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HomeMy WebLinkAboutStaff Report 2412-3928CITY OF PALO ALTO CITY COUNCIL Special Meeting Monday, February 10, 2025 Council Chambers & Hybrid 5:30 PM     Agenda Item     15.PUBLIC HEARING / QUASI-JUDICIAL. 3265 El Camino Real [24PLN-00012]: Approval of an Ordinance Rezoning the Subject Parcel From Commercial Services (CS) to Planned Community Zoning (PC) and Adoption of a Record of Land Use Action to Construct a 100% Affordable, Five-Story, 55 Unit Residential Rental Project. Environmental Assessment: Initial Study/15183 Streamlined CEQA Review. Public Comment, Staff Presentation City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: February 10, 2025 Report #:2412-3928 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 3265 El Camino Real [24PLN-00012]: Approval of an Ordinance Rezoning the Subject Parcel From Commercial Services (CS) to Planned Community Zoning (PC) and Adoption of a Record of Land Use Action to Construct a 100% Affordable, Five- Story, 55 Unit Residential Rental Project. Environmental Assessment: Initial Study/15183 Streamlined CEQA Review. RECOMMENDATION Staff Recommends the City Council take the following actions: 1. Consider the Initial Study Checklist/Streamlined Environmental Review prepared in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183; 2. Adopt the Ordinance in Attachment B amending the zone district from CS to PC; and 3. Approve the Record of Land Use Action in Attachment C. EXECUTIVE SUMMARY The applicant proposes to rezone the vacant parcel located at 3265 El Camino Real (Attachment A) from Commercial Services (CS) to Planned Community (PC), which is sometimes referred to as Planned Home Zoning (PHZ).1 The parcel would be developed with a 100% affordable, 55- unit residential rental project. Fourteen of the units are proposed to be dedicated at a rate affordable to low income, not to exceed 70% of area median income (AMI) levels. Forty-one of the units would be dedicated at a rate affordable to moderate income, not to exceed 110% of AMI. The applicant has also established a private agreement with the Palo Alto Educator Association (PAEA) to prioritize housing Palo Alto teachers when seeking tenants ; however, there is no guarantee that teachers will be the only occupants of the building. Staff’s review of the revised project concludes that it is consistent with the findings for approval of a Planned Community rezoning. The ARB and PTC recommended approval of the project on November 21, 2024, and January 15, 2025, respectively. Accordingly, staff recommends that the Council adopt the PC/PHZ ordinance in Attachment B and approve the record of land use 1 Referred to in this report as "Planned Home Zoning" (PHZ) to emphasize the focus on housing as the benefit to the community. PAMC Section 18.38, which outlines the requirement and process for Planned Community (PC) Zoning, remains the underlying code supporting application of this policy. action in Attachment C. The Program Statement and Development Schedule are included as Attachment H and the Development Plan is included as Attachment I. The City prepared an analysis of the project in accordance with CEQA Guidelines Section 15183, which evaluated the project’s consistency with the Comprehensive Plan and the Comprehensive Plan Environmental Impact Report (EIR). The analysis concludes that the project is consistent with the previously adopted Comprehensive Plan and that the adopted EIR adequately addresses the impacts of the proposed project. BACKGROUND On February 3, 2020, Council unanimously endorsed using Planned Community (PC) Zoning for housing and mixed-use housing projects to help spur housing production and rebranded it Planned Home Zoning (PHZ). In exchange for deviation from certain standards as allowed under the rezoning, if approved by Council, the project must include at least 20% of the housing units as deed restricted for lower-income households. Moreover, the number of housing units must offset the number of net new commercial jobs that are generated by the project. The project’s consistency with this Council direction is discussed further in this analysis. The applicant filed a prescreening application in 2023 to consider a zone change in accordance with Council’s direction regarding PHZ projects. Council held a prescreening hearing on September 11, 2023, to consider the proposed project. Project Description On January 10, 2024, Trachtenberg Architects filed an application on behalf of Half Dome Capitol to rezone the subject parcel from CS to PC/PHZ and to redevelop the site with 44 residential rental units. Twenty percent of the units were proposed to be restricted at a rate affordable to low income (not to exceed 80% AMI) and 80% of the units would be restricted at a rate affordable to moderate income (not to exceed 110% AMI). After the April 10, PTC meeting, the applicant revised the submittal in response to commissioner requests for a deeper level of affordability and more units. The revised proposal is a six-story building with 55 units that is 70 feet tall to the top of the roof deck line, 79 feet tall to the elevator overrun. Twenty-five percent of the units are proposed to be restricted at a rate affordable to low income (rents based on 70% AMI) and 75% of the units are proposed to be restricted at a rate affordable to moderate income (rents based on 110% AMI). The project includes 33,089 square feet of gross floor area on a 7,493 square foot lot (floor area ratio of 4.42: 1.0). The project also includes a 1,700 square foot roof top deck and 32 total parking spaces provided in an at-grade parking garage utilizing a parking lift system. The building’s exterior materials will be stucco siding, metal infill panels to frame the windows, and a painted cementitious paneling at the elevator and stairs on the side of the building which faces the Kasa Hotel and at the rear. The applicant’s project description is included in Attachment H. The project plans are included in Attachment I. Requested Entitlements, Findings and Purview: The following discretionary application is being requested: • Planned Community (PC/PHZ) Rezoning: The process for evaluating this type of application is set forth in PAMC 18.38.065. PC rezoning applications require review by the PTC and the Architectural Review Board, a final review of a development plan for review and recommendation by the PTC, and a decision by the Council. The findings under 18.38.060 must be made in the affirmative for project approval. The Architectural Review Board makes a recommendation on the development plan in accordance with the findings for architectural review in Section 18.76.020 pursuant to 18.38.065(b). These findings are included in Attachment B. For housing projects rezoning to PC (labeled “Planned Home Zoning”) Council expressed an expectation that projects provide at least 20% of the units at below market rate. Council Prescreening City Council held a prescreening to evaluate the proposed rezoning of the property for a 100% affordable housing project at the subject property on September 11, 2023. At the prescreening, Councilmembers provided the following feedback (applicant responses provided): •How long do the parking stackers take to cycle through? Will tenants be leaving all at once and create a circulation issue? o 10-60 seconds depending on vehicle location; Different zones can operate individually. •How will parking be allocated? Will spaces be un-bundled with units? o Unbundled; anticipated rates are $150/space. •What is the estimated rent and will it be affordable to teachers? o See “Public Benefit” discussion below. •Is the proposed driveway wide enough to allow vehicles to move in and out? o Driveway expanded from 14 feet to 20 feet Unbundled parking is a tool that encourages alternative modes of transit to and from work by providing parking on-site as a cost, rather than for free. Coupling unbundled parking with providing a free transit pass to tenants are incentives in the proposed TDM plan to reduce vehicle trips to and from work. While the applicant has proposed unbundled parking at a rate of $150/unit for units that receive a parking stall, it is a deviation and request of the PHZ application from the City’s definition of “affordable rent” under PAMC 16.65.020(d) which requires that parking be included in a tenant’s rent. . However, if parking were included in each unit’s rent, this would require rents to be uniformly lowered to maintain the effectiveness of unbundled parking as a tool. The applicant has noted that this would also make the project financially infeasible. Staff has concerns that applying a flat fee for unbundled parking will disproportionately impact low-income tenants. As a result, staff recommends adopting COA #14 which provides that the unbundled parking cost be capped at 4% and 5% of anticipated rent plus the utility allowance for the low-income and moderate-income units, respectively. This ratio would result in low- income units paying roughly $90.36 or $103.28 a month for parking, and moderate-income units paying roughly $177.40 or $202.80 a month for parking (see anticipated rents in Public Benefit section below). Either option would be a deviation from the City’s current code requirements, but Council could also require the applicant include the cost for parking in rent for these units. Planning and Transportation Commission (PTC) The PTC held the first formal hearing for this project on April 10, 2024, and the second hearing on January 15, 2025. Links to the PTC staff reports, meeting minutes, and video recordings are provided in the footnote below.2 At the initial hearing Commissioners provided feedback/requested information on expanding the rooftop open space, expanding the TDM plan provisions, the affordability level of the units, and analyzing site circulation. Following the PTC and ARB’s initial review, the applicant made substantive changes to the project design, which included increasing the unit count from 44 units to 55 units. The proposed floor area ratio (FAR) and height increased commensurate to the increase in units, resulting in a proposed FAR of 4.42 (previously 3.58 FAR) and height of 79 feet, 8 inches (previously 64 feet). The applicant has stated that this change allowed the project to be economically viable while addressing PTC and Council feedback to provide the units at a deeper level of affordability. On January 15, 2025, the PTC recommend approval of the project on a 3-2 vote [Chang, Summa – against]. Both Chair Chang and Commissioner Summa raised concerns that the project was not an Affordable Housing project based on the anticipated rent levels shown in the staff report for the Moderate-Income deed-restricted units and should not benefit from provisions in Title 16 that waive development impact fees for 100% Affordable Housing projects. At the hearing, the PTC made the following motion: Recommend approval of the project subject to the following additional conditions of approval: 1. Future residents shall be notified that if a future Residential Parking Permit (RPP) will be enacted, that they may be excluded from it. 2. The property manager shall provide an annual report to the City of the number of Palo Alto Unified School District employees that occupy the building and which unit types they are occupying. There was a robust discussion between the commissioners about whether units that are deed- restricted at a Moderate-Income level are truly below market rate or are charging rents that are comparable to market rate units based on available data. The PTC recommended that Council 2 April 10, 2024, PTC Agenda Item #2, 3265 El Camino Real: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13632 November 21, 2024 ARB Agenda Item #3, 3265 El Camino Real: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=15699 could study this to inform decisions on future housing projects and the options within the PHZ process. Staff would recommend that this item be added to the PTC or Council Work Plan and prioritized to other work if the Council would like to investigate this further. The PTC also wanted to understand the length of time that these units will be deed-restricted for and when that will be decided as it is not explicitly captured in draft Condition of Approval #14. During the discussion, staff noted that PAMC 16.65.075 requires that all affordable units be deed restricted to 99-years or a 55-year timeframe, when required by tax credit financing, and that those timeframes are typically negotiated by staff through the regulatory agreement after the project is approved. It is important to note that PAMC 16.65.075 applies to the City’s inclusionary housing requirements for ownership projects and that rental projects do not have an inclusionary housing requirement. Other 100% affordable housing projects have been deed restricted to a 55-year timeframe to maintain tax credit financing and staff recommends these units be similarly restricted given that the project is not receiving public subsidy. Draft Condition of Approval (COA) #14 has been updated to capture this recommendation. Architectural Review Board The ARB reviewed the project on April 18, 2024 and suggested improvements to the design related to the front and rear stucco facades, window placement towards Kasa Hotel, privacy screening between patios at level 2, expanding the rooftop deck, recessing the garage door, including an interior door to the garage from the lobby, and introducing a skylight over the bike area at the rear of the building. On November 1, 2024, the ARB reviewed the revised design and recommended approval of the project on a 4-1 vote [Baltay – against]. Board member Baltay was concerned that the design of the units and open space were substandard and inappropriate to expect residents to occupy given the physical limitations of the site and the density proposed. At the hearing, the ARB made the following motion: Recommend approval of the project with the following additional conditions of approval: 1. Modify the façade at the stairwells to introduce natural light. 2. Modify the rear wall to introduce natural light into the bike storage room. 3. Include auditory/visual warnings at garage door when opening. 4. Consider a schedule for garage door operation (e.g. open certain hours) 5. Return to the ARB Ad-Hoc to evaluate the painted cementitious panel along the stairwells a. Provide a detail showing how the articulation will be handled; consider using different colors/materials to create shadow and depth on the façade. b. Provide detail which shows the vertical transition between boards 6. Remove the requirement to recess the garage door from COA #28; Require that the door must open in less than 10 seconds to ensure efficient access to the site from El Camino Real. Except for COA #5a and 5b above, all other conditions were provided to be addressed at the building permit stage. Following Council approval of the project, staff will return to the ARB Ad- Hoc Committee to resolve COA #5a and 5b. ANALYSIS Comprehensive Plan, Area Plans, and Guidelines Compliance The Comprehensive Plan land use designation for the project site is Service Commercial, which allows for higher density multi-family near transit. The proposed project is located along El Camino Real, which is considered a high-quality transit corridor. Therefore, the proposed use is consistent with this land use designation. The project is also consistent with the policies set forth in the Comprehensive Plan, as detailed in Attachment C. Housing Element This site is included as a Housing Inventory Site in the adopted Housing Element, with an anticipated capacity of 44 units that may be provided at market rate. The project proposes 55 units, all of which would be below market rate, provided at a rate affordable to low income (70%) or moderate income (110%). Therefore, the project is consistent with the Housing Element and contributes to the City’s Regional Housing Needs Allocation (RHNA) goals, including goals to increase the number of units provided at below market rate levels. North Ventura Coordinated Area Plan The proposed development is located within the boundaries of the North Ventura Coordinated Area Plan (NVCAP). Therefore, the land use designation and the zoning of the site has changed since the application was first filed. However, as detailed in the ordinance implementing the NVCAP, projects that have been deemed complete prior to the effective date of the ordinance, would not be subject to the NVCAP goals and policies or the zoning regulations set forth in the ordinance. This project was deemed complete prior to adoption of the NVCAP and therefore continues to be analyzed in accordance with the regulations set forth under the existing zoning and land use designation. Nevertheless, the proposed land use designation under NVCAP is High-Density Mixed-Use. This land use designation is “intended to support five-to-six story mid- rise apartment buildings.” This designation requires active uses for ground floor frontages. As detailed in NVCAP, active uses include building lobbies. Therefore, the project is also consistent with the land use designation under the NVCAP. El Camino/South El Camino Real Design Guidelines3 The project is subject to both the El Camino Real and the South El Camino Real Design Guidelines. As detailed in Attachment F, the project is consistent with these guidelines. 3 South El Camino Real Design Guidelines: chrome: www.cityofpaloalto.org/files/assets/public/v/1/planning-amp- development-services/file-migration/current-planning/forms-and-guidelines/south-el-camino-real-design- guidelines.pdf Zoning Compliance For a PHZ project, the zoning development standards are customized for the building/site. Therefore, this project would deviate from the zoning development standards in a manner that is consistent with the zoning ordinance through to rezoning process. However, as detailed in the Zoning Comparison Table (Attachment D), there are several aspects of the project that exceed the underlying Service Commercial (CS) zoning district development standards, including: •Floor Area Ratio: 4.42:1.0 where 0.6:1.0 FAR is permitted; •Lot Coverage Ratio: 0.87:1.0 where 0.5:1.0 is permitted; •Height: 79 feet, 8 inches where 50 feet is permitted; •Parking: 324 parking stalls where 55 are required; •Rear Yard Setback: 0-5 feet where 10 feet is required; •Minimum Landscape/Open Space per Unit: 31 square feet where 150 square feet is required; •Rooftop Open Space: Rooftop garden provides 76% of open space for project where only 60% is permitted to be provided by rooftop garden; •Bike Parking: Four short-term bike parking spaces are provided off-site where six are required on-site; •Vehicle Loading Space: No short-term vehicle loading space is provided on site where one is required for projects with 50 or more units. Given that the project is 100% affordable, the Affordable Housing Incentive Program (AHIP) standards could also be applied to the site by-right to modify some development standards. Therefore, Attachment D also includes a comparison of the proposed development standards and the AHIP development standards for informational purposes. Multi-Modal Access & Parking The property is located on El Camino Real near the cross street of Lambert Avenue and is accessed via a right-in, right-out-only driveway entrance. The applicant proposes 32 parking spaces, or 0.5 spaces per residential unit. 30 parking spaces would be provided in vehicle stackers that would be independently accessible and two ADA parking spaces would be provided. This is an increase in the provided parking ratio from the original proposal reviewed by Council, which included 22 parking spaces in vehicle stackers for the 44 units proposed at that time. Typically, one parking space per unit is required for studio and one-bedroom units, and a Transportation Demand Management (TDM) plan can be used for an up to 100% reduction in required spaces for a 100% affordable housing project where units are available to households with income levels at or below the 120% AMI thresholds. The applicant has proposed a TDM plan for the proposed project, which is provided in Attachment E. The Office of Transportation has reviewed and approved the proposed TDM plan which includes, among 4 PAMC 18.52.040(b)(8) provides that the accessible loading zone adjacent to an accessible parking stall contributes to the number of vehicle spaces provided on site. While 32 spaces are provided, only 31 can be used to park a vehicle. other measures, a provision to provide free bus passes to all tenants via the Valley Transportation Authority (VTA) Smart Pass program. There are north and south-bound VTA bus stops within the immediate vicinity of the site that connect the site to other regional transit options like Caltrain. Conditions of Approval #30 and #31 require monitoring of the parking lift system and TDM program to ensure they are effective. If any deficiencies are found within the annual monitoring reports, penalties or modifications to the programs can be enacted to ensure the lift system works and the TDM plan goals are achieved. Fifty-five long-term bike parking spaces are proposed on the ground floor in a shared storage room, four short-term bike parking stalls are provided along El Camino Real, and five on-site shared electric bikes are provided in the storage room. Based on the nature of the puzzle lift system, vehicle stalls are shuffled around using the wall kiosk in the garage or a remote key fob until a stall is moved to the ground level for a vehicle to exit from or pull into the space. For the puzzle lift system to function properly, some stalls need to be left unused. In this case, two stalls will be left unused resulting in 30 of the 32 parking lift stalls being usable within the garage. The City’s traffic consultant Fehr & Peers analyzed the vehicle turning radii for the proposed parking lift stalls as detailed in the transportation analysis in Attachment I. Given that all stalls comply with the size requirements set forth in Chapter 18.54, in accordance with the conditions of approval that require proper management of the system, the proposed design is consistent with the City’s requirements. Caltrans is currently developing El Camino Real along the project frontage to add a bicycle lane. This eliminates the potential for a vehicle loading area as well as a trash loading area (e.g. for trash pickup) along El Camino Real in front of the property. Therefore, vehicle pick-up and drop- off as well as trash pickup for the project are anticipated to occur on Lambert Avenue. Bins will be brought out to Lambert Avenue and staged there by the property management prior to pick- up, then moved back to the trash enclosure following pick-up. Public Benefit As noted in the background section of this report, in February 2020 Council provided direction to staff to consider planned community rezoning applications for housing development projects that provide increased inclusionary below market rate units, rebranding these as Planned Home Zoning projects to emphasis the increased BMR units and/or affordability level of those units as the public benefit of the project. As a part of Council’s direction, a menu of options was identified as possible ways to meet the increased affordability requirements. Using Option #2, the weighted system, as shown below, the project is proposing an equivalency of 75% affordable units, exceeding the 20% minimum requirement in accordance with Council’s direction, as noted in Table 1 below. Since no commercial component is proposed, this project would inherently create more housing than jobs. Several Council members and commissioners raised concerns that these units would not be affordable to the target demographic the applicant has committed to serving and requested additional information from staff about affordability levels and teacher salaries. The California Department of Housing and Community Development (HCD) provides yearly data on the AMI limits for each income category, which varies based on the number of individuals in each household. The image below reflects the AMI for Santa Clara County for 2024:5 An image of the 2024-25 Palo Alto Unified School District (PAUSD) salary schedule is below:6 5 HCD Income Table: https://www.hcd.ca.gov/sites/default/files/docs/grants-and-funding/income-limits-2024.pdf 6 PAUSD Salary Schedule: https://resources.finalsite.net/images/v1717104008/pausdorg/r4v8ge0e5ln1e3szj8zw/salary_schedule_teachers_ 202425.pdf Based on the income limits, a low-income studio would be affordable to all individual salaries in the schedule and low-income 1-bedrooms would be affordable to over 90% of individual salary levels. Most of the salary steps in the PAUSD schedule, however, are too high for an individual to income-qualify to rent these low-income units. Moderate-income studios would be affordable for 35% of individual salary levels, and moderate-income 1-bedrooms would be affordable to 4% of individual salary levels. These figures are likely too low, however, because the PAUSD salary schedule only represents one individual’s income, while many units may be occupied by households with more than one income. Even the most expensive unit in the project will be affordable to a household making 1.8 times the lowest individual salary in the PAUSD schedule, and many households may have a combined income too high to qualify for these restricted units. Given the sizes of each unit within the proposed project, it’s likely that a two-person household would be the largest household size occupying these units. The City’s Below Market Rate (BMR) administrator would be responsible for income certifying individual(s) who apply to live in these units with the additional caveat that any teachers that apply to live in these units would be considered first over other potential tenants. There is no requirement in the draft ordinance that all or any of the future tenants in the building be teachers. As noted earlier in the report, following the April PTC and ARB meetings, the developer modified their design to increase the number of units from 44 to 55. This was driven by feedback from the PTC which encouraged ways to deepen the levels of affordability for the project. By increasing the number of units in the project, the applicant has been able to commit to limiting rent for the low-income units at 70% AMI as well as limiting rents for moderate- income units at 110% AMI. Previously, the applicant noted that it was not financially feasible to limit the low-income rents at 70% AMI and had proposed limiting them to 80% AMI instead. Anticipated 2024-25 rents for each unit type are shown below, as well as the household incomes at which these units would be affordable; anticipated rents are subject to change each year. The anticipated rents below reflect the cost of rent, plus an assumed utility allowance that Santa Clara County provides for units ($210/month for studios, $220/month for one- bedrooms). Rents for each unit type and income range would be $2,049/$2,362 for 70% AMI, or $3,338/$3,836 for 110% AMI. Notably, although rents are set using assumed household sizes of 1-person per studio and 2-persons per 1-bedroom, income qualification is based on actual household size. Thus, although rent plus utilities for a low-income studio may not exceed $2,259 per month, a two-person household may qualify for such studio with a household income of up to $118,000 per year (80% AMI for a two-person household). Rent + Utility Allowance Rent at 70% AMI Affordable to Annual Income Rent at 110% AMI Affordable to Annual Income Studio $2,259 $90,370 $3,548 $142,010 1-Bed $2,582 $103,250 $4,056 $162,250 Consistency with Application Findings Staff has prepared a detailed review of the proposed project’s consistency with the Findings for approval. The draft Architectural Review findings for the proposed project and draft findings for the PC ordinance are provided in Attachment C. Staff finds that the proposed project, as conditioned, meets all of the applicable findings for Architectural Review and the required determinations for PC ordinances. POLICY IMPLICATIONS Approving the proposed affordable housing project would support the city’s housing goals, providing 55 units with priority for local educators while aligning with the Comprehensive Plan and making progress toward the City’s RHNA targets. Redevelopment activates an underutilized site and would increase property tax revenue. However, the PTC, despite its support for the project, has noted concerns over affordability thresholds and the loss of revenue from development impact fees, as noted above. This project is entitled to an exemption from impact fees because it fits the City’s definition of 100% affordable housing. Staff believe the rent restrictions for the moderate-income units are a meaningful benefit that are likely to be more impactful over time. In addition, this project represents an unusual model for rent-restricted housing production that does not rely on public funding or competitive tax credits. Ultimately, the subject entitlement process as a legislative application conveys broad latitude to the City Council in terms of its discretion to approve or deny the project. Not approving the project could slow progress on housing production and may discourage future, similar, affordable housing proposals and influence ongoing work related to expanding the Housing Focus Area along a strategic location on El Camino Real. Moreover, with the recent upzoning of this site through the NVCAP, a substantially similar project could likely be achieved through use of the state density bonus law. FISCAL/RESOURCE IMPACT In accordance with the adopted fee schedule, applications for zone changes are processed as Cost Recovery applications; therefore, the City recovers the cost of staff time for processing the application. Additionally, because this is a 100% affordable housing development, no impact fees are required. The property is currently undeveloped; accordingly, the current site does not generate any revenue for the City. Therefore, there is no financial impact as a result of processing of this application except that property taxes would increase as a result of the development, once constructed. STAKEHOLDER ENGAGEMENT The Palo Alto Municipal Code requires notice of this public hearing be published in a local paper and mailed to owners and occupants of property within 600 feet of the subject property at least ten days in advance. Notice of a public hearing for this project was published in the Daily Post on January 31, 2025. Postcard mailing occurred on January 29, 2025. Public Comments As of the writing of this report, the City received one comment from the property owner for 3295 El Camino Real, which is provided in Attachment G. At a follow up meeting with staff and the applicant, the neighboring property owners asked for further clarity as to how their site would be protected during construction and afterwards for any regular maintenance needs, as well as understand whether any shoring or maintenance easements would be necessary between the two properties. The applicant noted that they designed the project to ensure that all shoring would be done within their own property boundaries and that no access or maintenance easements would be needed from the adjacent owners. Staff confirmed with the Chief Building Official that should any easements be necessary in the future; the City does not need to be party to those agreements and they can be established and recorded between the property owners at their own expense outside of the City’s review process. Additional public comments in support of the project are included in Attachment G. ENVIRONMENTAL REVIEW The City, acting as the lead agency, has analyzed the project in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA). Specifically, the City prepared an analysis of the project in accordance with CEQA Guidelines Section 15183, which evaluated the project’s consistency with the Comprehensive Plan and the Comprehensive Plan Environmental Impact Report (EIR). Section 15183 allows for streamlining of infill projects where the previously adopted EIR for a Comprehensive Plan adequately addresses the impacts of the proposed project. Plan level technical reports were prepared to confirm that the Comprehensive Plan EIR, including any mitigation that would be addressed as required through that EIR, would adequately address the impacts of the proposed project. This analysis and relevant attachments are included in Attachment I. ATTACHMENTS Attachment A: Location Map Attachment B: Ordinance Attachment C: Draft Record of Land Use Attachment D: Zoning Comparison Table Attachment E: TDM Plan Attachment F: South El Camino Real Design Guidelines Comparison Attachment G: Public Comments Attachment H: Program Statement and Schedule Attachment I: Development Plan and Environmental Documents APPROVED BY: Jonathan Lait, Planning and Development Services Director 15 From:LWV of Palo Alto To:Council, City Subject: Date: Attachments: Comment on Item 15, Feb. 10 Council Meeting, "The Academy" Sunday, February 9, 2025 5:17:18 PM CCTheacademy.docx CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. The League of Women Voters of Palo Alto supports the approval of "The Academy", a 100% affordable teacher housing development. Our letter of support is attached. -- League of Women Voters of Palo Alto 3921 E. Bayshore Road Palo Alto, CA 94303 Phone: (650) 903-0600 Web: www.lwvpaloalto.org Facebook: www.facebook.com/PaloAltoLeague/ Twitter: www.twitter.com/lwvpaloalto Feb. 9, 2025 To: Honorable Mayor Lauing and Council members Re: City Council Meeting Feb. 10, 2025, 3265 ECR “The Academy”; Action item15 The League of Women Voters of Palo Alto in 2023 urged the City to work with the developer to approve an affordable housing development on 3265 El Camino Real (“The Academy”) which would create 44 low- and moderate-income units for teachers in Palo Alto. Responding to comments that the project rents would not be affordable to many teachers, the developer reworked the project to lower the income level to 70% AMI (down from 80%) and increased the number of units from 44 to 55. Our board believes it is an even better project now that teachers making 70% of AMI will be eligible. Our comments are based on our League’s local housing position which supports actions by the City that improve the diversity of housing opportunities for all economic levels, ages, and ethnicities and which ensure that all housing is open to everyone without discrimination, and on the state and national League policy Meeting Basic Human Needs. Our city suffers from an extreme shortage of housing available for low- and moderate-income households, as high land prices, construction costs, the absence of adequate and/or available public or private financing, and land use policies force developers to focus on luxury homes. This private developer proposes to help alleviate the shortage of housing affordable to teachers by constructing studio and one-bedroom units in an area well-served by public transportation, bicycle routes, and retail. Significantly, without precedent for 100% below market units, no outright public subsidies are being requested (other than a relaxation of land use regulations). We urge the PTC to recommend approval of the revised application to Council. The benefits of this project are many. Teachers’ unions support this proposal. Local housing for teachers will eliminate hours-long commutes, help reduce greenhouse gas emissions and help restore the city’s economic diversity. It will also improve the quality of life in our community by having our essential teachers live where they work. Thank you for your consideration of the League’s point of view. Respectfully, Karen Kalinsky and Lisa Ratner Co-Presidents ____________________________________________________________________________________ 3921 E. Bayshore Road, Palo Alto CA 94303 (650) 903-0600 www.lwvpaloalto.org From: To: Joy Sleizer Council, City Subject: Date: 55 unit teacher housing Sunday, February 9, 2025 3:32:02 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Council Members, I urge you to support the 55 unit Teacher low income housing on Monday's agenda. It is so important to have some housing close by for educators. If no teacher qualifies for the housing, I would support any kind of housing since we need housing for everyone!! Thanks! Joy Sleizer Joy Sleizer 850 Webster Street Apt 706 Palo Alto, CA 94301 650-324-7425 650-353-4481 cell From:Palo Alto Forward To:Council, City Subject: Date: Support 3265 ECR - Agenda Item #15 Saturday, February 8, 2025 2:55:08 PM Attachments:3265 ECR Support Ltr (02.8.25).pdf Attach A 41 Pgs of Support Ltrs.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Mayor Lauing and City Council, Please find our attached support letter for the Teacher Housing Project at 3265 El Camino Real and 41 pages of previously submitted support letters. Thank you, -- Amie Ashton Executive Director Palo Alto Forward 650-793-1585 February 8, 2025 SUBJECT:Agenda Item #15 - 3265 El Camino Real Teacher Housing Dear Mayor Lauing and Council, We write in strong support of the proposed 55-unit affordable housing development at 3265 El Camino Real. The project has been under review for well over two years as part of a Planned Home Zoning (PHZ) process. It is time to approve this project, which has overwhelming community support (as evident in the support letters contained within Attachment A). We need creative and innovative housing projects like this one. In addition to helping meet our Regional Housing Needs Allocation numbers, construction of 55 affordable units for local teachers with ZERO public funding or subsidies is a win for our city. Students benefit when their teachers live in the community and can dedicate their intellectual and emotional energy to teaching, without having to endure long and expensive commutes each day. Districts can attract and retain the best employees when affordable housing like this is available. The project site is the perfect location for housing with its proximity to California Avenue retail and services, area transit and bikeways, and local schools. This type of housing directly helps our environment (with lowered vehicle miles traveled), economy (more residents to shop locally consistent with recommendation #10 from the City's Economic Development Strategy), and equity (housing at all income levels makes for a stronger community where people thrive). We urge you to approve the project. Show our residents that you are committed to implementing your identified housing priorities and goals. Thank you, Amie Ashton Executive Director, and on behalf of the Board of Palo Alto Forward Attachment A: 41 Pages of Support Letters for the Project January 11, 2025 SUBJECT:Agenda Item #3 - 3265 El Camino Real Teacher Housing Dear Chair Chang and Commissioners, We write in strong support of the proposed 55-unit affordable housing development on a vacant lot at 3265 El Camino Real. The project has been under review for over two years as part of a Planned Home Zoning (PHZ) process. It is time to move this forward to Council with a recommendation for approval. In addition to helping meet our Regional Housing Needs Allocation numbers, construction of 55 affordable units for local teachers with ZERO public funding or subsidies is a win for our city. Students benefit when their teachers live in the community and can dedicate their intellectual and emotional energy to teaching, without having to endure long and expensive commutes each day. Districts can attract and retain the best employees when affordable housing like this is available. The project site is the perfect location for housing with its proximity to California Avenue retail and services, area transit and bikeways, and local schools. This type of housing directly helps our environment (with lowered vehicle miles traveled), economy (more residents to shop locally consistent with recommendation #10 from the City's Economic Development Strategy), and equity (housing at all income levels makes for a stronger community where people thrive). We also fully support the necessary zoning and design deviations being requested by the project - especially given its location near major transit stops, Caltrain, local schools, services, and retail. Please move the project forward and allow our city to demonstrate its commitment to creating housing (especially affordable housing for our teachers) a priority. Thank you, Amie Ashton Executive Director, and on behalf of the Board of Palo Alto Forward I created this file to show a rough estimate of time and money savings from avoiding a long commute that can allow people to pay extra in rent and still come out better off financially My example is relevant to the teacher housing project but also to infill housing generally on the peninsula that allow some people to avoid long commutes My example is for a 50 Mile Commute Taking an Hour Each Way Note that actual travel times for 50 mile commutes are usually longer at peak hours Commute CostsMiles each way 50 60 0.655 Time each way (minutes) IRS Mileage Allowance estimate of total costs per mile ($) https://www.irs.gov/newsroom/irs-issues-standard-mileage-rates-for-2023-business-use-increases-3-cents-per-mile#:~:text=Beginning%20on%20January%201%2C%202023,the%20second%20half%20of%202022 65.5 c is probably low for Bay Area as our gas prices are far above the national average Gasoline cost ($per gallon) Miles per gallon Tolls per day ($) 5 20 7 Commute days per month 17 Most months have 21 or 22 weekdays and I used 17 days as a rough estimate to account for holidays and personal time IRS estimate of driving costs per monthGasoline costs per month $1,113.50$425Toll costs per month $119 travel time in minutes today to Palo Alto starting today Sept 18 at with no accidents showing today (Sept 19) at 6:30 the time from Gilroy was 97 minutes as there was an accident on Hwy 101 Example trips Miles 6:30am 7:00 AM 88Walnut Creek Gilroy San Ramon South San JoseLivermore 50 50 40 3240 79 77 67 4571 81 75 5393 Tracy Hollister Antioch 64 64 70 110 105 132 Time Costs Many workers are willing to trade money for less commuting for example https://www.businessinsider.com/us-remote-workers-would-take-pay-cut-to-keep-wfh-2023-5 https://www.businessnewsdaily.com/15004-survey-toll-of-commute.html https://www.fool.com/the-ascent/banks/articles/cheaper-home-or-shorter-commute-heres-how-to-decide Part of this is saving on car costs as described above and part is valuing the time saved that can be used for personal or family time Some sources (like the last link above) say to use 100% of the wage rate for the value of travel time saved The U.S. and CA departments of transportation use 100% for business travel and 50% for personal travel I used 50% and used a wage/salary rate of $40/hour roughly equivalent to $80,000 a year So that equals $20 an hour of time saved https://www.transportation.gov/sites/dot.gov/files/docs/USDOT%20VOT%20Guidance%202014.pdfpage 15 https://dot.ca.gov/-/media/dot-media/programs/transportation-planning/documents/data-analytics-services/transportation-economics/cal-bc/2022-cal-bc/guides/cal-bc-81-parameter--guide-v1-a11y.pdf Hourly wage % counted as value of time saved Commute hours 40 0.5 2 Commute days 17 Value of time saved per month $680 So if you save 2 hours a day for 17 days a month this comes to $680 a month Adding commute cost savings and time value savings results in substantial savings to an individual who no longer needs to commute 50 miles a day each way From: To: slevy@ccsce.com Council, City Cc: Subject: Date: Lait, Jonathan; Sauls, Garrett 3265 ECR item 15 Friday, February 7, 2025 10:34:13 AM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Mayor Lauing and council members, I write in support of the ARB, PTC and staff recommendation to approve this project. I want to call attention to some public benefits that support city goals and are in addition to the direct housing benefits to the new residents. This project will support the city's goal of adding customers to the Cal Ave area businesses. This benefit is true for this project and all housing additions in the DTN and Cal Ave areas. This project will support the city's and region's environmental goals in at least two ways: 1) Some residents will be able to eliminate long commutes that add to pollution, GHG emissions and congestion. Other residents will be able to reduce smaller, but still significant, commutes with similar benefits. 2) By virtue of proximity to Cal Ave, to the ECR buses and to the Stanford shuttles, residents will have the opportunity to reduce car use. They will not be able to eliminate all car use but, as with m family and others who live DTN or near Cal Ave, some car trips can be replaced by walking or biking. Reducing car use in any form has both environmental benefits and reduces demand for parking. There is a third I would call public benefit that came up in all the meetings I attended with Supervisor Simitian prior to the pandemic. Besides the time and money savings to residents and more family time, there is a benefit to Palo Alto parents and students of having more time available from teachers who no longer have to commute long distances. I am pleased that both unions representing teachers and staff strongly support this project related to the benefits it will bring their members and the public and look forward to it getting underway. Stephen Levy From: To: Susan Setterholm Council, City Cc:Palo Forward Subject: Date: Teacher housing support Thursday, February 6, 2025 3:19:12 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. I am in support of the teacher. I’m a teacher in another part of the Bay Area who can no longer afford to live and work in Palo Alto. Don’t force your current excellent teachers and teacher candidates out of the area. Approve the teacher housing. Susan Setterholm From: To: Ellen Turbow Council, City Subject: Date: Housing for Teachers Thursday, February 6, 2025 11:25:34 AM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear City Council, I support the proposal of housing for teachers. Ellen Turbow From: To: Nancy Krop Council, City Subject: Date: Support teacher housing Thursday, February 6, 2025 10:33:35 AM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear City Council, Please support the teacher affordable housing project. We need affordable housing for our teachers and staff. In an ideal world, no teacher or staff member should face a long commute to help our children. I spoke with some groundskeepers at Paly. They love their jobs. They’re passionate when they talk about their jobs. One man told me he kisses his sleeping children goodbye at 4 a.m. to arrive at Paly by 6 a.m. Then, he’s home in time to kiss them good night. That’s just wrong. Teachers facing long commutes, in traffic that only gets worse with time, can’t hang out and help our children after school. This affordable housing project is a small step in the right direction. Thank you Nancy Krop Barron Park neighborhood Sent from my iPhone From: To: Shannon McEntee Council, City Subject: Date: 55-unit teacher housing project Tuesday, February 4, 2025 5:39:05 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear City Council, I write in support of this 55-unit teacher housing project. Our teachers deserve to live in the communities they serve and we residents deserve to have them here. Having housing here will eliminate or at least decrease their commute and make their lives easier. That means they’ll have more energy for their teaching, it will reduce dangerous driving emissions, and reduce traffic. That’s a huge win win win. Please approve this project for both our teachers and for residents. Sincerely, Shannon Rose McEntee 410 Sheridan Ave. Palo Alto From: To: Lori wainen linberg Council, City Subject: Date: Affordable housing Tuesday, February 4, 2025 4:34:49 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Council, Please excuse typos, I have a hand disability and was a teacher in our communities for over 30 years. In order to have healthy communities, we need affordable housing. Commuting is not a sustainable option and certainly not green. We need to support our teachers and healthcare workers as well as many other frontline jobs. We are presently facing a shortage of teachers and healthcare workers dye to the high cost of housing. We need to do something to support our healthcare workers in America. Since Covid, they have been pushed beyond their limits in every way from not having proper protection, to ridiculously long hours and extreme stress, almost as much as being in a war. Add to that that they’ve cut their salaries and lowered their staff and people are leaving so they’re always short staffed. We need all the people who work in a hospital, but they are not getting paid a large enough salary to continue their jobs and AFFORD HOUSING and anything else. Presently we are even losing doctors. A hospital needs to run with janitors, EMTs, phlebotomist, CNA‘s, radiological Techs, surgical techs, and many others. It’s similar to the public schools. They also can’t be run anymore. We’re not getting teachers. We’re not getting teacher assistance. We’re not getting the janitors. They also cannot afford housing, but we cannot afford communities with no schools or proper healthcare. The dedicated workers are literally depressed and leaving. There is something fundamentally wrong with a community that pays people to make violent video games more than people who can teach her children to be responsible, happy contributing citizens, and those who can save your life. Thank You, Lori Wainen-Linberg ( Teacher for over 30 years) Sent from my iPhone From: To: Marian Sofaer Council, City Subject: Date: I support teacher housing Tuesday, February 4, 2025 4:33:49 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. I support teacher housing. Marian Sofaer Bryant Street From: To: Neir Eshel Council, City Subject: Date: in support of teacher housing Monday, February 3, 2025 5:44:21 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Palo Alto City Council, I'm writing to express my support, as a parent of two young children who will soon enter the Palo Alto public schools, for the proposal to build new housing for PAUSD teachers ("The Academy @ 3265 El Camino Real"). Palo Alto's high cost of living is one of the biggest challenges for teachers who come to serve our community, and we should support them by building them an affordable place to live. Thank you for your service. -Neir Eshel 1620 Bowdoin Pl, Palo Alto From: To: Felipe Jornada Council, City Subject: Date: Please approve The Academy @ 3265 El Camino Real Monday, February 3, 2025 1:37:47 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Palo Alto Planning Commission, I am writing to ask you to please approve the proposal to build new housing for PAUSD teachers ("The Academy @ 3265 El Camino Real"). Palo Alto's high cost of living is one of the biggest challenges for teachers who come to serve our community. We should support them by building them an affordable place to live. As a parent and a Palo Alto resident, I find passing such a project to be of the highest importance. Thank you for your service. Sincerely, Felipe – Felipe H. da Jornada Assistant Professor Department of Materials Science and Engineering 131 Durand Building Stanford, CA 94305 Stanford University https://jornada.stanford.edu/ Pronouns: he/him/his Please contact the group admin, Alice Jung (alijung@stanford.edu), if you have urgent requests and I’m unavailable. From: To: MaryAnne Kochenderfer Council, City Subject: Date: Please approve housing project for PAUSD teachers Monday, February 3, 2025 1:09:08 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Palo Alto City Council, Please approve the proposal to build new housing for PAUSD teachers ("The Academy @ 3265 El Camino Real"). Palo Alto's high cost of living is one of the biggest challenges for teachers who come to serve our community, and we should support them by building them an affordable place to live. Approving this project will make it easier for our district to attract and retain highly qualified teachers. Students also benefit from teachers who live in and understand their communities. Thank you for your service. Mary Anne Kochenderfer 1555 Drake Way, Palo Alto, CA 94304 From: To: L H Council, City Subject: Date: In support of PAUSD teacher housing Monday, February 3, 2025 1:09:01 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Dear Palo Alto City Council, Please approve the proposal to build new housingfor PAUSD teachers ("The Academy @ 3265 El Camino Real"). Palo Alto's high cost of living is one of the biggest challenges for teachers who come to serve our community, and we should support them by building them an affordable place to live. We have two young children and without their teachers, we would truly be at a loss. This is a priority for our community. Thank you for your service. Liem Chistol Parent of PAUSD Sent from Gmail Mobile February 10, 2025 www.cityofpaloalto.org 3265 El Camino Real Planned Home Zone (PHZ) City Council Garrett Sauls, Principal Planner 1 PHZ/PC Process •Prescreening – September 2023 •Formal application – January 2024 •PTC hearing(s) – April 10, 2024 •1st ARB hearing – April 18, 2024 •2nd ARB Hearing – November 21, 2024 •PTC Hearing – January 15, 2025 •Council decision – Today Public comments are accepted at all public hearings, and through writing at any time throughout this process. BACKGROUND / PROCESS 3 PROJECT OVERVIEW A Planned Home Zone (PHZ) rezoning to include: •Six-story, 55-unit residential rental project on a vacant lot •32 parking spaces – 30 in stackers & two accessible spaces (25 EV Stalls, 6 EV Ready Stalls) •55 bike lockers, four short-term bike spots, and five shared electric bikes •100% of the units will be deed restricted: •25% of units will be Low-Income (70% AMI) •75% will be Moderate-Income (110% AMI) 4 PROJECT OVERVIEW (Continued) The project deviates from the base CS zoning requirements in the following ways: •Rear yard setback (10 foot required, 0-5 feet proposed) •Site Coverage (50% permitted, 87% proposed) •Floor Area Ratio (0.6 permitted, 4.42 proposed) •Height (50 feet permitted, 79 feet proposed – to top of staircase); •Minimum Open Space per unit (150 square feet required, 31 square feet proposed) •Parking (55 required, 32 provided) •Loading Zone (One Short-Term Parking Stall per 50 units) 5 PROJECT LOCATION Location •Frontage on El Camino Real •Adjacent to El Camino Real Focus Area •Approximately 323 du/acre on 0.17 acres Surrounding Densities •3150 El Camino Real •144 du/acre on 2.55 acres •3001 El Camino Real •113 du/acre on 1.14 acres •3400 El Camino Real •65 du/acre on 3.5 acres 6 Council Feedback - September 11, 2023 The Council provided the following direction on the design: •Provide information on how long parking stackers take to cycle through; •Clarify if parking will be unbundled from units; •Provide information on anticipated rents and whether they will be affordable to teachers; •Consider expanding the driveway from 14 feet to 20 feet; 7 El Camino Real Frontage (NB) 8 El Camino Real Frontage (SB) 9 Rear Elevation 10 Rooftop Deck 11 TDM Plan Requirements •Unbundled Parking •Free VTA Smart Passes for all tenants •Shared E-Bikes •Online Transportation Kiosk/Transportation Coordinator 12 Circulation Fehr & Peers evaluated circulation to and within the site: •For lifts, PAMC requires capacity for full/mid-size vehicles which is smaller than typical code requirements. •Stalls 1-6 can be accessed with three or fewer maneuvers with both vehicle size types. •Stalls 7-8 require more based on vehicle size; mid-size - three or fewer, full-size - four to five maneuvers. •COA #18 requires Stalls 7 and 8 only be accessed by mid-size vehicles only given all stalls are assigned. Affordability Information Typical formula for calculating rents: HCD AMI Income Bracket for # PPH x .30 / 12 *Subject to increase every year Staff Report Corrections •In discussing affordability to PAUSD salary schedule, staff report used the HUD definition of cost-burden rather than the City's and HCD's definitions of “affordable rent.” •Under local definitions, all units are considered affordable to appropriately-sized households, even if there is some degree of cost-burden. I.E., rent + utilities based on 110% of AMI is still considered “affordable rent” for a household with income at 90% of AMI, even though their housing cost would exceed 30% of gross income. •Comparing the PAUSD salary schedule to the applicable low- and moderate-income bands: •One-person households w/ single PAUSD salary: 9% qualify for LI studios; 79% qualify for MI studios •Two-person households w/ single PAUSD salary: 21% qualify for LI studios or 1 BR; 79% qualify for MI studios or 1 BR. 14 15 •Project will satisfy Option 2 of Council’s PHZ requirements (Weighted Value BMR Units – minimum 20%, 75% provided). •Property is within the NVCAP boundaries. •Protected Valley Oak proposed for removal because dripline exceeds 25% of buildable area. •Roof deck will provide the majority of open space requirements. ADDITIONAL CONSIDERATIONS 16 RECOMMENDED MOTION 1.Consider the Initial Study Checklist/Streamlined Environmental Review prepared in accordance with California Environmental Quality Act (CEQA) Guidelines Section 15183; 2.Adopt the Ordinance in Attachment B amending the zone district from CS to PC; and 3.Approve the Record of Land Use Action in Attachment C. Garrett Sauls Principal Planner Garrett.Sauls@CityofPaloAlto.org •The base zoning is CS. The AHIP is the City’s local program to encourage 100% affordable housing projects. The project conforms and deviates in the following ways from CS and AHIP: 1.CS Lot Coverage: 50% (3,704); AHIP: No max; Proposal: 87% (6,525) 2.CS FAR: 60% (4,495); AHIP: 2.0 (14,984); Proposal: 4.42 (33,089) 3.CS Open Space/Unit: 150 sf; AHIP: 50 sf; Proposal: 31 sf 4.CS Height: 50 ft; AHIP: 50 ft; Proposal: 79 ft, 8 in 5.CS Parking: 1 space/1 bedroom unit (55); AHIP: 0.75 space/unit (42); Proposal: 32 AFFORDABLE HOUSING INCENTIVE PROGRAM *Bolded Standard Does not Comply w/ AHIP •The project conforms and deviates in the following ways from CS and the ECR Focus Area: 1.CS Lot Coverage: 50% (3,704); ECR FA: 70%; Proposal: 87% (6,525) 2.CS FAR: 60% (4,495); ECR FA: 4.0 (29,968); Proposal: 4.42 (33,089) 3.CS Open Space/Unit: 150 sf; ECR FA: 100 sf; Proposal: 31 sf 4.CS Height: 50 ft; ECR FA: 85 ft; Proposal: 79 ft, 8 in 5.CS Parking: 1 space/1 bedroom unit (55); ECR FA: 1 space/unit (42); Proposal: 32 EL CAMINO REAL FOCUS AREA *Bolded Standard Does not Comply w/ ECR FA •The project conforms and deviates in the following ways from CS and the NVCAP development standards: 1.CS Lot Coverage: 50% (3,704); NVCAP: 100% (7,492); Proposal: 87% (6,525) 2.CS FAR: 60% (4,495); NVACP: 3.0 (22,476); Proposal: 4.42 (33,089) 3.CS Open Space/Unit: 150 sf; NVCAP: 150 sf; Proposal: 31 sf 4.CS Height: 50 ft; NVCAP: 65 ft; Proposal: 79 ft, 8 in 5.CS Parking: 1 space/1 bedroom unit (55); NVCAP: 1 space/1 bedroom unit (42); Proposal: 32 NVCAP DEVELOPMENT STANDARDS *Bolded Standard Does not Comply w/ NVCAP 7 Modified Facades Previous Front/Side Facade Revised Front/Side Facade 8 Modified Facades Previous Front/Side Facade Revised Front/Side Facade 9 Modified Facades Previous Rear Facade Revised Rear Facade Alternative Parking/Trash Collection Solution 10 Windows Facing Kasa Hotel Previous Section Towards Kasa Revised Section Towards Kasa