress toward Housing Element Goals
Traffic Volumes on City Streets
Availability of Parks
Annually as part of report to HCD
Every 2 years
Every 4 years
Changes in student enrollment at public
elementary, middle and high schoolsPAUSD School Enrollments Annually
A S USTAINABLE C OMMUNITY
GOAL L-2 An enhanced sense of “community” with development designed to foster public life, meet
citywide needs and embrace the principles of sustainability.
Policy L-2.1 Maintain a citywide structure of Residential
Neighborhoods, Centers and Employment Districts.
Integrate these areas with the City’s and the region’s
transit and street system.
Policy L-2.2 Enhance connections between commercial and
mixed use centers and the surrounding residential
neighborhoods by promoting walkable and bikeable
connections and a diverse range of retail and
services that caters to the daily needs of residents.
Program L2.2.1 Explore whether there are appropriate locations to allow small-scale neighborhood-serving
retail facilities such as coffee shops and corner stores in residential areas.
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
Policy L-2.3
Policy L-2.4
As a key component of a diverse, inclusive community, allow and encourage a mix of housing types and sizes,
integrated into neighborhoods and designed for greater affordability, particularly smaller housing types, such as
studios, co-housing, cottages, clustered housing, accessory dwelling units and senior housing.
Use a variety of strategies to stimulate housing, near retail, employment, and transit, in a way that connects to
and enhances existing neighborhoods.
Program L2.4.1 Amend the Housing Element to eliminate housing sites along San Antonio Road and increase
residential densities in Downtown and the California Avenue area to replace potential units
from the sites eliminated.
Program L2.4.2 Allow housing at Stanford Shopping Center, provided that adequate parking and vibrant retail
is maintained and no reduction of retail square footage results from the new housing.
Program L2.4.3 Allow housing on the El Camino Real frontage of the Stanford Research Park. Explore multi-
family housing elsewhere in the Stanford Research Park and near Stanford University
Medical Center (SUMC).
Program L2.4.4 Assess non-residential development potential in the Community Commercial, Service
Commercial and Downtown Commercial Districts (CC, CS and CD) and the Neighborhood
Commercial District (CN), and convert non-retail commercial FAR to residential FAR, where
appropriate. Conversion to residential capacity should not be considered in Town and
Country Village.
Program L2.4.5 Update the municipal code to include zoning changes that allow a mix of retail and
residential uses but no office uses. The intent of these changes would be to encourage a mix
of land uses that contributes to the vitality and walkability of commercial centers and transit
corridors.
Program L2.4.6 Explore changing the Transfer of Development Rights (TDR) ordinances for both buildings of
historic significance and for seismic retrofits so that transferred development rights may be
used for residential capacity.
Program L2.4.7 Explore mechanisms for increasing multi-family housing density near multimodal transit
centers.
Program L2.4.8 Identify development opportunities for BMR and more affordable market rate housing on
publicly owned properties in a way that is integrated with and enhances existing
neighborhoods.
Policy L-2.5 Support the creation of affordable housing units for middle to lower income level earners, such as City and
school district employees, as feasible.
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Program L2.5.1 Collaborate with PAUSD in
exploring opportunities to build
housing that is affordable to
school district employees.
Policy L-2.6
Policy L-2.7
Create opportunities for new mixed use
development consisting of housing and retail.
Support efforts to retain housing that is more
affordable in existing neighborhoods, including a
range of smaller housing types.
Program L2.7.1 Review development standards to
discourage the net loss of
housing units.
Policy L-2.8 When considering infill redevelopment, work to minimize displacement of existing residents.
Program L2.8.1 Conduct a study to evaluate various possible tools for preventing displacement of existing
residents.
Program L2.8.2 Develop and implement a system to inventory the characteristics of existing housing units
and track changes in those characteristics on a regular basis. Make the information publicly
available.
Policy L-2.9
Policy L-2.10
Facilitate reuse of existing buildings.
Ensure regular coordination between the City and PAUSD on land development activities and trends in Palo
Alto, as well as planning for school facilities and programs. Under State law, impacts on school facilities cannot
be the basis for requiring mitigation beyond the payment of school fees or for denying development projects or
legislative changes that could result in additional housing units. The City will, however, assess the reasonably
foreseeable environmental impacts of development projects that result in new school construction or
enrollment.
Program L2.10.1 Collaborate with PAUSD to plan for space to accommodate future school expansions or new
school sites, and evaluate zoning space to accommodate new schools.
Policy L-2.11
Policy L-2.12
Encourage new development and redevelopment to incorporate greenery and natural features such as green
rooftops, pocket parks, plazas and rain gardens.
Ensure that future development addresses potential risks from climate change and sea level rise.
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D ISTINCT N EIGHBORHOODS
GOAL L-3 Safe, attractive residential neighborhoods, each with its own distinct character and within
walking distance of shopping, services, schools and/or other public gathering places.
N EIGHBORHOOD C OMPATIBILITY
Policy L-3.1
Policy L-3.2
Ensure that new or remodeled structures are compatible with the neighborhood and adjacent structures.
Preserve residential uses from conversion to office or short-term rentals.
Program L3.2.1 Evaluate and implement strategies to prevent conversion of residential and neighborhood-
serving retail space to office or short-term vacation rentals.
Policy L-3.3 Recognize the contribution of cottage cluster housing to the character of Palo Alto and retain and encourage this
type of development.
R ESIDENTIAL D ESIGN
Policy L-3.4 Ensure that new multi-family buildings, entries and outdoor spaces are designed and arranged so that each
development has a clear relationship to a public street.
Policy L-3.5 Avoid negative impacts of basement construction for single-family homes on adjacent properties, public
resources, and the natural environment.
Program L3.5.1 Develop a program to assess and manage both the positive and negative impacts of
basement construction in single family homes on the community and the environment,
including:
h Impacts to the natural environment, such as potential impacts to the tree canopy,
groundwater supply or quality and soil compaction.
h Safety issues such as increased surface flooding increased groundwater intrusion with sea
level rise, emergency access and egress, or sewage backflows.
C OMMERCIAL C ENTERS
GOAL L-4
Inviting pedestrian scale centers that offer a variety of retail and commercial services andprovide focal points and community gathering places for the city’s residential neighborhoods
and employment districts.
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C OMMERCIAL C ENTERS AND M IXED U SE A REAS
Policy L-4.1 Encourage the upgrading and revitalization of selected Centers in a manner that is compatible with the character
of surrounding neighborhoods, without loss of retail and existing small, local businesses.
Policy L-4.2 Preserve ground-floor retail, limit the displacement of existing retail from neighborhood centers and explore
opportunities to expand retail.
Program L4.2.1 Study the overall viability of ground-floor retail requirements in preserving retail space and
creating an active street environment, including the types of locations where such
requirements are most effective.
Program L4.2.2 Evaluate the effectiveness of formula retail limits adopted for California Avenue. Develop
incentives for local small businesses where warranted.
Program L4.2.3 Explore and potentially support new, creative and innovative retail in Palo Alto.
Policy L-4.3
Policy L-4.4
Encourage street frontages that contribute to retail vitality in all Centers. Reinforce street corners in a way that
enhances the pedestrian realm or that form corner plazas. Include trees and landscaping.
Ensure all Regional Centers and Multi-Neighborhood Centers provide centrally located gathering spaces that
create a sense of identity and encourage economic revitalization. Encourage public amenities such as benches,
street trees, kiosks, restrooms and public art.
Program L4.4.1 Study the feasibility of using public and private funds to provide and maintain landscaping
and public spaces such as parks, plazas, sidewalks and public art within commercial areas.
Program L4.4.2 Through public/private cooperation provide well-signed, clean and accessible restrooms.
Program L4.4.3 Collaborate with merchants to enhance the appearance of streets and sidewalks within all
Centers. Encourage the formation of business improvement districts and undertake a
proactive program of maintenance, repair, landscaping and enhancement.
Program L4.4.4 Identify priority street improvements that could make a substantial contribution to the
character of Centers, such as widening sidewalks, narrowing travel lanes, creating medians,
restriping to allow diagonal parking and planting trees.
Policy L-4.5 Support local-serving retail, recognizing that it provides opportunities for local employment, reduced commute
times, stronger community connections and neighborhood orientation.
Program L4.5.1 Revise zoning and other regulations as needed to encourage the preservation of space to
accommodate small businesses, start-ups and other services.
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Program L4.5.2 Consider planning, regulatory, or other incentives to encourage property owners to include
smaller office spaces in their buildings to serve small businesses, non-profit organizations,
and independent professionals.
H OTELS
Policy L-4.6 Sites within or adjacent to existing commercial areas and corridors are suitable for hotels. Give preference to
housing versus hotel use on sites adjacent to predominantly single-family neighborhoods.
Program L4.6.1 Explore increasing hotel FAR from 2.0 to 3.0 in the University Avenue/Downtown area and
2.5 in areas outside of Downtown.
R EGIONAL C ENTERS
University Avenue/Downtown
Policy L-4.7 MaintainandenhancetheUniversityAvenue/Downtown area as a major commercial center of the City, with a mix
of commercial, civic, cultural, recreational and residential uses. Promote quality design that recognizes the
regional and historical importance of the area and reinforces its pedestriancharacter.
Policy L-4.8 Ensure that University Avenue/Downtown is pedestrian-friendly and supports bicycle use. Use public art, trees,
bicycle racks and other amenities to create an environment that is inviting to pedestrians and bicyclists.
Program L4.8.1 Prepare a Coordinated Area Plan for Downtown.
Program L4.8.2 Study the feasibility of converting parts of University Avenue to a pedestrian zone.
Stanford Shopping Center
Policy L-4.9 Maintain Stanford Shopping Center as one of the Bay
Area’s premiere regional shopping centers. Promote
bicycle and pedestrian use and encourage any new
development at the Center to occur through infill.
Program L4.9.1 While preserving adequate parking
to meet demand, identify strategies
to reuse surface parking lots.
Program L4.9.2 Explore adding additional Floor Area
Ratio (FAR) for retail at Stanford
Shopping Center.
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M ULTI -N EIGHBORHOOD C ENTERS
California Avenue
Policy L-4.10 Maintain the existing scale, character and function
of the California Avenue business district as a
shopping, service and office center intermediate
in function and scale between Downtown and the
smaller neighborhood business areas.
Program L4.10.1 Prepare a coordinated area plan
for the North Ventura area and
surrounding California Avenue
area. The plan should describe a
vision for the future of the North
Ventura area as a walkable neighborhood with multi-family housing, ground floor retail, a
public park, creek improvements and an interconnected street grid. It should guide the
development of the California Avenue area as a well-designed mixed use district with diverse
land uses and a network of pedestrian-oriented streets.
Program L4.10.2 Create regulations for the California Avenue area that encourage the retention or
rehabilitation of smaller buildings to provide spaces for existing retail, particularly local, small
businesses.
Policy L-4.11 Improve the transition between the California-Cambridge area and the single family residential neighborhood of
Evergreen Park. Avoid abrupt changes in scale and density between the two areas.
Town and Country Village
Policy L-4.12 Recognize and preserve Town and Country Village
as an attractive retail center serving Palo Altans and
residents of the wider region. Future development
at this site should preserve its existing amenities,
pedestrian scale and architectural character while
also improving safe access for bicyclists and
pedestrians and increasing the amount of bicycle
parking.
Policy L-4.13
Policy L-4.14
In Town and Country Village, encourage a vibrant
retail environment and urban greening.
In Town and Country Village, encourage improvement of pedestrian, bicycle and auto circulation and
landscaping improvements, including maintenance of existing oak trees and planting additional trees.
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El Camino Real
Policy L-4.15 Recognize El Camino Real as both a local serving and regional serving corridor, defined by a mix of commercial
uses and housing.
N EIGHBORHOOD C ENTERS
Policy L-4.16 Improve the local-serving focus, and provide safe pedestrian, bicycle and multimodal access to all three Palo
Alto Neighborhood Centers – Charleston Shopping Center, Edgewood Plaza and Midtown Shopping Center.
Support their continued improvement and vitality.
Program L4.16.1 Maintain distinct neighborhood shopping areas that are attractive, accessible and convenient
to nearby residents.
Policy L-4.17
Policy L-4.18
Encourage maximum use of Neighborhood Centers by ensuring that the publicly maintained areas are clean,
well-lit and attractively landscaped.
Maintain Midtown Shopping Center as an attractive, pedestrian-oriented, one- to two-story Neighborhood
Center with diverse local-serving uses and adequate parking, and a network of pedestrian-oriented streets, ways
and gathering places. Encourage retention of Midtown’s grocery store and a variety of neighborhood retail
shops and services.
E MPLOYMENT D ISTRICTS
GOAL L-5 High quality employment districts, each with their own distinctive character and each
contributing to the character of the city as a whole.
Policy L-5.1 Foster compact Employment Districts developed in a
way that facilitates transit, pedestrian and bicycle
travel. Provide mixed uses to reduce the number of
auto trips.
Program L5.1.1 Explore with Stanford University
various development options for
adding to the Stanford Research
Park a diverse mix of uses,
including residential, commercial
hotel, conference center, commercial space for small businesses and start-ups, retail, transit
hub and other community-supporting services that are compatible with the existing uses, to
create a vibrant innovation-oriented community.
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Policy L-5.2 Provide landscaping, trees, sidewalks, pedestrian path and connections to the citywide bikeway system within
Employment Districts. Pursue opportunities to include sidewalks, paths, low water use landscaping, recycled
water and trees and remove grass turf in renovation and expansion projects.
Policy L-5.3
Policy L-5.4
Design paths and sidewalks to be attractive and comfortable and consistent with the character of the area where
they are located.
Maintain the East Bayshore and San Antonio Road/Bayshore Corridor areas as diverse business and light
industrial districts.
GOAL L-6 Well-designed building s that creat e coherent developmen t pattern s and enhance city streets
an d public spaces.
D ESIGN OF B UILDINGS AND P UBLIC S PACE
Policy L-6.1 Promote high-quality design and site
planning that is compatible with
surrounding development and public
spaces.
Program L6.1.1 Promote
programs and other
forms of public
awards
recognition for projects
of architectural merit
that contribute positively
to the community.
Policy L-6.2
Policy L-6.3
Use the Zoning Ordinance, design review process, design guidelines and Coordinated Area Plans to ensure high
quality residential and commercial design and architectural compatibility.
Encourage bird-friendly design.
Program L6.3.1 Develop guidelines for bird-friendly building design that minimizes hazards for birds and
reduces the potential for collisions.
Policy L-6.4
Policy L-6.5
In areas of the City having a historic or consistent design character, encourage the design of new development
to maintain and support the existing character.
Guide development to respect views of the foothills and East Bay hills along public street corridors in the
developed portions of the City.
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Policy L-6.6 Design buildings to complement streets and public spaces; to promote personal safety, public health and well-
being; and to enhance a sense of community safety.
Program L6.6.1 Modify design standards to ensure that mixed use development promotes a pedestrian-
friendly relationship to the street, including elements such as screened parking or
underground parking, street-facing windows and entries, and porches, windows, bays and
balconies along public ways, and landscaping, and trees along the street. Avoid blank or solid
walls at street level.
Policy L-6.7 Where possible, avoid abrupt changes in scale and density between residential and non-residential areas and
between residential areas of different densities. To promote compatibility and gradual transitions between land
uses, place zoning district boundaries at mid-block locations rather than along streets wherever possible.
Program L6.7.1 Implement architectural standards to assure they effectively address land use transitions.
Support existing regulations that preserve exposure to natural light for single-family residences.
Discourage the use of fences that obscure the view of the front of houses from the street.
Policy L-6.8
Policy L-6.9
Policy L-6.10 Encourage high quality signage that is attractive, energy-efficient, and appropriate for the location, and balances
visibility needs with aesthetic needs.
GOAL L-7 Conservation and preservation of Palo Alto’s historic buildings, sites and districts.
H ISTORIC R ESOURCES
Policy L-7.1 Encourage public and private upkeep and
preservation of resources that have historic merit,
including residences listed in the City’s Historic
Resource Inventory, the California Register of
Historical Resources, or the National Register of
Historic Places.
Program L7.1.1 Update and maintain the City’s
Historic Resource Inventory to
include historic resources that are
eligible for local, State, or federal listing. Historic resources may consist of a single building or
structure or a district.
Program L7.1.2 Reassess the Historic Preservation Ordinance to ensure its effectiveness in the maintenance
and preservation of historic resources, particularly in the University Avenue/Downtown area.
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Policy L-7.2 If a proposed project would substantially affect the
exterior of a potential historic resource that has not
been evaluated for inclusion into the City’s Historic
Resources Inventory, City staff shall consider
whether it is eligible for inclusion in State or federal
registers prior to the issuance of a demolition or
alterations permit. Minor exterior improvements
that do not affect the architectural integrity of
potentially historic buildings shall be exempt from
consideration. Examples of minor improvements
may include repair or replacement of features in
kind, or other changes that do not alter character-defining features of the building.
Policy L-7.3
Policy L-7.4
Policy L-7.5
Actively seek state and federal funding for the preservation of buildings of historical merit and consider
public/private partnerships for capital and program improvements.
Relocation may be considered as a preservation strategy when consistent with State and national standards
regarding the relocation of historic resources.
To reinforce the scale and character of University Avenue/Downtown, promote the preservation of significant
historic buildings.
Policy L-7.6
Policy L-7.7
Promote awards programs and other forms of public recognition for exemplary Historic Preservation projects.
Streamline, to the maximum extent feasible, any future processes for design review of historic structures to
eliminate unnecessary delay and uncertainty for the applicant and to encourage historic preservation.
R EHABILITATION AND R EUSE
Policy L-7.8 Promote adaptive reuse of old buildings.
Program L7.8.1 Promote and expand available incentives for the retention and rehabilitation of buildings with
historic merit in all zones and revise existing zoning and permit regulations to minimize
constraints to adaptive reuse.
Program L7.8.2 Create incentives to encourage salvage and reuse of discarded historic building materials.
Program L7.8.3 Seek additional innovative ways to apply current codes and ordinances to older buildings.
Use the State Historical Building Code for designated historic buildings.
Policy L-7.9 Allow compatible nonconforming uses for the life of historic buildings.
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Policy L-7.10
Policy L-7.11
Policy L-7.12
Ensure the preservation of significant historic
resources owned by the City of Palo Alto. Allow
such resources to be altered to meet
contemporary needs consistent with the Secretary
of the Interior Standards for Rehabilitation.
For proposed exterior alterations or additions to
designated Historic Landmarks, require design
review findings that the proposed changes are in
compliance with the Secretary of the Interior
Standards for Rehabilitation.
Maintain the historic integrity of building exteriors.
Consider parking exceptions for historic buildings to
encourage rehabilitation.
Program L7.12.1 Review parking exceptions for historic buildings in the Zoning Code to determine if there is
an effective balance between historic preservation and meeting parking needs.
Policy L-7.13
Policy L-7.14
Encourage and assist owners of historically significant buildings in finding ways to adapt and rehabilitate these
buildings, including participation in state and federal tax relief programs.
Continue to use a TDR Ordinance to allow the transfer of development rights from designated buildings of
historic significance in the Commercial Downtown (CD) zone to non-historic receiver sites in the CD zone.
Consider revising the TDR Ordinance so that transferred development rights may be used only for residential
development on the receiver sites.
A RCHAEOLOGICAL R ESOURCES
Policy L-7.15 Protect Palo Alto’s archaeological resources, including natural land formations, sacred sites, the historical
landscape, historic habitats and remains of settlements here before the founding of Palo Alto in the 19th
century.
Policy L-7.16 Continue to consult with tribes as required by California Government Code Section 65352.3. In doing so, use
appropriate procedures to accommodate tribal concerns when a tribe has a religious prohibition against
revealing precise information about the location or previous practice at a particular sacred site.
Policy L-7.17
Policy L-7.18
Assess the need for archaeological surveys and mitigation plans on a project-by-project basis, consistent with the
California Environmental Quality Act and the National Historic Preservation Act.
Require project proponents to meet State codes and regulations regarding the identification and protection of
archaeological and paleontological deposits, and unique geologic features.
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P ARKS AND G ATHERING P LACES
GOAL L-8 Attractive and safe parks, civic and cultural facilities provided in all neighborhoods and
maintained and used in ways that foster and enrich publiclife.
Policy L-8.1 Facilitate creation of new parkland to serve Palo
Alto's residential neighborhoods, as consistent with
the Parks, Trails, Open Space and Recreation Master
Plan.
Policy L-8.2
Policy L-8.3
Provide comfortable seating areas and plazas with
places for public art adjacent to library and
community center entrances.
Encourage small-scale local-serving retail services,
such as small cafes, delicatessens and coffee carts, in
civic centers: Mitchell Park, Rinconada Library and
Cubberly Community Center.
Policy L-8.4
Policy L-8.5
Create facilities for civic and intellectual life, such as
better urban public spaces for civic programs and
speakers, cultural, musical and artistic events.
Recognize public art and cultural facilities as a community benefit. Encourage the development of new and the
enhancement of existing public and private art and cultural facilities throughout Palo Alto. Ensure that such
projects are compatible with the character and identity of the surrounding neighborhood.
Policy L-8.6
Policy L-8.7
Seek potential new sites for art and cultural facilities, public spaces, open space and community gardens.
Encourage religious and private institutions to collaborate with the community and the surrounding
neighborhood.
P UBLIC S TREETS AND P UBLIC S PACES
GOAL L-9 Attractive, inviting public spaces and streets that enhance the image and character of the city.
STREETS AND P ARKING
Policy L-9.1 Recognize Sand Hill Road, University Avenue between Middlefield Road and San Francisquito Creek,
Embarcadero Road, Page Mill Road, Oregon Expressway, Interstate 280, Arastradero Road (west of Foothill
Expressway), Junipero Serra Boulevard/Foothill Expressway and Skyline Boulevard as scenic routes and preserve
their scenic qualities.
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Program L9.1.1 Evaluate existing zoning code
setback requirements to ensure
they are appropriate for scenic
routes.
Policy L-9.2 Encourage development that creatively integrates
parking into the project, including by locating it
behind buildings or underground wherever
possible, or by providing for shared use of parking
areas. Encourage other alternatives to surface
parking lots that minimize the amount of land devoted to parking while still maintaining safe streets, street trees,
a vibrant local economy and sufficient parking to meet demand.
Policy L-9.3 Treat residential streets as both public ways and neighborhood amenities. Provide and maintain continuous
sidewalks, healthy street trees, benches and other amenities that promote walking and “active” transportation.
Program L9.3.1 Review standards for streets and signage and update as needed to foster natural, tree-lined
streets with a minimum of signage.
PUBLIC S PACES
Policy L-9.4 Maintain and enhance existing public gathering
places and open spaces and integrate new public
spaces at a variety of scales.
Policy L-9.5
Policy L-9.6
Encourage use of data-driven, innovative design
methods and tactics and use data to understand to
evaluate how different community members use
public space.
Create, preserve and enhance parks and publicly accessible, shared outdoor gathering spaces within walking
and biking distance of residential neighborhoods.
Program L9.6.1 Analyze existing neighborhoods and determine where publicly-accessible shared, outdoor
gathering spaces are below the citywide standard. Create new public spaces, including public
squares, parks and informal gathering spaces in these neighborhoods.
G ATEWAYS
Policy L-9.7 Strengthen the identity of important community-wide gateways, including the entrances to the City at Highway
101, El Camino Real and Middlefield Road; the Caltrain stations; entries to commercial districts; Embarcadero
Road at El Camino Real and between Palo Alto and Stanford.
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Program L9.7.1 Develop a strategy to enhance gateway sites with special landscaping, art, public spaces
and/or public buildings. Emphasize the creek bridges and riparian settings at the entrances to
the City over Adobe Creek and San Francisquito Creek.
U RBAN F OREST
Policy L-9.8 Incorporate the goals of the Urban Forest Master
Plan, as periodically amended, into the
Comprehensive Plan by reference in order to assure
that new land uses recognize the many benefits of
trees in the urban context and foster a healthy and
robust tree canopy throughout the City.
Program L9.8.1 Establish incentives to encourage
native trees and low water use
plantings in new development
throughout the city.
Policy L-9.9 Involve the Urban Forester, or appropriate City staff, in development review.
U TILITIES AND I NFRASTRUCTURE
Policy L-9.10 Design public infrastructure, including paving, signs, utility structures, parking garages and parking lots to meet
high-quality urban design standards and embrace technological advances. Look for opportunities to use art and
artists in the design of public infrastructure. Remove or mitigate elements of existing infrastructure that are
unsightly or visually disruptive.
Program L9.10.1 Continue the citywide undergrounding of utility wires. Minimize the impacts of
undergrounding on street tree root systems and planting areas.
Program L9.10.2 Encourage the use of compact and well-designed utility elements, such as transformers,
switching devices, backflow preventers and telecommunications infrastructure. Place these
elements in locations that will minimize their visual intrusion.
Policy L-9.11 Provide utilities and service systems to serve all urbanized areas of Palo Alto and plan infrastructure
maintenance and improvements to adequately serve existing and planned development.
Program L9.11.1 Implement the findings of the City’s Infrastructure Blue Ribbon Committee and its emphasis
for rebuilding our civic spaces.
Program L9.11.2 Identify City-owned properties where combinations of wireless facilities can be co-located,
assuming appropriate lease agreements are in place.
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Policy L-9.12 Recognize the importance of regional infrastructure, such as the Regional Water Utility Infrastructure owned by
the San Francisco Public Utilities Commission (SFPUC).
Program L9.12.1 Coordinate with regional utility providers on activities that would impact their infrastructure
and right-of-way.
GOAL L-10 Maintain an economically viable local airport with minimal environmental impacts.
PALO A LTO A IRPORT
Policy L-10.1 Operate Palo Alto Airport (PAO) as a vital and efficient facility at its current level of operation without intruding
into open space areas. PAO should remain limited to a single runway and minor expansion shall only be
allowed in order to meet federal and State airport design and safety standards.
Program L10.1.1 Relocate the terminal building away from the Runway 31 clear zone and closer to the
hangars, allowing for construction of a replacement terminal.
Program L10.1.2 Update the Airport Layout Plan in accordance with Federal Aviation Administration
requirements, as needed, while ensuring conformance with the Baylands Master Plan to the
maximum extent feasible.
Program L10.1.3 Identify and pursue funding to address maintenance, safety and security improvements
needed at PAO.
Policy L-10.2
Policy L-10.3
Regulate land uses in the Airport Influence Area to ensure consistency with the Palo Alto Airport Comprehensive
Land Use Plan and the Baylands Master Plan.
Minimize the environmental impacts associated with PAO operations, including adverse effects on the character
of surrounding open space, noise levels and the quality of life in residential areas, as required by federal and
State requirements.
Program L10.3.1 Establish and implement a system for processing, tracking and reporting noise complaints
regarding local airport operations on an annual basis.
Program L10.3.2 Work with the airport to pursue opportunities to enhance the open space and habitat value
of the airport. These include:
h Maintaining native grasses;
h Reconstructing levees to protect the airport from sea level rise while enhancing public
access and habitat conservation; and
h Evaluating the introduction of burrowing owl habitat. This program is subject to federal
wildlife hazard requirements and guidelines for airports.
Policy L-10.4 Provide public access to the Airport for bicyclists and pedestrians.
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P A L O A L T O C O M P R E H E N S I V E P L A N
L A N D U S E A N D C O M M U N I T Y D E S I G N E L E M E N T
Program L10.4.1 Continue to provide a bicycle/pedestrian path adjacent to Embarcadero Road, consistent with
the Baylands Master Plan and open space character of the baylands subject to federal and
State airport regulations.
Policy L-10.5
Policy L-10.6
Address the potential impacts of future sea level rise through reconstruction of the Bayfront levee in a manner
that provides protection for the Airport and greater habitat along the San Francisco Bay frontage.
Encourage the use of alternatives to leaded fuel in aircraft operating in and out of Palo Alto Airport.
54
*NOT YET APPROVED*
1
Ordinance No. _____
Ordinance of the Council of the City of Palo Alto Adopting Chapter 18.14
(Housing Incentives) and Amending Various Chapters of Title 18 (Zoning) of the
Palo Alto Municipal Code to Implement Programs 1.1A and 1.1B of the City of
Palo Alto 2023-2031 Housing Element
The Council of the City of Palo Alto ORDAINS as follows:
SECTION 1. Findings and Declara�ons.
(a) On May 8, 2023, the City Council adopted the City of Palo Alto 2023-2031 Housing
Element (“Housing Element”) pursuant to Government Code Sec�on 65585.
(b) Program 1.1A of the Housing Element provides for amendments to the zoning ordinance
that are necessary to accommodate the City’s Regional Housing Needs Alloca�on (“RHNA”) on the
inventory of housing opportunity sites provided in Appendix D to the Housing Element.
(c) Program 1.1B of the Housing Element provides for addi�onal amendments to the zoning
ordinance for ROLM and GM zoned proper�es that exceed those required under Program 1.1A.
(d) Government Code Sec�ons 65583 and 65588 require that the City complete its rezoning
of sites under Program 1.1A by January 31, 2024, which is one year from the statutory deadline for
adop�on of the Housing Element.
(e) This ordinance implements Programs 1.1A and 1.1B of the Housing Element, resul�ng in
an inventory of sites suitable and available for development that is sufficient to meet the City’s RHNA
during the Housing Element planning period.
SECTION 2. Chapter 18.14 (Housing Incen�ves) of Title 18 (Zoning) of the Palo Alto Municipal
Code is added to read as follows:
CHAPTER 18.14: HOUSING INCENTIVES
18.14.010 Purpose
This chapter implements the regional housing needs strategy (RHNA) of the City’s Comprehensive Plan
Housing Element to rezone opportunity sites; facilitates housing produc�on; affirma�vely furthers fair
housing; and provides incen�ves for housing development, especially below-market rate housing.
18.14.020 Housing Element Opportunity Sites
This subsec�on implements the rezoning required to meet the RHNA in the 2023-2031 Housing Element,
pursuant to Appendix D. Regula�ons iden�fied in Table 1 and Table 2 modify and replace development
standards provided in base zoning district and applicable combining district regula�ons.
a) Applicability: This subsec�on applies to Housing Development Projects, as defined in
Government Code Sec�on 65589.5, on Housing Element opportunity sites listed in Appendix D
*NOT YET APPROVED*
2
and on sites within the GM/ROLM and El Camino Real Focus Areas depicted in Figure 1 and
Figure 3.
b) Permited Uses: Refer to the base zoning district and applicable combining districts for allowed
uses, except:
(1) Exclusively residen�al uses are permited on all Housing Element opportunity sites.
(2) Combining district use regula�ons shall not apply to exclusively residen�al projects on
housing opportunity sites designated in Appendix D of the Housing Element to
accommodate lower income households.
(3) Sites zoned to allow mixed use development and are iden�fied in Appendix D of the Housing
Element as suitable for lower income households, must be developed with a minimum of
two-thirds residen�al floor area.
c) Development Standards: Refer to base zoning district and applicable combining districts for
development standards except:
(1) Residen�al uses on R-1 zoned sites (faith-based ins�tu�ons) shall be subject to the
development standards for the RM-30 zoning district, pursuant to Chapter 18.13.040, except
that Maximum FAR shall be 1.25 and minimum density shall be 20 units per acre.
(2) RM-20, RM-30, RM-40, CN, CS, CC, CC(2), CD-C, and CD-N zoned sites as modified by Table 1
(3) GM, ROLM, and RP zoned sites as modified by Table 2
(4) PF zoned sites shall meet the following development standards:
(A) Downtown sites: CD-C standards, pursuant to Table 1 below
(B) California Avenue sites: CC(2) standards, pursuant to Table 1 below
(5) Specific Stanford University-owned sites and El Camino Real Focus Area sites may, as an
alterna�ve to State Density Bonus Law, meet base district regula�ons as modified by Table 3.
Housing Development Projects that u�lize State Density Bonus Law shall be subject to base
district standards or standards provided in Tables 1 and 2, as applicable. Addi�onally, El
Camino Real Focus Area sites shall:
(A) Complete Major Architectural Review pursuant to Sec�on 18.77.020
(B) Provide 20% of total units as on-site below-market rate housing affordable to
households earning up to 80% of AMI. This requirement shall apply in place of the
basic requirements set forth in Sec�ons 16.65.030 and 16.65.040.
(C) Not restrict residency to households with a par�cular ins�tu�onal affilia�on.
(6) Combining district design and development standards shall not apply to exclusively
residen�al projects on housing opportunity sites designated in Appendix D of the Housing
Element to accommodate lower income households.
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*NOT YET APPROVED*
3
Table 1
Housing Element Opportunity Site Development Standards (Residen�al and Commercial Mixed Use
Districts)
Base Zoning
District
Maximum FAR (1) Minimum
Landscape
Coverage
Residen�al Density (du/ac)(4) Other
Development
Standards Residen�al Total Minimum Maximum
CC(2) 1.5 2.0 (3) 20 See base district
regula�ons:
18.16.060
See base district
regula�ons:
18.16.060
CC 1.25 1.25 (3) 20
CS (El Camino
Real) 1.25 1.25 (3) 20
CS (Other) 1.25 1.25 (3) 20 See HE Appendix D
CN (El Camino
Real) 1.25 1.25 30% (3) 20
See base district
regula�ons:
18.16.060
CN (Other) 1.25 1.25 30% (3) 20 See HE Appendix D
CD-C 2.0 2.0 (2)
(3)
20
See base district
regula�ons:
18.18.060
See base district
regula�ons:
18.18.060 CD-N 1.5 1.5 (3) 20 See HE Appendix D
RP 1.25 1.25
(3)
25
None; 40 du/ac
an�cipated
See base district
regula�ons:
18.20.040
RM-40 1.5 1.5 (3) 31
See HE Appendix D
See base district
regula�ons:
18.13.040
RM-30 1.25 1.25 (3) 20
RM-20 1.25 1.25
See
18.13.040 20
(1) Nothing in this table increases the non-residen�al floor area permited in any district.
(2) FAR may be increased with transfer of development rights; see Chapter 18.18 for details.
(3) Landscape coverage may be provided above the ground-floor. If standard is not specified, refer
to base district regula�ons.
(4) Where no maximum density is provided in terms of du/ac, maximum density shall be
determined by es�ma�ng the realis�c development capacity of the site based on the objec�ve
development standards applicable to the project. Where noted, refer to Housing Element
Appendix D: Sites Inventory for specified densi�es.
//
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//
*NOT YET APPROVED*
4
Table 2
GM/ROLM Focus Area Development Standards for Housing Development Projects Only
Base Zoning
District
Maximum FAR Minimum
Landscape
Coverage
Maximum
Lot
Coverage
Residen�al Density
(du/ac)(2)
Maximum
Height
Minimum
Residen�al
Parking
Ra�os
Other
Development
Standards Residen�al Total Minimum Maximum
GM (Focus
Area, Figure
1) 2.5 2.5 20% (1) 70% 40
None; 90
du/ac
an�cipated 60
1 space per
studio/1-bed;
1.5 spaces per
2-bed+
See base
district
regula�ons:
18.20.040
GM (Other
Opportunity
Sites) 1.5 1.5 30% (1) 70% 25
None; See
HE Appendix
D for
an�cipated
densi�es
See
18.20.040 No change
ROLM
(Focus
Area, Figure
1) 2.5 2.5 20% (1) 70% 40
None; 90
du/ac
an�cipated 60
1 space per
studio/1-bed;
1.5 spaces per
2-bed+
ROLM
(Other
Opportunity
Sites) 1.5 1.5 (1) 70% 25
None; 50
du/ac
an�cipated 45 No change
(1) Landscape coverage may be provided above the ground-floor. If standard is not specified, refer
to base district regula�ons.
(2) These sites do not provide a maximum density in terms of du/ac; however, an�cipated densi�es
have been determined by es�ma�ng the realis�c development capacity of the site based on the
objec�ve development standards applicable to the project. Where referenced, the densi�es
specified in Housing Element Appendix D: Sites Inventory represent an�cipated densi�es based
on realis�c development capaci�es.
//
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*NOT YET APPROVED*
5
Figure 1: GM/ROLM Housing Element Focus Area
*NOT YET APPROVED*
6
Table 3
Site-Specific Development Standards (Stanford-Owned Sites & El Camino Real Focus Area)
Loca�on
Pasteur Dr. & 1100 Welch Rd. (1)(3)
(Figure 2)
El Camino Real Focus Area (1)
(Figure 3)
Minimum Front Setback 15 feet See base district regula�ons
Minimum Setback See base district regula�ons:
18.13.040
See base district regula�ons,
except:
For sites with a property line
abu�ng a low density
residen�al (RE, R2, or RMD) or
R1 single family residen�al
district: 20 feet
Maximum FAR 3.5 (Total) 4.0 (Total)
Maximum Site/Landscape
Coverage
(2) (2)
Maximum Lot Coverage 60% 70%
Maximum Density (du/ac) None None
Maximum Height 85 85
Daylight Plane Sand Hill Rd. frontage only: ini�al
height 60 feet above grade at the
Sand Hill Rd. setback line and a
45-degree angle
See base district regula�ons for
standards for daylight planes
Height Transi�ons n/a Within 100 � of low density
residen�al (RE, R2, or RMD) or
R1 single family zone district
property line: 35 �.
Between 100 and 150 � of low
density or R1 zone district
property line: 45 �.
Upper Story Step Back None El Camino Real frontage:
maximum height of 55 feet
within 20 feet of the El Camino
Real property line
Open Space 100 sq. �/unit (any combina�on
of common and/or private)
100 sq. �/unit (any combina�on
of common and/or private)
Minimum Residen�al Parking
(5)
0.5 spaces/unit 1 space/unit
(Per AB2097: 0 space/unit within
½ mile of Caltrain)
Other Development Standards See base district regula�ons:
18.13.040
See base district regula�ons
Design Criteria/Standards Compliance with Objec�ve
Design Standards pursuant to
Chapter 18.24 (4)
Architectural Review and
compliance with either
Objec�ve Design Standards
*NOT YET APPROVED*
7
pursuant to Chapter 18.24 or
Context-Based Design Criteria
pursuant to base district
regula�ons. (4)
(1) Site locations as defined in the 2023-2031 Housing Element
(2) Permitted above the ground-floor. If standard is not specified, refer to base district regulations.
(3) Housing may be developed in phases and individual phases may not meet all standards.
However, upon completion the project as a whole must conform to these standards. Individual
parcels shall be deed restricted to address standards that are met in aggregate, but not on a
parcel-by-parcel basis. In addition, for each phase, the applicant shall demonstrate, to the
satisfaction of the Director, that the overall site is capable of meeting all standards upon
completion of the project as a whole.
(4) Except, the following objective design standards shall be modified to meet the realistic capacity
identified in the Housing Element:
(a.) 18.24.050(b)(5): Diversity of Housing Types, shall be replaced with the following standard:
Maximum façade length shall be less than or equal to 250 feet.
(b.) 18.24.060(b)(7): Parking/Loading/Utilities, shall be replaced with the following standard:
Above grade structured parking levels facing a public right-of-way or publicly accessible
open space/path with the exception of vehicular alleys, shall compose no more than 50% of
any public frontage. Garage façades fronting on public right-of-way shall be screened with
decorative architectural screening (e.g. perforated metal panels, murals), lined with
habitable uses, or screened with landscaping (e.g., green wall, climbing vines).
(5) Projects providing fewer than 50% of the parking spaces that would be required under Section
18.52.040 shall develop and implement a transportation demand management plan containing,
at a minimum: free transit passes for residents; and provision of outlets appropriately spaced
for e-bike charging at 20% of bicycle parking spaces.
//
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*NOT YET APPROVED*
8
Figure 2: Pasteur Drive Focus Area
*NOT YET APPROVED*
9
Figure 3: El Camino Real Focus Area
*NOT YET APPROVED*
10
18.14.030 Housing Incen�ve Program (Reserved)
18.14.040 Affordable Housing Incen�ve Program (Reserved)
//
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*NOT YET APPROVED*
11
SECTION 3. Sec�on 18.12.030 (Land Uses) of Chapter 18.12 (R-1 Single-Family Residen�al District) of
Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (CHANGES SHOWN IN
UNDERLINE STRIKEOUT):
18.12.030 Land Uses
The permited and condi�onally permited uses for the single family residen�al districts are shown in
Table 1:
Table 1
PERMITTED AND CONDITIONAL R-1 RESIDENTIAL USES
R-1 and all R-1
Subdistricts
Subject to Regula�ons in:
[. . .]
RESIDENTIAL USES
Single-Family P
Two-Family use, under one ownership P 18.42.180
Mobile Homes P 18.42.180
Mul�ple-Family P(2) 18.14.020
Residen�al Care Homes P
[. . .]
(1) An Accessory Dwelling Unit or a Junior Accessory Dwelling Unit associated with a single-family
residence on a lot is permited, subject to the provisions of Chapter 18.09.
(2) Housing Element opportunity sites (faith-based ins�tu�ons) only.
SECTION 4. Sec�on 18.12.040 (Development Standards) of Chapter 18.12 (R-1 Single-Family Residen�al
District) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows:
18.12.040 Development Standards
(a) Site Specifica�ons, Building Size, Height and Bulk, and Residen�al Density
The development standards for the R-1 district and the R-1 subdistricts are shown in Table 2, except:
(1) To the extent such standards may be modified by Sec�on 18.42.180 for two-family uses pursuant
to California Government Code Sec�on 65852.21 (SB 9, 2021;
(2) On Housing Element opportunity sites (faith-based ins�tu�ons): development standards for
Mul�ple-Family uses are iden�fied in Sec�on 18.14.020, which states that sites shall meet the
development standards for the RM-30 zoning district, except that Maximum FAR shall be 1.25.
[. . .]
*NOT YET APPROVED*
12
SECTION 5. Chapter 18.13: MULTIPLE FAMILY RESIDENTIAL (RM-20, RM-30 AND RM-40) DISTRICTS
[. . .]
18.13.040 Development Standards
(a) Site Specifica�ons, Building Size and Bulk, and Residen�al Density
The site development regula�ons in Table 2 shall apply in the mul�ple-family residence districts,
provided that more restric�ve regula�ons may be recommended by the Architectural Review Board and
approved by the Director of Planning and Development Services, pursuant to the regula�ons set forth in
Chapter 18.76, and the objec�ve design standards set forth in Chapter 18.24. Except that sites
designated as Housing Element Opportunity Sites shall meet the development standards specified in
Chapter 18.14.020.
Table 2
Mul�ple Family Residen�al Development Table
RM-20 RM-30 RM-40 Subject to
regula�ons in:
[. . .]
Maximum Site Coverage:
Base 35% 40% 45%
Addi�onal area permited to be covered by
covered pa�os or overhangs otherwise in
compliance with all applicable laws
5% 5% 5%
Maximum Floor Area Ra�o (FAR)(4) 0.5:1 0.6:1 1.0:1
Residen�al Density (units)
Maximum number of units per acre(3) 20 30 40 18.13.040(g)
18.14.020
Minimum number of units per acre(8) 11 16 21 18.14.020
Minimum Site Open Space(5) (percent) 35 30 20 18.13.040(e)
18.14.020
Minimum Usable Open Space (sf per unit)(5) 150 150 150
Minimum common open space (sf per unit) 75 75 75 18.13.040(e)
Minimum private open space (sf per unit) 50 50 50
Performance Criteria See provisions of Chapter 18.23 Ch. 18.23
Landscape Requirements 18.40.130
Parking(6) See provisions of Chapter 18.52 Ch. 18.52
[. . .]
*NOT YET APPROVED*
13
SECTION 6. Chapter 18.20: OFFICE, RESEARCH, AND MANUFACTURING (MOR, ROLM, RP, AND GM)
[. . .]
18.20.030 Land Uses
(a) Permited and Condi�onally Permited Land Uses
Table 1 lists the land uses permited or condi�onally permited in the industrial and manufacturing
districts.
Table 1
Industrial/Manufacturing District Land Uses
[P = Permited Use CUP = Condi�onal Use Permit Required]
MOR ROLM
ROLM(E)
RP
RP(5)
GM Subject to Regula�ons
in Chapter:
[. . .]
RESIDENTIAL USES
Single-Family Not permited 18.20.040(b)
Two-Family Not permited
Mul�ple-Family (Housing
Element Opportunity Site) P P P
18.14.020
Mul�ple-Family (Other
Sites) CUP CUP(1) CUP CUP(1)
18.14.020
Residen�al Care Homes P CUP CUP CUP 18.23.100(B)
[. . .]
(1) Adjacent to Bayshore Freeway and generally bounded by East Charleston Road and Loma
Verde Avenue (see Figure 1), subject to CUP
[. . .]
//
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*NOT YET APPROVED*
14
Figure 1: GM/ROLM Housing Element Focus Area
*NOT YET APPROVED*
15
18.20.040 Site Development Standards
[. . .]
(b) Development Standards for Exclusively Residen�al Uses
Residen�al uses shall be permited in the MOR, RP, RP(5), ROLM, ROLM(E), and GM zoning districts,
subject to the following criteria.
(1) It is the intent of these provisions that a compa�ble transi�on be provided from lower density
residen�al zones to higher density residen�al or non-residen�al zones. The Village Residen�al
development type should be evaluated for use in transi�on areas and will provide the greatest flexibility
to provide a mix of residence types compa�ble with adjacent neighborhoods.
(2) No new single-family or two-family residen�al development is permited in any of the office,
research and manufacturing districts, and no new residen�al development is permited within 300 feet
of an exis�ng Hazardous Materials Tier 2 use. Exis�ng single-family and two-family uses and exis�ng
residen�al development within 300 feet of an exis�ng Hazardous Materials Tier 2 use shall be permited
to remain, consistent with the provisions of Chapter 18.70 (Nonconforming Uses and Noncomplying
Facili�es).
(3) MOR District. All mul�-family development in the MOR zoning district shall be permited subject to
approval of a condi�onal use permit and compliance with the development standards prescribed for the
RM-30 zoning district.
(4) RP and RP(5) Districts. All mul�-family development in the RP, and RP(5) zoning districts that is
located within 150 feet of an R-E, R-1, R-2, RMD, or similar density residen�al PC zone shall be permited
subject to the provisions above in 18.20.040(b)(2), approval of a condi�onal use permit, and compliance
with the development standards prescribed for the RM-20 zoning district, including Village Residen�al
development types. Mul�-family development in the MOR, RP, and RP(5) zoning districts that is located
greater than 150 feet from an R-E, R-1, R-2, RMD, or low density residen�al PC shall be permited subject
to the provisions above in 18.20.040(b)(2), approval of a condi�onal use permit, and compliance with
the development standards prescribed for the RM-30 zoning district, except for sites designated as
Housing Element Opportunity Sites or Focus Areas, which are regulated by Chapter 18.14.020.
(5) ROLM (E) District. All mul�-family development in the ROLM(E) zoning district shall be permited
subject to the provisions above in 18.20.040(b)(2), approval of a condi�onal use permit, and compliance
with the development standards prescribed for the RM-20 zoning district.
(6) ROLM District. All mul�-family development in the ROLM zoning district shall be permited subject
to the provisions above in 18.20.040(b)(2), approval of a condi�onal use permit, and compliance with
the development standards prescribed for the RM-30 zoning district, except for sites designated as
Housing Element Opportunity Sites or Focus Areas, which are regulated by Chapter 18.14.020.
(7) GM District. All residen�al development is prohibited in the GM zoning district, except for sites
designated as Housing Element Opportunity Sites or Focus Areas, which are regulated by Chapter
18.14.020.
*NOT YET APPROVED*
16
(8) Combining Districts. Combining district use regula�ons and design and development standards shall
not apply to exclusively residen�al projects on Housing Element opportunity sites designated to
accommodate lower income households. See Sec�on 18.14.020 for details.
(c) Development Standards for Mixed (Residen�al and Nonresiden�al) Uses in the MOR, ROLM,
ROLM(E), RP, and RP(5) zoning Districts
Mixed (residen�al and nonresiden�al) uses shall be permited in the MOR, ROLM, ROLM(E), RP, and
RP(5) zoning districts, subject to the following criteria:
(1) It is the intent of these provisions that a compa�ble transi�on be provided from lower density
residen�al zones to higher density residen�al, non-residen�al, or mixed use zones. The Village
Residen�al development type should be evaluated for use in transi�on areas and will provide the
greatest flexibility to provide a mix of residence types compa�ble with adjacent neighborhoods.
(2) New sensi�ve receptor land uses shall not be permited within 300 feet of a Hazardous Materials
Tier 2 or Tier 3 use. Exis�ng sensi�ve receptors shall be permited to remain, consistent with the
provisions of Chapter 18.70 (Nonconforming Uses and Noncomplying Facili�es).
(3) ROLM(E) District. Mixed (residen�al and nonresiden�al) development in the ROLM(E) zoning
district shall be permited, subject to the provisions above in 18.20.040(c)(2), approval of a condi�onal
use permit, determina�on that the nonresiden�al use is allowable in the district and that the residen�al
component of the development complies with the development standards prescribed for the RM-20
zoning district. The maximum floor area ra�o (FAR) for mixed use development is 0.3 to 1.
(4) ROLM District. Mixed (residen�al and nonresiden�al) development in the ROLM zoning district
shall be permited, subject to the provisions above in 18.20.040(c)(2), approval of a condi�onal use
permit, determina�on that the nonresiden�al use is allowable in the district and that the residen�al
component of the development complies with the development standards prescribed for the RM-30
zoning district. The maximum floor area ra�o (FAR) for mixed use development is 0.4 to 1. Except that
sites designated as Housing Element Opportunity Sites or Focus Areas shall meet the development
standards specified in Chapter 18.14.020.
(5) GM District. Mixed use (residen�al and nonresiden�al) development is prohibited in the GM
zoning district, except for sites designated as Housing Element Opportunity Sites or Focus Areas, which
are regulated by Chapter 18.14.020.
In compu�ng residen�al densi�es for mixed (residen�al and nonresiden�al) uses, the density
calcula�on for the residen�al use shall be based on the en�re site, including the nonresiden�al por�on
of the site.
[. . .]
//
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*NOT YET APPROVED*
17
SECTION 7. Chapter 18.16: NEIGHBORHOOD, COMMUNITY, AND SERVICE COMMERCIAL (CN, CC AND CS)
DISTRICTS
[. . .]
18.16.060 Development Standards
[. . .]
(b) Mixed Use and Residen�al
Table 4 specifies the development standards for new residen�al mixed use developments and residen�al
developments. These developments shall be designed and constructed in compliance with the following
requirements and the objec�ve design standards in Chapter 18.24,except that sites designated as
Housing Element Opportunity Sites shall meet the development standards as modified in Chapter
18.14.020. Non-Housing Development Projects and Housing Development Projects that elect to deviate
from one or more objec�ve standards in Chapter 18.24 shall meet the context-based design criteria
outlined in Sec�on 18.16.090, provided that more restric�ve regula�ons may be recommended by the
architectural review board and approved by the director of planning and development services, pursuant
to Sec�on 18.76.020.
Table 4
Mixed Use and Residen�al Development Standards
CN CC CC(2) CS Subject to
regula�ons in:
[. . .]
Maximum Site Coverage 50% 50% 100% 50%
Minimum Landscape/Open Space
Coverage 35% 30% 20% 30% 18.14.020
Usable Open Space (Private and/or
Common)
150 sq � per unit (2) 18.16.090
Maximum Height (�)
Standard 35' (4) 50' 37' 50'
Por�ons of a site within 150 �. of an
abu�ng residen�al district (other than
an RM-40 or PC zone) (5)
35' 35' 35' 35' 18.08.030
Daylight Plane for lot lines abu�ng
one or more residen�al zoning
districts
Daylight plane height and slope shall be iden�cal to
those of the most restric�ve residen�al zoning district
abu�ng the lot line
Residen�al Density (net) (3) 15 or 20 (9) See sub-
sec�on
(e)
below
No maximum 30 18.16.060(i)
18.14.020
Sites on El Camino Real No maximum No maximum
Maximum Residen�al Floor Area Ra�o
(FAR) 0.5:1 (4) 0.6:1 0.6:1 18.16.065
18.14.020
*NOT YET APPROVED*
18
CN CC CC(2) CS Subject to
regula�ons in:
[. . .]
Maximum Nonresiden�al Floor Area
Ra�o (FAR) 0.4:1 2.0:1 0.4:1
Total Mixed Use Floor Area Ra�o (FAR) 0.9:1 (4) 2.0:1 1.0:1 18.16.065
18.14.020
Minimum Mixed Use Ground Floor
Commercial FAR (6) 0.15:1(10) 0.15:1(10)
0.25:1 (7) (10) 0.15:1 (10)
Parking See Chapters 18.52 and 18.54 (Parking) 18.52, 18.54
[. . .]
(c) Exclusively Residen�al Uses
Exclusively residen�al uses are generally prohibited in the CN, CS, CC(2) and CC zone districts, except
on housing inventory sites iden�fied in the Housing Element, subject to the standards in
Sec�on 18.16.060(b), and on CS and CN sites on El Camino Real and CC(2) sites, subject to the following.
(1) On CS and CN sites on El Camino Real and on CC(2) sites, where the retail shopping (R) combining
district or the retail preserva�on provisions of Sec�on 18.40.180 do not apply, exclusively residen�al
uses are allowed subject to the standards in Sec�on 18.16.060(b) and the following addi�onal
requirements:
(A) Residen�al units shall not be permited on the ground-floor of development fron�ng on El
Camino Real unless set back a minimum of 15 feet from the property line or the 12-foot effec�ve
sidewalk setback along the El Camino Real frontage, whichever is greater. Common areas, such as
lobbies, stoops, community rooms, and work-out spaces with windows and architectural detail are
permited on the ground-floor El Camino Real frontage.
(B) Parking shall be located behind buildings or below grade, or, if infeasible, screened by
landscaping, low walls, or garage structures with architectural detail.
(C) Combining district use regula�ons and design and development standards shall not apply
to exclusively residen�al projects on Housing Element opportunity sites designated to accommodate
lower income households. See Sec�on 18.14.020 for details.
//
//
//
//
//
//
*NOT YET APPROVED*
19
SECTION 8. Chapter 18.18: DOWNTOWN COMMERCIAL (CD) DISTRICT
18.18.060 Development Standards
[. . .]
(b) Mixed Use and Residen�al
Table 3 specifies the development standards for new residen�al mixed use developments and
residen�al developments. Housing Development Projects shall be designed and constructed in
compliance with the following requirements and the objec�ve design standards in Chapter 18.24. Non-
Housing Development Projects and Housing Development Projects that elect to deviate from one or
more objec�ve standards in Chapter 18.24 shall meet context-based design criteria outlines in
Sec�on 18.18.110, provided that more restric�ve regula�ons may be recommended by the architectural
review board and approved by the director of planning and development services, pursuant to
Sec�on 18.76.020:
TABLE 3
MIXED USE AND RESIDENTIAL DEVELOPMENT STANDARDS
CD-C CD-S CD-N Subject to regula�ons
in Sec�on:
[. . .]
Maximum Site Coverage No requirement 50% 50%
Minimum Landscape Open Space
Coverage 20% 30% 35% 18.14.020
Usable Open Space (Private and/or
Common)
150 sq � per unit (1) 18.18.110
Maximum Height (�)
Standard 50' 50' 35' 18.08.030
Por�ons of a site within 150 �. of an
abu�ng residen�al district (other than
an RM-40 or PC zone)(4)
40' 40' 35' 18.08.030
Daylight Plane for lot lines abu�ng
one or more residen�al zoning
districts or a residen�al PC district
Daylight plane height and slope iden�cal to those
of the most restric�ve residen�al zone abu�ng
the lot line
Residen�al Density (net)(2) No maximum 30 30 18.14.020
Maximum Weighted Average
Residen�al Unit Size(5)
1,500 sq � per
unit No maximum No maximum
Maximum Residen�al Floor Area Ra�o
(FAR) 1.0:1(3) 0.6:1(3) 0.5:1(3) 18.14.020,
18.18.065, 18.18.070
Maximum Nonresiden�al Floor Area
Ra�o (FAR) 1.0:1(3) 0.4:1 0.4:1
*NOT YET APPROVED*
20
Total Floor Area Ra�o (FAR)(3) 2.0:1(3) 1.0:1(3) 0.9:1(3) 18.14.020,
18.18.065, 18.18.070
Parking Requirement See Chapters 18.52 and 18.54 Chs. 18.52, 18.54
[. . .]
(c) Exclusively Residen�al Uses
(1) Exclusively residen�al uses are allowed in the CD-C subdistrict, except in the ground floor (GF)
combining district. However, GF combining district use regula�ons and design and development
standards shall not apply to exclusively residen�al projects on Housing Element opportunity sites
designated to accommodate lower income households. See Sec�on 18.14.020 for details.
(2) Exclusively residen�al uses are generally prohibited in the CD-N and CD-S subdistricts. Such uses
are allowed, however, where a site is designated as a housing inventory site in the Housing Element of
the Comprehensive Plan. Such sites shall be developed pursuant to the regula�ons for the mul�-family
zone designa�on (RM-20, RM-30, or RM-40) iden�fied for the site in the Housing Element.
SECTION 9. Chapter 18.28 SPECIAL PURPOSE (PF, OS and AC) DISTRICTS
[. . .]
18.28.040 Land Uses
Table 1 shows the permited (P) and condi�onally permited (CUP) land uses for the Special Purpose
Districts.
Table 1
Land Uses
PF OS AC Subject to Regula�ons
in Chapter:
[. . .]
Single-family dwellings P
Manufactured housing (including mobile homes on
permanent founda�ons)
P 18.40.
Mul�ple-Family (Housing Element Opportunity Site) P 18.14.020
Guest ranches CUP
Residen�al care facili�es, when u�lizing exis�ng
structures on the site
CUP(1)
Residen�al Care Homes P
Residen�al use, and accessory buildings and uses
customarily incidental to permited dwellings;
provided, however, that such permited dwellings
shall be for the exclusive use of the owner or
owners, or lessee or lessor of land upon which the
permited agricultural use is conducted, and the
P
*NOT YET APPROVED*
21
residence of other members of the same family and
bona fide employees of the aforemen�oned
[. . .]
[. . .]
18.28.050 Site Development Standards
(a) Development Standards. On Housing Element opportunity sites (City-owned parking lots):
development standards are iden�fied in Sec�on 18.14.020
Table 2
Special Purpose District Site Development Standards
[. . .]
(b) Open Space Impervious Coverage and Floor Area
(1) Residen�al Use
The impervious coverage and floor area ra�os shall be determined based on a sliding scale
calcula�on. Table 3 provides the range of allowable percentages for the calcula�on. Allowable
development for other site sizes between 1 and 10 acres shall be calculated on a prorated basis between
the acreages shown in Table 3. Except that on Housing Element opportunity sites (City-owned parking
lots), development standards are iden�fied in Sec�on 18.14.020.
Table 3
Open Space Residen�al Impervious Coverage and Floor Area Ra�o Scale
[. . .]
SECTION 10. If any sec�on, subsec�on, sentence, clause, or phrase of this Ordinance is for any reason
held to be invalid or uncons�tu�onal by a decision of any court of competent jurisdic�on, such decision
shall not affect the validity of the remaining por�ons of this Ordinance. The City Council hereby declares
that it would have passed this Ordinance and each and every sec�on, subsec�on, sentence, clause, or
phrase not declared invalid or uncons�tu�onal without regard to whether any por�on of the ordinance
would be subsequently declared invalid or uncons�tu�onal.
//
//
//
//
*NOT YET APPROVED*
22
SECTION 11. In accordance with the California Environmental Quality Act (CEQA), the City prepared
an Addendum to the 2017 Comprehensive Plan Environmental Impact Report (EIR), analyzing the
poten�al environmental impacts of the 2023-2031 Housing Element. On May 8, 2023, the City Council
adopted Resolu�on No. 10107, finding that the Addendum and the 2017 EIR adequately analyzed the
environmental impacts of the Housing Element, including Program 1.1A and 1.1B of the Housing
Element, which this ordinance implements.
SECTION 12. This ordinance shall be effec�ve on the thirty-first date a�er the date of its adop�on.
INTRODUCED:
PASSED:
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
____________________________ ____________________________
City Clerk Mayor
APPROVED AS TO FORM: APPROVED:
____________________________ ____________________________
Assistant City Atorney City Manager
____________________________
Director of Planning and Development Services
City of Palo Alto
Appendix D: Site Inventory
May 2023
Adopted
2023-2031 Housing Element
Table A: Site Inventory
Strategy Site Address/Intersection
5 Digit
ZIP Code
Assessor
Parcel Number
General Plan
Designation (Current)
Zoning Designation
(Current)
Minimum Density
Allowed (units/acre)
Maximum Density
Allowed (units/acre)
Parcel Size
(Acres)Existing Use/Vacancy
Lower
Income Capacity
Moderate
Income Capacity
Above Moderate
Income Capacity
Total
Capacity Year Built
Improvement to
Land Value Ratio CoStar Rating
Multi-Family Allowed 555 UNIVERSITY AV 94301 120-03-024 CC CD-C 0 40 0.17 One story office space (FAR: 0.9)0 0 5 5 1970 1.01 2
Multi-Family Allowed 435 TASSO ST 94301 120-03-025 CC CD-C 0 40 0.33 Three story office space (FAR: 2.0)0 10 0 10 1984 1.5 3
Multi-Family Allowed 624 UNIVERSITY AV 94301 120-03-040 MF RM-40 31 40 0.15 Two story office space (FAR: 0.6)0 0 4 4 1926 0.33 2
Multi-Family Allowed 543 COWPER ST 94301 120-03-067 CC CD-C 0 40 0.23 One story office space (FAR: 0.9)0 0 7 7 1978 1.47 2
Multi-Family Allowed 330 LYTTON AV 94301 120-15-003 CC CD-C 0 40 0.16 One story restaurant space (FAR: 0.9)0 0 5 5 1957 1.46 2
Multi-Family Allowed 401 WAVERLEY ST 94301 120-15-007 CC CD-C 0 40 0.22 One story commercial (FAR: 0.5), surface parking 0 0 7 7 1977 1.09 2
Multi-Family Allowed 444 COWPER ST 94301 120-15-014 CC CD-C 0 40 0.14 Surface Parking 0 0 4 4 1900 0.04
Multi-Family Allowed 426 WAVERLEY ST 94301 120-15-039 CC CD-C 0 40 0.12 Two story commercial building (FAR: 0.5)0 0 3 3 1920 0.32
Multi-Family Allowed 318 UNIVERSITY AV 94301 120-15-058 CC CD-C 0 40 0.18 One story restaurant (FAR: 0.8)0 0 5 5 1926 0.53 2
Multi-Family Allowed 328 UNIVERSITY AV 94301 120-15-059 CC CD-C 0 40 0.18 One story retail (FAR: 0.8)0 0 5 5 1926 0.53 2
Multi-Family Allowed 527 WAVERLEY ST 94301 120-15-080 CC CD-C 0 40 0.16 Surface Parking 0 0 5 5 1900 0
Multi-Family Allowed 515 WAVERLEY ST 94301 120-15-081 CC CD-C 0 40 0.18 Surface Parking 0 0 5 5 1900 0
Multi-Family Allowed 550 WAVERLEY ST 94301 120-15-084 CC CD-C 0 40 0.14 One story restaurant (FAR: 0.9)0 0 4 4 1952 0.91 3
Multi-Family Allowed 560 WAVERLEY ST 94301 120-15-085 CC CD-C 0 40 0.14 Two story restaurant (FAR: 0.9)0 0 4 4 1938 0.89 2
Multi-Family Allowed 630 COWPER ST 94301 120-16-011 CC CD-C 0 40 0.34 One story office space (FAR: 0.4), surface parking 0 10 0 10 1956 0.45 1
Multi-Family Allowed 464 FOREST AV 94301 120-16-044 SOFA I CAP RM-40 31 40 0.23 One story medical office (FAR: 0.4), surface parking 0 0 7 7 1952 0.39 2
Multi-Family Allowed 163 EVERETT AV 94301 120-25-042 CN CD-N 0 30 0.19 One story office space (FAR: 0.5), surface parking 0 0 4 4 1951 0.7 1
Multi-Family Allowed 525 ALMA ST 94301 120-26-109 CC CD-C 0 40 0.25 One story retail (FAR: 1.0)0 0 8 8 1948 1.39 2
Multi-Family Allowed 654 HIGH ST 94301 120-27-037 CC CD-C 0 40 0.19 Two story office space 0 0 6 6 1900 0.04 3
Multi-Family Allowed 660 HIGH ST 94301 120-27-039 SOFA II CAP RT-50 0 50 0.14 One story office space (FAR: 0.9)0 0 5 5 1946 1.3 1
Multi-Family Allowed 701 EMERSON ST 94301 120-27-049 SOFA II CAP RT-35 0 50 0.22 One story commercial (FAR: 0.2), surface parking 0 0 8 8 2003 0.98 1
Multi-Family Allowed 721 EMERSON ST 94301 120-27-072 SOFA II CAP RT-35 0 50 0.12 One story office space (FAR: 0.6), surface parking 0 0 4 4 2003 0.8 1
Multi-Family Allowed 718 EMERSON ST 94301 120-27-073 SOFA II CAP RT-35 0 50 0.12 One story auto service (FAR: 0.8)0 0 4 4 1950 0.54 1
Multi-Family Allowed 839 EMERSON ST 94301 120-28-033 SOFA II CAP RT-35 0 50 0.12 One story office space (FAR: 0.2), surface parking 0 0 4 4 1959 0.03 2
Multi-Family Allowed 821 EMERSON ST 94301 120-28-036 SOFA II CAP RT-35 0 50 0.12 One story vacant office space (FAR: 0.4), surface parking 0 0 4 4 1966 0.32 2
Multi-Family Allowed 840 EMERSON ST 94301 120-28-037 SOFA II CAP RT-35 0 50 0.48 Surface Parking 0 19 0 19 1959 0.03 2
Multi-Family Allowed 849 HIGH ST 94301 120-28-040 SOFA II CAP RT-35 0 50 0.24 One story office space (FAR: 0.4), surface parking 0 9 0 9 1950 1.49 2
Multi-Family Allowed 875 ALMA ST 94301 120-28-045 SOFA II CAP RT-50 0 50 0.32 One story retail (FAR: 0.7), surface parking 0 12 0 12 1949 0.79 1
Multi-Family Allowed 853 ALMA ST 94301 120-28-046 SOFA II CAP RT-50 0 50 0.16 One story office space (FAR: 0.4), surface parking 0 0 6 6 1927 0.11 2
Multi-Family Allowed 901 HIGH ST 94301 120-28-050 SOFA II CAP RT-35 0 50 0.32 Auto Storage 0 12 0 12 1900 0.01
Multi-Family Allowed 975 HIGH ST 94301 120-28-089 SOFA II CAP RT-35 0 50 0.35 One story office space (FAR: 0.5)0 14 0 14 1968 0.47 1
Multi-Family Allowed 929 HIGH ST 94301 120-28-090 SOFA II CAP RT-35 0 50 0.12 One story office space (FAR: 0.4), surface parking 0 0 4 4 1955 0.2 1
Multi-Family Allowed 925 HIGH ST 94301 120-28-091 SOFA II CAP RT-35 0 50 0.14 Auto Storage 0 0 5 5 0.01
Multi-Family Allowed 940 HIGH ST 94301 120-28-092 SOFA II CAP RT-35 0 50 0.18 Auto garage 0 0 7 7 1946 0.63 2
Multi-Family Allowed 960 HIGH ST 94301 120-28-093 SOFA II CAP RT-35 0 50 0.12 Auto garage 0 0 4 4 1947 0.59 1
Multi-Family Allowed 917 ALMA ST 94301 120-28-097 SOFA II CAP RT-50 0 50 0.24 One story office space (FAR: 0.9)0 9 0 9 1929 1.2 2
Multi-Family Allowed 829 EMERSON ST 94301 120-28-099 SOFA II CAP RT-35 0 50 0.19 One story retail (FAR: 0.4), surface parking 0 0 7 7 1962 0.9 2
Multi-Family Allowed 1015 ALMA ST 94301 120-30-049 SOFA II CAP RT-35 0 50 0.12 One story commercial (FAR: 0.2)0 0 4 4 1955 1.25 2
Multi-Family Allowed 466 GRANT AV 94306 124-33-037 MF RM-40 31 40 0.19 Residential (1)0 0 5 5 1900 0.02
Table B: Sites Identified to be Rezoned to Accommodate Shortfall Housing Need
Strategy Site Address/Intersection
5 Digit
ZIP Code
Assessor
Parcel Number
Very Low-
Income Low-Income
Moderate-
Income
Above
Moderate-Income
Parcel Size
(Acres)
Current General
Plan Designation
Current
Zoning
Proposed General Plan (GP)
Designation
Proposed
Zoning
Minimum
Density Allowed
Maximum
Density Allowed
Total
Capacity Description of Existing Uses
Year
Built
Improvement to
Land Value Ratio
CoStar
Rating
Upzone 2011 EL CAMINO REAL 94306 124-31-024 0 0 0 4 0.2 CN CN CN CN 0 40 4 One story retail (FAR: 0.6), surface parking 1930 0.62
Upzone LEGHORN ST 94303 147-05-012 9 10 0 8 0.85 CS CS CS CS 0 40 27 Auto storage 1900 0
Upzone 725 UNIVERSITY AV 94301 003-02-021 0 0 8 0 0.25 MF RM-30 MF RM-30 16 40 8 One story medical office (FAR: 0.4), surface parking 1954 0.41 1
Upzone 701 UNIVERSITY AV 94301 003-02-022 0 0 8 0 0.25 MF RM-30 MF RM-30 16 40 8 One story medical office (FAR: 0.5), surface parking 1959 0.12 2
Upzone 435 MIDDLEFIELD RD 94301 003-02-023 0 0 7 0 0.23 MF RM-30 MF RM-30 16 40 7 One story medical office (FAR: 0.5), surface parking 1961 0.91 0.25
Upzone 720 UNIVERSITY AV 94301 003-02-047 0 0 13 0 0.41 MF RM-30 MF RM-30 16 40 13 One story office space (FAR: 0.5), surface parking 1954 0.37 2
Upzone 827 MIDDLEFIELD RD 94301 003-32-064 0 0 4 0 0.23 MF RM-20 MF RM-20 8 30 4 Residential (1)1926 0.21
Upzone 853 MIDDLEFIELD RD 94301 003-32-094 4 4 0 4 0.8 MF RM-20 MF RM-20 8 30 12 One story medical offices (FAR: 0.5), surface parking 1952 0.57 2
Upzone MIDDLEFIELD RD 94301 120-03-046 0 0 0 3 0.13 MF RM-20 MF RM-20 8 30 3 Surface Parking 1900 0.02
Upzone 660 MIDDLEFIELD RD 94301 120-04-017 0 0 6 0 0.29 MF RM-20 MF RM-20 8 30 6 One story medical offices (FAR: 0.4), surface parking 1951 0.29 2
Upzone 643 WEBSTER ST 94301 120-04-022 0 0 0 6 0.23 MF RM-30 MF RM-30 16 40 6 Residential (1)1903 0.03
Upzone 744 MIDDLEFIELD RD 94301 120-04-053 0 0 8 0 0.37 MF RM-20 MF RM-20 8 30 8 One story medical offices (FAR: 0.5), surface parking 1956 0.69
Upzone 652 HOMER AV 94301 120-05-008 5 6 0 4 0.64 MF RM-20 MF RM-20 8 30 15 One story medical offices (FAR: 0.5), surface parking 1956 0.36 2
Upzone 850 MIDDLEFIELD RD 94301 120-05-011 5 6 0 4 0.66 MF RM-20 MF RM-20 8 30 15 One story medical offices (FAR: 0.7), surface parking 1955 0.47 2
Upzone 884 MIDDLEFIELD RD 94301 120-05-012 0 0 5 0 0.23 MF RM-20 MF RM-20 8 30 5 One story medical offices (FAR: 0.6), surface parking 1953 0.69 1
Upzone 343 COWPER ST 94301 120-10-044 0 0 0 6 0.19 MF RM-30 MF RM-30 16 40 6 Two story office space (FAR: 0.5), surface parking 1907 0.13
Upzone 720 COWPER ST 94301 120-16-046 0 0 7 0 0.23 MF RM-30 MF RM-30 16 40 7 One story medical office (FAR: 0.6), surface parking 1973 0.49 1
Upzone 116 EMERSON ST 94301 120-24-019 0 0 4 0 0.24 MF RM-20 MF RM-20 8 30 4 Residential (1)1922 0.92
Upzone 124 EMERSON ST 94301 120-24-020 0 0 4 0 0.24 MF RM-20 MF RM-20 8 30 4 Residential (1)1926 0.35
Upzone 262 HAWTHORNE AV 94301 120-25-158 0 0 0 4 0.16 MF RM-30 MF RM-30 16 40 4 Residential (1)1918 0.97
Upzone 202 BRYANT ST 94301 120-25-159 0 0 0 4 0.16 MF RM-30 MF RM-30 16 40 4 Residential (1)1918 0.61
Upzone 75 ENCINA AV 94301 120-33-003 0 0 0 4 0.13 CS CS CS CS 0 40 4 One story office space (FAR: 1.0)1958 0.44 1
Upzone 63 ENCINA AV 94301 120-33-004 0 0 0 8 0.27 CS CS CS CS 0 40 8 One story office space (FAR: 1.0)1941 1.17 1
Upzone 27 ENCINA AV 94301 120-33-010 0 0 0 5 0.16 CS CS CS CS 0 40 5 Surface parking 1900
Upzone 825 EL CAMINO REAL 94301 120-33-011 0 0 0 6 0.2 CS CS CS CS 0 40 6 One story medcial offices (FAR: 0.5), surface parking 1955 0.37 1
Upzone 805 EL CAMINO REAL 94301 120-33-012 0 0 0 7 0.24 CS CS CS CS 0 40 7 One story medcial offices (FAR: 0.5)1940 0.56 2
Upzone 841 EL CAMINO REAL 94301 120-34-001 7 7 0 6 0.64 CS CS CS CS 0 40 20 One story car wash (FAR: 0.2), surface parking 1973 0 2
Upzone 116 COLERIDGE AV 94301 124-17-003 0 0 4 0 0.23 MF RM-20 MF RM-20 8 30 4 Residential (1)1952 0.09
Upzone 119 SEALE AV 94301 124-18-045 0 0 4 0 0.23 MF RM-20 MF RM-20 8 30 4 Residential (1)1966 0.53 2
Upzone 114 SEALE AV 94301 124-18-050 0 0 4 0 0.23 MF RM-20 MF RM-20 8 30 4 Residential (1)1962 0.55
Upzone 127 RINCONADA AV 94301 124-18-095 0 0 4 0 0.23 MF RM-20 MF RM-20 8 30 4 Residential (1)1932 0.14
Upzone 122 RINCONADA AV 94301 124-19-003 0 0 0 4 0.23 MF RM-20 MF RM-20 8 30 4 Residential (1)1925 0.78 2
Upzone 1681 EL CAMINO REAL 94306 124-25-044 4 5 0 4 0.91 MF RM-20 MF RM-20 8 30 13 One story medical offices (FAR: 0.5), surface parking 1939 0.11 2
Upzone 2181 PARK BL 94306 124-27-038 0 0 8 0 0.25 MF RM-30 MF RM-30 16 40 8 Two story office space (FAR: 1.2), surface parking 1957 1.07 2
Upzone 325 COLLEGE AV 94306 124-28-013 0 0 0 5 0.2 MF RM-30 MF RM-30 16 40 5 Residential (1)1938 0.23
Upzone 1921 EL CAMINO REAL 94301 124-30-017 0 0 10 0 0.43 CN CN CN CN 0 30 10 One story restaurant (FAR: 0.4), surface parking 1945 0.98 2
Upzone 2137 EL CAMINO REAL 94306 124-31-058 0 0 7 0 0.32 CN CN CN CN 0 30 7 Surface Parking 1900 0.01
Upzone 2127 EL CAMINO REAL 94301 124-31-059 0 0 6 0 0.25 CN CN CN CN 0 30 6 One story office space (0.6), surface parking 1940 0.91 2
Upzone 430 CAMBRIDGE AV 94306 124-32-009 0 0 0 4 0.14 CC CC CC CC 0 40 4 One story tutoring center/ office space (FAR: 1.0)1958 1.33 2
Upzone 456 CAMBRIDGE AV 94306 124-32-012 0 0 0 5 0.16 CC CC CC CC 0 40 5 One story retail (FAR: 1.0)1951 0.82 2
Upzone 417 COLLEGE AV 94306 124-32-026 0 0 0 5 0.2 MF RM-30 MF RM-30 16 40 5 Residential (1)1948 0.6
Upzone 371 COLLEGE AV 94306 124-32-031 0 0 0 5 0.2 MF RM-30 MF RM-30 16 40 5 Residential (1)1949 0.08
Upzone 2401 EL CAMINO REAL 94306 124-33-061 0 0 0 7 0.24 CC CC CC CC 0 40 7 One story commercial (FAR: 0.5), surface parking 1975 0.56 3
Upzone 4151 MIDDLEFIELD RD 94301 127-15-023 4 5 0 4 0.93 MF RM-20 MF RM-20 8 30 13 Two story office space (FAR: 0.6), surface parking 1961 1.26 3
Upzone 2801 MIDDLEFIELD RD 94306 127-34-052 0 0 0 4 0.17 CN CN CN CN 0 30 4 Two story office space (FAR: 0.4), surface parking 1986 1 2
Upzone 708 COLORADO AV 94306 127-34-054 0 0 0 3 0.13 CN CN CN CN 0 30 3 One story commercial (FAR: 0.5), surface parking 1968 1.14 2
Upzone 706 COLORADO AV 94306 127-34-092 0 0 0 4 0.18 CN CN CN CN 0 30 4 One story retail FAR: 0.8), surface parking 1954 1.27 2
Upzone 2741 MIDDLEFIELD RD 94306 127-34-095 0 0 0 5 0.22 CN CN CN CN 0 30 5 Two story retail (FAR: 0.5)1956 1.43 3
Upzone 2811 MIDDLEFIELD RD 94306 127-34-098 15 15 0 12 1.74 CN CN CN CN 0 30 42 One story commercial (FAR: 0.5), surface parking 1964 0.1 2
Upzone 3200 MIDDLEFIELD RD 94306 132-10-148 0 0 8 0 0.37 MF RM-20 MF RM-20 8 30 8 One story medical offices (FAR: 0.5)1957 0.68 0.31
Upzone 460 LAMBERT AV 94306 132-38-017 0 0 0 7 0.22 CS CS CS CS 0 40 7 Surface parking 1937 0.08
Upzone 3200 ASH ST 94306 132-38-045 0 0 0 12 0.39 CS CS CS CS 0 40 12 One story office space FAR: 0.6)1975 1.2 2
Upzone 3260 ASH ST 94306 132-38-047 0 0 0 7 0.22 CS CS CS CS 0 40 7 One story office space (FAR: 0.5), surface parking 1998 0.49 2
Upzone 268 LAMBERT AV 94306 132-38-048 0 0 11 0 0.35 CS CS CS CS 0 40 11 One story office space (FAR: 0.5), surface parking 1963 0.65 2
Upzone 320 LAMBERT AV 94306 132-38-058 0 0 8 0 0.28 CS CS CS CS 0 40 8 One story retail (FAR: 0.5), surface parking 1978 0.42 2
Upzone 425 PORTAGE AV 94306 132-38-068 0 0 0 12 0.4 CS CS CS CS 0 40 12 One story commercial (FAR: 0.8)1951 0.12 1
Upzone 3337 EL CAMINO REAL 94306 132-39-005 0 0 0 5 0.17 CS CS CS CS 0 40 5 Two story vacant office space (FAR: 0.9)1938 0.72 2
Upzone 411 LAMBERT AV 94306 132-39-017 0 0 0 5 0.16 CS CS CS CS 0 40 5 One story commercial (FAR: 0.6), vacant 1900 0
Upzone 3339 EL CAMINO REAL 94306 132-39-074 0 0 0 11 0.36 CS CS CS CS 0 40 11 One story lodging Berbeda Place (FAR: 0.5), surface parking 1955 0.75 2
Upzone EL CAMINO REAL 94306 132-39-075 0 0 0 4 0.18 CN CN CN CN 0 30 4 Surface Parking
Upzone 3345 EL CAMINO REAL 94306 132-39-080 0 0 0 7 0.22 CS CS CS CS 0 40 7 One story restaurant (FAR: 0.5), surface parking 1968 0.37 2
Upzone 455 LAMBERT AV 94306 132-39-087 0 0 0 10 0.32 CS CS CS CS 0 40 10 One story office space (FAR: 0.5), surface parking 1965 0.57 2
Upzone 3691 EL CAMINO REAL 94306 132-40-062 0 0 6 0 0.25 CN CN CN CN 0 30 6 One story restaurant (FAR: 0.6), surface parking 1946 0.92 2
Upzone 397 CURTNER AV 94306 132-41-025 0 0 0 4 0.19 MF RM-30 MF RM-30 16 40 4 Residential (2)1954 0.73 2
Upzone 3825 EL CAMINO REAL 94301 132-41-088 0 0 0 11 0.35 CS CS CS CS 0 40 11 One story medical office (FAR: 0.4), Surface parking 1963 0.2 2
Upzone 3839 EL CAMINO REAL 94306 132-41-089 0 0 0 5 0.17 CS CS CS CS 0 40 5 One story auto service (FAR: 0.5), surface parking 1947 0.68 2
Upzone 3929 EL CAMINO REAL 94306 132-42-068 0 0 0 5 0.17 CS CS CS CS 0 40 5 One story retail (FAR: 0.4), surface parking 1948 0.49 2
Upzone 3939 EL CAMINO REAL 94306 132-42-070 0 0 0 5 0.17 CS CS CS CS 0 40 5 One story retail (FAR: 0.4), surface parking 1948 0.7 2
Upzone 3903 EL CAMINO REAL 94306 132-42-072 5 6 0 5 0.53 CS CS CS CS 0 40 16 One retail (FAR: 0.5), surface parking 1997 1.06 3
Upzone 3901 EL CAMINO REAL 94301 132-42-073 12 13 0 11 1.1 MF RM-30 MF RM-30 16 40 36 One story lodging (FAR: 0.4), surface parking 1956 1.09 0.38
Upzone 4085 EL CAMINO WY 94306 132-43-153 6 6 0 5 0.71 CN CN CN CN 0 30 17 One story retail Goodwill Donation Center (FAR: 0.4), surface parking 1985 0.71 3
Upzone 4127 EL CAMINO REAL 94306 132-46-104 0 0 10 0 0.45 CN CN CN CN 0 30 10 Two story office space (FAR: 0.3), surface parking 1963 0.14 2
Upzone 4195 EL CAMINO REAL 94301 132-46-119 0 0 0 11 0.35 CS CS CS CS 0 40 11 One story auto service (FAR: 0.3), surface parking 1989 0.89 3
Upzone 2754 MIDDLEFIELD RD 94306 132-55-029 4 5 0 4 0.55 CN CN CN CN 0 30 13 One story Retail (FAR: 0.5), surface parking 1952 0.61 2
Upzone 564 COLLEGE AV 94306 137-01-036 0 0 0 3 0.13 CN CN CN CN 0 30 3 One story office space (FAR: 0.5)1949 0.47 2
Upzone 2280 EL CAMINO REAL 94301 137-01-113 0 0 10 0 0.43 CN CN CN CN 0 30 10 Fast food restaurant (FAR: 0.2), surface parking 1969 0.07 2
Upzone 2080 EL CAMINO REAL 94306 137-01-132 0 0 7 0 0.31 CN CN CN CN 0 30 7 One story retail (FAR: 0.9)1961 1.18 2
Upzone KENDALL AV 94306 137-08-033 0 0 0 3 0.13 CN CN CN CN 0 30 3 Vacant
Upzone 3636 EL CAMINO REAL 94301 137-08-078 0 0 6 0 0.25 CN CN CN CN 0 30 6 One story restaurant (FAR: 0.4), surface parking 1953 0.09 2
Upzone 3516 EL CAMINO REAL 94301 137-08-079 0 0 0 7 0.23 CS CS CS CS 0 40 7 One story retail space (FAR: 0.7), surface parking 1946 0.1 2
Upzone 3606 EL CAMINO REAL 94301 137-08-080 5 6 0 5 0.65 CN CN CN CN 0 30 16 Vacant 0
Upzone 3630 EL CAMINO REAL 94301 137-08-081 0 0 8 0 0.37 CN CN CN CN 0 30 8 Two story office space (FAR 0.6), surface parking 1963 1.39 2
Upzone 3508 EL CAMINO REAL 94301 137-08-088 0 0 7 0 0.24 CS CS CS CS 0 40 7 One story auto service (FAR: 0.3), surface parking 1950 0.16 2
Upzone 3666 EL CAMINO REAL 94301 137-08-097 0 0 6 0 0.25 CN CN CN CN 0 30 6 Two story office space (FAR: 0.4), surface parking 1931 0.46 0.44
Upzone 3700 EL CAMINO REAL 94301 137-11-078 0 0 8 0 0.36 CN CN CN CN 0 30 8 One story retail (FAR: 0.2), surface parking 1953 0.01
Upzone 3972 EL CAMINO REAL 94301 137-11-091 0 0 0 6 0.25 CN CN CN CN 0 30 6 One story auto service and gas station (FAR: 0.6), surface parking 1959 0.27 2
Upzone 4146 EL CAMINO REAL 94301 137-24-034 6 7 0 5 0.77 MF RM-20 MF RM-20 8 30 18 Vacant 0
Upzone 4201 MIDDLEFIELD RD 94301 147-05-086 0 0 10 0 0.32 CS CS CS CS 0 40 10 One story auto service (FAR: 0.3), surface parking 1992 1.09 3
Upzone 716-720 SAN ANTONIO RD 94303 147-05-087 15 15 0 13 1.36 CS CS CS CS 0 40 43 One story retail space (FAR: 0.5), surface parking 1965 0.44 2
Upzone 760 SAN ANTONIO RD 94303 147-05-091 7 7 0 6 0.65 CS CS CS CS 0 40 20 One story retail (FAR: 0.5), surface parking 1975 0.49 2
Upzone 780 SAN ANTONIO RD 94303 147-05-092 0 0 13 0 0.42 CS CS CS CS 0 40 13 One story auto service (FAR: 0.3), surface parking 1988 0.14 3
Upzone 3902 MIDDLEFIELD RD 94303 147-08-048 21 21 0 17 4.26 CN CN CN CN 0 30 59 One story commercial/retail (FAR: 0.4), surface parking 0.08 3
Upzone 3900 MIDDLEFIELD RD 94303 147-08-049 0 0 6 0 0.29 CN CN CN CN 0 30 6 One story commercial (FAR: 0.5), surface parking 1958 0.07 2
Upzone 320 SAN ANTONIO RD 94306 147-09-069 8 9 0 7 0.76 MF;RO RM-30 MF;RO RM-30 16 40 24 Vacant 0
Upzone 4279 EL CAMINO REAL 94306 148-01-016 9 9 0 8 0.8 CS CS CS CS 0 40 26 Two story lodging (FAR: 0.7), surface parking 1961 0.52 2
Upzone 4335 EL CAMINO REAL 94301 148-09-010 0 0 12 0 0.4 CS CS CS CS 0 40 12 One story commercial (FAR: 0.7), surface parking 1966 1.21 2
Upzone 4291 EL CAMINO REAL 94301 148-09-014 8 8 0 7 1.16 CS CS CS CS 0 40 23 Two story commercial (FAR: 0.6), surface parking 1957 0.33 2
Upzone 4230 EL CAMINO REAL 94301 167-08-030 5 6 0 5 0.52 CS CS CS CS 0 40 16 One story car rental (FAR: 0.4), Surface parking 1950 0.05 3
Upzone 4238 EL CAMINO REAL 94306 167-08-031 7 7 0 6 0.65 CS CS CS CS 0 40 20 Two story lodging, The Palo Alto Inn (FAR: 0.5), surface parking 1953 0.37 0.96
Upzone 4232 EL CAMINO REAL 94301 167-08-036 0 0 0 13 0.43 CS CS CS CS 0 40 13 One story preschool (FAR: 0.5), surface parking 1954 1.08 2
Upzone 4224 EL CAMINO REAL 94301 167-08-037 7 7 0 6 0.63 CS CS CS CS 0 40 20 One story restaurant (FAR: 0.5), surface parking 1946 0.41 2
Caltrain Station 530 LYTTON AV 94301 120-03-070 7 8 0 6 0.67 CC CD-C CC CD-C 0 40 21 Four story office building (FAR: 0.8) 1906 2
Caltrain Station 343 HAWTHORNE AV 94301 120-12-019 0 0 0 6 0.25 MF RM-20 MF RM-20 8 40 6 Residential (2)1959 1.35
Caltrain Station 221 BRYANT ST 94301 120-14-011 0 0 0 3 0.13 MF RM-20 MF RM-20 8 40 3 Residential (1)1928 0.08
Caltrain Station 305 LYTTON AV 94301 120-14-101 0 0 7 0 0.23 CC CD-C CC CD-C 0 40 7 Two story office space (FAR: 1.2), surface parking 1980 1.14 2
Caltrain Station 170 EMERSON ST 94301 120-24-025 0 0 0 3 0.13 MF RM-20 MF RM-20 8 50 3 Residential (2)1912 0.72
Caltrain Station 230 EMERSON ST 94301 120-25-036 0 0 0 4 0.13 MF RM-20 MF RM-20 8 50 4 Residential (1)1901 0.39
Caltrain Station 251 HIGH ST 94301 120-25-043 0 0 0 7 0.19 CC CD-N CC CD-N 0 50 7 One story dentist office (FAR: 0.8) 1956 1.32 2
Caltrain Station 291 ALMA ST 94301 120-25-056 0 0 0 5 0.13 CC CD-N CC CD-N 0 50 5 One story office building (FAR: 0.5) 1959 0.01 1
Caltrain Station 326 BRYANT ST 94301 120-25-070 0 0 0 4 0.12 MF RM-30 MF RM-30 16 50 4 Two story medical office space (FAR: 0.7)1946 0.63 1
Caltrain Station 324 EMERSON ST 94301 120-25-094 0 0 0 4 0.13 MF RM-30 MF RM-30 16 50 4 Residential (1)1911 0.43
Caltrain Station 345 HIGH ST 94301 120-25-100 0 0 0 4 0.13 MF RM-30 MF RM-30 16 50 4 Residential (1)1990 1.08
Caltrain Station 412 EMERSON ST 94301 120-26-106 0 0 0 6 0.15 CC CD-C CC CD-C 0 50 6 One story restaurant (FAR: 0.9)1958 0.5 2
Caltrain Station 640 RAMONA ST 94301 120-27-015 0 0 0 4 0.12 CC CD-C CC CD-C 0 50 4 One story restaurant (FAR: 0.9)1910 1 3
Caltrain Station 227 FOREST AV 94301 120-27-017 0 0 0 4 0.12 CC CD-C CC CD-C 0 50 4 Two story office space (1.0)1965 1.32 2
Caltrain Station 635 HIGH ST 94301 120-27-034 0 0 0 4 0.12 CC CD-C CC CD-C 0 50 4 One story office space (FAR: 0.8)1946 0.08 1
Caltrain Station 160 HOMER AV 94301 120-28-005 0 0 0 4 0.14 SOFA II CAP RT-35 SOFA II CAP RT-35 0 40 4 Surface Parking 1961 0.03
Caltrain Station 828 BRYANT ST 94301 120-28-018 0 0 0 4 0.13 SOFA I CAP AMF SOFA I CAP AMF 0 40 4 One story office space (FAR: 0.4)1900 0.72 2
Caltrain Station 145 ADDISON AV 94301 120-28-094 0 0 0 5 0.18 SOFA II CAP RT-35 SOFA II CAP RT-35 0 40 5 One story office space (FAR: 0.4), surface parking 1950 0.77 2
Caltrain Station 100 ADDISON AV 94301 120-30-050 0 0 7 0 0.24 SOFA II CAP RT-35 SOFA II CAP RT-35 0 40 7 One story preschool (FAR: 0.4), surface parking 1980 2
Caltrain Station 330 BRYANT ST 94301 120-65-002 0 0 0 3 0.13 MF RM-30 MF RM-30 16 50 3 Residential (2)1982 1
Caltrain Station 106 RINCONADA AV 94301 124-19-001 0 0 0 3 0.11 MF RM-20 MF RM-20 8 50 3 Residential (1)1925 0.06
Caltrain Station 114 RINCONADA AV 94301 124-19-002 0 0 0 3 0.11 MF RM-20 MF RM-20 8 50 3 Residential (1)1925 0.4
Caltrain Station 2151 PARK BL 94306 124-27-039 0 0 10 0 0.26 MF RM-30 MF RM-30 16 50 10 Two story office building (FAR: 1.2), surface parking 1958 1.05 2
Caltrain Station PARK BL 94306 124-28-003 0 0 0 11 0.29 CC CC CC CC 0 50 11 Surface Parking 1900
Caltrain Station 2211 PARK BL 94306 124-28-043 0 0 14 0 0.35 MF RM-30 MF RM-30 16 50 14 One stury office building (FAR: 0.5), surface parking 1956 0.33 2
Caltrain Station 1963 EL CAMINO REAL 94306 124-30-015 0 0 8 0 0.28 CN CN CN CN 0 40 8 Auto service and convience store (FAR: 0.5)1950 0.05 2
Caltrain Station 1885EL CAMINO REAL 94306 124-30-060 0 0 0 4 0.13 CN CN CN CN 0 40 4 Two story office space (FAR: 1.0), surface parking 1.5 2
Caltrain Station 1895 EL CAMINO REAL 94306 124-30-061 0 0 0 5 0.16 CN CN CN CN 0 40 5 Two story office space (FAR: 0.4)1.49 2
Caltrain Station 2001 EL CAMINO REAL 94306 124-31-025 0 0 0 5 0.18 CN CN CN CN 0 40 5 One story retail (FAR: 0.4)1953 0.18
Caltrain Station CAMBRIDGE AV 94306 124-32-050 7 7 0 6 0.65 CC PF CC PF 0 40 20 Parking structure 1910
Caltrain Station 415 CAMBRIDGE AV 94306 124-32-052 0 0 0 4 0.13 CC CC CC CC 0 40 4 Two story vacant office building (FAR: 0.8)0.87 2
Caltrain Station 2455 EL CAMINO REAL 94306 124-33-008 0 0 12 0 0.38 CC CC CC CC 0 40 12 Two story lodging (FAR: 0.7), surface parking 1970 0.1 2
Caltrain Station 445 SHERMAN AV 94306 124-33-043 0 0 8 0 0.28 CC CC CC CC 0 40 8 Two story office space (FAR: 1.0)1975 0.61 3
Caltrain Station 3197 PARK BL 94306 132-26-076 8 8 0 7 0.59 LI GM LI GM 0 50 23 One story office space (FAR: 0.6), surface parking 1.43 2
Caltrain Station 3040 PARK BL 94306 132-32-036 0 0 0 6 0.17 LI GM LI GM 0 50 6 One story office space (FAR: 0.4)1953 0.9 1
Caltrain Station PARK BL 94306 132-32-042 0 0 8 0 0.28 MF RM-30 MF RM-30 16 40 8 Surface Parking 1961
Caltrain Station PARK BL 94306 132-32-043 15 16 0 13 1.38 MF RM-30 MF RM-30 16 40 44 Surface Parking 1950
Caltrain Station 404 SHERIDAN AV 94306 132-36-025 0 0 0 4 0.11 MF RM-40 MF RM-40 31 50 4 Surface Parking
Caltrain Station 2673 EL CAMINO REAL 94306 132-36-077 7 7 0 6 0.64 CN CN CN CN 0 40 20 One story retail (FAR: 0.3), surface parking 1970 0.59 2
Caltrain Station 2805 EL CAMINO REAL 94306 132-37-067 0 0 12 0 0.39 CS CS CS CS 0 40 12 One story retail (FAR: 0.4), surface parking 1946 0.92 2
Caltrain Station 555 COLLEGE AV 94306 137-01-069 0 0 15 0 0.48 CN CN CN CN 0 40 15 Single story office space (FAR: 0.5), surface parking 1958 0.57 2
Caltrain Station 2200 EL CAMINO REAL 94306 137-01-070 0 0 13 0 0.41 CN CN CN CN 0 40 13 Auto service and convience store (FAR: 0.2), surface parking 1990 0.19 2
Caltrain Station YALE ST 94306 137-01-078 0 0 0 4 0.14 CN CN CN CN 0 40 4 Surface Parking 1958
Caltrain Station 2000 EL CAMINO REAL 94306 137-01-116 0 0 8 0 0.27 CN CN CN CN 0 40 8 One story restaurant (FAR: 0.4), surface parking 1.14 2
Caltrain Station 577 COLLEGE AV 94306 137-01-125 0 0 14 0 0.44 CN CN CN CN 0 40 14 Two story office space (FAR: 0.8), surface parking 1958 1.24 3
Caltrain Station 2310 EL CAMINO REAL 94306 137-01-129 8 9 0 7 0.76 CN CN CN CN 0 40 24 One story restaurant (FAR: 0.4), surface parking 1924 1.39 3
Caltrain Station 2400 EL CAMINO REAL 94306 142-20-012 8 9 0 7 0.75 CS CS CS CS 0 40 24 Two Story Office Building 1.01 2
Caltrain Station NITA AV 94306 147-09-056 18 18 0 14 1.25 RO ROLM RO ROLM 0 50 50 Surface Parking
Transit Corridor 105 LOWELL AV 94301 124-17-035 0 0 0 2 0.11 MF RM-20 MF RM-20 8 40 2 Residential (1)1948 0.11
Transit Corridor 114 LOWELL AV 94301 124-17-040 0 0 0 4 0.17 MF RM-20 MF RM-20 8 40 4 Residential (1)1985 0.45
Transit Corridor 120 LOWELL AV 94301 124-17-041 0 0 0 4 0.17 MF RM-20 MF RM-20 8 40 4 Residential (1)1988 0.42
Transit Corridor 126 LOWELL AV 94301 124-17-042 0 0 0 4 0.17 MF RM-20 MF RM-20 8 40 4 Residential (1)1994 0.13
Transit Corridor 211 MANZANITA AV 94306 124-24-008 0 0 0 3 0.14 MF RM-20 MF RM-20 8 40 3 Residential (1)1937 0.99
Transit Corridor 12 CHURCHILL AV 94306 124-24-025 0 0 0 2 0.14 MF RM-20 MF RM-20 8 40 2 Residential (2)1945 0.09
Transit Corridor 16 CHURCHILL AV 94306 124-24-026 0 0 0 3 0.14 MF RM-20 MF RM-20 8 40 3 Residential (1)1945 0.2
Transit Corridor LAMBERT AV 94306 132-38-018 0 0 0 7 0.23 CS CS CS CS 0 40 7 Surface parking 1955 0.03
Transit Corridor 3457 EL CAMINO REAL 94306 132-39-077 0 0 0 4 0.15 CN CN CN CN 0 40 4 One story retail (FAR: 0.6)1950 1.11 1
Transit Corridor 3487 EL CAMINO REAL 94306 132-39-078 0 0 0 6 0.2 CN CN CN CN 0 40 6 Two story retail (FAR: 0.8), surface parking 1963 0.6 2
Transit Corridor 3505 EL CAMINO REAL 94306 132-40-060 0 0 0 4 0.14 CN CN CN CN 0 40 4 Two story office space (FAR: 0.3)1950 1.26 2
Transit Corridor 3545 EL CAMINO REAL 94306 132-40-063 0 0 0 4 0.14 CN CN CN CN 0 40 4 Two story retail (FAR: 0.4)1969 1.34 2
Transit Corridor 3897 EL CAMINO REAL 94306 132-41-086 0 0 0 10 0.36 CS CS CS CS 0 40 10 One story car wash (FAR: 0.2)2000 0.52 3
Transit Corridor 4131 EL CAMINO WY 94306 132-44-010 0 0 0 5 0.16 CN CN CN CN 0 40 5 One story restaurant (FAR: 0.4) surface parking 1956 0.43 3
Transit Corridor 4125 EL CAMINO WY 94306 132-44-012 0 0 0 5 0.18 CN CN CN CN 0 40 5 One story art school (FAR: 0.7)1955 1.11 2
Transit Corridor 4123 EL CAMINO REAL 94306 132-46-103 0 0 0 6 0.2 CN CN CN CN 0 40 6 One story restaurant (FAR: 0.3)surface parking 1960 0.64 2
Transit Corridor 4117 EL CAMINO REAL 94306 132-46-105 0 0 0 5 0.16 CN CN CN CN 0 40 5 One story office space (FAR: 0.2), surface parking 1983 0.85 3
Transit Corridor 4113 EL CAMINO REAL 94306 132-46-116 0 0 0 6 0.21 CN CN CN CN 0 40 6 One story restaurant (FAR: 0.4)1990 1.09 3
Transit Corridor EL CAMINO REAL 94306 137-11-074 0 0 0 3 0.12 CN CN CN CN 0 40 3 Surface parking
Transit Corridor 3760 EL CAMINO REAL 94306 137-11-079 0 0 0 3 0.12 CN CN CN CN 0 40 3 Surface parking 0.04
Transit Corridor 3924 EL CAMINO REAL 94306 137-11-084 0 0 0 5 0.16 CN CN CN CN 0 40 5 One story commercial (FAR: 0.98) 1934 0.57 3
Transit Corridor 3944 EL CAMINO REAL 94306 137-11-085 0 0 0 7 0.22 CN CN CN CN 0 40 7 One story retail space (FAR: 0.5) 1987 0.49 3
Transit Corridor 3864 EL CAMINO REAL 94306 137-11-089 0 0 0 5 0.18 CN CN CN CN 0 40 5 One story restaurant (FAR: 0.5)1956 1.19 0.45
Transit Corridor 3780 EL CAMINO REAL 94306 137-11-098 0 0 7 0 0.24 CN CN CN CN 0 40 7 One story retail (FAR: 0.4)1950 0.13 0.42
Transit Corridor MAYBELL AV 94306 137-24-045 4 4 0 3 0.56 CN RM-20 CN RM-20 8 40 11 Surface parking 0.02
Transit Corridor 4170 EL CAMINO REAL 94306 137-24-046 11 12 0 10 1.01 CS CS CS CS 0 40 33 One story retail store (FAR: 0.5), surface parking 1996 1.01 3
Transit Corridor 561 VISTA AV 94306 137-37-004 7 7 0 6 0.65 MF RM-30 MF RM-30 16 40 20 One story Faith-based insitution. Congregation Emek Beracha 1975 0.03 2
City Owned Parking Lots WAVERLY ST & LYTTON AVE 94301 120-14-088 14 15 0 13 0.85 CC PF CC PF 0 50 42 Surface parking
City Owned Parking Lots COWPER ST & HAMILTON AVE 94301 120-15-073 11 12 0 10 0.67 CC PF CC PF 0 50 33 Surface parking
City Owned Parking Lots WAVERLY ST & HAMILTON AVE 94301 120-15-086 11 11 0 10 0.64 CC PF CC PF 0 50 32 Surface parking
City Owned Parking Lots EMERSON ST 94301 120-26-027 9 10 0 8 0.54 CC PF CC PF 0 50 27 Surface parking
City Owned Parking Lots NEW MAYFIELD LN 94301 124-32-055 10 10 0 8 0.56 CC PF CC PF 0 50 28 Surface parking
City Owned Parking Lots SHERMAN AVE & PERAL LN 94301 124-33-007 17 18 0 15 1 CC PF CC PF 0 50 50 Surface parking
Faith-Based Institutions 1985 LOUIS RD 94303 003-50-022 9 9 0 8 1.09 SF R-1 SF R-1 0 30 26 Surface parking/vacant land surrounding faith-based insitution
Faith-Based Institutions 1140 COWPER ST 94301 120-18-048 5 5 0 4 0.61 SF R-1 SF R-1 0 30 14 Surface parking/vacant land surrounding faith-based insitution
Faith-Based Institutions 3505 MIDDLEFIELD RD 94306 127-47-042 12 13 0 11 1.5 SF R-1 SF R-1 0 30 36 Surface parking/vacant land surrounding faith-based insitution 3
Faith-Based Institutions 2490 MIDDLEFIELD RD 94301 132-01-083 0 0 11 0 0.46 SF R-1 SF R-1 0 30 11 Surface parking/vacant land surrounding faith-based insitution
Faith-Based Institutions 2890 MIDDLEFIELD RD 94306 132-03-193 6 7 0 5 0.76 SF R-1 SF R-1 0 30 18 Surface parking/vacant land surrounding faith-based insitution 3
Faith-Based Institutions 3149 WAVERLEY ST 94306 132-20-161 5 6 0 5 0.69 SF R-1 SF R-1 0 30 16 Surface parking/vacant land surrounding faith-based insitution 3
GM 860 E CHARLESTON RD 94303 127-15-002 0 0 16 0 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.7), surface parking 1956 1.11 2
GM 4055 FABIAN WY 94303 1271-50-06 0 0 16 0 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.5), surface parking 1957 0.69 1
GM 801 SAN ANTONIO RD 94303 127-15-041 0 0 0 14 0.2 LI GM LI GM 0 90 14 Faith-based insitution (FAR: 0.6), surface parking 1957 1.43 1
GM 799 SAN ANTONIO RD 94303 127-15-042 0 0 16 0 0.23 LI GM LI GM 0 90 16 One story restaurant (FAR: 0.2), surface parking 1960 0.76 2
GM 797 SAN ANTONIO RD 94303 127-15-043 0 0 16 0 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.5), surface parking 1962 1.43 2
GM 830 E CHARLESTON RD 94303 127-15-049 0 0 18 0 0.27 LI GM LI GM 0 90 18 One story auto service (FAR: 0.2), surface parking 1961 0.25 2
GM 809 SAN ANTONIO RD 94303 127-15-050 0 0 25 0 0.37 LI GM LI GM 0 90 25 Two story office space (FAR: 1.4), surface parking 1956 0.89 2
GM 849 E CHARLESTON RD 94303 127-37-001 0 0 16 0 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.5), surface parking 1959 0.47 2
GM E CHARLESTON RD 94303 127-37-002 0 0 0 15 0.22 LI GM LI GM 0 90 15 Surface parking
GM FABIAN WY 94303 127-37-005 0 0 28 0 0.4 LI GM LI GM 0 90 28 One story office space (FAR: 0.5), surface parking 0 2
GM FABIAN WY 94303 127-37-007 0 0 31 0 0.45 LI GM LI GM 0 90 31 Two story office space (FAR: 1.0), surface parking 0 2
GM 811 E CHARLESTON RD 94303 127-37-016 13 13 0 11 0.54 LI GM LI GM 0 90 37 One story auto service (FAR: 0.2), surface parking 1972 0.21 1
GM 3980 FABIAN WY 94303 127-37-018 17 17 0 14 0.69 LI GM LI GM 0 90 48 One story vacant office space (FAR: 0.5), surface parking 1995 1.01 3
GM 3960 FABIAN WY 94303 127-37-019 16 17 0 14 0.68 LI GM LI GM 0 90 47 One story vacant office space (FAR: 0.5), surface parking 1995 0.45 2
GM 3940 FABIAN WY 94303 127-37-023 31 31 0 26 1.27 LI GM LI GM 0 90 88 Two story office space (FAR: 0.8), surface parking 1991 0.51 3
GM 4030 TRANSPORT ST 94303 147-01-013 0 0 0 29 0.45 LI GM LI GM 0 90 29 Two story office space (FAR: 1.2), surface parking 1954 1.13 2
GM 989 COMMERCIAL ST 94303 147-01-016 0 0 0 13 0.19 LI GM LI GM 0 90 13 One story office space (FAR: 0.7), surface parking 1958 1.13 1
GM 977 COMMERCIAL ST 94303 147-01-018 0 0 0 13 0.19 LI GM LI GM 0 90 13 One story office space (FAR: 0.7), surface parking 1957 1.46 2
GM 990 COMMERCIAL ST 94303 147-01-041 19 20 0 17 0.79 LI GM LI GM 0 90 56 Two story office space (FAR: 0.8), surface parking 1999 1 3
GM 4051 TRANSPORT ST 94303 147-01-068 0 0 0 18 0.26 LI GM LI GM 0 90 18 Two story office space (FAR: 1.4), surface parking 1957 0.77 1
GM 4047 TRANSPORT ST 94303 147-01-069 0 0 0 17 0.25 LI GM LI GM 0 90 17 One story office space (FAR: 0.8), surface parking 1956 0.48 1
GM 4045 TRANSPORT ST 94303 147-01-070 13 13 0 11 0.54 LI GM LI GM 0 90 37 Two story office space (FAR: 0.8), surface parking 1957 1.26 1
GM 4041 TRANSPORT ST 94303 147-01-071 0 0 0 16 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.8), surface parking 1959 1.5 1
GM 4039 TRANSPORT ST 94303 147-01-072 0 0 0 16 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.5), surface parking 1959 0.33 3
GM 4035 TRANSPORT ST 94303 147-01-073 0 0 0 16 0.23 LI GM LI GM 0 90 16 One story office space (FAR: 0.5), surface parking 1958 0.63 2
GM 4075 TRANSPORT ST 94303 147-01-079 0 0 0 11 0.16 LI GM LI GM 0 90 11 One story office space (FAR: 0.8), surface parking 1957 0.39 1
GM 4019 TRANSPORT ST 94303 147-01-096 0 0 0 21 0.31 LI GM LI GM 0 90 21 Two story office space (FAR: 1.2), surface parking 1958 0.35 2
GM 4007 TRANSPORT ST 94303 147-01-097 13 13 0 11 0.54 LI GM LI GM 0 90 37 One story office space (FAR: 0.8), surface parking 1957 1.26 1
GM 4067 TRANSPORT ST 94303 147-01-099 0 0 0 17 0.25 LI GM LI GM 0 90 17 Two story medical office space (FAR: 0.7), surface parking 1959 1.08 1
GM 4083 TRANSPORT ST 94303 147-01-116 12 13 0 11 0.51 LI GM LI GM 0 90 36 Two story office space (FAR: 1.0), surface parking 1980 1.5 3
GM 999 COMMERCIAL ST 94303 147-01-122 0 0 0 21 0.3 LI GM LI GM 0 90 21 Two story office space (FAR: 0.9), surface parking 1966 1 2
GM 991 COMMERCIAL ST 94303 147-01-123 0 0 0 24 0.35 LI GM LI GM 0 90 24 One story preschool (FAR: 0.5), surface parking 2005 0.79 2
GM TRANSPORT ST 94303 147-02-017 16 16 0 14 0.66 LI GM LI GM 0 90 46 Surface parking 0
ROLM 1060 E MEADOW CIR 94303 127-10-049 27 28 0 24 1.13 RO ROLM RO ROLM 0 90 79 One story office space (FAR: 0.5), surface parking 1964 0.77 2
ROLM 1066 E MEADOW CIR 94303 127-10-050 52 53 0 45 2.15 RO ROLM RO ROLM 0 90 150 One story office space (FAR: 0.5), surface parking 1976 0.89 2
ROLM 1068 E MEADOW CIR 94303 127-10-051 24 25 0 21 1 RO ROLM RO ROLM 0 90 70 One story office space (FAR: 0.5), surface parking 1974 0.6 2
ROLM 3600 W BAYSHORE RD 94303 127-10-076 51 51 0 43 2.08 RO ROLM RO ROLM 0 90 145 Two story office space (FAR: 0.5), surface parking 1990 1.12 3
ROLM 1053 E MEADOW CIR 94303 127-10-081 39 39 0 34 1.6 RO ROLM RO ROLM 0 90 112 One story office space (FAR: 0.5), surface parking 1970 0.42 2
ROLM 1036 E MEADOW CIR 94303 127-10-094 75 75 0 64 3.06 RO ROLM RO ROLM 0 90 214 One story office space (FAR: 0.5), surface parking 1965 0.58 3
ROLM 1050 E MEADOW CIR 94303 127-10-099 64 64 0 55 2.62 RO ROLM RO ROLM 0 90 183 Two story office space (FAR: 0.4), surface parking 1968 0.44 3
ROLM 3460 W BAYSHORE RD 94303 127-36-029 36 37 0 31 1.49 RO ROLM RO ROLM 0 90 104 Two story office space (FAR: 0.5), surface parking 1970 1 3
Stanford Sites PASTEUR DRIVE + 1100 WELCH RD 94305 142-03-038, 142-05-032 0 0 0 425 8.4 RO RM-40 MF RM-40 31 40 425 Portable structures, surface parking
Stanford Sites 3128 EL CAMINO REAL 94306 142-20-035, 142-20-079, 142-20-080 0 0 0 144 1.23 CS CS CS CS 0 30 144 One story fast food restaurant (FAR: 0.2), surface parking 1974 0.94 3
Developer Interest 3398, 3400, 3490 EL CAMINO REAL 94306 137-08-072 40 41 34 0 3.6 CS CS CS CS 0 40 115 One story auto service (FAR: 0.5), surface parking
Developer Interest 550 HAMILTON AV 94301 120-04-005 14 15 13 0 1.32 CC PC CC PC 0 40 42 Three story office space (FAR: 0.7), surface parking 1971 0.85 3
Developer Interest 980 MIDDLEFIELD RD 94301 120-05-077 5 6 5 0 0.51 MF PC MF PC 0 40 16 One story commercial space (FAR: 0.8)1951 2
Developer Interest 955 ALMA ST 94301 120-28-096 0 0 7 0 0.24 SOFA II CAP RT-35 SOFA II CAP RT-35 0 40 7 One story office space (FAR: 0.8)1947 1.65 3
Developer Interest 70 ENCINA AV 94301 120-34-006 0 0 0 4 0.14 CC CC CC CC 0 40 4 Surface parking
Developer Interest 705 SAN ANTONIO RD 94303 127-15-045 6 6 5 0 0.56 CS CS CS CS 0 40 17 Auto service
Developer Interest 3997 FABIAN WAY 94303 127-37-003 0 0 8 0 0.28 LI GM LI GM 0 40 8 Surface parking
Developer Interest 2951 EL CAMINO REAL 94306 132-37-052 0 0 10 0 0.33 CS CS CS CS 0 40 10 One story office space (FAR: 0.4), surface parking 1975 0.63 3
Developer Interest 300 LAMBERT AV 94306 132-38-061 0 0 10 0 0.33 CS CS CS CS 0 40 10 One story auto service (FAR: 0.7), surface parking 1970 0.94 1
Developer Interest 340 PORTAGE AV (1 acre site & DA)94306 132-38-071 17 18 24 0 13 MF RM-30 MF RM-30 0 40 59 One story commercial use
Developer Interest 3300 EL CAMINO REAL 94306 142-20-046 33 34 29 0 3.01 RO RP RO RP 0 40 96 Surface parking
Developer Interest 3150 EL CAMINO REAL 94306 142-20-054 8 9 7 0 0.75 CS CS CS CS 0 40 24 One story Restaurant (FAR: 0.3), surface parking 1969 0.65 2
Developer Interest 808-814 SAN ANTONIO RD 94303 147-03-043 0 0 0 7 0.44 CS CS CS CS 0 40 7 One story car rental (FAR: 0.4), Surface parking 1956 0.42 2
Developer Interest 4225 MIDDLEFIELD RD 94303 147-05-068 6 6 5 0 0.54 CS CS CS CS 0 40 17 One story commercial use
Developer Interest 4233 MIDDLEFIELD RD 94303 147-05-069 8 9 7 0 0.77 CS CS CS CS 0 40 24 One story auto service
Developer Interest 708-710 SAN ANTONIO RD 94303 147-05-090 0 0 8 0 0.26 CS CS CS CS 0 40 8 Auto service
Developer Interest 762 SAN ANTONIO RD 94304 147-05-102 10 10 9 0 0.93 CS CS CS CS 0 40 29 Truck rental
Developer Interest 4345 EL CAMINO REAL 94306 148-09-011 11 11 9 0 0.99 CS CS CS CS 0 40 31 Two story lodging. The Palo Alto Country Inn (FAR: 0.4), surface parking 1953 0.38 2
Table C: Land Use
Zoning Designation General Land Uses Allowed
R‐1 Low density residential (Chapter 18.12)
RM‐20 Multi‐family residential uses (Chapter 18.13)
RM‐30 Multi‐family residential uses (Chapter 18.13)
RM‐40 Multi‐family residential uses (Chapter 18.13)
CS Residential and non‐residential uses (Chapter 18.16)
CN Residential and non‐residential uses (Chapter 18.16)
CC Residential and non‐residential uses (Chapter 18.16)
CD‐C Residential and non‐residential uses (Chapter 18.18)
CD‐N Residential and non‐residential uses (Chapter 18.18)
RT‐35 Residential and non‐residential uses up to 35 feet
RT‐40 Residential and non‐residential uses up to 40 feet
RT‐50 Residential and non‐residential uses up to 50 feet
GM Light manufacturing, research, and commercial services uses (Chapter 18.20)
ROLM Light manufacturing, research, and commercial services uses (Chapter 18.20)
PC Any use in accordance with approved development plan (Chapter 18.38)
PF Public facilities (Chapter 18.28)
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A NALYSIS OF L AND U SE C ONTROLS
This section analyzes the impact of all relevant land use controls on whether, independently and
cumulatively, they present a constraint on the development of a variety of housing types. In summary,
this analysis reveals standards that represent a constraint to achieving housing production at densities
specified in the existing regulations and/or rezonings identified to meet the RHNA. First, the ground-level
landscaping requirement, generally 20 percent minimum, acts as a lot coverage limitation in the
commercial mixed use districts and represents a constraint to housing production at densities identified
in the Sites Inventory. The landscaping standard is proposed to be modified as part of the Program 1.1
zoning changes in order to achieve the stated density. Second, proposed density changes in the ROLM to
meet the RHNA, from 30 du/ac to 65 du/ac, will mean that other existing standards, such as height, FAR,
landscaping/lot coverage, or parking, will be constraints to achieving the density threshold. These
standards are also proposed to be modified as part of Program 1.1 to facilitate housing production at
stated densities.
To evaluate constraints, the City has prepared physical site test models of all development standards
specified in the Zoning Ordinance and summarized in the tables above , including setbacks, coverage,
density, FAR, open space, building height, and parking.
These models illustrate that multi-family development is physically feasible in all zones that allow housing,
including on the smaller sites in the Sites Inventory. Townhomes are feasible in all scenarios. Stacked flats
are generally feasible, but larger sites (above 10,000 sq. ft.) and/or corner lots are better for allowing
parking and circulation access. Smaller sites and interior lots are generally more constrained. However, as
detailed further below, in some instances, development standards need to be modified to achieve the
RHNA densities projected for some properties in the Sites Inventory.
Notably, residential density and parking standards do not correlate. Since the City requires 1 space/unit
for studios and 1-bedrooms, but 2 spaces/unit for 2+ bedrooms, in a hypothetical project, the same
amount of parking can serve either more studios/1-bedrooms (higher densities) or fewer 2+ bedroom
units (lower densities). These parking requirements apply to all multifamily projects regardless of zone.
Multifamily projects are being approved and built in Palo Alto in townhome and stacked flat
configurations, which suggests that projects are financially feasible for at least these projects. Some of
these projects take advantage of the Housing Incentive Program or State Density Bonus Law for increased
density, which generally improves financial feasibility for low and moderate-density buildings using wood
construction.
Housing development projects that meet objective development and design standards have a high level
of certainty for approval, potentially within 60 days of completeness for projects undergoing the City’s
Streamlined Review Process (subject to one study session with the ARB) or other State streamlining bills
(e.g., SB35 or AB2162) and exempt from CEQA. Projects that seek exceptions and utilize the subjective
Context-Based Design Criteria and Architectural Review Process are subject to subjective findings and up
to three public hearings with the ARB.
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Figure 4-2 CD(C) Zone Model
This 5,125 square foot CD(C) site accommodates four dwelling units in a townhome typology. This district
does not have setback or residential density standards, but does have a 50-foot height limit (which
reduces to 40 feet at the front of the site which is within 150 feet of a lower density residential district ).
At 1.23 FAR, this model exceeds the base FAR of 1.0, but is still below the Housing Incentive Program limit
of 3.0 FAR. FAR is the density limit for the district since there is no residential density standard expressed
in du/ac. The model also achieves the ground-level 20 percent landscape and 150 square feet/unit open
space requirements, average unit size maximum of 1,500 square feet, and provides 2 parking spaces per
unit in a tandem configuration. The resulting 3-story townhome attached townhome typology is a wood
construction type that is cost effective and commonly found in the area.
Existing zoning and proposed Housing Element programs provide a path to achieve more units and change
housing and construction types to stacked flats. . In the absence of a maximum density expressed in
dwelling units per acre, various development standards would need to be modified to increase density on
the site. For example, based the City’s analysis, the percent ground-level landscaping standard precludes
the project from achieving the allowable density and therefore represents a constraint on housing
production at the 50 du/ac threshold identified in the Sites Inventory for sites within 1/4 mile of major
transit. As part of Program 1.1, standards will be modified to allow the landscaping standard to be met
above ground-level (e.g., on a courtyard or the rooftop). This change could allow podium construction,
accommodate more units and parking, still within the existing height limit. Further, 100 percent below-
market rate projects could benefit from other development standards through the existing HIP to achieve
4-29
substantially more units per acre. AB2097 also exempts this site from parking requirements altogether,
which would also increase unit yield beyond what is illustrated here.
Figure 4-3 CN Zone Model
This 15,800 square foot CN site accommodates 12 apartments and ground-floor retail in a mixed-use
typology. Key standards modeled include setbacks, 20 percent ground-floor landscape coverage, 35-foot
maximum building height, and the land use requirement to provide ground-floor retail. There is no
maximum residential density expressed in du/ac for sites on El Camino Real in this district, but FAR of 1.5
and lot coverage of 100 percent is permitted with the Housing Incentive Program. The model provides the
required 21 parking spaces in a below-grade garage. Although subterranean parking is a high cost option,
it is somewhat common in Palo Alto.
The ground-level landscaping requirement represents a constraint to achieving the 40 du/ac density
threshold identified in the Sites Inventory for this site which is located within a ½ mile of a major transit
corridor. Program 1.1 addresses the zoning constraint imposed by modifying the landscaping coverage
standard to achieve Sites Inventory densities.
To incentivize greater housing production potential, as an alternative to State Density Bonus Law, Program
3.4 proposes changes to the Housing Incentive Program. For example, greater building height and
adjustments to the daylight plane, could be used to achieve more density, while bringing the parking
above-grade. Further, the Housing Incentive Program offers 100 percent below-market rate projects relief
from these other development standards, including parking as low as 0.75/unit, height up to 50 feet, and
landscaping above the ground-floor.
4-30
Figure 4-4 RM-20 Zone Model
This 10,000 square foot site accommodates four townhome units, achieving 18 du/ac in a zone that allows
20 du/ac. The model takes into account setbacks, 30-foot height limit, daylight plane requirements, 35
percent lot coverage, 35 percent ground-floor landscaping and 150 square feet per unit open space
requirements and achieves the 8 parking spaces required for 3- and 4-bedroom units through tuck-under
and surface parking. State law already allows up to at least 1.0 FAR. The resulting 3-story attached
townhome typology is a wood construction type that is cost effective and commonly found in the area.
Surface and tuck-under parking are likewise cost effective.
Existing zoning and proposed Housing Element programs provide a path for how to achieve even more
units. Program 1.1A requires RM sites to receive a density increase, in this case from 20 to 30 du/ac. This
would provide the option of more and smaller units (i.e., studios and 1-bedrooms) which carry lower
parking requirements. Thus, this site could achieve five or six units (up to 26 du/ac) while still providing
just seven or eight total parking spaces.
4-31
Figure 4-5 RM-30 Zone Model
This 6,600 square foot site accommodates four townhome units, achieving 27 du/ac in a zone that allows
30 du/ac. The model takes into account setbacks, 35-foot height limit, daylight plane requirements, 40
percent lot coverage, 35 percent ground-floor landscaping and 150 square feet per unit open space
requirements, and achieve the 8 parking spaces required through tuck-under parking. State law already
allows up to at least 1.0 FAR. The resulting 3-story attached townhome typology is a wood construction
type that is cost effective and commonly found in the area.
Existing zoning and proposed Housing Element programs provide a path for how to achieve even more
units. Program 1.1A requires RM sites to receive a density increase, in this case from 30 to 40 du/ac. This
would provide the option of more and smaller units (i.e., studios and 1-bedrooms) which carry lower
parking requirements. Thus, this site could achieve up to six units (up to 40 du/ac) while still providing six
to eight total parking spaces.
4-32
Figure 4-6 RM-40 Zone Model – Parking Compliant with City Code
This 5,000 square foot site accommodates four apartments, achieving 35 du/ac in a zone that allows 40
du/ac. The model takes into account setbacks, 40-foot height limit, daylight plane requirements, 45
percent lot coverage, 20 percent ground-floor landscaping and 150 square feet per unit open space
requirements, and achieves the 7 parking spaces required through a ground-level garage. State law
already allows up to at least 1.0 FAR. The resulting 3-story attached townhome typology is a wood
construction type that is cost effective and commonly found in the area.
State law, existing zoning and proposed Housing Element programs provide a path for how to achieve
even more units. Program 1.1A requires RM sites, to receive a density increase, in this case from 40 to 50
du/ac. On smaller sites distant from transit, mechanical lifts may be necessary to meet parking
requirements while still allowing for circulation in the driveway and garage. Mechanical lifts are allowed
and have been used in Palo Alto as a viable way to shrink the footprint devoted to parking.
Larger sites (e.g., 10,000 sq. ft.) allow for improved garage and driveway circulation that can physically
accommodate parking. But, the City also modeled a 5,000 square foot interior lot, as opposed to a corner
lot, which proved to be more challenging to design driveways and garage circulation. On interior lots, no
parking or reduced parking strategies allowed for higher unit yields. Sites located within ½-mile of transit
may invoke AB2097 parking reductions that would allow for additional unit yield up to 50 du/ac.
4-33
On this small site, to achieve five units (up to 50 du/ac), the model could develop a range of studios or 1-
bedrooms (which carry lower parking requirements) thereby achieving the maximum density while still
providing up to seven total parking spaces, even without the use of mechanical lifts.
Figure 4-7 ROLM Zone Model – Existing Zoning: 16 du/ac Yield
This 1-acre ROLM site accommodates 16 townhome units, achieving 16 du/ac in a zone that allows 30
du/ac. This zone district generally follows the RM-30 zoning standards. Therefore, the model takes into
account setbacks, 35-foot height limit, daylight plane requirements, 40 percent lot coverage, 35 percent
ground-floor landscaping and 150 square feet per unit open space requirements, and achieves the 32
parking spaces required. The resulting 3-story attached townhome typology is a wood construction type
that is cost effective and commonly found in the area.
4-34
However, this model is not achieving the full allowable density, which allows for up to 30 dwelling units.
With the current standards, 30 units are not feasible on this 1-acre site. This is primarily due to the 40
percent lot coverage and 0.6 FAR limits, and to some extent the depth of the parcel which necessitates a
full hammerhead design to accommodate Fire Department access. These standards represent a constraint
to achieving the density set forth in the code. Ways to rectify this constraint are described below.
Figure 4-8 ROLM Zone Model – Existing Zoning: 30 du/ac Yield
The figure above explores what it will take to achieve 30 du/ac and transition from a townhome to an
apartment typology, namely: (1) a taller height limit (from 35 to 45 feet) to accommodate unit sizes and
allow for all tuck under parking, (2) increased lot coverage from 40 percent to 70 percent, (3) FAR of
1.25; (4) parking reduced to 1 space per studio/1-bedroom and 1.25 spaces per 2+ bedroom.
However, the Housing Element strategy for this portion of the GM/ROLM in Bayshore in the Sites
Inventory anticipates a density of up to 70 du/ac, as shown below.
Figure 4-9 ROLM Zone Model – Proposed Zoning (Program 1.1): 70 du/ac Yield
4-35
Proposed Housing Element programs provide a path for how to achieve a density of 70 du/ac. At this
density, the housing typology transitions to stacked flats (apartments or condos). In addition to increasing
density standards, this model assumes a number of possible changes to development standards that
would reduce this constraint: (1) height limit from 35 to 55 feet; (2) lot coverage increase from 40 percent
to 70 percent, (3) FAR up to 2.0; (4) allowance for the 20 percent landscaping requirement to be met
above the ground-floor; and (5) 1 space per studio/1-bedroom and 1.25-1.5 spaces per 2+ bedroom.
Program 1.1 addresses the zoning constraint imposed by existing zoning regulations by modifying a
combination of standards, such as height, FAR, lot coverage, landscaping, and parking to enable housing
production at the density proposed in the Sites Inventory.
S INGLE R OOM O CCUPANCY U NITS
The Palo Alto Zoning Ordinance allows Single Room Occupancy (SRO) units as a multiple tenant structure
with individual resident rooms. The City permits SRO units in CN, CC, and CS zones and multi-family
residential zoning districts as shown in Table 4-3 using development standards that encourage the
construction of the maximum number of units. Sites that have access to community services and public
transportation are highly desired for SRO residents. Tenants typically share bathrooms and/or kitchens,
while some rooms may include kitchenettes, bathrooms, or half-baths.
REVISED 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: Clare Campbell, Manager of Long
Range Planning
PREPARED WITH THE ASSISTANCE OF: Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
REPORT DATE: November 2023
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CITY OF PALO ALTO P a g e | i
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 ................................................................. 11
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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CITY OF PALO ALTO P a g e | 1
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
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 3
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: Clare Campbell, Manager of Long Range Planning, Clare.Campbell@cityofpaloalto.org
650-617-3191
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
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 7
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 299 sites that could provide housing to meet the City’s RHNA and buffer. These
sites are shown on Figure 3.
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Figure 3 Housing Element Update Sites Inventory Locations
PROJECT DESCRIPTION
1 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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. Entitled development would generate 452 units within the city.
Twenty pipeline projects have also been identified generating 824 units. Total entitled and
proposed development would generate 1,276 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 1,276 units and the 512 projected ADUs towards
total RHNA (and buffer) of 6,695 units, there is a shortfall of 4,907 units. The proposed HEU
identifies 279 sites that could accommodate 5,005 units2 to meet the RHNA allocation during
the 2023-2031 period plus an additional buffer. Most of the parcels are developed but
underutilized. Parcels that were considered during this phase included:
Underutilized sites such as lots with uses that are no longer needed or need rehabilitation
Locations where housing could be denser
Locations near public transit and services
Locations where housing could be added near commercial buildings or in business parks to
create “live-work” neighborhoods
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 299 sites identified to meet RHNA, the majority (157 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.
2 Note that the identified sites’ yield of 5,005 exceeds the calculated shortfall of 4,907 units by 98 units; the revised total unit
yield to meet RHNA is 6,793 units.
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STRATEGIES TO MEET RHNA
The City identified nine strategies to identify additional housing opportunity sites to
accommodate for the remaining total shortfall of 4,907 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 157 sites would be rezoned and these rezoned sites would have a
capacity for an estimated 3,948 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.
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
PROJECT DESCRIPTION
1 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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 AND EL CAMINO REAL & PAGE MILL ROAD FOCUS AREA 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. In addition, sites surrounding the Stanford University-owned sites in the El Camino
Real & Page Mill Road Focus Area have been identified for housing. Program 1.1 would increase
development intensity in the El Camino Real & Page Mill Road Focus Area to allow FARs up to
4.0 and heights up to 85 feet.
ADDITIONAL SITES IDENTIFIED BY CITY STAFF
Twenty-two 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).
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TOTAL SITES INVENTORY
Table 2 shows the total inventory of sites and units to meet the RHNA of 6,086 units. 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
6,793 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
Approved and Entitled – Credit N/A1 452
ADU – Credit N/A2 512
Planned Units (Pipeline) 20 824
Underutilized Sites (no rezoning required) 122 1,057
Rezoning to Meet the RHNA 157 3,948
Total 299 6,793
1 The project sites (11) for entitled developments are not counted in the 299 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.
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.
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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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 299 sites identified to meet RHNA and 122 of those sites do not
require a zone change. Therefore, while they are identified sites for 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,
20 pipeline sites have been removed from the CEQA buildout assumptions because they are
already undergoing or have already undergone project-specific review. Lastly, one site has been
added to the CEQA analysis. Therefore, as shown on Table 3, 280 sites are analyzed for the
purposes of CEQA.
In addition, the CEQA analysis assumes a higher unit yield than what is shown on Table 2
because of an assumed higher density assigned to the RHNA 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. Therefore, as shown on Table 3, the assumed
unit yield associated with the 280 sites is 6,860 units.
In addition, 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 240 sites with a yield of 6,919 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 280 6,860
Sites adjusted or removed for CEQA review2 (122) (1,057)
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 240 6,919
( ) denotes subtraction
1 These sites have been reduced to not include the Planned Units/Pipeline count reflected in Table 2. The CEQA unit yield is higher than the
RHNA sites yield because of an assumed higher density development assigned to some of the sites.
2 These sites do not involve changes in development density (122 sites with 1,057 units) or involve pipeline projects (20 sites with 824 units);
therefore, they have been excluded from the CEQA buildout or adjusted 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 919 more residential
units and 3,287 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 6,919 +919
New Population (# of people) 14,080 17,3671 +3,287
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
919 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 919 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 919 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
3 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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2 Agriculture and Forestry Resources
Where was
Impact
Analyzed in
the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Convert Prime Farmland,
Unique Farmland, Farmland
of Statewide Importance
(Farmland), as shown on
maps prepared pursuant to
the Farmland Mapping and
Monitoring Program of the
California Resources Agency,
to non-agricultural use?
EIR Pages 7-1
through 7-2
No No No N/A
b. Conflict with existing zoning
for agricultural use or a
Williamson Act contract?
EIR Pages 7-1
through 7-2
No No No N/A
c. Conflict with existing zoning
for, or cause rezoning of,
forest land (as defined in
Public Resources Code
Section 12220(g));
timberland (as defined by
Public Resources Code
Section 4526); or timberland
zoned Timberland
Production (as defined by
Government Code Section
51104(g))?
EIR Pages 7-1
through 7-2
No No No N/A
d. Result in the loss of forest
land or conversion of forest
land to non-forest use?
EIR Pages 7-1
through 7-2
No No No N/A
e. Involve other changes in the
existing environment which,
due to their location or
nature, could result in
conversion of Farmland to
non-agricultural use or
conversion of forest land to
non-forest use?
EIR Pages 7-1
through 7-2
No No No N/A
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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CITY OF PALO ALTO P a g e | 3 3
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
3 4 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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3 Air Quality
Where was
Impact Analyzed
in the EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Conflict with or obstruct
implementation of the
applicable air quality
plan?
EIR Pages 4.2-2
through 4.2-13
No No No No
b. Result in a cumulatively
considerable net
increase of any criteria
pollutant for which the
project region is non-
attainment under an
applicable federal or
state ambient air quality
standard?
EIR Pages 4.2-13
through 4.2-21
No No No No
c. Expose sensitive
receptors to substantial
pollutant
concentrations?
EIR Pages 4.2-22
through 4.2-29
No No No No
d. Result in other emissions
(such as those leading to
odors) adversely
affecting a substantial
number of people?
EIR Pages 4.2-29
through 4.2-31
No No No N/A
ANALYSIS IN PREVIOUS ENVIRONMENTAL DOCUMENTS
Section 4.2, Air Quality, of the 2017 EIR analyzed the 2030 Comprehensive Plan’s impacts
related to air quality. The 2017 EIR found that implementation of the 2030 Comprehensive Plan
could conflict with or obstruct the implementation of the 2010 Bay Area Clean Air Plan.
Although Scenario 6 was found to result in a lower vehicle miles traveled (VMT) per capita and
a lower VMT per service population than under existing conditions at the time, it could not be
verified whether the 2030 Comprehensive Plan would aid or hinder implementation of control
measures outlined in the 2010 Bay Area Clean Air Plan. Therefore, Mitigation Measure AIR-1
would be required to reduce impacts to a less than significant level.
The 2017 EIR also found that the 2030 Comprehensive Plan could violate an air quality
standard; contribute substantially to an existing or project air quality violation; and/or result in
a cumulatively considerable net increase of any criteria pollutant for which the project region is
nonattainment under an applicable federal or State ambient air quality standard, resulting in
significant and unavoidable impacts. Even with implementation of mitigation measures AIR-2a
through 2d, impacts would be significant since future development projects would contribute
to increases in concentrations of air pollutants.
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 17.3 percent over baseline 2015 conditions and would not exceed the rate of
increase from the forecast population of approximately 24.8 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.
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 86,756 17,219 24.8%
Vehicle Trips 96,097 112,696 16,599 17.3%
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 17.3 percent over baseline
2015 conditions, it would not exceed the rate of increase from the forecast population growth
of approximately 24.8 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 919 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-cancer5 health impacts (CARB 2021).
Generation of DPM from construction typically occurs in a single area for a short period.
Construction of development facilitated by the project would occur over approximately a
decade, but use of diesel-powered construction equipment in any one area would likely occur
for no more than a few years for an individual project and would cease when construction is
completed in that area. It is impossible to quantify risk without identified specific project
details, timelines, and locations.
Projects developed under the proposed HEU would be required to comply with applicable
BAAQMD regulatory requirements and control strategies and the CARB In-Use Off-Road Diesel
Vehicle Regulation, which are intended to reduce emissions from construction equipment and
activities. Additionally, future development facilitated by the proposed HEU would be required
to comply with Mitigation Measure AQ-2a of the 2017 EIR, requiring implementation of
construction emission measures that would reduce construction-related TACs. According to the
OEHHA, construction of individual projects lasting longer than two months or placed within
1,000 feet of sensitive receptors could potentially expose nearby sensitive receptors to
substantial pollutant concentrations and therefore could result in potentially significant risk
impacts (OEHHA 2015). These projects could exceed BAAQMD’s thresholds of an increased
cancer risk of greater than 10.0 in a million and an increased non-cancer risk of greater than 1.0
Hazard Index (Chronic or Acute). Therefore, construction impacts from TAC emissions would be
5 Non-cancer risks include premature death, hospitalizations and emergency department visits for exacerbated chronic heart
and lung disease, including asthma, increased respiratory symptoms, and decreased lung function (CARB 2021a).
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potentially significant. However, future development would be required to comply with
Mitigation Measure AIR-3a of the 2017 EIR, which outlines requirements for the preparation of
health risk assessments (HRA) and the inclusion of best practices, as well as Policy N-5.6 of the
2030 Comprehensive Plan, adopted in compliance with Mitigation Measure AIR-3b of the 2017
EIR, which would ensure compliance with BAAQMD requirements. Therefore, this impact would
be less than significant with mitigation, and would be generally the same as for the 2030
Comprehensive Plan as analyzed in the 2017 EIR. There would be no new or substantially more
severe significant impacts than what was analyzed in the 2017 EIR, and further analysis is not
warranted.
OPERATION
In the Bay Area, there are several urban or industrialized communities where the exposure to
TACs is relatively high in comparison to others. The City of Palo Alto is not located in an
impacted community according to BAAQMD CEQA Guidelines. Sources of TACs include, but are
not limited to, land uses such as freeways and high-volume roadways, truck distribution
centers, ports, rail yards, refineries, chrome plating facilities, dry cleaners using
perchloroethylene, and gasoline dispensing facilities (BAAQMD 2017a). Operation of
development facilitated by the project would not involve these uses, and therefore, would not
be considered a source of TACs. In addition, residences do not typically include new stationary
sources onsite, such as emergency diesel generators. However, if a residential project did
include a new stationary source onsite, it would be subject to BAAQMD Regulation 2, Rule 2
(New Source Review) and require permitting. This process would ensure that the stationary
source does not exceed applicable BAAQMD health risk thresholds. Development facilitated by
the project would be required to comply with the residential indoor air quality requirements in
the Title 24 Building Energy Efficiency Standards, which currently require Minimum Efficiency
Reporting Value 13 (or equivalent) filters for heating/cooling systems and ventilation systems in
residences (Section 150.0[m])). Therefore, this impact would be less than significant, and would
be generally the same as the impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan.
There would be no new or substantially more severe significant impacts than what was
analyzed in the 2017 EIR, and further analysis is not warranted.
PROJECT SITING
Development facilitated by the project would occur under the jurisdiction of BAAQMD. CARB
screening methodology for project siting is used in this analysis. In 2005, CARB issued
recommendations to avoid siting new residences within 500 feet of a freeway, urban roads with
100,000 vehicles/day, or rural roads with 50,000 vehicles/day or close to known stationary TAC
sources (CARB 2005). BAAQMD’s average daily traffic (ADT) threshold is lower, at 10,000
vehicles per day (BAAQMD 2017a).
Development facilitated by the project could place sensitive receptors living in housing within
approximately 500 to 1,000 feet of roadways with more than 10,000 annual average daily
traffic (AADT), and highways or freeways. Examples of roadways with over 10,000 vehicles per
day include US 101, SR 82/El Camino Real, I-280, Middlefield Road, Alma Street, Foothill
Expressway/Junipero Serra Boulevard, University Avenue, Embarcadero Road, Oregon
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 919 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
5 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
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4 Biological Resources
Where was
Impact
Analyzed in the
EIR?
Could Proposed
Changes
Involve New or
Substantially
More Severe
Impacts?
Do New
Circumstances
Result in New
or Substantially
More Severe
Impacts?
Does New
Information
Result in New
or Substantially
More Severe
Significant
Impacts?
Do 2017 EIR
Mitigation
Measures
Address
and/or
Resolve
Impacts?
Would the project:
a. Have a substantial
adverse effect, either
directly or through
habitat modifications, on
any species identified as
a candidate, sensitive, or
special status species in
local or regional plans,
policies, or regulations,
or by the California
Department of Fish and
Wildlife or U.S. Fish and
Wildlife Service?
EIR Pages 4.3-6
through 4.3-8
No No No Yes
b. Have a substantial
adverse effect on any
riparian habitat or other
sensitive natural
community identified in
local or regional plans,
policies, or regulations,
or by the California
Department of Fish and
Wildlife or U.S. Fish and
Wildlife Service?
EIR Pages 4.3-8
through 4.3-9
No No No N/A
c. Have a substantial
adverse effect on state
or federally protected
wetlands (including, but
not limited to, marsh,
vernal pool, coastal, etc.)
through direct removal,
filling, hydrological
interruption, or other
means?
EIR Pages 4.3-8
through 4.3-9
No No No N/A
d. Interfere substantially
with the movement of
any native resident or
migratory fish or wildlife
species or with
established native
resident or migratory
wildlife corridors, or
impede the use of native
wildlife nursery sites?
EIR Page 4.3-9 No No No Yes
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 919 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 919
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 919 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 919 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 919 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 919 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 919 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 919 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 919 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 919 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 919 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 919 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 919 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 919 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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CITY OF PALO ALTO P a g e | 7 9
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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CITY OF PALO ALTO P a g e | 8 1
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 1,047 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 919 units facilitated by the proposed project would
generate approximately 4,036 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 47 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 919 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 26 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 178 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 4,288 MTCO2e per year. As discussed in Section 14, Population and
Housing, the service population from the project would be 2,307 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 4,036
Area 47
Energy 0
Water 26
Waste 178
Refrigerants 1
Total 4,288
Service Population 2,307
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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CITY OF PALO ALTO P a g e | 8 3
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 June
2023 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 2023a, 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 919 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 919 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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CITY OF PALO ALTO P a g e | 8 9
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 919
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 919 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 919 more residential units
than analyzed under the 2017 EIR, future development would be required to comply with
federal, State, and local regulations pertaining to hazards and hazardous materials which would
reduce impacts to a less than significant level. Therefore, the project would not result in new
significant effects not addressed in the prior EIR, and no new mitigation measures are
warranted. This issue does not require further study in an EIR.
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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 2022c). 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 919 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
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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 6,793 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 2023b). 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 919 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-19, MRZ-3 10, or MRZ-4 11,
meaning that no significant mineral deposits are present or data does not exist to identify the
significance of mineral deposits (City of Palo Alto 2017a). Therefore, there would be no impacts
regarding mineral resources, generally the same as the impact analyzed in the 2017 EIR for the
2030 Comprehensive Plan. Because here would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
9 MRZ-1: Adequate information indicates that no significant mineral deposits are present or likely to be present.
10 MRZ-3: The significance of mineral deposits cannot be determined from the available data.
11 MRZ-4: There is insufficient data to assign any other MRZ designation.
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 919 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 919 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 17.3 percent. It is unlikely that
a vehicle trip growth of 17.3 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 17.3
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 919 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 919 more residential units compared to Scenario 6 of
the 2017 EIR, it would place more sensitive receptors in proximity to existing railways. These
additional receptors would be exposed to similar vibration levels as considered in the 2017 EIR.
While vibration impacts related to rail pass-bys would be short-term, temporary, and generally
restricted to the areas in the immediate vicinity of a railway, vibration effects from on-going rail
pass-bys could be objectionable. These vibration effects can range from no perceptible effects
at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate
levels, to slight structural damage at the highest levels. Vibration from rail pass-bys rarely
reaches the levels that can damage structures, but groundborne vibration and groundborne
noise can reach perceptible and audible levels in buildings that are close to railways. As such,
appropriate setbacks, buffers, and/or other measures can largely eliminate these impacts since
these basic techniques are particularly effective approaches to avoid vibration impacts.
However, individual project review would still be needed to ensure appropriately reduced
vibration impacts arising from rail pass-bys. Future development would also be required to
comply with policies N-6.3, 6.11, and 6.14 of the 2030 Comprehensive Plan, adopted in
compliance with Mitigation Measures NOISE-5a and NOISE-5b of the 2017 EIR, which would
reduce railway pass-by vibration impacts to a less than significant level, generally the same as
the impact for the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new
or substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
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c. For a project located within the vicinity of a private airstrip or an airport land use plan or,
where such a plan has not been adopted, within two miles of a public airport or public use
airport, would the project expose people residing or working in the project area to excessive
noise levels?
As discussed in the 2017 EIR, the City of Palo Alto owns and operates the Palo Alto Airport
(KPAO), a relatively small public air facility which primarily serves single-engine, general aviation
(GA) aircraft. At the nearest points within city limits, Palo Alto is located approximately 2.6
miles to the west of Moffett Federal Airfield (KNUQ), 6 miles to the southeast of San Carlos
Airport (KSQL), 10 miles to the northwest of the San Jose International Airport (SJC), 15 miles to
the southeast of San Francisco International Airport (SFO), and 17 miles to the south of Oakland
International Airport (OAK) (City of Palo Alto 2017a). As shown in Figure 5 of the Palo Alto
Airport CLUP, none of the housing inventory sites are located within the airport’s 55 to 70 CNEL
noise contours, and therefore would not exceed the “Normally Acceptable” noise levels for
compatibility for those land uses. Nonetheless, as with the 2017 EIR, future development would
be required to comply with policies L-10.3 and N-6.12 of the 2030 Comprehensive Plan,
adopted in compliance with Mitigation Measure NOISE-1b, which would reduce impacts from
airport or heliport noise to a less than significant level. Therefore, impacts would be less than
significant with mitigation, and would be generally the same as the impact for the 2017 EIR for
the 2030 Comprehensive Plan. Because there would be no new or substantially more severe
significant impacts than what was analyzed in the 2017 EIR, further analysis is not warranted.
CONCLUSION
Although the proposed HEU would facilitate the development of 919 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 6,919 new
residential units in the city by the year 2031, or approximately 919 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 919 units compared to Scenario 6
would lead to an increase of approximately 2,307 new residents during the housing element
cycle 2023 to 2031 assuming all of the estimated 919 units are built (DOF 2022).
Although the proposed HEU would increase residential units compared to Scenario 6, the State
requires that all local governments adequately plan to meet the housing needs of their
communities. Given that the State is currently in an ongoing housing crisis due to an insufficient
housing supply, the additional units under the proposed project would further assist in
addressing the existing crisis and meeting the housing needs of the City’s communities.
Furthermore, the proposed HEU would first be submitted to the HCD for review and approval
to ensure that it would adequately address the housing needs and demands of the city.
Approval by the HCD would ensure that population and housing growth under the proposed
HEU would not be substantial or unplanned.
Additionally, growth under the proposed HEU would be concentrated in locations where such
development is encouraged by adopted plans due to their proximity to transit and
transportation corridors as well as located near commercial uses and services and on
underutilized sites. The proposed HEU would facilitate infill growth, promote housing in close
proximity to employment opportunities, and support regional planning efforts.
Lastly, this analysis is conservative because it assumes a maximum buildout scenario. The
project’s actual contribution to population growth may be less than estimated. In addition, the
project would not involve the extension of roads or other infrastructure that could indirectly
lead to population growth. The city is mostly developed and is supported by existing public
services and infrastructure which are sufficient to serve the additional housing units. Therefore,
the project would not result in substantial unplanned population growth, either directly or
indirectly, and impacts would be less than significant, generally the same as the impact
analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no new or
substantially more severe significant impacts than what was analyzed in the 2017 EIR, further
analysis is not warranted.
b. Would the project displace substantial numbers of existing people or housing, necessitating
the construction of replacement housing elsewhere?
“Substantial” displacement would occur if the proposed project would displace more
residences than would be accommodated through growth facilitated by the project. The goal of
the proposed project is to accommodate and encourage new residential development in Palo
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Alto. A portion of the housing units would be developed at a density range that could
accommodate low and very low-income housing as required to meet the 6th Cycle RHNA.
Development under the proposed HEU would result in 919 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 919 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 2022d).
Although the proposed HEU would increase the number of residential units by 919 compared to
Scenario 6 of the 2017 EIR, future development would be facilitated on non-vacant and
underutilized sites in urbanized areas such as along El Camino Real, the California Avenue area,
the Downtown area, and in the GM/ROLM zones which are already served by existing fire
stations. Future remodeling or expansion of PAFD facilities to accommodate new equipment
would not be needed to specifically to serve the additional residential units, which would be
added incrementally in various locations in the city and served by more than one fire station.
Therefore, impacts would be less than significant, and would be generally the same as the
impact analyzed in the 2017 EIR for the 2030 Comprehensive Plan. Because there would be no
new or substantially more severe significant impacts than what was analyzed in the 2017 EIR,
further analysis is not warranted.
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b. Would the project result in substantial adverse physical impacts associated with the
provision of new or physically altered police protection facilities, or the need for new or
physically altered police protection facilities, the construction of which could cause
significant environmental impacts, in order to maintain acceptable service ratios, response
times or other performance objectives?
Police protection in the city is provided by the Palo Alto Police Department (PAPD). As discussed
under Impact (a), although the proposed HEU would increase the number of residential units by
919 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 was evaluated separately in accordance
with CEQA to identify potential environmental impacts and mitigation measures as needed for
the approved project. With the new police station, which is anticipated to be operational in
early 2024, 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 919 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 of the 2030 Comprehensive Plan;
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 919 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 919 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 919 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. This can be attributed to a more balanced jobs-housing ratio where job growth is
more proportional to residential growth; placing more residents in proximity to alternative
modes of transportation and promoting bicycling and walking; and implementing the Bus Rapid
Transit (BRT) on El Camino Real with queue-jumping lanes and signal prioritization at
intersections.
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
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CITY OF PALO ALTO P a g e | 1 3 7
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
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 9.25 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 9.25 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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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 919 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 919 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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CITY OF PALO ALTO P a g e | 1 4 7
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 919 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
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 1 4 9
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 919 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 11,132 acre-feet per year (AFY) by 2030, and the city’s Individual Supply
Guarantee would be 19,118 AFY by 2030. As shown on Table 28, the additional 919 units
facilitated by the proposed HEU compared to the 2017 EIR would increase water demand by
approximately 59,735 gallons per day (gpd) or 70.0 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. Therefore, the proposed project would increase Palo Alto’s estimated 2030 normal-
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 5 0 | P a g e Addendum to the 2030 Comprehensive Plan EIR
year water demand by approximately 0.6 percent, which would not exceed the City’s individual
supply guarantee, even with the adjustment to the supply guarantee as outlined in the UWMP,
and there would be sufficient water supply to accommodate the proposed project.
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 65 919 59,735 70.0
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
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the RWQCP would have at least 5 MGD of excess capacity in 2062. Assuming that wastewater
generation is 80 percent of water use, the proposed HEU would increase wastewater
generation by approximately 47,788 gpd.13 This would constitute approximately 0.3 percent of
the RWQCP’s excess dry flow capacity and therefore the RWQCP would have sufficient capacity
to accommodate the 919 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 3,676 pounds per day of solid waste, which equates to 1.8 tons or
16.3 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
13 59,735 gpd times 0.8 = 47,788 gpd
IMPACT ANALYSIS
UTILITIES AND SERVICE SYSTEMS
1 5 2 | P a g e Addendum to the 2030 Comprehensive Plan EIR
to new development on the project sites, implementation of the project would generate
approximately 0.3 tons or 2.9 cubic yards per day of solid waste for disposal at landfills.
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 919 dwelling
units
4 pounds/unit/day 3,676 1.8 16.3
Total Assuming 82% Diversion Rate 662 0.3 2.9
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
cy (CalRecycle 2022d). With development facilitated by the proposed HEU, it is estimated that
the 919 units would generate approximately 2.9 cubic yards of solid waste per day, or 1,059
cubic yards of solid waste per year for disposal at landfills. This represents 0.007 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
CITY OF PALO ALTO 2023-2031 HOUSING ELEMENT
CITY OF PALO ALTO P a g e | 1 5 3
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
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 919 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
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IMPACT ANALYSIS
a. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project substantially impair an adopted emergency response plan
or emergency evacuation plan?
b. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project, due to slope, prevailing winds, and other factors,
exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations
from a wildfire or the uncontrolled spread of a wildfire?
c. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts
to the environment?
d. If located in or near state responsibility areas or lands classified as very high fire hazard
severity zones, would the project expose people or structures to significant risks, including
downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
As shown in the CAL FIRE Fire Hazard Severity Zone Map, only the area west of I-280 is located
in a High Fire Hazard Severity Zone (HFHSZ) while the rest of the city east of I-280 is located in
an area with low wildfire risk. Similar to what was analyzed in the 2017 EIR, the proposed HEU
would facilitate development in non-vacant and underutilized sites in urbanized areas of the
city east of I-280, 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 919 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
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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
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operational emissions from plans. Discussion of these impacts considers the cumulative nature
of criteria pollutants in the region. Therefore, the project would not result in a cumulatively
considerable contribution to an air quality impact.
As discussed in Section 6, Energy, development facilitated by the project would not result in a
wasteful, inefficient, or unnecessary consumption of energy, and operation of the new
residential structures would not result in potentially significant environmental effects due to
the wasteful, inefficient, or unnecessary consumption of energy. Development facilitated by the
project would be consistent with the energy-related goals, policies, and actions of the
Statewide plans and the City’s 2030 Comprehensive Plan; therefore, the project would not
make a cumulatively considerable contribution to a significant cumulative impact with respect
to consistency with renewable energy and energy efficiency plans. Projects throughout the Bay
Area are required to adhere to applicable renewable energy and energy efficiency laws,
programs, and policies such as California’s RPS, AB 2076, and Title 24 standards to avoid the
wasteful, inefficient, or unnecessary consumption of energy.
As discussed in Section 8, Greenhouse Gas Emissions, the impact of GHG emissions generated
by development facilitated by the proposed HEU is inherently cumulative. GHG emissions from
one project cannot, on their own, result in changes in climatic conditions; therefore, the
emissions from any project must be considered in the context of their contribution to
cumulative global emissions, which is the basis for determining a significant cumulative impact.
This is determined through the project’s consistency with applicable GHG emission thresholds
and applicable plans, policies, or regulations adopted for the purpose of reducing the emissions
of GHGs. GHG emissions from development facilitated by the project would not exceed the
BAAQMD interpolated 2031 plan-level threshold. In addition, development facilitated by the
project would be consistent with the 2022 Scoping Plan, Plan Bay Area 2050, 2030
Comprehensive Plan, and the City’s S/CAP. Therefore, the project would not result in a
significant cumulative impact related to GHG emissions.
As discussed in Section 14, Population and Housing, the proposed HEU would result in an
increase of 919 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
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significant, growth-inducing impacts, and irreversible changes beyond those previously
discussed in the 2017 EIR.
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CONCLUSION
As demonstrated in the discussions above regarding the potential effects of the proposed HEU,
substantial changes are not proposed to the 2030 Comprehensive Plan nor have substantial
changes in circumstances occurred that would require major revisions to the 2017 EIR prepared
for the 2030 Comprehensive Plan. Significant impacts beyond those identified and analyzed in
the 2017 EIR would not be expected to occur as a result of the proposed project. Overall, the
proposed HEU would result in no new information of substantial importance that would have
new, more severe impacts, or new mitigation measures from what was identified in the 2017
EIR. As such, the proposed project would not result in conditions identified in State CEQA
Guidelines Section 15162, and a Subsequent or Supplemental EIR is not required for the
proposed project. Again, it should be noted that the proposed project would be subject to all
previously required mitigation measures from the 2017 EIR, as applicable. The MMRP adopted
for the 2030 Comprehensive Plan would continue to be applicable to the proposed project.
Based on the above analysis, this Addendum to the 2017 EIR for the 2030 Comprehensive Plan
has been prepared in accordance with Section 15164 of the State CEQA Guidelines.
CONCLUSION
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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
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IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the
Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte,
V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M. I. Gomis,
M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu
and B. Zhou (eds.)] Cambridge University Press.
https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf
Office of Emergency Services. 2017. Santa Clara County Operational Area Hazard Mitigation Plan.
https://emergencymanagement.sccgov.org/sites/g/files/exjcpb261/files/For%20Partners/Local-
Hazard-Mitigation-Plan-LHMP-Vol-1.pdf
Palo Alto, City of. 2005. Palo Alto Single-Family Individual Review Guidelines. Adopted June 10, 2005.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/file-
migration/current-planning/forms-and-guidelines/individual-review-ir-guidelines.pdf
______. 2012. City of Palo Alto Bicycle and Pedestrian Transportation Plan.
https://www.cityofpaloalto.org/files/assets/public/transportation/projects/bicycle-pedestrian-
transportation-plan_adopted-july-2012.pdf
______. 2016. City of Palo Alto Comprehensive Plan Draft EIR Volume 1. Adopted February 5, 2016.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/paloaltocompplandeir_vol1_web-1.pdf
______. 2017a. City of Palo Alto Comprehensive Plan Update Supplement to the Draft EIR.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/paloalto_compplanupdate_suppeir_feb2017.pdf
______. 2017b. City of Palo Alto Comprehensive Plan. Adopted November 13, 2017.
https://www.cityofpaloalto.org/files/assets/public/planning-amp-development-services/3.-
comprehensive-plan/comprehensive-plan/full-comp-plan-2030_with-june21-amendments.pdf
______. 2018. City of Palo Alto Zero Waste Plan. Adopted August 2018.
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. Dewatering Sites.
https://www.google.com/maps/d/viewer?mid=14ztztkt6te1yanSaxzUhuJONY-
E&ll=37.43630527807649%2C-122.13162251821232&z=14
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______. 2022d. Fire Station No. 4 Replacement Project.
https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-Services/Engineering-
Projects/Fire-Station-No.-4-Replacement-Project
______. 2023a. 2022 Sustainability and Climate Action Plan.
https://www.cityofpaloalto.org/files/assets/public/v/1/sustainability/reports/2022-scap-
report_final.pdf
______. 2023b. 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
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Appendix A
Vehicle Miles Traveled Analysis
Technical Memorandum
Date: November 1, 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 280 sites that could provide additional housing of 6,860 residential units within the City
of Palo Alto. The majority of the sites are located throughout Palo Alto’s Downtown and South of the Forest
Area in districts that allow for a mix of residential and commercial uses near transit and services.
Senate Bill 743
Based on revisions in State law to implement Senate Bill (SB) 743, public agencies in California
are mandated to use vehicle miles traveled (VMT) as the metric for CEQA transportation
analyses starting July 1, 2020. The CEQA Guidelines now identify VMT as the most appropriate metric for
evaluating a project’s transportation impacts. With the California Natural Resources Agency’s certification
and adoption of the changes to the CEQA Guidelines, automobile delay, and congestion, as measured by
level of service (LOS) and other similar metrics, no longer constitutes a significant environmental effect
under CEQA. However, LOS is used outside the CEQA document to evaluate other non-CEQA transportation
impacts of development projects, such as congestion, circulation, and safety issues and concerns.
Palo Alto Vehicle Miles Traveled Policy
On June 15, 2020, the 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 the 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 would not
VMT Analysis for the Palo Alto Housing Element Update (HEU) November 1, 2023
Page | 2
be required; however, the CEQA analysis would still include a qualitative assessment of
VMT, discussing the site(s) and location characteristics.
The City of Palo Alto has established the following VMT screening criteria to determine land use
development projects that may be exempt from additional VMT analysis under the City’s VMT guidelines:
• Small Projects: Projects that generate fewer than 110 trips per day. This may equate to non-
residential projects of 10,000 sq. ft., or less and residential projects of 20 units or less.
• Projects in Low VMT Areas: Residential and office projects located in low-VMT areas1 with similar
features (i.e., density, mix of uses, transit accessibility) as existing developments in these areas.
• Projects in Proximity to Major Transit Stops: Projects that are located within a half mile of an
existing or planned high-quality transit corridor or major transit stations, and meet the following
additional criteria:
(1) is high density (minimum floor area ratio of 0.75),
(2) does not exceed parking requirements,
(3) is consistent with Plan Bay Area, and
(4) does not replace affordable units with smaller numbers of moderate- or above moderate-
income units.
• Affordable Housing: 100% affordable housing projects in infill locations.
• Local Serving Retail: Retail projects of 50,000 sq. ft. or less.
Thresholds of Significance
Land use projects not screened out will require quantitative VMT analyses, and their VMTs must be below
pre-determined thresholds to be considered as having a less-than-significant impact. Consistent with State
CEQA Guidelines Section 15064.3, the City of Palo Alto has adopted the thresholds of significance for
residential projects. A residential project that exceeds a level of 15% below existing (baseline) County
home-based VMT per resident may indicate a significant transportation impact. Because the proposed
Housing Element is a citywide plan, this threshold is applied to the citywide home-based VMT per resident.
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.
VMT Analysis for the Palo Alto Housing Element Update (HEU) November 1, 2023
Page | 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 280 Housing Element sites are spread out over 54 TAZs.
Scenarios Analyzed
In addition to evaluating VMT for the Housing Element, VMT associated with Scenario 6 of the City’s
Comprehensive Plan was also analyzed. The land use assumptions and transportation networks of the PA
model were updated to reflect the year 2031 conditions. The year 2031 land use data outside Palo Alto was
interpolated between VTA’s 2015 and 2040 land use assumptions. Palo Alto’s two future land use scenarios
reflect the increases in households and employment proposed for the Comprehensive Plan and the Housing
Element, respectively. The following scenarios are addressed in the VMT analysis.
• Baseline (2015) Conditions: The baseline (2015) PA model is used to determine the baseline home-
based VMT per resident for the TAZs in Palo Alto, as well as to determine the countywide average
VMT per resident and the 85th percentile of the countywide average VMT per resident.
• Comprehensive Plan (2031) Conditions: This scenario includes the proposed land uses assumed for
Scenario 6 of Palo Alto’s Comprehensive Plan. Scenario 6 contains 6,000 additional housing units
and 8,868 jobs.
• Housing Element (2031) Conditions: This scenario includes the proposed land uses assumed in the
Housing Element. The Housing Element includes 6,860 additional housing units and 8,868 jobs.
Figures 1 and 2 present the growth in housing units for the TAZs assumed for the Comprehensive Plan and
the Housing Element Plan, respectively. The increase in jobs, which is assumed to be the same for both the
Comprehensive Plan and the Housing Element Plan, is shown on Figure 3.
2 Documentation of the Palo Alto Travel Forecasting Model Update is summarized in a Technical Memorandum: Palo Alto
Model Update and Validation Results, January 5, 2023.
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
175
5
96
36
22
34
8
246
98
6
69
52
26
67
38
18
47
996
14
25
24
384
23
123
252
86
701
67
1121
11
155
238
300
425
39
30
43
812
54
66
136
156
8
99
30
8
15 14
60
11
77
191
82
Legend
Increase in the Number of Housing Units
0 - 1
2 - 50
51 - 200
201 - 500
501 - 996
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
VMT Analysis for the Palo Alto Housing Element Update (HEU) November 1, 2023
Page | 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 9.25, 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 following site-specific analysis is provided for informational purposes only, and, as explained earlier,
the relevant analysis for CEQA purposes is citywide VMT.
The 280 Housing Element sites are spread out over 54 TAZs. A VMT analysis for each of the 54 TAZs shows
that the Housing Element sites in six TAZs have a VMT per resident higher than the threshold of 85 percent
of the countywide average. A summary of the VMT data for those six TAZs is shown in Table 2.
Table 2
Housing Sites in TAZs with VMTs Higher than 85 Percent of the County Average
The VMT per resident at four TAZs (473, 477, 495, and 533) is still lower than the county average of 12.90.
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 802,681 34,631 86,756 9.25
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
473 38,997 1,345 3,454 11.29 996
477 26,317 842 2,113 12.45 812
495 4,692 212 408 11.51 11
496 8,059 324 619 13.02 14
525 6,387 175 439 14.54 175
533 14,990 645 1,233 12.15 30
Total 2,038
1 Residential VMT = Home-Based Trip Productions * Travel Distance
2 VMT per Resident = Residential VMT / Population
Note: The threshold of significance is 85 percent of the county average, or 10.97 daily miles per resident
VMT Analysis for the Palo Alto Housing Element Update (HEU) November 1, 2023
Page | 8
Individual housing development projects located at sites in these four 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.
TAZs 496 and 525 have VMT per resident values greater than the countywide average, and the VMTs at
these TAZs are immitigable. Projects located in these two TAZs may require a project-specific VMT analysis,
as appropriate under state law.
The sites in the other 48 TAZs have VMT per resident values less than 85 percent of the county average. A
map of the VMT per resident for the Housing Element TAZs is shown on Figure 4.
Figure 4
Home-Based VMT per Resident for the Housing Element TAZs
City of Palo Alto
14.54
8.6310.22
9.46
9.59
3.68
8.82
10.92
7.95
8.928.11
11.29
6.33
6.18
8.04
10.04
10.35
10.93 6.41
10.71
10.12
3.92
9.91
8.85
13.02
5.82
7.24
6.11
9.55
5.86
6.31 6.66
10.65
10.96
11.51
8.86
12.45
5.44
10.64
12.15
9.06
10.76
9.91
8.42
4.54
5.82
9.11
8.66
7.48
7.56
9.29
6.16
7.61
8.89
Legend
VMT is less than 85% of the County Average
VMT is between 85% and 100 % of the County Average
VMT is greater than 100 % of the County Average
XX.XX = Home-based VMT per Resident
Appendix B
Greenhouse Gas Emissions Modeling Results
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PaloAltoHEU-GHGEmissions DetailedReport
TableofContents
1.BasicProjectInformation
1.1.BasicProjectInformation
1.2.LandUseTypes
1.3.User-SelectedEmissionReductionMeasuresbyEmissionsSector
2.EmissionsSummary
2.1.ConstructionEmissionsComparedAgainstThresholds
2.2.ConstructionEmissionsbyYear,Unmitigated
2.4.OperationsEmissionsComparedAgainstThresholds
2.5.OperationsEmissionsbySector,Unmitigated
3.ConstructionEmissionsDetails
3.1.Demolition(2023)-Unmitigated
3.3.SitePreparation(2023)-Unmitigated
3.5.Grading(2023)-Unmitigated
3.7.BuildingConstruction(2023)-Unmitigated
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3.9.BuildingConstruction(2024)-Unmitigated
3.11.BuildingConstruction(2025)-Unmitigated
3.13.BuildingConstruction(2026)-Unmitigated
3.15.Paving(2026)-Unmitigated
3.17.ArchitecturalCoating(2025)-Unmitigated
3.19.ArchitecturalCoating(2026)-Unmitigated
4.OperationsEmissionsDetails
4.1.MobileEmissionsbyLandUse
4.1.1.Unmitigated
4.2.Energy
4.2.1.ElectricityEmissionsByLandUse-Unmitigated
4.2.3.NaturalGasEmissionsByLandUse-Unmitigated
4.3.AreaEmissionsbySource
4.3.1.Unmitigated
4.4.WaterEmissionsbyLandUse
4.4.1.Unmitigated
4.5.WasteEmissionsbyLandUse
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4.5.1.Unmitigated
4.6.RefrigerantEmissionsbyLandUse
4.6.1.Unmitigated
4.7.OffroadEmissionsByEquipmentType
4.7.1.Unmitigated
4.8.StationaryEmissionsByEquipmentType
4.8.1.Unmitigated
4.9.UserDefinedEmissionsByEquipmentType
4.9.1.Unmitigated
4.10.SoilCarbonAccumulationByVegetationType
4.10.1.SoilCarbonAccumulationByVegetationType-Unmitigated
4.10.2.AboveandBelowgroundCarbonAccumulationbyLandUseType-Unmitigated
4.10.3.AvoidedandSequesteredEmissionsbySpecies-Unmitigated
5.ActivityData
5.1.ConstructionSchedule
5.2.Off-RoadEquipment
5.2.1.Unmitigated
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5.3.ConstructionVehicles
5.3.1.Unmitigated
5.4.Vehicles
5.4.1.ConstructionVehicleControlStrategies
5.5.ArchitecturalCoatings
5.6.DustMitigation
5.6.1.ConstructionEarthmovingActivities
5.6.2.ConstructionEarthmovingControlStrategies
5.7.ConstructionPaving
5.8.ConstructionElectricityConsumptionandEmissionsFactors
5.9.OperationalMobileSources
5.9.1.Unmitigated
5.10.OperationalAreaSources
5.10.1.Hearths
5.10.1.1.Unmitigated
5.10.2.ArchitecturalCoatings
5.10.3.LandscapeEquipment
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5.11.OperationalEnergyConsumption
5.11.1.Unmitigated
5.12.OperationalWaterandWastewaterConsumption
5.12.1.Unmitigated
5.13.OperationalWasteGeneration
5.13.1.Unmitigated
5.14.OperationalRefrigerationandAirConditioningEquipment
5.14.1.Unmitigated
5.15.OperationalOff-RoadEquipment
5.15.1.Unmitigated
5.16.StationarySources
5.16.1.EmergencyGeneratorsandFirePumps
5.16.2.ProcessBoilers
5.17.UserDefined
5.18.Vegetation
5.18.1.LandUseChange
5.18.1.1.Unmitigated
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5.18.1.BiomassCoverType
5.18.1.1.Unmitigated
5.18.2.Sequestration
5.18.2.1.Unmitigated
6.ClimateRiskDetailedReport
6.1.ClimateRiskSummary
6.2.InitialClimateRiskScores
6.3.AdjustedClimateRiskScores
6.4.ClimateRiskReductionMeasures
7.HealthandEquityDetails
7.1.CalEnviroScreen4.0Scores
7.2.HealthyPlacesIndexScores
7.3.OverallHealth&EquityScores
7.4.Health&EquityMeasures
7.5.EvaluationScorecard
7.6.Health&EquityCustomMeasures
8.UserChangestoDefaultData
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1.BasicProjectInformation
1.1.BasicProjectInformation
DataField Value
ProjectName PaloAltoHEU-GHGEmissions
ConstructionStartDate 2/7/2023
OperationalYear 2031
LeadAgency —
LandUseScale Plan/community
AnalysisLevelforDefaults County
Windspeed(m/s)4.20
Precipitation(days)18.8
Location PaloAlto,CA,USA
County SantaClara
City PaloAlto
AirDistrict BayAreaAQMD
AirBasin SanFranciscoBayArea
TAZ 1726
EDFZ 1
ElectricUtility CityofPaloAlto
GasUtility CityofPaloAltoUltilities
AppVersion 2022.1.1.20
1.2.LandUseTypes
LandUseSubtype Size Unit LotAcreage BuildingArea(sqft)LandscapeArea(sq
ft)
SpecialLandscape
Area(sqft)
Population Description
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ApartmentsMidRise 919 DwellingUnit 24.2 882,240 0.00 0.00 2,307 —
1.3.User-SelectedEmissionReductionMeasuresbyEmissionsSector
Nomeasuresselected
2.EmissionsSummary
2.1.ConstructionEmissionsComparedAgainstThresholds
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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 46.9 39.8 48.3 0.06 1.81 19.8 21.6 1.66 10.1 11.8 —11,987 11,987 0.55 0.66 33.9 12,226
Daily,
Winter
(Max)
——————————————————
Unmit.4.36 46.8 27.4 43.7 0.04 1.20 7.26 7.75 1.10 1.73 2.19 —11,486 11,486 0.42 0.68 0.88 11,699
Average
Daily
(Max)
——————————————————
Unmit.3.02 28.2 18.5 30.2 0.03 0.76 4.99 5.62 0.70 1.90 2.61 —8,108 8,108 0.28 0.47 10.2 8,264
Annual
(Max)
——————————————————
Unmit.0.55 5.14 3.37 5.51 0.01 0.14 0.91 1.03 0.13 0.35 0.48 —1,342 1,342 0.05 0.08 1.69 1,368
2.2.ConstructionEmissionsbyYear,Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
Year 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)
2023 4.77 4.01 39.8 46.2 0.06 1.81 19.8 21.6 1.66 10.1 11.8 —11,024 11,024 0.55 0.63 33.9 11,260
2024 4.25 3.61 16.6 43.9 0.04 0.53 6.16 6.70 0.49 1.47 1.97 —10,876 10,876 0.37 0.63 31.7 11,106
2025 4.66 46.9 16.7 48.3 0.04 0.50 7.26 7.75 0.46 1.73 2.19 —11,987 11,987 0.37 0.66 33.9 12,226
2026 4.23 46.7 15.6 46.0 0.04 0.44 7.26 7.69 0.41 1.73 2.14 —11,811 11,811 0.37 0.66 30.7 12,048
Daily-
Winter
(Max)
——————————————————
2023 4.34 3.68 27.4 41.9 0.04 1.20 6.16 6.75 1.10 1.47 2.02 —10,588 10,588 0.42 0.65 0.88 10,792
2024 4.15 3.51 17.2 39.9 0.04 0.53 6.16 6.70 0.49 1.47 1.97 —10,450 10,450 0.41 0.65 0.82 10,654
2025 4.36 46.8 17.3 43.7 0.04 0.50 7.26 7.75 0.46 1.73 2.19 —11,486 11,486 0.41 0.68 0.88 11,699
2026 4.16 46.4 16.3 41.5 0.04 0.44 7.26 7.69 0.41 1.73 2.14 —11,322 11,322 0.41 0.68 0.80 11,534
Average
Daily
——————————————————
2023 2.70 2.28 18.5 21.7 0.03 0.76 4.86 5.62 0.70 1.90 2.61 —4,574 4,574 0.18 0.16 3.23 4,629
2024 2.96 2.50 12.1 28.3 0.03 0.38 4.36 4.74 0.35 1.04 1.40 —7,526 7,526 0.28 0.46 9.77 7,681
2025 3.02 28.2 12.0 30.2 0.03 0.35 4.99 5.34 0.32 1.19 1.51 —8,108 8,108 0.27 0.47 10.2 8,264
2026 1.72 19.0 7.12 17.4 0.02 0.21 2.82 3.03 0.19 0.67 0.87 —4,643 4,643 0.16 0.26 5.20 4,730
Annual ——————————————————
2023 0.49 0.42 3.37 3.96 0.01 0.14 0.89 1.03 0.13 0.35 0.48 —757 757 0.03 0.03 0.53 766
2024 0.54 0.46 2.21 5.16 0.01 0.07 0.80 0.87 0.06 0.19 0.25 —1,246 1,246 0.05 0.08 1.62 1,272
2025 0.55 5.14 2.19 5.51 0.01 0.06 0.91 0.97 0.06 0.22 0.28 —1,342 1,342 0.05 0.08 1.69 1,368
2026 0.31 3.47 1.30 3.18 <0.005 0.04 0.51 0.55 0.04 0.12 0.16 —769 769 0.03 0.04 0.86 783
2.4.OperationsEmissionsComparedAgainstThresholds
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
Un/Mit.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)
——————————————————
Unmit.14.8 36.5 17.2 104 0.32 0.87 26.7 27.6 0.86 6.77 7.64 397 38,156 38,553 32.3 1.22 60.7 39,785
Daily,
Winter
(Max)
——————————————————
Unmit.14.3 36.0 18.5 98.2 0.30 0.87 26.7 27.6 0.86 6.77 7.64 397 36,573 36,970 32.4 1.32 7.73 38,181
Average
Daily
(Max)
——————————————————
Unmit.12.5 34.7 8.69 87.3 0.24 0.15 25.1 25.2 0.14 6.36 6.50 397 24,312 24,709 32.1 1.21 28.7 25,900
Annual
(Max)
——————————————————
Unmit.2.28 6.34 1.59 15.9 0.04 0.03 4.58 4.61 0.03 1.16 1.19 65.7 4,025 4,091 5.31 0.20 4.74 4,288
2.5.OperationsEmissionsbySector,Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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 13.7 12.8 8.09 100 0.26 0.14 26.7 26.9 0.13 6.77 6.90 —26,643 26,643 1.00 1.01 54.4 27,022
Area 1.06 23.7 9.07 3.86 0.06 0.73 —0.73 0.73 —0.73 0.00 11,513 11,513 0.22 0.02 —11,525
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 ———————————89.6 0.00 89.6 0.31 0.20 —156
Waste ———————————307 0.00 307 30.7 0.00 —1,076
Refrig.————————————————6.32 6.32
Total 14.8 36.5 17.2 104 0.32 0.87 26.7 27.6 0.86 6.77 7.64 397 38,156 38,553 32.3 1.22 60.7 39,785
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——————————————————Daily,
Winter
(Max)
Mobile 13.3 12.3 9.46 94.3 0.25 0.14 26.7 26.9 0.13 6.77 6.90 —25,059 25,059 1.13 1.11 1.41 25,418
Area 1.06 23.7 9.07 3.86 0.06 0.73 —0.73 0.73 —0.73 0.00 11,513 11,513 0.22 0.02 —11,525
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 ———————————89.6 0.00 89.6 0.31 0.20 —156
Waste ———————————307 0.00 307 30.7 0.00 —1,076
Refrig.————————————————6.32 6.32
Total 14.3 36.0 18.5 98.2 0.30 0.87 26.7 27.6 0.86 6.77 7.64 397 36,573 36,970 32.4 1.32 7.73 38,181
Average
Daily
——————————————————
Mobile 12.4 11.5 8.46 87.2 0.24 0.13 25.1 25.2 0.12 6.36 6.49 —24,028 24,028 1.02 1.01 22.3 24,378
Area 0.03 23.2 0.22 0.10 <0.005 0.02 —0.02 0.02 —0.02 0.00 284 284 0.01 <0.005 —284
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 ———————————89.6 0.00 89.6 0.31 0.20 —156
Waste ———————————307 0.00 307 30.7 0.00 —1,076
Refrig.————————————————6.32 6.32
Total 12.5 34.7 8.69 87.3 0.24 0.15 25.1 25.2 0.14 6.36 6.50 397 24,312 24,709 32.1 1.21 28.7 25,900
Annual ——————————————————
Mobile 2.27 2.10 1.54 15.9 0.04 0.02 4.58 4.60 0.02 1.16 1.18 —3,978 3,978 0.17 0.17 3.70 4,036
Area <0.005 4.23 0.04 0.02 <0.005 <0.005 —<0.005 <0.005 —<0.005 0.00 47.0 47.0 <0.005 <0.005 —47.1
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 ———————————14.8 0.00 14.8 0.05 0.03 —25.8
Waste ———————————50.9 0.00 50.9 5.09 0.00 —178
Refrig.————————————————1.05 1.05
Total 2.28 6.34 1.59 15.9 0.04 0.03 4.58 4.61 0.03 1.16 1.19 65.7 4,025 4,091 5.31 0.20 4.74 4,288
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3.ConstructionEmissionsDetails
3.1.Demolition(2023)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
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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 ———————
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
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3.3.SitePreparation(2023)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
4.70 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
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———————0.150.15—0.290.29——————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
Offsite ——————————————————
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
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
4.43 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
Dust
From
Material
Movement
——————9.20 9.20 —3.65 3.65 ———————
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
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 ——————————————————
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——————————————————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
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.BuildingConstruction(2023)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
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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
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 2.67 2.44 1.99 31.3 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,898 5,898 0.29 0.21 26.8 5,996
Vendor 0.27 0.10 3.73 1.78 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,728 2,728 0.17 0.40 7.08 2,859
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 2.57 2.33 2.43 26.9 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,461 5,461 0.16 0.23 0.70 5,534
Vendor 0.27 0.10 3.94 1.83 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,730 2,730 0.17 0.40 0.18 2,853
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
——————————————————
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Worker 0.54 0.49 0.47 5.62 0.00 0.00 1.14 1.14 0.00 0.27 0.27 —1,167 1,167 0.03 0.05 2.45 1,184
Vendor 0.06 0.02 0.82 0.38 <0.005 0.01 0.14 0.15 0.01 0.04 0.05 —577 577 0.04 0.08 0.65 603
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 0.09 1.03 0.00 0.00 0.21 0.21 0.00 0.05 0.05 —193 193 <0.005 0.01 0.40 196
Vendor 0.01 <0.005 0.15 0.07 <0.005 <0.005 0.03 0.03 <0.005 0.01 0.01 —95.5 95.5 0.01 0.01 0.11 99.9
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.BuildingConstruction(2024)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
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0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite
truck
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
Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 2.54 2.31 1.79 29.1 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,785 5,785 0.10 0.21 24.7 5,876
Vendor 0.27 0.10 3.56 1.70 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,694 2,694 0.17 0.40 7.08 2,824
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 2.45 2.21 2.23 25.0 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,357 5,357 0.15 0.23 0.64 5,430
Vendor 0.26 0.10 3.77 1.75 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,695 2,695 0.17 0.40 0.18 2,818
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 1.74 1.57 1.44 17.6 0.00 0.00 3.87 3.87 0.00 0.91 0.91 —3,879 3,879 0.09 0.16 7.59 3,938
Vendor 0.19 0.07 2.64 1.24 0.01 0.03 0.49 0.52 0.03 0.14 0.16 —1,930 1,930 0.12 0.29 2.18 2,020
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 0.32 0.29 0.26 3.22 0.00 0.00 0.71 0.71 0.00 0.17 0.17 —642 642 0.02 0.03 1.26 652
Vendor 0.03 0.01 0.48 0.23 <0.005 <0.005 0.09 0.09 <0.005 0.02 0.03 —319 319 0.02 0.05 0.36 334
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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3.11.BuildingConstruction(2025)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
1.35 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 ——————————————————
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——————————————————Daily,
Summer
(Max)
Worker 2.42 2.19 1.60 27.1 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,671 5,671 0.10 0.21 22.4 5,760
Vendor 0.25 0.10 3.40 1.64 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,650 2,650 0.15 0.38 7.02 2,775
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 2.18 2.12 2.03 23.2 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,253 5,253 0.13 0.23 0.58 5,325
Vendor 0.25 0.09 3.57 1.67 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,652 2,652 0.15 0.38 0.18 2,769
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 1.54 1.49 1.30 16.3 0.00 0.00 3.86 3.86 0.00 0.90 0.90 —3,793 3,793 0.08 0.15 6.90 3,848
Vendor 0.18 0.07 2.51 1.19 0.01 0.03 0.49 0.52 0.03 0.14 0.16 —1,894 1,894 0.10 0.27 2.17 1,980
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 0.28 0.27 0.24 2.98 0.00 0.00 0.70 0.70 0.00 0.16 0.16 —628 628 0.01 0.03 1.14 637
Vendor 0.03 0.01 0.46 0.22 <0.005 <0.005 0.09 0.09 <0.005 0.02 0.03 —314 314 0.02 0.05 0.36 328
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.BuildingConstruction(2026)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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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2,405—0.020.102,3972,397—0.35—0.350.38—0.380.0213.09.851.071.28Off-Road
Equipment
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
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 2.14 2.09 1.40 25.2 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,564 5,564 0.10 0.21 20.3 5,650
Vendor 0.25 0.08 3.23 1.58 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,604 2,604 0.15 0.38 6.35 2,728
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 2.08 1.85 1.83 21.5 0.00 0.00 5.47 5.47 0.00 1.28 1.28 —5,154 5,154 0.13 0.23 0.53 5,226
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Vendor 0.24 0.08 3.42 1.61 0.02 0.04 0.69 0.73 0.04 0.19 0.23 —2,606 2,606 0.15 0.38 0.16 2,724
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 0.79 0.70 0.63 8.25 0.00 0.00 2.09 2.09 0.00 0.49 0.49 —2,019 2,019 0.05 0.08 3.40 2,048
Vendor 0.09 0.03 1.29 0.62 0.01 0.01 0.27 0.28 0.01 0.07 0.09 —1,009 1,009 0.06 0.15 1.06 1,056
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 0.14 0.13 0.11 1.51 0.00 0.00 0.38 0.38 0.00 0.09 0.09 —334 334 0.01 0.01 0.56 339
Vendor 0.02 0.01 0.24 0.11 <0.005 <0.005 0.05 0.05 <0.005 0.01 0.02 —167 167 0.01 0.02 0.18 175
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
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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 ————————————————
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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
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 ——————————————————
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
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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.ArchitecturalCoating(2025)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
——————————————————
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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
Architect
ural
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 0.48 0.44 0.32 5.41 0.00 0.00 1.09 1.09 0.00 0.26 0.26 —1,134 1,134 0.02 0.04 4.48 1,152
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 0.44 0.42 0.41 4.64 0.00 0.00 1.09 1.09 0.00 0.26 0.26 —1,051 1,051 0.03 0.05 0.12 1,065
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 0.25 0.25 0.22 2.71 0.00 0.00 0.64 0.64 0.00 0.15 0.15 —630 630 0.01 0.03 1.15 639
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
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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 0.05 0.05 0.04 0.49 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —104 104 <0.005 <0.005 0.19 106
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.ArchitecturalCoating(2026)-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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 0.12 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
——————————————————
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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
Architect
ural
Coatings
—3.21 ————————————————
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 0.43 0.42 0.28 5.04 0.00 0.00 1.09 1.09 0.00 0.26 0.26 —1,113 1,113 0.02 0.04 4.06 1,130
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 0.42 0.37 0.37 4.31 0.00 0.00 1.09 1.09 0.00 0.26 0.26 —1,031 1,031 0.03 0.05 0.11 1,045
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 0.17 0.15 0.13 1.74 0.00 0.00 0.44 0.44 0.00 0.10 0.10 —426 426 0.01 0.02 0.72 432
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
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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 0.02 0.32 0.00 0.00 0.08 0.08 0.00 0.02 0.02 —70.6 70.6 <0.005 <0.005 0.12 71.6
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.OperationsEmissionsDetails
4.1.MobileEmissionsbyLandUse
4.1.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
MidRise
13.7 12.8 8.09 100 0.26 0.14 26.7 26.9 0.13 6.77 6.90 —26,643 26,643 1.00 1.01 54.4 27,022
Total 13.7 12.8 8.09 100 0.26 0.14 26.7 26.9 0.13 6.77 6.90 —26,643 26,643 1.00 1.01 54.4 27,022
Daily,
Winter
(Max)
——————————————————
Apartme
nts
MidRise
13.3 12.3 9.46 94.3 0.25 0.14 26.7 26.9 0.13 6.77 6.90 —25,059 25,059 1.13 1.11 1.41 25,418
Total 13.3 12.3 9.46 94.3 0.25 0.14 26.7 26.9 0.13 6.77 6.90 —25,059 25,059 1.13 1.11 1.41 25,418
Annual ——————————————————
Apartme
nts
MidRise
2.27 2.10 1.54 15.9 0.04 0.02 4.58 4.60 0.02 1.16 1.18 —3,978 3,978 0.17 0.17 3.70 4,036
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Total 2.27 2.10 1.54 15.9 0.04 0.02 4.58 4.60 0.02 1.16 1.18 —3,978 3,978 0.17 0.17 3.70 4,036
4.2.Energy
4.2.1.ElectricityEmissionsByLandUse-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
MidRise
————————————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
MidRise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
Annual ——————————————————
Apartme
nts
MidRise
————————————0.00 0.00 0.00 0.00 —0.00
Total ————————————0.00 0.00 0.00 0.00 —0.00
4.2.3.NaturalGasEmissionsByLandUse-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
MidRise
0.00 0.00 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)
——————————————————
Apartme
nts
MidRise
0.00 0.00 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
MidRise
0.00 0.00 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.AreaEmissionsbySource
4.3.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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 1.06 0.53 9.07 3.86 0.06 0.73 —0.73 0.73 —0.73 0.00 11,513 11,513 0.22 0.02 —11,525
Consum
er
Products
—18.9 ————————————————
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————————————————4.31—Architect
ural
Total 1.06 23.7 9.07 3.86 0.06 0.73 —0.73 0.73 —0.73 0.00 11,513 11,513 0.22 0.02 —11,525
Daily,
Winter
(Max)
——————————————————
Hearths 1.06 0.53 9.07 3.86 0.06 0.73 —0.73 0.73 —0.73 0.00 11,513 11,513 0.22 0.02 —11,525
Consum
er
Products
—18.9 ————————————————
Architect
ural
Coatings
—4.31 ————————————————
Total 1.06 23.7 9.07 3.86 0.06 0.73 —0.73 0.73 —0.73 0.00 11,513 11,513 0.22 0.02 —11,525
Annual ——————————————————
Hearths <0.005 <0.005 0.04 0.02 <0.005 <0.005 —<0.005 <0.005 —<0.005 0.00 47.0 47.0 <0.005 <0.005 —47.1
Consum
er
Products
—3.45 ————————————————
Architect
ural
Coatings
—0.79 ————————————————
Total <0.005 4.23 0.04 0.02 <0.005 <0.005 —<0.005 <0.005 —<0.005 0.00 47.0 47.0 <0.005 <0.005 —47.1
4.4.WaterEmissionsbyLandUse
4.4.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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)
——————————————————
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Apartme
MidRise
———————————89.6 0.00 89.6 0.31 0.20 —156
Total ———————————89.6 0.00 89.6 0.31 0.20 —156
Daily,
Winter
(Max)
——————————————————
Apartme
nts
MidRise
———————————89.6 0.00 89.6 0.31 0.20 —156
Total ———————————89.6 0.00 89.6 0.31 0.20 —156
Annual ——————————————————
Apartme
nts
MidRise
———————————14.8 0.00 14.8 0.05 0.03 —25.8
Total ———————————14.8 0.00 14.8 0.05 0.03 —25.8
4.5.WasteEmissionsbyLandUse
4.5.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
MidRise
———————————307 0.00 307 30.7 0.00 —1,076
Total ———————————307 0.00 307 30.7 0.00 —1,076
Daily,
Winter
(Max)
——————————————————
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1,076—0.0030.73070.00307———————————Apartme
nts
Total ———————————307 0.00 307 30.7 0.00 —1,076
Annual ——————————————————
Apartme
nts
MidRise
———————————50.9 0.00 50.9 5.09 0.00 —178
Total ———————————50.9 0.00 50.9 5.09 0.00 —178
4.6.RefrigerantEmissionsbyLandUse
4.6.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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
MidRise
————————————————6.32 6.32
Total ————————————————6.32 6.32
Daily,
Winter
(Max)
——————————————————
Apartme
nts
MidRise
————————————————6.32 6.32
Total ————————————————6.32 6.32
Annual ——————————————————
Apartme
nts
MidRise
————————————————1.05 1.05
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Total ————————————————1.05 1.05
4.7.OffroadEmissionsByEquipmentType
4.7.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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.StationaryEmissionsByEquipmentType
4.8.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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 ——————————————————
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Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.9.UserDefinedEmissionsByEquipmentType
4.9.1.Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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.SoilCarbonAccumulationByVegetationType
4.10.1.SoilCarbonAccumulationByVegetationType-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
Vegetatio
n
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)
——————————————————
Total ——————————————————
Daily,
Winter
(Max)
——————————————————
Total ——————————————————
Annual ——————————————————
Total ——————————————————
4.10.2.AboveandBelowgroundCarbonAccumulationbyLandUseType-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
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.AvoidedandSequesteredEmissionsbySpecies-Unmitigated
CriteriaPollutants(lb/dayfordaily,ton/yrforannual)andGHGs(lb/dayfordaily,MT/yrforannual)
Species 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)
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Annual ——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
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——————————————————Remove
d
Subtotal ——————————————————
———————————————————
5.ActivityData
5.1.ConstructionSchedule
PhaseName PhaseType StartDate EndDate DaysPerWeek WorkDaysperPhase PhaseDescription
Demolition Demolition 2/7/2023 4/18/2023 5.00 50.0 —
SitePreparation SitePreparation 4/19/2023 5/31/2023 5.00 30.0 —
Grading Grading 6/1/2023 9/14/2023 5.00 75.0 —
BuildingConstruction BuildingConstruction 9/15/2023 7/17/2026 5.00 740 —
Paving Paving 7/31/2026 10/3/2026 5.00 46.0 —
ArchitecturalCoating ArchitecturalCoating 3/4/2025 7/28/2026 5.00 366 —
5.2.Off-RoadEquipment
5.2.1.Unmitigated
PhaseName EquipmentType FuelType EngineTier NumberperDay HoursPerDay Horsepower LoadFactor
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 RubberTiredDozers Diesel Average 2.00 8.00 367 0.40
SitePreparation RubberTiredDozers Diesel Average 3.00 8.00 367 0.40
SitePreparation 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
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Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading RubberTiredDozers 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
BuildingConstruction Cranes Diesel Average 1.00 7.00 367 0.29
BuildingConstruction Forklifts Diesel Average 3.00 8.00 82.0 0.20
BuildingConstruction GeneratorSets Diesel Average 1.00 8.00 14.0 0.74
BuildingConstruction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
BuildingConstruction Welders Diesel Average 1.00 8.00 46.0 0.45
Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving PavingEquipment Diesel Average 2.00 8.00 89.0 0.36
Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
ArchitecturalCoating AirCompressors Diesel Average 1.00 6.00 37.0 0.48
5.3.ConstructionVehicles
5.3.1.Unmitigated
PhaseName TripType One-WayTripsperDay MilesperTrip VehicleMix
Demolition ————
Demolition Worker 15.0 11.7 LDA,LDT1,LDT2
Demolition Vendor —8.40 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsitetruck ——HHDT
SitePreparation ————
SitePreparation Worker 17.5 11.7 LDA,LDT1,LDT2
SitePreparation Vendor —8.40 HHDT,MHDT
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SitePreparation Hauling 0.00 20.0 HHDT
SitePreparation Onsitetruck ——HHDT
Grading ————
Grading Worker 20.0 11.7 LDA,LDT1,LDT2
Grading Vendor —8.40 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsitetruck ——HHDT
BuildingConstruction ————
BuildingConstruction Worker 662 11.7 LDA,LDT1,LDT2
BuildingConstruction Vendor 98.2 8.40 HHDT,MHDT
BuildingConstruction Hauling 0.00 20.0 HHDT
BuildingConstruction Onsitetruck ——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 Onsitetruck ——HHDT
ArchitecturalCoating ————
ArchitecturalCoating Worker 132 11.7 LDA,LDT1,LDT2
ArchitecturalCoating Vendor —8.40 HHDT,MHDT
ArchitecturalCoating Hauling 0.00 20.0 HHDT
ArchitecturalCoating Onsitetruck ——HHDT
5.4.Vehicles
5.4.1.ConstructionVehicleControlStrategies
Non-applicable.Nocontrolstrategiesactivatedbyuser.
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5.5.ArchitecturalCoatings
PhaseName ResidentialInteriorAreaCoated
(sqft)
ResidentialExteriorAreaCoated
(sqft)
Non-ResidentialInteriorArea
Coated(sqft)
Non-ResidentialExteriorArea
Coated(sqft)
ParkingAreaCoated(sqft)
ArchitecturalCoating 2,542,752 847,584 0.00 0.00 —
5.6.DustMitigation
5.6.1.ConstructionEarthmovingActivities
PhaseName MaterialImported(cy)MaterialExported(cy)AcresGraded(acres)MaterialDemolished(sq.ft.)AcresPaved(acres)
Demolition 0.00 0.00 0.00 ——
SitePreparation ——45.0 0.00 —
Grading ——225 0.00 —
Paving 0.00 0.00 0.00 0.00 —
5.6.2.ConstructionEarthmovingControlStrategies
Non-applicable.Nocontrolstrategiesactivatedbyuser.
5.7.ConstructionPaving
LandUse AreaPaved(acres)%Asphalt
ApartmentsMidRise —0%
5.8.ConstructionElectricityConsumptionandEmissionsFactors
kWhperYearandEmissionFactor(lb/MWh)
Year kWhperYear 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
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2026 0.00 0.00 0.00 0.00
5.9.OperationalMobileSources
5.9.1.Unmitigated
LandUseType Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year
ApartmentsMidRise 4,999 4,512 3,759 1,734,678 37,869 34,180 28,472 13,139,958
5.10.OperationalAreaSources
5.10.1.Hearths
5.10.1.1.Unmitigated
HearthType Unmitigated(number)
ApartmentsMidRise —
WoodFireplaces 0
GasFireplaces 469
PropaneFireplaces 0
ElectricFireplaces 0
NoFireplaces 450
ConventionalWoodStoves 0
CatalyticWoodStoves 0
Non-CatalyticWoodStoves 0
PelletWoodStoves 0
5.10.2.ArchitecturalCoatings
ResidentialInteriorAreaCoated(sqft)ResidentialExteriorAreaCoated(sqft)Non-ResidentialInteriorAreaCoated
(sqft)
Non-ResidentialExteriorAreaCoated
(sqft)
ParkingAreaCoated(sqft)
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2542752 847,584 0.00 0.00 —
5.10.3.LandscapeEquipment
Season Unit Value
SnowDays day/yr 0.00
SummerDays day/yr 180
5.11.OperationalEnergyConsumption
5.11.1.Unmitigated
Electricity(kWh/yr)andCO2andCH4andN2OandNaturalGas(kBTU/yr)
LandUse Electricity(kWh/yr)CO2 CH4 N2O NaturalGas(kBTU/yr)
ApartmentsMidRise 5,506,344 0.00 0.0000 0.0000 0.00
5.12.OperationalWaterandWastewaterConsumption
5.12.1.Unmitigated
LandUse IndoorWater(gal/year)OutdoorWater(gal/year)
ApartmentsMidRise 41,923,958 0.00
5.13.OperationalWasteGeneration
5.13.1.Unmitigated
LandUse Waste(ton/year)Cogeneration(kWh/year)
ApartmentsMidRise 571 —
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5.14.OperationalRefrigerationandAirConditioningEquipment
5.14.1.Unmitigated
LandUseType EquipmentType Refrigerant GWP Quantity(kg)OperationsLeakRate ServiceLeakRate TimesServiced
ApartmentsMidRise AverageroomA/C&
OtherresidentialA/C
andheatpumps
R-410A 2,088 <0.005 2.50 2.50 10.0
ApartmentsMidRise Householdrefrigerators
and/orfreezers
R-134a 1,430 0.12 0.60 0.00 1.00
5.15.OperationalOff-RoadEquipment
5.15.1.Unmitigated
EquipmentType FuelType EngineTier NumberperDay HoursPerDay Horsepower LoadFactor
5.16.StationarySources
5.16.1.EmergencyGeneratorsandFirePumps
EquipmentType FuelType NumberperDay HoursperDay HoursperYear Horsepower LoadFactor
5.16.2.ProcessBoilers
EquipmentType FuelType Number BoilerRating(MMBtu/hr)DailyHeatInput(MMBtu/day)AnnualHeatInput(MMBtu/yr)
5.17.UserDefined
EquipmentType FuelType
——
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5.18.Vegetation
5.18.1.LandUseChange
5.18.1.1.Unmitigated
VegetationLandUseType VegetationSoilType InitialAcres FinalAcres
5.18.1.BiomassCoverType
5.18.1.1.Unmitigated
BiomassCoverType InitialAcres FinalAcres
5.18.2.Sequestration
5.18.2.1.Unmitigated
TreeType Number ElectricitySaved(kWh/year)NaturalGasSaved(btu/year)
6.ClimateRiskDetailedReport
6.1.ClimateRiskSummary
Cal-Adaptmidcentury2040–2059averageprojectionsforfourhazardsarereportedbelowforyourprojectlocation.TheseareunderRepresentationConcentrationPathway(RCP)8.5whichassumesGHG
emissionswillcontinuetorisestronglythrough2050andthenplateauaround2100.
ClimateHazard ResultforProjectLocation Unit
TemperatureandExtremeHeat 11.8 annualdaysofextremeheat
ExtremePrecipitation 4.05 annualdayswithprecipitationabove20mm
SeaLevelRise 0.00 metersofinundationdepth
Wildfire 10.7 annualhectaresburned
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TemperatureandExtremeHeatdataareforgridcellinwhichyourprojectarelocated.Theprojectionisbasedonthe98thhistoricalpercentileofdailymaximum/minimumtemperaturesfromobserved
historicaldata(32climatemodelensemblefromCal-Adapt,2040–2059averageunderRCP8.5). Eachgridcellis6kilometers(km)by6km,or3.7miles(mi)by3.7mi.
ExtremePrecipitationdataareforthegridcellinwhichyourprojectarelocated.Thethresholdof20mmisequivalenttoabout¾aninchofrain,whichwouldbelighttomoderaterainfallifreceivedoverafull
dayorheavyrainifreceivedoveraperiodof2to4hours.Eachgridcellis6kilometers(km)by6km,or3.7miles(mi)by3.7mi.
SeaLevelRisedataareforthegridcellinwhichyourprojectarelocated.TheprojectionsarefromRadkeetal.(2017),asreportedinCal-Adapt(Radkeetal.,2017,CEC-500-2017-008),andconsider
inundationlocationanddepthfortheSanFranciscoBay,theSacramento-SanJoaquinRiverDeltaandCaliforniacoastresultingdifferentincrementsofsealevelrisecoupledwithextremestormevents.
Usersmayselectfromfourscenariostoviewtherangeinpotentialinundationdepthforthegridcell.Thefourscenariosare:Norise,0.5meter,1.0meter,1.41meters
Wildfiredataareforthegridcellinwhichyourprojectarelocated.TheprojectionsarefromUCDavis,asreportedinCal-Adapt(2040–2059averageunderRCP8.5),andconsiderhistoricaldataofclimate,
vegetation,populationdensity,andlarge(>400ha)firehistory.Usersmayselectfromfourmodelsimulationstoviewtherangeinpotentialwildfireprobabilitiesforthegridcell.Thefoursimulationsmake
differentassumptionsaboutexpectedrainfallandtemperatureare:Warmer/drier(HadGEM2-ES),Cooler/wetter(CNRM-CM5),Averageconditions(CanESM2),Rangeofdifferentrainfallandtemperature
possibilities(MIROC5).Eachgridcellis6kilometers(km)by6km,or3.7miles(mi)by3.7mi.
6.2.InitialClimateRiskScores
ClimateHazard ExposureScore SensitivityScore AdaptiveCapacityScore VulnerabilityScore
TemperatureandExtremeHeat N/A N/A N/A N/A
ExtremePrecipitation N/A N/A N/A N/A
SeaLevelRise 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
SnowpackReduction N/A N/A N/A N/A
AirQualityDegradation N/A N/A N/A N/A
Thesensitivityscorereflectstheextenttowhichaprojectwouldbeadverselyaffectedbyexposuretoaclimatehazard.Exposureisratedonascaleof1to5,withascoreof5representingthegreatest
exposure.
Theadaptivecapacityofaprojectreferstoitsabilitytomanageandreducevulnerabilitiesfromprojectedclimatehazards.Adaptivecapacityisratedonascaleof1to5,withascoreof5representingthe
greatestabilitytoadapt.
Theoverallvulnerabilityscoresarecalculatedbasedonthepotentialimpactsandadaptivecapacityassessmentsforeachhazard.Scoresdonotincludeimplementationofclimateriskreductionmeasures.
6.3.AdjustedClimateRiskScores
ClimateHazard ExposureScore SensitivityScore AdaptiveCapacityScore VulnerabilityScore
TemperatureandExtremeHeat N/A N/A N/A N/A
ExtremePrecipitation N/A N/A N/A N/A
SeaLevelRise N/A N/A N/A N/A
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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
SnowpackReduction N/A N/A N/A N/A
AirQualityDegradation N/A N/A N/A N/A
Thesensitivityscorereflectstheextenttowhichaprojectwouldbeadverselyaffectedbyexposuretoaclimatehazard.Exposureisratedonascaleof1to5,withascoreof5representingthegreatest
exposure.
Theadaptivecapacityofaprojectreferstoitsabilitytomanageandreducevulnerabilitiesfromprojectedclimatehazards.Adaptivecapacityisratedonascaleof1to5,withascoreof5representingthe
greatestabilitytoadapt.
Theoverallvulnerabilityscoresarecalculatedbasedonthepotentialimpactsandadaptivecapacityassessmentsforeachhazard.Scoresincludeimplementationofclimateriskreductionmeasures.
6.4.ClimateRiskReductionMeasures
7.HealthandEquityDetails
7.1.CalEnviroScreen4.0Scores
ThemaximumCalEnviroScreenscoreis100.Ahighscore(i.e.,greaterthan50)reflectsahigherpollutionburdencomparedtoothercensustractsinthestate.
Indicator ResultforProjectCensusTract
ExposureIndicators —
AQ-Ozone 10.6
AQ-PM 15.6
AQ-DPM 54.0
DrinkingWater 38.1
LeadRiskHousing 68.1
Pesticides 0.00
ToxicReleases 28.4
Traffic 30.2
EffectIndicators —
CleanUpSites 73.7
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Groundwater 91.9
HazWasteFacilities/Generators 51.9
ImpairedWaterBodies 23.9
SolidWaste 0.00
SensitivePopulation —
Asthma 0.66
Cardio-vascular 4.54
LowBirthWeights 36.4
SocioeconomicFactorIndicators —
Education 3.87
Housing 22.1
Linguistic 24.8
Poverty 8.07
Unemployment 29.4
7.2.HealthyPlacesIndexScores
ThemaximumHealthPlacesIndexscoreis100.Ahighscore(i.e.,greaterthan50)reflectshealthiercommunityconditionscomparedtoothercensustractsinthestate.
Indicator ResultforProjectCensusTract
Economic —
AbovePoverty 95.14949313
Employed 43.98819453
MedianHI 99.29423842
Education —
Bachelor'sorhigher 99.60220711
Highschoolenrollment 100
Preschoolenrollment 73.48902862
Transportation —
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AutoAccess 68.11240857
Activecommuting 83.57500321
Social —
2-parenthouseholds 94.40523547
Voting 96.57384833
Neighborhood —
Alcoholavailability 81.20107789
Parkaccess 81.35506224
Retaildensity 46.32362376
Supermarketaccess 56.22994996
Treecanopy 94.4180675
Housing —
Homeownership 63.76235083
Housinghabitability 86.19273707
Low-inchomeownerseverehousingcostburden 41.33196458
Low-increnterseverehousingcostburden 96.25304761
Uncrowdedhousing 87.19363531
HealthOutcomes —
Insuredadults 99.75619145
Arthritis 0.0
AsthmaERAdmissions 96.2
HighBloodPressure 0.0
Cancer(excludingskin)0.0
Asthma 0.0
CoronaryHeartDisease 0.0
ChronicObstructivePulmonaryDisease 0.0
DiagnosedDiabetes 0.0
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LifeExpectancyatBirth 97.7
CognitivelyDisabled 80.8
Physically Disabled 96.9
HeartAttackERAdmissions 93.0
MentalHealthNotGood 0.0
ChronicKidneyDisease 0.0
Obesity 0.0
PedestrianInjuries 19.6
PhysicalHealthNotGood 0.0
Stroke 0.0
HealthRiskBehaviors —
BingeDrinking 0.0
CurrentSmoker 0.0
NoLeisureTimeforPhysicalActivity 0.0
ClimateChangeExposures —
WildfireRisk 0.0
SLRInundationArea 95.8
Children 64.0
Elderly 25.8
EnglishSpeaking 76.2
Foreign-born 51.5
OutdoorWorkers 79.5
ClimateChangeAdaptiveCapacity —
ImperviousSurfaceCover 86.7
TrafficDensity 34.0
TrafficAccess 87.4
OtherIndices —
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Hardship 0.9
OtherDecisionSupport —
2016Voting 98.7
7.3.OverallHealth&EquityScores
Metric ResultforProjectCensusTract
CalEnviroScreen4.0ScoreforProjectLocation(a)7.00
HealthyPlacesIndexScoreforProjectLocation(b)99.0
ProjectLocatedinaDesignatedDisadvantagedCommunity(SenateBill535)No
ProjectLocatedinaLow-IncomeCommunity(AssemblyBill1550)No
ProjectLocatedinaCommunityAirProtectionProgramCommunity(AssemblyBill617)No
a:ThemaximumCalEnviroScreenscoreis100.Ahighscore(i.e.,greaterthan50)reflectsahigherpollutionburdencomparedtoothercensustractsinthestate.
b:ThemaximumHealthPlacesIndexscoreis100.Ahighscore(i.e.,greaterthan50)reflectshealthiercommunityconditionscomparedtoothercensustractsinthestate.
7.4.Health&EquityMeasures
NoHealth&EquityMeasuresselected.
7.5.EvaluationScorecard
Health&EquityEvaluationScorecardnotcompleted.
7.6.Health&EquityCustomMeasures
NoHealth&EquityCustomMeasurescreated.
8.UserChangestoDefaultData
Screen Justification
LandUse PursuanttoDOF2.51residentsperhousehold,consistentwithPopandHousing
Construction:ConstructionPhases Architecturalcoatingoccurssimultaneouslyasbuildingconstruction
Construction:ArchitecturalCoatings BAAQMDRegulation8Rule3,NonflatCoating
Operations:ArchitecturalCoatings BAAQMDRegulation8Rule3,NonflatCoating
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Operations:EnergyUse PursuanttoPaloAlto'sAll-ElectricOrdinance,naturalgasconvertedtoelectricity
Operations:WaterandWasteWater WTP100%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
From:Ted O"Hanlon
To:Council, City
Cc:Lait, Jonathan; Sar Peruri; Amy Shyr
Subject:11/13/2023: Item #9 Letter on behalf of Creekside Inn property owner to City Council
Date:Monday, November 13, 2023 11:41:36 AM
Attachments:Creekside Owner Rep CC letter 11-13-23.pdf
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Councilmembers
Please review the attached letter highlighting potential limiting factors to housing projects at
the Creekside Inn property at 3400 El Camino Real as part of the Area Focus Plan to be
reviewed with Item #9 this evening.
I do plan to be present at tonight's session and available to respond to any questions regarding
the letter or the property in general.
Thank You
Ted O'Hanlon
---
Ted O'Hanlon
tedohanlon@gmail.com
415.317.5070 mobile/text
CA DRE #01868277
Page 1
Explore Real Estate
CA BRE # 01478789
2625 Middlefield Rd, #101
Palo Alto, CA 94306
November 12, 2023
City Council
City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
Subject: El Camino Real Focus Area Plan and
3400 El Camino Real (Creekside Inn property)
Dear Honorable Mayor and Members of the City Council:
On behalf of SF Creekside, LLC, an Oxford Capital Group-led joint venture that
owns and operates the Creekside Inn (Creekside) property we are taking this
opportunity to share observations regarding potential constraints to redevelopment
and creating housing on the property.
Background
Presently the Creekside Inn property contains 11 buildings with 180 hotel rooms
with ancillary event, operations and conference space with 2 retail dining venues
on approximately 3.6-acres at 3400 El Camino Real.
In 2022, a “pre-application” to redevelop the property with 382 residential units was
submitted and considered by Planning Staff and City Council. See Figure 2.
In June 2023, another preliminary application was submitted utilizing the “Builder’s
Remedy” tool that proposed a mixed use that would continue the hotel presence
as suggested by City Council in 2022, while retaining several existing buildings.
The plan would create 185 new residential units in two new buildings, a cluster of
4 townhome units would replace an existing operations structure adjacent to
Matadero Avenue. The renovation of 3 existing hotel buildings with 63 rooms and
a new hotel building with another 137 guest rooms, would total 200 guest rooms
on the property. See Figure 3.
ECR Focus Area Plan & 3400 ECR Page 2 of 6
Area Focus Plan
Recently the City of Palo Alto has studied an Area Focus Plan to promote housing
projects on El Camino Real that included the Creekside property. The focus plan
suggests significant increases in development standards, most notably in building
heights of up to 85 feet and a Floor Area Ratio (FAR) of up to 4.0. However in
comparison to other properties in the focus area, there are 2 characteristics that
significantly limit Creekside: 1) Matadero Creek, and 2) the property relationship
to R-1 zoning, that result in challenges in achieving an FAR of even 2.5 let alone
4.0.
Thus, while being included in the Focus Area with the intent to motivate a project
that includes a significant number of housing units, by further curtailing the property
area and/or heights where FAR can be placed, this can also yield no project at all.
Recently the Planning and Transportation Commission (PTC) reviewed the Focus
Area and recommended several items that would significantly constrain a potential
project.
Riparian Setbacks
We understand and are mindful that Matadero Creek is a valuable and sensitive
area. At the commencement of ownership’s consideration to redevelop the site,
WRA Environmental Consultants were retained to study the area to better
understand its constraints and opportunities. In doing so, we have understood that
a 20 foot setback from the top of the bank is reasonable and supportable given
existing conditions and guidelines.
As it is today, there are existing buildings encroaching in this area and at the E l
Camino Real frontage of the property where Matadero Creek transitions to a
culvert and is covered by a parking lot (see Figure 1 herein, areas highlighted in
red). At the same time, WRA identified several opportunities to enhance Matadero
Creek including native habitat restoration (currently dominated by non-native flora)
and providing public recreation access. Further, a redevelopment would alleviate
several of the existing encroachments as owner planning has been attentive to
enhancing and respecting this setback area and as such would further enhance
the area adjacent to the creek.
Property Setbacks
The property’s existing zoning adjacent to the R-1 neighbors is multi-family with a
required 10 foot setback. As Figure 1 illustrates, highlighted in blue, 2 existing
buildings are already closer to the property line or at this setback measure. An
increase in the rear setback to 20 feet, as suggested by PTC, would eliminate the
opportunity for housing units in the rear of the site along Matadero Avenue that
most recently proposed 4 attached townhomes. A lso in the 2 previous owner
proposals from 2022 and 2023, particularly the other corner of the property, a
significant setback has been proposed that would be greater than the 20 feet that
PTC recently recommended as part of the Focus Area.
ECR Focus Area Plan & 3400 ECR Page 3 of 6
As the Planning Staff and ordinance text note, Planning and Transportation
Commissioner Hechtman dissented on the extension of 10 foot setbacks to 20
feet. This was based on the observation that the current setbacks of 10 feet are
indicative of the existing zoning that has been in place and it would be reasonable
to remain without the need for further setback extensions.
So for these 2 setback matters, any extensions of the rear property or to riparian
setbacks beyond current standards greatly diminishes housing potential and would
likely preclude the pursuit of a project in not meeting initial feasibility requirements.
Building Height Limits from R-1 Zone
Current zoning standards require a 35 foot height limit 150 feet from the adjacent
property line. The Focus Area initially, and specifically for the Creekside property,
suggested modifications to this setback area that might allow for greater heights
starting 75 feet from the property line, such that the first 75 feet maintain the 35
foot height limit, but the next 75 feet provide a transition for greater building height,
particularly for the proposed 85 foot height allowances on El Camino Real. As the
Focus Area has progressed through review, PTC is recommending that the first
100 feet maintain the 35 foot height restriction.
Similar to Matadero Creek’s current and future environmental condition, there is
understanding of the sensitivity to building height and the adjacent R -1
neighborhood. However when considering this criteria, and the opportunity for
housing it might contain, we would caution to defining the area in advance of a
collaborative effort to refine what is a feasible, actionable and supportable for this
specific area.
Best Regards,
Ted O’Hanlon
Consulting Project Executive
cc: Jonathan Lait (jonathan.lait@cityofpaloalto.org)
Sar Peruri (SPeruri@oxford-capital.com)
ECR Focus Area Plan & 3400 ECR Page 4 of 6
Figure 1- Existing Property Layout
ECR Focus Area Plan & 3400 ECR Page 5 of 6
Figure 2 – July 2022 Proposed Site Plan, note rear building setbacks
ECR Focus Area Plan & 3400 ECR Page 6 of 6
Figure 3 – June 2023 Proposed Site plan – note rear building setbacks and existing
>50’ hotel building within 150’ of rear property line
From:President LWVPaloAlto
To:Council, City
Subject:LWVPA Communication item #9 at 11/13/23 meeting
Date:Monday, November 13, 2023 10:49:26 AM
Attachments:LWVPA PACC 11.13.23 Agenda item 9.docx
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November 13, 2023
RE: Agenda item 9
Dear Mayor Kou, Vice Mayor Stone and Council Members,
The League of Women Voters writes in support of the city increasing height and densities in
zoning districts throughout Palo Alto, along El Camino Real, close to existing transit, parks,
retail, and jobs.
The City’s recent priorities, Climate Change and Housing for Social and Economic Balance,
align with the League of Women Voters positions that local government should adopt policies
that do not provide decent housing and a suitable living environment for people of all income
levels; reduce greenhouse gas emissions from lengthy commutes; and does not result in the
isolation of lower-income families.
More than half of our regional housing allocation requires the production or preservation of
homes serving low-moderate-middle income households. More than half of our green-house
gas emissions, according to the Air Resources Board, come from tail-pipe emissions from
cars, a significant portion from lengthy commutes by people working here who cannot afford
to live here.
Additional height and density changes along ECR and other districts close to existing public
transit are a good first step which could result in more housing (both market rate and below
market rate); reduction of greenhouse gas emissions; and walkable, car-free neighborhoods.
Increasing height and density city-wide also could help address the City's Duty to
Affirmatively Further Fair Housing, as noted by the HCD in its letter rejecting the City's
Housing Element. Increased height and density is currently concentrated in the southeast San
Antonio Road corridor, potentially isolating low income housing in one neighborhood away
from the City's major job centers, close to a polluting freeway which currently lacks public
transit, parks, and retail. We urge the City to use the MTC grant money to study increasing
height and density in the area east of University Ave CalTrain, which is a high opportunity
area close to public transit, shopping, and jobs.
We believe, however, that changing zoning by itself will not be enough to produce the low and
moderate income units needed to address displacement of low and moderate income
households. The City should make it a priority to identify additional sources of financing for
production and preservation of low and moderate income housing, such as tax-exempt bonds;
adopt programs which lower the costs of building, renting or home ownership, including land
banking and the use of public lands; and adopt even stronger tenant protections against
displacement than currently exists. We look forward to upcoming city discussions on these
matters.
Sincerely,
Judy Kleinberg & Nancy Shepherd
Co-Presidents, League of Women Voters of Palo Alto
3921 E. Bayshore Road, Palo Alto CA 94303 (650) 903-0600 www.lwvpaloalto.org
November 13, 2023
RE: Agenda item 9
Dear Mayor Kou, Vice Mayor Stone and Council Members,
The League of Women Voters writes in support of the city increasing height and densities in zoning
districts throughout Palo Alto, along El Camino Real, close to existing transit, parks, retail, and jobs.
The City’s recent priorities, Climate Change and Housing for Social and Economic Balance, align with
the League of Women Voters positions that local government should adopt policies that do not
provide decent housing and a suitable living environment for people of all income levels; reduce
greenhouse gas emissions from lengthy commutes; and does not result in the isolation of lower-
income families.
More than half of our regional housing allocation requires the production or preservation of homes
serving low-moderate-middle income households. More than half of our green-house gas emissions,
according to the Air Resources Board, come from tail-pipe emissions from cars, a significant portion
from lengthy commutes by people working here who cannot afford to live here.
Additional height and density changes along ECR and other districts close to existing public transit
are a good first step which could result in more housing (both market rate and below market rate);
reduction of greenhouse gas emissions; and walkable, car-free neighborhoods.
Increasing height and density city-wide also could help address the City's Duty to Affirmatively Further
Fair Housing, as noted by the HCD in its letter rejecting the City's Housing Element. Increased height
and density is currently concentrated in the southeast San Antonio Roa d corridor, potentially isolating
low income housing in one neighborhood away from the City's major job centers, close to a polluting
freeway which currently lacks public transit, parks, and retail. We urge the City to use the MTC grant
money to study increasing height and density in the area east of University Ave CalTrain, which is a
high opportunity area close to public transit, shopping, and jobs.
We believe, however, that changing zoning by itself will not be enough to produce the low and
moderate income units needed to address displacement of low and moderate income households.
The City should make it a priority to identify additional sources of financing for production and
preservation of low and moderate income housing, such as tax-exempt bonds; adopt programs which
lower the costs of building, renting or home ownership, including land banking and the use of public
lands; and adopt even stronger tenant protections against displacement than currently exist s.
We look forward to upcoming city discussions on these matters
Sincerely,
Judy Kleinberg & Nancy Shepherd
3921 E. Bayshore Road, Palo Alto CA 94303 (650) 903-0600 www.lwvpaloalto.org
Co-Presidents
From:Jessica Rose Agramonte
To:Council, City
Subject:ECR Housing Nov 13, 2023 City Council Meeting Agenda Item 9
Date:Monday, November 13, 2023 8:47:54 AM
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Dear Council Members,
I am writing regarding the El Camino Real Housing Focus Area. We are commercial property
owners of 2951 El Camino Real who have carefully investigated options for multifamily
residential development on this ideally located site, that is included in the Housing Element.
The site is located on the Eastside of El Camino Real, across from the current El Camino Real
Housing Focus area. We have two requests, consistent with notes and recommendations in the
Planning Staff Report:
1) Please DIRECT Planning Staff to further study the Eastside of El Camino Real to include it
in the El Camino Real Housing Focus Area.
2) Please approve the original Planning Staff recommendations for the El Camino Real
Housing Focus Area, as they were based on experienced consultants who recommended a 10'
setback from R1, with a 75' transitional setback for 35' heights and 75'-100' transitional
setback for 45' heights. Anything more, (such as the current 100' setback for 35' height) would
make multifamily residential development unfeasible, in an otherwise ideal location on El
Camino Real, located within the transit corridor.
Thank you for your consideration of these requests,
Jessica Rose Agramonte
From:Deborah Goldeen
To:Council, City
Subject:More Zoning For Housing
Date:Sunday, November 12, 2023 9:51:36 PM
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on links.
________________________________
It’s my understanding that item 9 on tonight’s agenda (Nov.13) about changing zoning to allow for more housing? I
just read through item 9 three times and can’t make heads or tails of it. But I do know that I would like to tear down
my single family stand alone house and replace it with a duplex or a triplex so that maybe one or two more families
can buy into Palo Alto, but City of Palo Alto zoning won’t allow it.
The emotional undercurrent of this city has gone from optimistic and progressive in the ’70’s to excited and
ambitious in the ‘80s to overwhelming and distressed in the ’90’s to just plain mean in the 00’s. In the past couple
years, there is now a palpable anger.
Why it is such a hard concept to understand that other people matter and that those other people need housing too I
don’t know. Not only is ignoring that wrong and bad, but at some point it becomes perilous. I think it behooves the
council to do whatever it can to modify zoning to allow as much housing as possible.
At the very least, if someone wants to use their property to increase housing stock, city zoning should allow for that.
Deborah Goldeen, 2130 Birch, (650)799-3652
From:Greg Schmid
To:Council, City
Subject:Agenda Item #9 on Nov 13: Land Use Element of Comp Plan
Date:Sunday, November 12, 2023 5:24:13 PM
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The 6,086 housing units required by HCD to be built in Palo Alto between 2023 and
2031 are based entirely on a Bay Area new jobs forecast made by HCD in 2019. The
new jobs numbers were subsequently translated into jobs in each city with new
housing concentrated near the new jobs by an internal technical committee directed
by MTC that included the state agencies HCD and DOF.
California Code 65584.01 (current as of Jan 1, 2023) states clearly that the total
population projected for the region by the Department of Finance shall be within 1.5
percentage points of that made by the Council of Governments. If it is not then "the
population of the region shall be the population projection for the region prepared by
the Department of Finance".
Note that in 2019, the Department of Finance forecast a population growth of 7% for
the SF Bay Area in the period 2020-2030, consistent with the housing numbers. But,
in April 2023, the Department updated their projection that showed a population
decline of 1.7% for the Bay Area from 2020-2030. (Note that the 2023 projection
showed a decline of 1.2% for Santa Clara County).
Before approving the Land Use Element of the Comp Plan, it would be appropriate to
ask a representative of DOF to appear publicly before the Council to state clearly
whether that state agency approves of the 2019 population and housing projections
used in the current Bay Area Housing Element. Those numbers appear to be wildly
out of range.
Gregory Schmid
Palo Alto
gregschmid@sbcglobal.net
From:Camas J. Steinmetz
To:Council, City; Burt, Patrick; Kou, Lydia; Lauing, Ed; Lythcott-Haims, Julie; Stone, Greer; Tanaka, Greg; Veenker,
Vicki
Cc:Lait, Jonathan; Stump, Molly; Shikada, Ed
Subject:JCC & Moldaw Ltr re Nov 13 Agenda Item No. 9- HE Rezonings Impacting Fabian Way
Date:Friday, November 10, 2023 4:10:18 PM
Attachments:image001.png
JCC & Moldaw Ltr re Nov 13 Agenda Item No. 9- HE Rezonings Impacting Fabian Way.pdf
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Dear Mayor Kou and Members of the City Council:
On behalf of my clients, the Oshman Family Jewish Community Center and the Moldaw Residences,
please find and consider the attached letter prior to taking action Monday on the proposed
Resolution Amending the Land Use Element of the Palo Alto Comprehensive Plan and an Ordinance
Implementing Program 1.1A and 1.1B of the Housing Element.
Sincerely,
Camas J. Steinmetz
Camas J. Steinmetz, Partner
Jorgenson, Siegel, McClure & Flegel, LLP
1100 Alma Street, Suite 210 | Menlo Park, CA 94025
Phone: (650) 743-9700 |Email: cjs@jsmf.com
W I L L I A M L. M c C L U R E
J O H N L. F L E G E L
D A N K. S I E G E L
J E N N I F E R H. F R I E D M A N
M I N D I E S. R O M A N O W S K Y
D A V I D L. A C H
G R E G O R Y K. K L I N G S P O R N
N I C O L A S A. F L E G E L
K R I S T I N A A. FENT O N
KIMBERLY J. BRUMMER
C A M A S J . S T E I N M E T Z
PHILIP S. SOUSA
____________
B R I T T N E Y L. S T A N D L E Y
CHRISTIAN D . PETRANGELO
JOSEPH H. FELDMAN
J O R G E N S O N, S I E G E L, M c C L U R E & F L E G E L, L L P
A T T O R N E Y S A T L A W
1 1 0 0 A L M A S T R E E T, S U I T E 2 1 0
M E N L O P A R K, C A L I F O R N I A 9 4 0 2 5 -3 3 9 2
(6 5 0 ) 3 2 4 -9 3 0 0
F A C S I M I L E (6 5 0 ) 3 2 4 -0 2 2 7
w w w .j s m f .c o m
Camas J. Steinmetz
(650) 743 -9700 | cjs@jsmf.com
O F C O U N S E L
KENT MITCHELL
____________
R E T I R E D
J O H N D. J O R G E N S O N
MARGARET A. SLOAN
D I A N E S. G R E E N B E R G
____________
D E C E A S E D
M A R V I N S. S I E G E L
(1 9 3 6 - 2 0 1 2 )
J O H N R.C O S G R O V E
(1 9 3 2 - 2 0 1 7 )
November 10, 2023
Mayor Kou and Members of the City Council
City of Palo Alto
city.council@cityofpaloalto.org
Via Email
Re: November 13, 2023 Agenda Item No. 9- Resolution Amending the Land Use Element of
the Palo Alto Comprehensive Plan and an Ordinance Implementing Program 1.1A and
1.1B of the Housing Element (the “Amendments”)
Dear Honorable Mayor Kou and Members of the City Council:
This law firm represents the Oshman Family Jewish Community Center (the “JCC”) and the
Moldaw Residences, a senior living community (“Moldaw”) with respect to the potential
redevelopment of certain parcels of land on Fabian Way that abut the Taube
Koret Campus for Jewish Life in Palo Alto (the “Campus”), where both organizations are situated.
If the proposed Amendments are adopted, these adjacent parcels on Fabian Way will be eligible
for substantial increases in maximum height and density. While the JCC and Moldaw support the
City’s goals to create more housing, we are concerned that if these increases are granted as a
matter of right – without exercising the City’s general police power to protect the public health,
safety and welfare - the existing neighbors will be negatively impacted.
We understand that these Amendments serve the laudable goal of accommodating increased
residential density to meet the City’s RHNA (Regional Housing Needs Allocation) obligations.
However, we are concerned that – as applied to the proposed 3997 Fabian Way project in
particular - these Amendments, with their relaxed development and use restrictions, will have
unintended negative consequences on the members, users and elderly residents of the
Campus. The average age of the Moldaw resident is 87 years and many have limited mobility
requiring the use of walkers and canes. They spend a significant amount of time in their homes,
2
so any adjacent development resulting in the deprivation of natural sunlight in their rooms will
have a material impact on their mental and physical health.
We therefore ask that the City exercise vigilance in continuing to: (1) require and enforce
compliance with the contextual design criteria and objective design standards set forth in
Municipal Code Chapter 18.24; (2) exercise its discretion in requiring project modifications and
conditions to satisfy the architectural review findings set forth in Municipal Code Sections
18.76.020; and (3) exercise its general police power to protect the public health, safety and
welfare. Particularly in current circumstances, and given the age and composition of the residents
and visitors to the Campus, a large new complex overlooking the Campus merits rigorous scrutiny
from the City.
For example, the proposed Amendments allow multifamily residential use (which is currently
prohibited) on the 3997 Fabian Way project site (zoned GM and designated as an opportunity
site) and increase its maximum height to 60 feet. We remind the City that this 60-foot standard
is a maximum and not a by right entitlement. In other words, the City will still retain its discretion
to require a reduction in this maximum height to protect the public health, safety and welfare, bring
the project into compliance with the contextual design criteria and objective design standards set
forth in Municipal Code Chapter 18.24, and satisfy the architectural review findings set forth in
Municipal Code Sections 18.76.020. including for example, to provide “harmonious transitions in
scale, mass and character to adjacent land uses and land use designations” and to “enhance
living conditions on the site (if it includes residential uses) and in adjacent residential areas”. See
Municipal Code Section 18.76.020(d)(2)(D) and (E).
In closing, the JCC and Moldaw support the City’s obligation to meet its assigned RHNA
allocation by adopting the proposed Amendments, and we look forward to working with the City
and their neighbors to make sure that any new developments subject to these Amendments do
not negatively affect the Campus and the Campus community.
Sincerely,
Camas J. Steinmetz
Cc: Ed Shikada, City Manager
Molly Stump, City Attorney
Jonathan Lait, Planning and Development Director
From:Yarkin, Genna (SFO - X56990)
To:Council, City
Cc:Plume, Tamsen (SFO - X56941); Gary Johnson (gary@acclaimcompanies.com); Mark Johnson
Subject:Public Comment - Item 9 for 11-13-2023 Hearing - Stakeholder comments by Acclaim Companies
Date:Friday, November 10, 2023 12:37:17 PM
Attachments:Acclaim Companies - Stakeholder Comments on Item 9 for 11-13-2023 Hearing.pdf
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Good afternoon Councilmembers,
On behalf of our client Acclaim Companies, enclosed please find public comments that address Item
9 you will be hearing this coming Monday evening, November 13th.
Thank you for your attention to this matter,
Genna Yarkin | Holland & Knight PRIDE
She/Her/Hers
Associate
Holland & Knight LLP
560 Mission Street, Suite 1900 | San Francisco, California 94105
Phone 415.743.6990 | Fax 415.743.6910
genna.yarkin@hklaw.com | www.hklaw.com
________________________________________________
Add to address book | View professional biography
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immediately, delete the e-mail from your computer and do not copy or disclose it to anyone else. If you are not an
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confidence in order to preserve the attorney-client or work product privilege that may be available to protect
confidentiality.
Acchtuiii
COMPANIES
11/10/2023
City Council of the City of Palo Alto
250 Hamilton Avenue
Palo Alto, CA 94301
125 Willow Road P 650.324.9439
Menlo Park, CA 94025 www.acclaimcompanies.com
RE: Stakeholder Comments on Item 9 — Public Hearing to Adopt Amendments to the Palo
Alto Comprehensive Plan and Zoning Code to Implement Programs 1.1A and 1.1B of the
Housing Element
Dear Councilmembers,
On November 13th, the Council will be considering important updates to the Zoning Code that
implement Programs 1.1A and 1.1B of the City's Housing Element, which the Council adopted on
May 8th, 2023. Acclaim Companies submitted an SB 330 preliminary application in January and a
formal application in June of this year, for 380 multifamily residential units at 3128 and 3150-3160 El
Camino Real (the "Project"). We have since received one round of City comments and responded in
October. Our Project includes affordable housing and qualifies for certain important tools in the State
Density Bonus Law the ("SDBL").
The entire project site is included in the Housing Element Site Inventory, in the area that the Zoning
Code updates related to Program 1.1A, would designate the "El Camino Real Focus Area." We
understand that the City has worked hard to prepare Zoning Code amendments that would
accommodate our Project proposal, and that may allow us to achieve the same Project without use of
the SDBL. This is consistent with the text of Housing Element Program 1.1A which includes a
statement that the City will, "for the housing opportunity site located at 3128 El Camino Real
(McDonald's), as an alternative to the State Density Bonus law, amend zoning regulations to allow at
least 144 housing units with a maximum height of 50 feet nearest El Camino Real and transitioning
taller away from the street to minimize a wall effect; allow a minimum of 315 housing units if
combined with an adjacent property."
Because we have a vested right to proceed with the Project as proposed pursuant to SB 330, it is not
necessary for us to proceed under the City's proposed alternative to the SDBL. But we do have a desire
to work with the City to achieve a mutually desirable Project and process, to the greatest extent feasible.
However as currently drafted, the Zoning Code amendments that pose an alternative to the SDBL in
the El Camino Real Focus Area, would make our Project infeasible. Each of the below requirements,
if not modified, would reduce the Project's square footage and therefore either require the Project to
reduce its total number of units or change its unit mix, skewing more heavily toward smaller units.
Both the overall unit count and the unit mix are important features of the Project's feasibility.
Accordingly, we are unable to consider abandoning our vested rig>ht to proceed under the SDBL. unless
further updates are made to the amendments before the] are adopted. These proposed changes (and
the reasons for them) are as follows:
1. Increase the Height Allowed for the Upper Story Step Back Along the El Camino Real
Frontage
In the draft of Chapter 18.14.020, Table 3 currently requires that along the El Camino Real frontage,
the maximum height is 55 feet for upper stories within 20 feet of the El Camino Real property line.
We request that one of the following changes be made:
• Increase the stepback height to 59 feet; or
• Clarify that the 55 -foot measurement does not include a parapet
The reason for this change is that the 55 -foot height, if measured to include all building features
including the needed parapet, would not allow us to maintain 10 -foot plate heights for each floor when
taking the project site's slope into account.
2. Make Upper Story Step Back Depth Along the El Camino Real Frontage Consistent With
the Objective Design Standards
In the draft of Chapter 18.14.020, Table 3 currently requires that along the El Camino Real frontage,
the maximum height is 55 feet for upper stories within 20 feet of the El Camino Real property line.
We request that with regard to depth, the step back "shall be a minimum depth of six feet along the El
Camino Real frontage, and the step shall occur for a minimum of 70% of the facade length." This is
consistent with the existing requirement in the City's Objective Design Standards, Section
18.24.050(b)(1)(A).
A deeper step back requirement would conflict with the City's Fire Truck Aerial Access requirements.
Fire trucks must be able to access the Project from within 30 feet of the curb.
3. Decrease the Objective Design Standards' Residential Landscape Requirement in the
Setback Area
Zoning Code Section 18.24.040(b)(5), which is not currently modified by the Zoning Code
Amendments, requires that for projects with ground -floor residential use, that 60% of required setback
areas be landscaped. In order to comply with this requirement, the Project would need to remove a
portion of the building, reducing its unit count. Compliance with the requirement would also create an
unusual street frontage for an urban environment fronting El Camino Real. The requirement also does
not allow for any public gathering spaces or adequate space for entry paths to the Project building.
We hereby request that the requirement be modified in Chapter 18.14.020, Table 3, to allow 10%
landscape coverage in the setback area (which is what is allowed for retail and retail -like use).
We appreciate your consideration of these important changes, and we look forward to bringing much -
needed housing to Palo Alto.
Sincerer.
Mark Johnson
#232617547_v2
125 Willow Road Menlo Park, CA 94025 1 P 650.324.9439 1 www.acclaimcompanies.com
From:Palo Alto Forward
To:Council, City
Subject:Comment Ltr, Agenda Item #9
Date:Friday, November 10, 2023 9:51:38 AM
Attachments:CC Zoning Cmnt Ltr (Agenda Item 9).pdf
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Honorable Mayor and City Council,
At Palo Alto Forward, our aim is to bring people and organizations together to build the
foundation of support you need to ensure more housing is constructed in our city. Please see
our attached letter that includes our partners in housing, the environment, and commitment to
equity:
Mothers Out Front
350SV Palo Alto Climate Action
Palo Alto Student Climate Coalition
SV@Home
Action Council of the Unitarian Universalist Church of Palo Alto
Thank you,
--
Amie Ashton
Executive Director, Palo Alto Forward
650-793-1585
November 10, 2023
SUBJECT: Agenda Item #9 - Housing Element Programs Implementation
Mayor Kou and Honorable City Council Members,
We applaud the work of the Planning Department in keeping the Housing Element moving
forward. We also extend our congratulations to the Housing Element Working Group and the
City Council for taking additional actions related to zoning changes on a portion of El Camino
Real (described below) that will facilitate economically viable housing development.
The innovative zoning regulations being explored for El Camino Real between Page Mill Road
and Matadero Avenue are a step toward a compliant Housing Element and ultimately actual
construction of much-needed housing. The higher floor area ratio (FAR), height, and density
allowed, as well as reduced parking mandates, are what is needed to make housing
economically feasible in our city.
These changes are - very simply - not enough . This sentiment is shared by the coalition of
citizens and organizations who are signatories to this letter for the reasons outlined below.
For the Environment: If we do not build housing near our existing jobs, we put further pressure
on the far suburbs, agricultural land, and natural habitats. Our decisions locally drive sprawling
developments in distant suburbs on a regional level. Constructing housing here in our city near
jobs, shopping, services and transit also shows our commitment to the environment and climate
and demonstrates our compliance with the goals in the city’s Sustainability/Climate Action Plan.
For our Schools: Declining enrollment is a continued threat to our outstanding local schools.
These schools underpin our sense of community and neighborhood identity. We need planned
housing growth near schools in coordination with the school district officials to keep our
education system strong and children thriving, and prevent neighborhood school
closures/program reductions caused by insufficient enrollment.
For our Businesses: Local businesses experience difficulties in hiring and retaining
employees, higher worker costs, more traffic congestion, more air pollution, less time with
family, and less time participating in community recreational activities and events. Additional
housing construction would provide high-quality jobs to local skilled workers, which drives our
local economy. In addition, more housing would provide more customers for our local
businesses hard hit by the customer decline from work from home.
For our Commitment to Principles of Equity: We have much work to do to address
Department of Housing and Community Development (HCD) concerns raised regarding
Affirmatively Furthering Fair Housing. For example, we need to spread the units more evenly
across the city. Decreasing reliance on the City’s discretionary Housing Incentive Program
(HIP), and fixing constraints and processing timeline issues can result in lower development
costs and decreased rents for rent-burdened households (which tend to be BIPOC households).
We understand that the agenda before you tonight relates to very specific area rezonings.
However, we urge you to include in your motion direction to Planning Department staff to
expand the reach and scope of the El Camino upzoning to other areas, specifically to
parcels near transit and job centers. This direction could be included in the third draft of the
Housing Element, which would show HCD we are serious about compliance.
Recent public comments on the Housing Element have been overwhelmingly supportive of
increased development standards. We can and should be a leader in creating innovative
housing solutions, beautiful environments, community spaces, and exciting architecture. We
fully support your efforts to achieve great things for our city.
Linda Hutchins-Knowles
Co-Founder & Team Coordinator Palo Alto
Student Climate Coalition
Regina Celestin Williams
Executive Director
Amie Ashton, Executive Director
on Behalf of the Board of Directors
Action Council of the Unitarian
Universalist Church of Palo Alto
From:slevy@ccsce.com
To:Council, City
Cc:Lait, Jonathan; Shikada, Ed; Nose, Kiely; Guagliardo, Steven
Subject:Nov 13 item 9
Date:Wednesday, November 8, 2023 4:55:11 PM
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Mayor Kou and council members,
I want to thank the staff and support the proposed zoning and development standards
revisions for the ECR focus area and Stanford properties.
Here are my takeaways from that effort:
1) Direct engagement with property owners and their team produced a substantial upward
change in density and FAR and other changes that can hopefully produce economically
feasible housing projects that also include a 20% BMR commitment.
2) There is a strong inference that similar efforts DTN, around Cal Ave and in the GM/ROLM
areas will produce similar results that can strongly increase our ability to meet our housing
goals. The ECR effort is a great start and calls for replication.
I applaud the council for their decisive action Monday to maintain Cal Ave and Ramona
areas car free, based in part from their recognition that a loss of customers from work from
home and online shopping are the major forces restricting retail growth in DTN and Cal Ave.
Here are my takeaways from that positive discussion:
1) More housing DTN and near Cal Ave will add customers and customers with minimal need
for cars to access these shopping and dining areas.
2) Though it has not been a past council preference, limited office growth (if there are
proposals) can offset some of the loss of customers from WFH.
3) More housing in these areas (I live DTN) will more evenly distribute new housing
between north and south PA and in areas close to shopping, services, jobs and transit.
I hope the council will acknowledge and pursue the strong connections between housing,
retail and making it easier to access areas without using a car.
Not related to the housing discussion, i do support better signage and the other
improvements discussed for making the streets attractive but also call attention to the Cal
Ave study findings that zoning and permitting complexity were identified by owners as
barriers to new development.
Stephen Levy
From:Kristi Bascom
To:Kou, Lydia; Stone, Greer; Burt, Patrick; Lauing, Ed; Lythcott-Haims, Julie; Tanaka, Greg;
Vicki.Veemker@cityofpaloalto.org; Clerk, City
Cc:Sharlene Carlson; a_m_mason@yahoo.com; Julie Baskind; Laura D. Beaton
Subject:Request for action on 11/13/2023 City Council Meeting Agenda Item 9
Date:Tuesday, November 7, 2023 12:56:44 PM
Attachments:image001.png
PAR letter to PACC re Agenda Item 9 for 11.13.2023.pdf
You don't often get email from kbascom@smwlaw.com. Learn why this is important
CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.
Dear Honorable Mayor and Councilmembers, Please accept the attached request for Council action on Item #9 on the 11/13/2023 CityCouncil agenda (Ordinance Implementing Program 1.1A and 1.1B of the Housing Element,Including: 1) New Chapter 18.14: Housing Incentives, and 2) Modifications to Base ZoningDistricts Throughout Title 18). We represent the Palo Alto Redwoods Homeowner’s Association (PAR), a community of117 market rate and affordable condominiums located at 4250 El Camino Real. For sometime, PAR has been exploring ways to ensure that their wholly-residential communityreceives protection from the impacts of neighboring commercial uses such as late nightnoise, impacts to privacy, and protection of the daylight plane. To achieve this goal forPAR, and to also benefit other existing and future residential communities in the City facingsimilar issues, we have identified a few minor zoning text amendments. The details areexplained in the attached letter, but in short, PAR is requesting Council’s support tosupplement the zoning text amendments proposed by Staff in Agenda Item #9 with theadditional language we’re proposing. We believe our amendments can be added to theOrdinance that the Council is considering for adoption which is already amending relevantsections of Title 18. We believe these additional amendments can help demonstrate Palo Alto’s commitment tosupporting residential neighborhoods. Thank you in advance for your consideration. Sincerely,Kristi Bascom
Kristi Bascom
Urban Planner
Shute, Mihaly & Weinberger LLP
396 Hayes Street
San Francisco, CA 94102-4421
p: 415/552-7272 x 202 | c: 925/872-6327
www.smwlaw.com | A San Francisco Green Business
November 7, 2023
Via Electronic Mail Only
Honorable Mayor Lydia Kou and Members of the City Council
City of Palo Alto
E-Mail: Lydia.Kou@cityofpaloalto.org, Greer.Stone@cityofpaloalto.org,
Pat.Burt@cityofpaloalto.org, Ed.Lauing@cityofpaloalto.org,
Julie.LythcottHaims@cityofpaloalto.org, Greg.Tanaka@cityofpaloalto.org,
Vicki.Veemker@cityofpaloalto.org, City.Clerk@cityofpaloalto.org,
Re: 11/13/2023 City Council Meeting Agenda Item 9: Ordinance
Implementing Program 1.1A and 1.1B of the Housing Element, Including:
1) New Chapter 18.14: Housing Incentives, and 2) Modifications to Base
Zoning Districts Throughout Title 18
Dear Honorable Mayor and Members of the Palo Alto City Council:
I am writing on behalf of the Palo Alto Redwoods Homeowners Association (“PAR”) to
propose a few minor but important revisions to the Title 18 Zoning Ordinance Amendment you
are considering at the Council meeting on November 13, 2023. These revisions will help ensure
that higher density housing constructed on properties zoned for commercial uses will be treated
like the residential uses they are. These proposed revisions will apply to new housing
development as well as existing residential properties that have been built in commercial zones.
The revisions will demonstrate Palo Alto’s commitment to ensuring that new neighborhoods –
often created in non-traditional areas – are buffered from impacts created by commercial
neighbors such as noise, reduction in access to daylight, and impacts to privacy.
The specific zoning ordinance revisions proposed by PAR are shown in redline in
Attachments 1 and 2 to this letter. Generally speaking, the text revisions extend protections that
currently apply to “residentially zoned property” and apply them to “exclusively residential uses”
as well. This means that whether a property is zoned residential, commercial, or mixed use, if
the property is developed with a wholly residential use, it will be provided the same protection
from inadvertent impacts. The proposed amendments are to PAMC Section 18.16.040(b), which
protects residential uses from the impacts of late night activities, and to PAMC Section
18.16.060, which includes development standards for mixed-use and non-residential uses
including requirements for setbacks, building height, and daylight plane.
Honorable Mayor Lydia Kou and Members of the City Council
November 7, 2023
Page 2
The proposed changes would not only provide these basic protections to the Palo Alto
Redwoods community, but it would also apply other existing residential communities. Likewise,
it would apply to the thousands of future residential units that the City is incentivizing through
implementation of the Housing Element, many of which are likely to be sited on commercially-
zoned land. Simply put, it is most fair and efficient to treat all exclusively residential properties
similarly. Further, not adopting the changes could easily result in an increased burden on the
City when future residents on commercially-zoned properties appeal or otherwise contest
adjacent commercial development to try to get the same projections that residentially-zoned
properties enjoy.
In light of the City’s current efforts to update its zoning code, PAR believes this is an
ideal opportunity for the City to consider these minor changes. We submitted a letter to the
Planning and Transportation Commission when they reviewed the Ordinance Amending the Palo
Alto Municipal Code Title 18 (Zoning) to Implement Housing Element Programs 1.1A and 1.1B
at their meeting on October 11, 2023 and asked for their consideration, but they were not able to
act on the request (see Attachment 3). The City Council, however, can choose to do so. PAMC
Section 18.80.100 (Action by City Council) states: “After consideration of the recommendation
of the planning commission, and the completion of a public hearing, if any, the council may
approve, modify, or disapprove the proposed change of-district boundaries or change of any
other provisions of this title. Should the council determine that a change of district boundaries or
change of any other provisions of this title shall be appropriate, such change shall be
accomplished by ordinance.” Therefore, PAR respectfully requests that the City Council
incorporates these additional zoning text amendments into the Title 18 ordinance being
considered in Item 9 at the November 13, 2023 public hearing.
We believe that PAR’s proposed amendments are covered under the public noticing
completed for Item 9, as it broadly described the project as an “Ordinance Implementing
Program 1.1A and 1.1B of the Housing Element, Including: 1) New Chapter 18.14: Housing
Incentives, and 2) Modifications to Base Zoning Districts Throughout Title 18.” The
amendments proposed by PAR fit within this description. Furthermore, PAR’s proposed text
amendments will not result in an increase in housing production or other impacts beyond the text
amendments already identified by City Staff. We believe that the CEQA documentation
identified in the staff report that covers the proposed Amendments to Title 18 (Zoning) of the
Palo Alto Municipal Code (PAMC) will cover these additional text amendments as well and no
additional CEQA documentation should be required.
We believe that these requested amendments are aligned with the Housing Element
efforts the City is currently implementing and are not incongruous with the zoning ordinance
amendments the City Council is considering in Item 9. If PAR had to apply for this zoning text
Honorable Mayor Lydia Kou and Members of the City Council
November 7, 2023
Page 3
amendment in a separate process, the cost would be at least $30,000 1, and would involve
additional City Staff time and effort to process the application. Because these amendments will
benefit all exclusively residential uses that have been, or will be, developed on commercially-
zoned land and are adjacent to commercial properties, it seems reasonable to think that the City
Council would prefer to incorporate these minor changes now.
If the City Council decides to not incorporate the proposed revisions at this time, PAR
requests that the Council direct staff to study and initiate amendments to Sections 18.16.040(b)
and 18.16.060 to incorporate the changes shown in Attachments 1 and 2. PAMC Sections
18.80.080 (a) and (b) allows the Council to make a motion to initiate changes to the provisions of
Title 18 of their own accord.
On behalf of PAR, we truly appreciate the City Council’s consideration of this request to
incorporate the text amendments shown in Attachments 1 and 2 into the Title 18 Zoning
Ordinance Amendment being considered at the November 13, 2023 public hearing. Please do
not hesitate to contact me if you have any questions regarding this request or if we can provide
any further information that will help with the City Council’s decision. We look forward to the
Council’s discussion and deliberations at the meeting on the 13th.
Very truly yours,
SHUTE, MIHALY & WEINBERGER LLP
Kristi T. Bascom, AICP
Urban Planner
Attachments:
1: Proposed revisions to PAMC Section 18.16.040(b)
2: Proposed revisions to PAMC Section 18.16.060
3: Letter submitted by PAR to the Planning and Transportation Commission dated October 10,
2023
1710592.2
1 According to the City’s Fee Schedule: $4,484.53 deposit for the prescreening, $1,345.00 public
noticing fee, $9,144.54 deposit for Zone Change (Regular and Text Amendments), and $14,957.00 for the
legal review of legislative/zone change. The schedule also notes that “all fees will be recovered”, so
those that are a deposit are likely to increase with no cap to the potential costs incurred by the Applicant.
1
18.16.040 Land Uses
(b) Late Night Use and Activities
The following regulations restrict businesses that operate or have associated
activities at any time between the hours of 10:00 p.m. and 6:00 a.m., where such site
abuts or is located within 50 feet of residentially zoned properties or properties
with exclusively residential uses.
(1) Such businesses shall be operated in a manner to protect residential
properties from excessive noise, odors, lighting or other nuisances from any
sources during those hours.
(2) For properties located in the CN or CS zone districts, businesses that operate
or have associated activities at any time between the hours of 10:00 p.m. and
6:00 a.m. shall be required to obtain a conditional use permit. The director
may apply conditions of approval as are deemed necessary to assure that the
operations or activities are compatible with the nearby residentially zoned
property or property developed with exclusively residential uses.
1
18.16.060 Development Standards
(a) Exclusively Non-Residential Uses
Table 3 specifies the development standards for exclusively non-residential uses
and alterations to non-residential uses or structures in the CN, CC, CC(2) and CS
districts. These developments shall be designed and constructed in compliance with
the following requirements and the context-based design criteria outlined in Section
18.16.090, provided that more restrictive regulations may be recommended by the
architectural review board and approved by the director of planning and
development services, pursuant to Section 18.76.020.
Table 3
Exclusively Non-residential Development Standards
CN CC CC(2) CS Subject to regulations
in Section
Minimum Site
Specifications
Site Area (ft 2 )
Site Width (ft)
Site Depth (ft)
None required
Minimum Setbacks
Front Yard (ft)
0 - 10' to
create an 8'
- 12'
effective
sidewalk
width (1),
(2), (8)
None
Required
(8)
0 - 10' to
create an
8' - 12'
effective
sidewalk
width (1),
(2), (8)
0 - 10' to
create an
8' - 12'
effective
sidewalk
width (1),
(2), (8)
Setback lines imposed
by a special setback
map pursuant to
Chapter 20.08 of this
code
Rear Yard (ft)
None required
Interior Side Yard (ft)
Street Side Yard (ft) 20' (2) None required
Minimum Yard (ft) for lot
lines abutting or opposite
residential districts or
residential PC districts or
properties developed with
exclusively residential
uses
10’ (2) 10’ (2) 10’ (2) 10’ (2)
2
CN CC CC(2) CS Subject to regulations
in Section
Build-To-Lines 50% of frontage built to setback (7)
33% of side street built to setback (7)
Minimum setbacks from
alleys for structures other
than public parking
garages (ft) (3)
Corner lots, from rear lot
line on the alley
Not applicable
8’
Not
applicable
Corner lots, from side lot
line on the alley None
All lots other than corner
lots 20’
Maximum Site Coverage 50% None required
Maximum Height (ft)
18.08.030
Standard
25' and 2
stories
50’ 37’ (4) 50’
Portions of a site within
150 ft. of an abutting
residential district (other
than a PC zone) or within
150 ft. of an abutting
property developed with
exclusively residential
uses. (9)
35’ 35’ 35’
Maximum Floor Area
Ratio (FAR) 0.4:1 2.0:1 0.4:1 18.18.060(e)
Maximum Floor Area
Ratio (FAR) for Hotels N/A - (5) 2.0:1 2.0:1 18.18.060(d)
Daylight Plane for lot
lines abutting one or
more residential zone
districts other than an
RM-40 or PC zone or for
lot lines abutting a
property developed with
3
CN CC CC(2) CS Subject to regulations
in Section
exclusively residential
uses.
Initial Height at side or
rear lot line (ft) - (6) - (6) - (6) - (6)
Slope - (6) - (6) - (6) - (6)
(1) No parking or loading space, whether required or optional, shall be located in the first 10
feet adjoining the street property line of any required yard.
(2) Any minimum front, street side, or interior yard shall be planted and maintained as a
landscaped screen excluding areas required for access to the site. A solid wall or fence
between 5 and 8 feet in height shall be constructed along any common interior lot line.
(3) No setback from an alley is required for a public parking garage.
(4) As measured to the peak of the roof or the top of a parapet; penthouses and equipment
enclosures may exceed this height limit by a maximum of five feet, but shall be limited to an
area equal to no more than ten percent of the site area and shall not intrude into the daylight
plane.
(5) See additional regulations in subsection (e) of this Section 18.16.050.
(6) The initial height and slope shall be identical to those of the most restrictive residential zone
abutting the site line in question.
(7) Twenty-five-foot driveway access permitted regardless of frontage; build-to requirement
does not apply to CC district.
(8) A 12-foot sidewalk width is required along El Camino Real frontage.
(9) Distance shall be measured from the property line of the subject site. 150-foot measurement
may be reduced to 50 feet at minimum, subject to approval by the Planning Director, upon
recommendation by the Architectural Review Board pursuant to criteria set forth in Chapter
18.76.
(b) Mixed Use and Residential
Table 4 specifies the development standards for new residential mixed use
developments and residential developments. These developments shall be designed
and constructed in compliance with the following requirements and the objective
design standards in Chapter 18.24. Non-Housing Development Projects and Housing
Development Projects that elect to deviate from one or more objective standards in
Chapter 18.24 shall meet the context-based design criteria outlined in Section
18.16.090, provided that more restrictive regulations may be recommended by the
architectural review board and approved by the director of planning and
development services, pursuant to Section 18.76.020.
4
Table 4
Mixed Use and Residential Development Standards
CN CC CC(2) CS Subject to regulations
in:
Minimum Site
Specifications
Site Area (ft2)
None required
Site Width (ft)
Site Depth (ft)
Minimum Setbacks
Setback lines imposed
by a special setback
map pursuant to
Chapter 20.08 of this
code may apply
Front Yard (ft)
0' - 10' to
create an 8'
- 12'
effective
sidewalk
width (8)
None
Required
(8)
0' - 10' to
create an
8' - 12'
effective
sidewalk
width (8)
0' - 10' to
create an
8' - 12'
effective
sidewalk
width (8)
Rear Yard (ft) 10' for residential portion; no requirement for
commercial portion
Rear Yard abutting
residential zone district or
a property developed with
exclusively residential
uses (ft)
10’
Interior Side Yard if
abutting residential zone
district or a property
developed with
exclusively residential
uses (ft)
10’
Street Side Yard (ft) 5’
Built-to-Lines 50% of frontage built to setback (1)
33% of side street built to setback (1)
Permitted Setback
Encroachments
Balconies, awnings, porches, stairways, and similar
elements may extend up to 6' into the setback.
Cornices, eaves, fireplaces, and similar architectural
features (excluding flat or continuous walls or
enclosures of interior space) may extend up to 4' into
the front and rear setbacks and up to 3' into interior
side setbacks
Maximum Site Coverage 50% 50% 100% 50%
Minimum
Landscape/Open Space
Coverage
35% 30% 20% 30%
5
CN CC CC(2) CS Subject to regulations
in:
Usable Open Space
(Private and/or
Common)
150 sq ft per unit (2) 18.16.090
Maximum Height (ft)
Standard 35’ (4) 50’ 37’ 50’
Portions of a site within
150 ft. of an abutting
residential district (other
than an RM-40 or PC zone)
or within 150 ft of an
abutting property
developed with
exclusively residential
uses.
35’ 35’ 35’ 35’ 18.08.030
Daylight Plane for lot
lines abutting one or
more residential zoning
districts or abutting a
property developed with
exclusively residential
uses.
Daylight plane height and slope shall be identical to
those of the most restrictive residential zoning
district abutting the lot line. If no residential zoning
district abuts the lot line, the daylight plane and
slope shall be identical to that of any exclusively
residential use abutting the lot line.
Residential Density
(net)(3) 15 or 20 (9)
See sub-
section (e)
below
No
maximum
30 18.16.060(i)
Sites on El Camino Real No
maximum
No
maximum
Sites on San Antonia Rd
between Middlefield Rd
and E. Charleston Rd.
15 or 20 (9) No
maximum
Maximum Residential
Floor Area Ratio (FAR) 0.5:1(4) 0.6:1 0.6:1 18.16.065
Maximum
Nonresidential Floor
Area Ratio (FAR)
0.4:1 2.0:1 0.4:1
Total Mixed Use Floor
Area Ratio (FAR) 0.9:1 (4) 2.0:1 1.0:1 18.16.065
Minimum Mixed Use
Ground Floor Commercial
FAR(6)
0.15:1 (10)
0.15:1
(10)
0.25:1 (7)
(10)
0.15:1
(10)
Parking See Chapters 18.52 and 18.54 (Parking) 18.52, 18.54
(1) Twenty-five-foot driveway access permitted regardless of frontage; build-to requirement
does not apply to CC district.
(2) Required usable open space: (1) may be any combination of private and common open
spaces; (2) does not need to be located on the ground (but rooftop gardens are not included
as open space except as provided below); (3) minimum private open space dimension six
feet; and (4) minimum common open space dimension twelve feet.
6
For CN and CS sites on El Camino Real and CC(2) sites that do not abut a single- or two-
family residential use or zoning district, rooftop gardens may qualify as usable open space
and may count as up to 60% of the required usable open space for the residential component
of a project. In order to qualify as usable open space, the rooftop garden shall meet the
requirements set forth in Section 18.40.230.
(3) Residential density shall be computed based upon the total site area, irrespective of the
percent of the site devoted to commercial use.
(4) For CN sites on El Camino Real, height may increase to a maximum of 40 feet and the FAR
may increase to a maximum of 1.0:1 (0.5:1 for nonresidential, 0.5:1 for residential).
(5) Distance shall be measured from the property line of the subject site. 150-foot measurement
may be reduced to 50 feet at minimum, subject to approval by the Planning Director, upon
recommendation by the Architectural Review Board pursuant to criteria set forth in Chapter
18.76.
(6) Ground floor commercial uses generally include retail, personal services, hotels and eating
and drinking establishments. Office uses may be included only to the extent they are
permitted in ground floor regulations.
(7) If located in the California Avenue Parking Assessment District.
(8) A 12-foot sidewalk width is required along El Camino Real frontage.
(9) Residential densities up to 20 units/acre are allowed on CN zoned housing inventory sites
identified in the Housing Element. Other CN zoned sites not located on El Camino Real are
subject to a maximum residential density of up to 15 units/acre.
(10) In the CC(2) zone and on CN and CS zoned sites on El Camino Real, there shall be no
minimum mixed use ground floor commercial FAR for a residential project, except to the
extent that the retail preservation requirements of Section 18.40.180 or the retail shopping
(R) combining district (Chapter 18.30(A)) applies.
October 10, 2023
Via Electronic Mail Only
Jonathan Lait, Planning Director
City of Palo Alto
E-Mail: jonathan.lait@cityofpaloalto.org
City of Palo Alto Planning & Transportation Commission
E-Mail: Planning.Commission@CityofPaloAlto.org
Re: Proposed Changes to the Palo Alto Zoning Code to Incorporate
Residential Protections for the Palo Alto Redwoods Community
Dear Mr. Lait and Planning and Transportation Commissioners:
I am writing on behalf of the Palo Alto Redwoods Homeowners Association
(“PAR”) to suggest a few minor but important updates to the City’s zoning code. The
117-unit Palo Alto Redwoods condominium complex located at 4250 El Camino Real,
includes a diverse group of residents, with both market-rate and deed-restricted below-
market-rate homes.
As you may be aware, the land where Palo Alto Redwoods is located is currently
zoned as commercial. The land surrounding Palo Alto Redwoods is also zoned as
commercial. Consequently, Palo Alto Redwoods – despite being a property with only
residential uses – does not enjoy some of the protections that other residentially zoned
properties in Palo Alto receive with respect to buffering of incompatible land uses.
PAR has explored rezoning the land where Palo Alto Redwoods is located to a
high-density residential district, which would allow the community to benefit from the
zoning code’s buffering protections. But City staff informed PAR in February of this year
that the rezoning process could potentially cost thousands of dollars with no guarantee of
success.
In light of the City’s current efforts to review its zoning code, however, PAR
believes there is an opportunity for the City to consider some minor changes that could
Jonathan Lait
October 10, 2023
Page 2
benefit Palo Alto Redwoods and similarly situated communities. These changes would
afford our residents many of the protections that the City’s other residentially zoned
properties currently enjoy.
I have reviewed the City’s zoning code and identified two sections of the
Municipal Code that that could be revised to achieve PAR’s goals with minimal changes.
These sections currently set standards for hours of operation, minimum setbacks, building
height, and daylight plane for commercially zoned properties located close to
residentially zoned land. By changing the refences in these code sections from
“residential zoning” to “residential uses,” the zoning code would provide Palo Alto
Redwoods residents similar protections as other residential zones, even though Palo Alto
Redwoods is located on commercially zoned land.
This proposed change would not only provide basic protections to the Palo Alto
Redwoods community. It would likewise benefit other existing and the 6,000 to 20,000
future residential properties that the City will be approving through implementation of the
housing element, which are likely to be sited on commercially-zoned land. By including
PAR’s proposed change in the City’s upcoming zoning changes, it would support
residential uses in commercial zones by ensuring that such residential developments
enjoy the same protections as residential uses on residentially zoned land. Further, not
adopting the changes could easily result in an increased burden on the City when future
residents on commercially zoned properties appeal or otherwise contest adjacent
commercial development to try to get the same projections that residentially zoned
properties enjoy. Simply put, it is most fair and efficient to treat all residential properties
similarly.
I have attached redlined versions containing proposed changes to the two
referenced code sections—section 18.16.040, governing hours of operation, and section
18.16.060, governing building setbacks, building height, and daylight plane. We
appreciate the Planning Commission’s consideration of these changes and hope the
Commission will include these minor amendments with other the other zoning changes it
is currently considering.
Please do not hesitate to contact me if you have any questions or if I can provide
any further information.
Jonathan Lait
October 10, 2023
Page 3
Very truly yours,
SHUTE, MIHALY & WEINBERGER LLP
Kristi T. Bascom, Urban Planner
November 13, 2023 www.cityofpaloalto.org
HOUSING ELEMENT
IMPLEMENTATION
Program 1.1
Zoning Code Amendments
PTC Public Hearing
Consultant: Jean Eisberg, Lexington Planning
2
1.Action Item to consider Comprehensive Plan and Zoning Amendments pursuant
to Program 1.1A and 1.1B of the Housing Element
2.Consider Planning & Transportation Commission recommendations and public
comments; take legislative action to adopt proposed zoning code amendments
MEETING PURPOSE
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HOUSING ELEMENT STATUS
City Council
Adopted
Housing
Element
City Sent to
HCD
SeMay/June 2023. August 2023
HCD Issued
Comment
Letter
July 2023
Revise Housing Element
Update Sites Inventory
City Council to Re-Adopt
Re-Submit to HCD
Implement Housing Element
Program 1.1 Zoning Changes
Other Zoning Amendments
Other Programs
Fall 2023 - Winter 2024
Due January 2024
4
1.Rezone R-1, ROLM, RP, GM, and PF districts to allow
multiple-family housing as a permitted use
2.Upzone to increase density/floor area ratio
3.Modify standards to reduce constraints and ensure
development is feasible at planned densities
4.Complete other statutory requirements (e.g.,
allowing 100% residential uses and 50% residential
for mixed use)
PROGRAM 1.1A: ADEQUATE SITES INVENTORY
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PROGRAM 1.1A: ADEQUATE SITES INVENTORY
●Density: 20-50 → 30-50 du/ac (or not regulated)
●FAR: 0.5-1.25 → 1.25-2.5 (or higher in focus areas)
●Allow landscape coverage requirement to be met
above the ground-level
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●Density: 30 → 90 du/ac
●FAR: 0.5-1.25 → 2.5
●Height: 35-50 → 60 feet
●Modifications to lot coverage and landscape coverage
●Parking reduction for 2+ bedroom units
●State Density Bonus applies
→ integrated planning will be required to support related
improvements to transit, parks, services, etc.
PROGRAM 1.1B: GM/ROLM FOCUS AREA
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PROGRAM 1.1A: STANFORD SITES
●Program 1.1A (Adequate Sites Inventory) calls for specific changes to three
Stanford University-owned sites: higher FARs and densities expected
**Current proposal is to expand this program to account for more sites in this area
of El Camino Real (Parmani Hotel and potentially Palo Alto Square)
3150 El Camino Real 3300 El Camino Real Welch/Pasteur/Sand Hill Rd.
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PASTEUR DR. (STANFORD)
●Redevelop existing housing
●Stanford affiliates only
●Maintain landscaped setback
●Existing utility easement provides
break in facade length
●Inclusionary housing fee payment
●Must meet Objective Standards (as
modified)
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DRAFT STANDARDS (PASTEUR DR.)
Maximum FAR 3.5
Maximum Lot Coverage 60%
Maximum Density None
Maximum Height 85
Daylight Plane Sand Hill Rd. frontage only
Open Space 100 sq. ft/unit (any combination of
common and/or private)
Minimum Parking 0.5 spaces/unit ●Alternative to State Density Bonus Law
●Other standards, refer to RM-40 base
zoning district
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EL CAMINO REAL FOCUS AREA
Identify opportunity sites taking into
consideration HCD feedback, existing
potential development plans and legal
uncertainties related to builder’s
remedy
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OPPORTUNITIES & CONTEXT
●Few adjacencies/existing residents
●Excellent access to transit, jobs,
shopping, services, and Stanford
●Motivated property owners
●Builder’s remedy and
pre-applications submitted
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DRAFT REGULATIONS (EL CAMINO FOCUS AREA)
Maximum FAR 4.0
Maximum Lot Coverage 70%
Maximum Density (du/ac)None
Maximum Height 85
Daylight Plane or Step Back Upper story stepback on El Camino Real.
Daylight planes and height transitions
abutting low density residential
Open Space 100 sq. ft/unit (any combination of
common and/or private)
Minimum Parking 1 space/unit
●Incentive: Standards are an alternative to
State Density Bonus Law
●Design Review: Projects must go through
Architectural Review
●Transportation Demand Management: To
achieve reduced parking, must provide
transit passes and e-bike parking
●Affordability: Project must provide 20%
Inclusionary Housing (on-site) @ 80% AMI
●Other Standards: See base zoning district
(i.e., RP, RM-20, CS)
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❏Meets State Housing Element law requirements & timeline
❏Completes Program 1.1A & 1.1B in the Housing Element
❏Improves physical feasibility to meet densities and increase
unit yield
❏Increases affordable housing production and generate more
in-lieu fees
❏Resets the “base” density and density bonus allowed under
State Density Bonus Law
❏Adds complexity: need to look in two chapters for applicable
standards
EFFECTS OF PROPOSED ZONING CHANGES
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●Zoning changes necessitate revisions to Land
Use Element to allow higher density uses
●Attachment A annotates amendments to the
Land Use Element to:
○Permit higher FARs and densities, as
stipulated in the Zoning Ordinance
○Allow multi-family on R-1 faith-based sites
COMPREHENSIVE PLAN AMENDMENTS
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PTC FEEDBACK AND ACTION
●PTC recommended that the City Council approve amendments to the
Comprehensive Plan and Zoning Ordinance, with amendments:
○Research minimum densities in the GM/ROLM Focus Area
■Staff increased minimum densities to discourage townhomes and
encourage stacked flats
○Consider impact of lost property tax revenues due to Stanford affiliate housing
■Draft ordinance prevents affiliate housing on El Camino Real.
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PTC FEEDBACK AND ACTION (CONTINUED)
●Modify a state-mandated requirement to increase the minimum residential floor area
requirement from 50% to 65% for mixed use projects on opportunity sites identified as
meeting lower income households
○Staff recommends maintaining State threshold of 50% (ordinance reflects PTC
recommendation)
●For the El Camino Real Focus Area, require a 20-foot setback adjacent to the R-1 zoning
district and extend the height transition zone to 35’ height within 100 feet of the R-1
property line and 45’ height between 100’ and 150’
○Staff recommends maintaining existing 10-foot rear setback, required daylight plane,
and required height transition (ordinance reflects PTC recommendation)
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3400 EL CAMINO REAL TRANSITIONS
●Creek Protections: Staff is securing a consultant to evaluate Comp Plan programs
related to stream corridor protections, including setback standards; current code
requires a 20-foot top of bank setback.
●Height Transitions: Height limits adjacent to R-1 zoning district
150 ft.
setback
to R-1 Zone
(35-foot
maximum
height)
35 ft. max
height w/in
0-75 ft
45 ft. max
height w/in
75-150 ft
RM-30 zone
requires a 10-foot
setback
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CORRESPONDENCE
1.Property owner of shaded
properties, seeks inclusion in
the Housing Focus Area
○Requires study - Council
may direct future inclusion
2.Acclaim Companies (3150 ECR)
asserts standards infeasible:
○Building height
○Upper level setbacks
○Landscaping requirements
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SUMMARY
Discussion Sequence
1.Staff presentation
2.Council clarifying questions
3.Public comment
4.Councilmember Veenker Recusal
5.Discussion on Stanford-owned properties (Pasteur
Drive and Housing Focus Area)
6.Council Motion on Stanford-owned properties &
Housing Focus Area
7.Councilmember Veenker returns to the dias
8.Deliberation / Action on remaining portions of the
ordinance / land use element amendment
Council Considerations Regarding the Housing Focus Area
1.PTC Housing Focus Area Recommendations
○Restrictions on Stanford-affiliate housing (El Camino
Real sites)
○Transitional height recommendations from R1 zoned
properties (low density housing)
○Increased setback from R1 and low density zoning
2.Provide direction to staff to explore opportunities to expand the
Housing Focus Area
3.Acclaim Companies letter concerning the Housing Focus Area
○Exempt parapet/guardrail height in the Focus Area (and
Pasteur Drive site)
○Transitional height limit adjacent to El Camino Real:
retain or modify (fire safety / alternative setback)
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STAFF RECOMMENDATION
1.Adopt a resolution amending the Comprehensive Plan Land Use Element
2.Adopt an ordinance amending Title 18 (Zoning) to implement Program 1.1A
and 1.1B of the Housing Element regarding the Adequate Sites Inventory
November 13, 2023 www.cityofpaloalto.org
HOUSING ELEMENT
IMPLEMENTATION
Program 1.1
Zoning Code Amendments
PTC Public Hearing
Consultant: Jean Eisberg, Lexington Planning