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HomeMy WebLinkAbout2025-11-10 City Council Agenda PacketCITY COUNCIL Regular Meeting Monday, November 10, 2025 Council Chambers & Hybrid 5:30 PM Amended Agenda Amended agenda items appear below in RED (Time Estimates Updated)   Palo Alto City Council meetings will be held as “hybrid” meetings with the option to attend by teleconference or in person. Information on how the public may observe and participate in the meeting is located at the end of the agenda. The meeting will be broadcast on Cable TV Channel 26, live on YouTube https://www.youtube.com/c/cityofpaloalto, and streamed to Midpen Media Center https://midpenmedia.org. VIRTUAL PARTICIPATION CLICK HERE TO JOIN (https://cityofpaloalto.zoom.us/j/362027238) Meeting ID: 362 027 238 Phone:1(669)900-6833   PUBLIC COMMENTS General Public Comment for items not on the agenda will be accepted in person for up to three minutes or an amount of time determined by the Chair. General public comment will be heard for 30 minutes. Additional public comments, if any, will be heard at the end of the agenda. Public comments for agendized items will be accepted both in person and via Zoom for up to three minutes or an amount of time determined by the Chair. Requests to speak will be taken until 5 minutes after the staff’s presentation or as determined by the Chair. Written public comments can be submitted in advance to city.council@PaloAlto.gov and will be provided to the Council and available for inspection on the City’s website. Please clearly indicate which agenda item you are referencing in your subject line. PowerPoints, videos, or other media to be presented during public comment are accepted only by email to city.clerk@PaloAlto.gov at least 24 hours prior to the meeting. Once received, the Clerk will have them shared at public comment for the specified item. To uphold strong cybersecurity management practices, USB’s or other physical electronic storage devices are not accepted. Signs and symbolic materials less than 2 feet by 3 feet are permitted provided that: (1) sticks, posts, poles or similar/other type of handle objects are strictly prohibited; (2) the items do not create a facility, fire, or safety hazard; and (3) persons with such items remain seated when displaying them and must not raise the items above shoulder level, obstruct the view or passage of other attendees, or otherwise disturb the business of the meeting. TIME ESTIMATES Listed times are estimates only and are subject to change at any time, including while the meeting is in progress. The Council reserves the right to use more or less time on any item, to change the order of items and/or to continue items to another meeting. Particular items may be heard before or after the time estimated on the agenda. This may occur in order to best manage the time at a meeting or to adapt to the participation of the public.  1 November 10, 2025 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. CALL TO ORDER   SPECIAL ORDERS OF THE DAY (5:30 - 5:35 PM)   1.Proclamation Recognizing National Police Records and Support Personnel Week CLOSED SESSION (5:35 - 7:20 PM)   2.Public Employee Performance Evaluations Authority: Cal. Gov. Code section 54957(b) Title: City Clerk, City Auditor, and City Attorney   3.Conference with Labor Negotiator Authority: Cal. Gov. Code section 54957.6 Agency Representative: Dan Rich, Municipal Resources Group Unrepresented Employees: City Attorney, City Clerk and City Manager   AGENDA CHANGES, ADDITIONS AND DELETIONS   PUBLIC COMMENT (7:20 - 7:50 PM) Members of the public may speak in-person ONLY to any item NOT on the agenda. 1-3 minutes depending on number of speakers. Public Comment is limited to 30 minutes. Additional public comments, if any, will be heard at the end of the agenda. COUNCIL MEMBER QUESTIONS, COMMENTS, ANNOUNCEMENTS (7:50 - 8:05 PM) Members of the public may not speak to the item(s).  CONSENT CALENDAR (8:05 - 8:10 PM) Items will be voted in one motion unless removed from the calendar by three Council Members.  4.FIRST READ: Adopt an Ordinance Amending PAMC Chapter 10.56 (Special Speed Zones) to Update Speed Limit Studies for Nine Streets and Approve the 2025 Traffic Survey; CEQA status – categorically exempt. 5.Approval of a Budget Amendment in the General Fund for the Planning and Development Services Department’s Deposit-Based Fee Program for Private Development Studies for a Net Zero Impact. CEQA Status: Not a Project  2 November 10, 2025 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. AA1.Adopt a Resolution Deferring CPAU Late Fees and Collection Actions for Certain Customers Affected by the Ongoing Federal Government Shutdown; CEQA Status – Not a Project. New Item Added CITY MANAGER COMMENTS   BREAK (15 MINUTES) ACTION ITEMS (Item 6: 8:25 - 9:10 PM, Item 7: 9:10 - 9:55 PM; Item 8: 9:55 - 10:40 PM) Include: Report of Committees/Commissions, Ordinances and Resolutions, Public Hearings, Report of Officials, Unfinished Business and Council Matters.   6.PUBLIC HEARING / QUASI-JUDICIAL. 660 University Ave [21PLN-00341]: Request for Approval of a Planned Home Zoning (PHZ) on Three Parcels (511 Byron Street, 660 University Avenue, 680 University Avenue/500 Middlefield Road), to Demolish Existing Buildings and Provide a New Six Story Mixed-Use Building with Approximately 1,900 Square Feet of Office, 70 Multi-Family Residential Units, and a Two Level Below-Grade Parking Garage. CEQA Status: A Draft Environmental Impact Report Circulated for Public Review Beginning on April 2, 2024, and Ending on May 17, 2024. The City published a Final EIR in March 2025 and a revised Final EIR in October 2025. Zoning District: RM-20 (Multi-Family Residential). 7.Approval of the Four-Quadrant Gate System as the preferred Quiet Zone Implementation Measure at the Churchill, Meadow, and Charleston Rail Crossings as Recommended by the Rail Committee; CEQA status - categorically exempt. 8.REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment) ADJOURNMENT INFORMATION REPORTS Information reports are provided for informational purposes only to the Council and the public but are not listed for action or discussion during this meeting’s agenda.   A.Independent Police Auditor's (IPA) Report of Review of Investigations Between December 2024 and May 2025 and Police Department Use of Force Report for the Same Period  3 November 10, 2025 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. OTHER INFORMATION Standing Committee Meetings this week Policy & Services Committee November 12, 2025 CANCELED City Schools Liaison Committee November 13, 2025 Climate Action & Sustainability Committee November 14, 2025 CANCELED Public Comment Letters Schedule of Meetings   AMENDED AGENDA ITEMS   AA1.Adopt a Resolution Deferring CPAU Late Fees and Collection Actions for Certain Customers Affected by the Ongoing Federal Government Shutdown; CEQA Status – Not a Project. New Item Added      4 November 10, 2025 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. PUBLIC COMMENT INSTRUCTIONS Members of the Public may provide public comments to teleconference meetings via email, teleconference, or by phone. 1.Written public comments may be submitted by email to city.council@PaloAlto.gov. 2.For in person public comments please complete a speaker request card located on the table at the entrance to the Council Chambers and deliver it to the Clerk prior to discussion of the item. 3.Spoken public comments for agendized items using a computer or smart phone will be accepted through the teleconference meeting. To address the Council, click on the link below to access a Zoom-based meeting. Please read the following instructions carefully. ◦You may download the Zoom client or connect to the meeting in- browser. If using your browser, make sure you are using a current, up-to-date browser: Chrome 30 , Firefox 27 , Microsoft Edge 12 , Safari 7 . Certain functionality may be disabled in older browsers including Internet Explorer. Or download the Zoom application onto your smart phone from the Apple App Store or Google Play Store and enter in the Meeting ID below. ◦You may be asked to enter an email address and name. We request that you identify yourself by name as this will be visible online and will be used to notify you that it is your turn to speak. ◦When you wish to speak on an Agenda Item, click on “raise hand.” The Clerk will activate and unmute speakers in turn. Speakers will be notified shortly before they are called to speak. ◦When called, please limit your remarks to the time limit allotted. A timer will be shown on the computer to help keep track of your comments. 4.Spoken public comments for agendized items using a phone use the telephone number listed below. When you wish to speak on an agenda item hit *9 on your phone so we know that you wish to speak. You will be asked to provide your first and last name before addressing the Council. You will be advised how long you have to speak. When called please limit your remarks to the agenda item and time limit allotted. CLICK HERE TO JOIN Meeting ID: 362-027-238 Phone: 1-669-900-6833 Americans with Disability Act (ADA) It is the policy of the City of Palo Alto to offer its public programs, services and meetings in a manner that is readily accessible to all. Persons with disabilities who require materials in an appropriate alternative format or who require auxiliary aids to access City meetings, programs, or services may contact the City’s ADA Coordinator at (650) 329-2550 (voice) or by emailing ada@PaloAlto.gov. Requests for assistance or accommodations must be submitted at least 24 hours in advance of the meeting, program, or service.    5 November 10, 2025 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas.   California Government Code §84308, commonly referred to as the "Levine Act," prohibits an elected official of a local government agency from participating in a proceeding involving a license, permit, or other entitlement for use if the official received a campaign contribution exceeding $500 from a party or participant, including their agents, to the proceeding within the last 12 months. A “license, permit, or other entitlement for use” includes most land use and planning approvals and the approval of contracts that are not subject to lowest responsible bid procedures and have a value over $50,000. A “party” is a person who files an application for, or is the subject of, a proceeding involving a license, permit, or other entitlement for use. A “participant” is a person who actively supports or opposes a particular decision in a proceeding involving a license, permit, or other entitlement for use, and has a financial interest in the decision. The Levine Act incorporates the definition of “financial interest” in the Political Reform Act, which encompasses interests in business entities, real property, sources of income, sources of gifts, and personal finances that may be affected by the Council’s actions. If you qualify as a “party” or “participant” to a proceeding, and you have made a campaign contribution to a Council Member exceeding $500 made within the last 12 months, you must disclose the campaign contribution before making your comments.  6 November 10, 2025 Materials submitted after distribution of the agenda packet are available for public inspection at www.paloalto.gov/agendas. City Council Staff Report Report Type: SPECIAL ORDERS OF THE DAY Lead Department: Police Meeting Date: November 10, 2025 Report #:2510-5276 TITLE Proclamation Recognizing National Police Records and Support Personnel Week ATTACHMENTS Attachment A: Proclamation Recognizing National Police Records and Support Personnel Week APPROVED BY: Andrew Binder, Police Chief Item 1 Item 1 Staff Report        Item 1: Staff Report Pg. 1  Packet Pg. 7 of 517  NATIONAL POLICE RECORDS AND SUPPORT PERSONNEL WEEK November 9-15, 2025 WHEREAS, law enforcement agencies throughout the state depend upon law enforcement records and support personnel to provide them with vital services; and WHEREAS, law enforcement records and support personnel are crucial to helping law enforcement agencies identify, pursue, capture, and process suspected lawbreakers; and WHEREAS, these professionals continually use their expertise and experience to assist in tracking felons, maintaining criminal statistics, and improving apprehension strategies; and WHEREAS, the California Law Enforcement Association of Records Supervisors held its Annual Training and Technology Conference on November 3 through 7, 2025; and WHEREAS, it is important to recognize the City of Palo Alto’s law enforcement records and support personnel for their valuable contributions to our law enforcement system. NOW, THEREFORE I, Ed Lauing, Mayor of the City of Palo Alto, on behalf of the entire City Council, do hereby recognize November 9-15, 2025, as National Police Records and Support Personnel Week in the City of Palo Alto. Presented: November 10, 2025 ______________________________ Ed Lauing Mayor Proclamation Item 1 Attachment A - Proclamation Recognizing National Police Records and Support Personnel Week        Item 1: Staff Report Pg. 2  Packet Pg. 8 of 517  City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Transportation Meeting Date: November 10, 2025 Report #:2509-5204 TITLE FIRST READ: Adopt an Ordinance Amending PAMC Chapter 10.56 (Special Speed Zones) to Update Speed Limit Studies for Nine Streets and Approve the 2025 Traffic Survey; CEQA status – categorically exempt. RECOMMENDATION Staff recommends that the City Council: 1. Approve the 2025 Engineering and Traffic Survey (Attachment A), and 2. Adopt an ordinance re-establishing posted speed limits for nine streets pursuant to the California Vehicle Code (Attachment B). EXECUTIVE SUMMARY This report presents the results and recommendations of the engineering and traffic survey that was conducted as Phase 2 in 2025 for nine street segments (Attachment A). This updated survey was intended to serve as the basis for the establishment and enforcement of speed limits for certain street segments within the City of Palo Alto. These enforceable speed limits incorporate the provisions of recent legislative changes from Assembly Bill (AB) 43 and AB 1938. Based on the results of the Engineering and Traffic Survey (E&TS), existing posted speed limits on nine street segments would either continue to be, or would be newly justified by the survey, and these street segments would therefore be eligible for enforcement by use of radar. BACKGROUND Speed limits in California are governed by the California Vehicle Code (CVC), including § 627, 22348 through 22413 and 40802. In conformance with these state laws, vehicle speed laws can only be enforced using radar when speed limits are determined by an engineering and traffic survey that verifies the 85th percentile speeds (the speed below which 85% of drivers operate in free flow conditions). On September 8, 2025 City Council considered the E&TSs for 23 Palo Alto streets (Phase 1) that had expired. Based on these surveys, Council adopted an amendment to PAMC Chapter 10.56 at Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 1  Packet Pg. 9 of 517  a second hearing on September 29, 2025. As a result, the Police Department is now able to enforce the speed limits using radar on those approved 23 segments. ANALYSIS Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 2  Packet Pg. 10 of 517  The counts were used to determine the collision rates for each segment, which in turn was used as a factor in determining the appropriate speed limit for each segment. Other information that factored into the determination of recommended speed included designation as a safety corridor as well as location within a business district or residence district as defined in the CVC. Table 1: 2025 City of Palo Alto Engineering & Traffic Survey Segments No.Street Survey Limits Roadway Type 85th Percentile Speed (mph) Existing Speed Limit (mph) Recommen ded Speed Limit (mph) Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 3  Packet Pg. 11 of 517  Next Steps Pending Council adoption of the attached ordinance, City staff will provide messaging to community members on enforcement; and add the above corridors to traffic enforcement patrols. The consultant fee for completing the engineering and traffic survey data collection, analysis and recommendation was $24,260 and was funded in FY 2024 and FY 2025 Adopted Budgets in the Transportation and Parking Improvements Capital Project (PL-12000). No additional funds are needed to adopt the ordinance. The process for establishing speed limits is defined under the CVC and CA-MUTCD. Additionally, recent community engagement activities indicate strong support for this action. Extensive stakeholder engagement was conducted as part of the Safety Action Plan, which identified a proactive Speed Management Program as a key step to creating a culture and climate of systemic safety. This action is one element of such an approach. City staff will conduct additional community outreach to inform members of public that enforcement will be undertaken along these corridors. Approval of this ordinance would not result in any new impacts to the existing environment. This project is considered as a minor alteration to the existing street system, and therefore categorically exempt (Class 1 Exemption, Section 15301) from the provisions of the California Environmental Quality Act (CEQA). Attachment A: 2025 Engineering and Traffic Survey Attachment B: Ordinance Amending PAMC Chapter 10.56 to Establish Speed Limits Attachment C: Study Segments Phase 1&2 : Ria Hutabarat Lo, Chief Transportation Official Item 4 Item 4 Staff Report        Item 4: Staff Report Pg. 4  Packet Pg. 12 of 517  FINAL REPORT SEPTEMBER 2025 Engineering and Traffic Survey City of Palo Alto, CA Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 5  Packet Pg. 13 of 517  Final Report September 25, 2025 City of Palo Alto, California Engineering and Traffic Survey Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 6  Packet Pg. 14 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 7  Packet Pg. 15 of 517  ii TABLE OF CONTENTS 1.0 Introduction .............................................................................................................................................. 1 1.1 Relevant California Vehicle Code Sections ................................................................................................................. 6 2.0 Data Collection and Analysis ................................................................................................................ 10 2.1 Radar Speed Surveys and Analysis ..............................................................................................................................10 2.2 Average Daily Traffic (ADT) Volumes ..........................................................................................................................12 2.3 Traffic Collision Data ..........................................................................................................................................................15 3.0 Speed Limit Recommendations ............................................................................................................ 19 TABLES Table 1: Survey Segments ................................................................................................................................................................. 3 Table 2: Safety Corridor Definition Requirements ................................................................................................................... 8 Table 3: Land Uses and Facilities that Generate High Concentrations of Bicyclists and/or Pedestrians ........... 9 Table 4: Procedure of Rounding and Speed Limit Reductions on Local Agency Roadways .................................. 9 Table 5: Speed Survey Summary ................................................................................................................................................. 12 Table 6: Average Daily Traffic Volumes .................................................................................................................................... 13 Table 7: Collision History Summary ........................................................................................................................................... 16 Table 8: Collision Rates Summary ............................................................................................................................................... 17 Table 9: Recommended Speed Limits Summary .................................................................................................................. 21 Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 8  Packet Pg. 16 of 517  iii FIGURES Figure 1: Types of Speed Limits ...................................................................................................................................................... 1 Figure 2: Survey Locations ................................................................................................................................................................ 4 Figure 3: Existing Speed Limits ........................................................................................................................................................ 5 Figure 4: Average Daily Traffic Volumes................................................................................................................................... 14 Figure 5: Collision Analysis ............................................................................................................................................................ 18 Figure 6: Illustration of Examples of Applicability of Rounding and Speed Limit Reductions on Local Agency Roadways ................................................................................................................................................................................... 20 Figure 7: Recommended Speed Limits ..................................................................................................................................... 22 APPENDICES Appendix A: Recommended Speed Limit Certifications and Supporting Data (Speed Survey Collection Forms and Average Daily Traffic Volumes) Appendix B: Collision Data Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 9  Packet Pg. 17 of 517  1 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O 1.0 INTRODUCTION The purpose of this survey is to evaluate the speed limits for nine segments within the City of Palo Alto and recommend speed limit changes, if any, in accordance with the Assembly Bill 43 and State of California regulations and guidelines. The California Vehicle Code (CVC) Section 627 authorizes the California Department of Transportation (Caltrans) and local authorities to conduct engineering and traffic surveys. These surveys are used to determine safe and appropriate speed limits on roads, considering factors such as traffic speed, roadway conditions, collision history, and traffic volume. The surveys must follow established methods to ensure that the speed limits are set based on actual driving behavior and safety considerations. CVC Section 40802 requires that Engineering and Traffic Survey (E&TS) for speed limits should be conducted at least once every seven or 14 years based on established criteria. State and local agencies re-evaluate non-statutory speed limits on their street segments that have undergone a significant change in roadway characteristics or surrounding land uses since the speed limits were last reviewed. The California State Legislature sets in place the regulations for California speed limits and the California Vehicle Code (CVC) places these regulations into language used primarily for enforcement purposes. Various jurisdictions have responsibility for roadways throughout California, including the responsibility to set speed limits on these roadways according to the standards and procedures established by Caltrans. The guidelines from the California Manual for Setting Speed Limits published by Caltrans (Rev. March, 2025) are used in this study. These guidelines help in establishing speed limits that are uniform throughout the state and avoid influence from political pressure or emotional perceptions. Speed limits are established primarily for protecting the public and property from reckless and unsafe driving behavior. Speed limits are generally established at or near the 85th percentile speed. The 85th percentile speed, also referred to as the critical speed, is defined as the speed at or below which 85 percent of vehicles are moving in free flow conditions. Speed limits established on this basis conform to the consensus of those who drive on the roadways as to what speed is reasonable and safe under normal driving conditions. Figure 1 illustrates the various speed limit signs for different zones and roadways. Figure 1: Types of Speed Limits Source: FHWA Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 10  Packet Pg. 18 of 517  2 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Many factors influence drivers and their perception of the safe speed at which to operate a vehicle. These factors should be considered collectively because it is not practical to consider each individually. The design and physical characteristics of the roadway place limitations on the safe operating speed of vehicles. These characteristics include, but are not limited to: • Roadway geometrics, shoulder condition, grade, curvature, alignment, and sight distance • Roadside developments, zoning, and environment • Parking practices • Bicycle and pedestrian activity • Driveway density • Signalized or stop-controlled intersections; and • Rural, residential or developed areas. This report presents the results of the E&TS conducted in April 2025 and March 2025 for nine street segments throughout the City of Palo Alto, and incorporates input from radar speed surveys, average daily traffic counts, segment collision analyses, and analyses of roadway characteristics. The nine survey segments included in the study are listed in Table 1; illustrated in Figure 2; and categorized below by roadway types according to the Palo Alto City’s General Plan: • 7 segments are designated as ‘Major Arterials’ • 2 segments are designated as ‘Collectors’ The existing speed limits for the survey segments are illustrated in Figure 3 and summarized in Table 1. Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 11  Packet Pg. 19 of 517  3 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Table 1: Survey Segments No. Street Survey Limits Roadway Classification Roadway Type No. of Lanes Width (feet) Length (miles) Existing Speed Limit (mph) 1 Alma Street University Avenue to Lincoln Avenue Major Arterial Undivided 4 56 0.51 25 2 Birch Street California Avenue to Oregon Expressway Collector Divided 2 50 0.22 25 3 Coyote Hill Road Page Mill Road to Hillview Avenue Collector Undivided 4 60 0.68 35 4 Embarcadero Road Embarcadero Road to Highway 101 Major Arterial Undivided 4 55 0.83 25 5 Embarcadero Road Highway 101 to Middlefield Road Major Arterial Undivided 4 55 1.21 25 6 Embarcadero Road Middlefield Road to Alma Street Major Arterial Undivided 4 46 0.75 25 7 Road E Charleston Road Major Arterial Undivided 4 60 1.68 25 8 Road South City Limits Major Arterial Undivided 4 70 0.53 25 9 Avenue Middlefield Road Major Arterial Undivided 2 46 1.04 25 Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 12  Packet Pg. 20 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 13  Packet Pg. 21 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 14  Packet Pg. 22 of 517  6 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O 1.1 Relevant California Vehicle Code Sections Applicable California Vehicle Code (CVC) Code sections for conducting an E&TS are summarized below: CVC SECTION 235 – BUSINESS DISTRICT: A “business district” is that portion of a highway and the property contiguous thereto (a) upon one side of which highway, for a distance of 600 feet, 50 percent or more of the contiguous property fronting thereon is occupied by buildings in use for business, or (b) upon both sides of which highway, collectively, for a distance of 300 feet, 50 percent or more of the contiguous property fronting thereon is so occupied. A business district may be longer than the distances specified in this section if the above ratio of buildings in use for business to the length of the highway exists. CVC SECTION 515 – RESIDENCE DISTRICT: A “residence district” is that portion of a highway and the property contiguous thereto, other than a business district, (a) upon one side of which highway, within a distance of a quarter of a mile, the contiguous property fronting thereon is occupied by 13 or more separate dwelling houses or business structures, or (b) upon both sides of which highway, collectively, within a distance of a quarter of a mile, the contiguous property fronting thereon is occupied by 16 or more separate dwelling houses or business structures. A residence district may be longer than one-quarter of a mile if the above ratio of separate dwelling houses or business structures to the length of the highway exists. Embarcadero Road between Highway 101 and Middlefield Road has more than 16 houses collectively on both the sides of the segment within quarter mile, which qualifies it as a residence district. CVC SECTION 627 – ENGINEERING AND TRAFFIC SURVEY: A survey of highway and traffic conditions in accordance with methods determined by Caltrans for use by state and local authorities, which shall include consideration of prevailing speeds as determined by traffic engineering measurements, collision records, and highway, traffic, and roadside conditions not readily apparent to the driver. Local authorities may also consider residential district density (as defined in Section 515) and pedestrian and bicyclist safety. CVC SECTION 22349 – MAXIMUM SPEED LIMITS: Provides that no person shall drive a vehicle upon a highway at a speed greater than 65 mph. An exception to this, as stated in CVC Section 22356, is that Caltrans may increase speed and these increases can only be made after consultation with the California Highway Patrol (CHP) based on an engineering and traffic survey. Even if the maximum speed is raised, certain vehicles are still not permitted to be driven over 55 mph. These are listed below: • Motor trucks have three or more axles or any truck towing another vehicle • Passenger vehicles towing other vehicles • School buses transporting school pupils • Farm labor vehicles transporting passengers • Vehicles transporting explosives CVC SECTION 22350 – BASIC SPEED LAW: Provides that no person shall drive a vehicle upon a highway at a speed greater than is reasonable or prudent having due regard for weather, visibility, the traffic on, and the surface and width of, the highway, and in no event at a speed which endangers the safety of persons or property. In other words, a driver violates the basic speed law if he or she is driving at unsafe speeds, even if that speed is lower than the posted regulatory speed limit sign. Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 15  Packet Pg. 23 of 517  7 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O CVC SECTION 22351 – SPEED LAW VIOLATIONS: States that the speed of any vehicle upon a highway not more than the limits specified in CVC Section 22352 or established as authorized in the CVC is lawful unless clearly proved to be in violation of the Basic Speed Law. This same section also states that the speed of any vehicle upon a highway in excess of the prima facie speed limits in CVC Section 22352 or established as authorized in the CVC is unlawful unless the defendant establishes by competent evidence that the speed in excess of said limits did not constitute a violation of the Basic Speed Law at the time, place and under the conditions then existing. CVC SECTION 22352 – PRIMA FACIE SPEED LIMITS: Establishes prima facie speed limits for local roads and streets. The term “prima facie”, as used in the CVC, is a speed limit that applies when no other specific speed limit is posted. It is a Latin term meaning “at first face” or “at first appearance”. It is also defined as “first view” and “before investigation”. Prima facie evidence is evidence sufficient to establish fact, or to raise presumption of fact, unless rebutted. These speed limits shall be applicable unless changed as authorized in the CVC and, if so changed, only when signs have been erected giving notice thereof. It sets two speed limits covering six classes of location. A speed limit of 15 mph applies at railroad crossings, at uncontrolled highway intersections with obstructed views, and on alleys. A speed limit of 25 mph applies on any highway in any business or residence district, unless a different limit is established by procedures described in the CVC by local authority or Department of Transportation. The 25-mph limit also applies in school zones or passing a senior center with standard erected warning sign for both. Embarcadero Road between Highway 101 and Middlefield Road, which is classified as a residence district, a 25-mph speed limit is enforceable. CVC SECTION 22357 (INCREASE OF LOCAL SPEED LIMITS TO 65 MPH) AND CVC SECTION 22358 (DECREASE OF LOCAL SPEED LIMITS): Under California Vehicle Code §22357, a city or county may increase a local street’s prima facie 25 mph speed limit to 30, 35, 40, 45, 50, 55, or 60 mph, or set a maximum of up to 65 mph, if an engineering and traffic survey demonstrates that a higher speed is safe and will facilitate traffic movement. Any such change only becomes effective once proper signs are posted, and future adjustments must also be supported by a new engineering and traffic survey. However, this section does not apply to special 25 mph zones near schools or senior centers, which are regulated under separate provisions. CVC SECTION 22358.3 (DECREASE ON NARROW STREETS) AND CVC SECTION 22358.4 (DECREASE OF LOCAL LIMITS NEAR SCHOOLS OR SENIOR CENTERS): California Vehicle Code §22358.3 allows a city or county, through ordinance or resolution, to set a speed limit of 20 or 15 mph on residential or business streets, excluding state highways when the road is notably narrow (a roadway width not exceeding 25 feet). This adjustment may be made based solely on the street’s residential character and its dimensions, without a requirement for an engineering and traffic survey. Meanwhile, §22358.4 gives local authorities the power to lower the standard 25 mph prima facie speed limit as established by §22352(b), to 20 or 15 mph, if an engineering and traffic survey indicates the higher speed is neither reasonable nor safe. Any such change must be supported by appropriate signage and, in the case of state highways, must also be approved by the Department of Transportation. Additionally, §22358.4 Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 16  Packet Pg. 24 of 517  8 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O permits special 15 mph or 25 mph speed limits near schools during school hours or noon recess within 500 feet (for 15 mph) or 500–1,000 feet (for 25 mph) of school buildings or grounds and under specific traffic conditions, even if a broader survey isn’t conducted. CVC SECTION 22358.5 – DOWNWARD SPEED ZONING: Physical conditions such as width, curvature, grade, and surface conditions, or any other condition readily apparent to a driver, in the absence of other factors, would not require special downward speed zoning. CVC SECTION 22358.6 – ROUNDING OF SPEED LIMITS: Authorizes local agencies to round speed limits to the nearest five miles per hour of the 85th percentile speed of the free-flowing traffic. In cases where the 85th percentile speed results in rounding up to the nearest five-mile per hour increment, the local authority may round the speed limit down to the lower five-mile per hour increment. Local authorities may additionally lower the speed limit as provided by CVC Section 22358.7, but not by more than 12.4 mph below the 85th percentile speed. Furthermore, they may retain or reinstate a previously adopted speed limit under Section 22358.8 without further reduction, even if other provisions would normally require a change. CVC SECTION 22358.7 – 5 MPH SPEED LIMIT REDUCTION: Authorizes local agencies to reduce the speed limit by an additional 5 mph if the portion of highway has been designated as a “safety corridor,” as defined in the California Manual on Uniform Traffic Control Devices (CA MUTCD; Table 2), or if the portion of highway is adjacent to any land use or facility that generates high concentrations of bicyclists or pedestrians (Table 3), especially those from vulnerable groups such as children, senior, persons with disabilities, and the unhoused. Table 2: Safety Corridor Definition Requirements Crash Weighting Factors to Develop One Serious/Fatal Injury Safety Corridor data and other factors to prioritize safety corridors. Suggested weighting factors are as follows: • Crash Severity: Fatal Crashes, Serious Injury Crashes • Mode: Pedestrian-bicycle-related crashes, vehicle/other • Disadvantaged Community Status: MPO/RTPA or locally defined disadvantaged community status based on most current version of CalEnviroScreen • Vulnerable Populations: Seniors (age 65 and older) and Youth (under age 15) based on the American Community Survey • School proximity (within 0.25 miles) based on the California Crash Density overlapping "corridor" segments to create a consistent unit of measurement and assess the concentration of linear patterns of injuries within a defined distance. The highest scoring (i.e. most fatal and serious injury crashes per mile) "corridor" segments within a street needs to be identified and an appropriate threshold set to Maintenance for safety corridors. However, such frequency need not exceed seven Source: 2014 CA MUTCD, Revision 7, Table 2B-105(CA) Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 17  Packet Pg. 25 of 517  9 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Table 3: Land Uses and Facilities that Generate High Concentrations of Bicyclists and/or Pedestrians Land Use Transit Factors Presence of Pedestrian/Bicyclist Infrastructure Demographic Factors Local Data Source: 2014 CA MUTCD, Revision 7, Table 2B-106(CA) The procedure of rounding speed limits according to CVC Section 22358.6 and CVC Section 22358.7 is tabulated in Table 4. Table 4: Procedure of Rounding and Speed Limit Reductions on Local Agency Roadways 85th-Percentile Speed (mph) Rounding to nearest 5 mph increment (CVC 22358.6(a)) If rounding to nearest is up, may round down (CVC 22358.6(c)) If rounding to nearest is down, may additionally lower by 5 mph (CVC 22358.6(b)) adjacent to high concentration of bicyclists & pedestrians, may additionally lower by 5 mph 47.5-50.0 50 45 No 40 45.1-47.4 45 No 40 35 42.5-45.0 45 40 No 35 40.1-42.4 40 No 35 30 Source: 2014 CA MUTCD, Revision 7, Table 2B-104(CA) CVC SECTION 22358.8 – RETAINMENT OF LOCAL SPEED LIMIT: Authorizes local agencies to retain an existing speed limit on a portion of highway if it was established in a previous E&TS with a speed limit certification sheet and if a registered traffic engineer has determined that no additional general-purpose lanes have been added to the portion of highway since completion of the previous E&TS. Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 18  Packet Pg. 26 of 517  10 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O CVC SECTION 40802 (A)(2) – PRIMA FACIE SPEED LIMITS: Provides that prima facie speed limits established under CVC Sections 22352(b)(1), 22354, 22357, 22358, and 22358.3 may not be enforced by radar unless the speed limit has been justified by an engineering and traffic survey within the last five years. This CVC section does not apply to a local street, road or school zone. CVC SECTION 40802 (B) – PRIMA FACIE SPEED LIMITS: For purposes of this section, a local street or road is one that is functionally classified as "local" on the "California Road System Maps," that are approved by the Federal Highway Administration and maintained by Caltrans. When a street or road does not appear on the "California Road System Maps," it may be defined as a "local street or road" if it primarily provides access to abutting residential property and meets the following three conditions: • Roadway width of not more than 40 feet. • Not more than one-half mile of uninterrupted length. Interruptions shall include official traffic control signals as defined in CVC Section 445; and • Not more than one traffic lane in each direction. 2.0 DATA COLLECTION AND ANALYSIS The data collection procedure and speed survey analysis methodology are briefly discussed below. 2.1 Radar Speed Surveys and Analysis The speed surveys involve the use of radar guns to collect sample speeds on selected street segments. A key aspect for conducting the surveys is to ensure that street segments with unique characteristics are individually surveyed. The most crucial component of a speed zone survey is the selection of locations for the data collection task. The prevailing speed at the data collection point was selected to be representative of the entire speed zone area. Radar speed surveys were conducted for nine segments in April 2025 and May 2025 on days with fair weather, clear visibility, and dry pavement conditions. The survey locations were selected where the prevailing speeds were representative of the entire street segment and were not too close to any traffic control devices. The selected locations were situated beyond the influence of stops, dips, curves, parked vehicles, and any other condition that may affect the normal rate of travel. An effort was made to ensure that the presence of radar survey equipment did not affect the speed of the traffic being surveyed. The radar speed surveys were conducted for all study segments, using calibrated radar equipment by certified technicians. Most sample sizes for a particular segment included around 100 vehicles. A Speed Survey Form was used to collect and summarize the following attributes: • Street surveyed • Precise location • Street direction • Date/day of the survey • Start time & end time of survey • Number of vehicles surveyed Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 19  Packet Pg. 27 of 517  11 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O • 85th percentile speed, 50th percentile speed, 10-mile pace • Percent and number of vehicles observed within the 10-mph pace • Percent and number of vehicles observed below pace • Percent and number of vehicles observed above pace • Range of speeds observed and standard deviation A description of some of the attributes is provided below: 50TH PERCENTILE SPEED (MEDIAN SPEED): The speed above and below which 50 percent of the sample speeds were observed. This value indicates the speed that a driver may choose to drive without the influence of any speed limits, speed signs, or enforcement. 85TH PERCENTILE SPEED (CRITICAL SPEED): The speed at or below 85 percent of the sample speeds were observed. The 85th percentile speed of a spot speed survey is the primary indicator of the appropriate speed limit for a section of the roadway. 10 MPH PACE SPEED: The 10-mph increment (range) of speeds containing the greatest number of vehicles. In most cases, the 85th percentile speed and the recommended speed lie within the range, frequently in the middle to upper range of the interval. The percentage of vehicles that fall within the pace speed is an indicator of the bunching of vehicular speeds. The number of observed vehicles within the 10-mph pace is often between 40 and 80 percent of the entire sample. AVERAGE SPEED: The average speed is simply the cumulative speed divided by the number of observed vehicles. SPEED RANGE: The range of speed is simply the difference in speeds of the fastest and slowest vehicles observed. A wide range of speeds (more than 30 mph, for example) indicates less favorable conditions than a narrow range. The greater the range, the more inconsistency in travel speeds with a greater likelihood of traffic collisions. In general, uniform speeds result in a smooth progression of traffic. The radar speed survey data was compiled and analyzed to determine the 50th percentile speed, the 85th percentile speed, the average speed, the speed range, the 10-mph pace speed, and the percentage of vehicles observed within the 10-mph pace. Table 5 presents the speed survey summary with existing speed limits, median speed, critical speed, 10- mile pace speed, and the percentage of vehicles observed within pace. Speeds were collected for 100 vehicles for each of the nine segments. The completed speed survey forms for all nine study segments are included in Appendix A. Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 20  Packet Pg. 28 of 517  12 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Table 5: Speed Survey Summary No. Street Survey Limits Speed Limit Median (mph) 85th Percentile (mph) 10-Mile Pace (mph) Percent w/in Pace 1 Alma Street Lincoln Avenue 25 31 36 27-36 74% 2 Birch Street 25 20 23 15-24 90% 3 Road Hillview Avenue 35 40 44 36-45 77% 4 25 34 39 30-39 71% 5 25 33 39 30-39 70% 6 25 29 34 24-33 74% 7 Middlefield Road Oregon Expressway to E Charleston Road 25 29 34 24-33 79% 8 Middlefield Road E Charleston Road to South City Limits 25 30 33 25-34 100% 9 University Avenue East City Limits to Middlefield Road 25 29 33 24-33 77% 2.2 Average Daily Traffic (ADT) Volumes The TJKM team collected average daily traffic (ADT) counts for all nine study segments by conducting tube counts along the segments. The tube count was scheduled on Tuesday, April 29, 2025, for all the study segments, but the two segments – Coyote Hill Road between Page Mill Road and Hillview Avenue was collected on Tuesday, May 6, 2025, and Middlefield Road between E Charleston Road and San Antonio Road was collected on Thursday, May 29, 2025. These counts were also used to determine the collision rates for each segment, which in turn was used as a factor in determining the appropriate speed limit for each segment. Table 6 summarizes the roadway classification and ADT volumes for each of the nine study segments. The existing ADT volumes for the survey segments are illustrated in Figure 4. The ADT counts are available in Appendix A. Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 21  Packet Pg. 29 of 517  13 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Table 6: Average Daily Traffic Volumes No. Street Survey Limits Direction Roadway Classification No. of Lanes NB/EB SB/WB 1 Alma Street Avenue to NB/SB Major Arterial 4 11,930 11,869 23,799 2 Birch Street to Oregon NB/SB Collector 2 1,397 3,866 5,263 3 Coyote Hill Road to Hillview NB/SB Collector 4 1,362 1,235 2,597 4 Embarcadero Road Road to Highway EB/WB Major Arterial 4 2,443 2,463 4,906 5 Road Middlefield Road EB/WB Major Arterial 4 15,398 14,814 30,212 6 Road to Alma Street EB/WB Major Arterial 4 13,070 13,434 26,504 7 Middlefield Road Expressway to E NB/SB Major Arterial 4 6,932 6,838 13,770 8 Middlefield Road Road to South NB/SB Major Arterial 4 8,461 8,798 17,259 9 Avenue Middlefield Road EB/WB Major Arterial 2 8,394 9,031 17,425 Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 22  Packet Pg. 30 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 23  Packet Pg. 31 of 517  15 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O 2.3 Traffic Collision Data Collisions reported at study segments were obtained from the Statewide Integrated Traffic Records System (SWITRS) database for a period of five years from January 2020 to December 2024. Collision rates are a significant factor in determining the appropriate speed limits. Figure 4 summarizes the type and the total number of collisions for all study segments. Table 8 and Figure 5 summarize the collision rates (per million vehicle miles travelled) for the study segments in comparison with the statewide averages. Additional collision data is available in Appendix B of this report. Definitions for Collision Types: The types of collisions and their definitions are defined by CHP and are listed below: Head-On: Two motor vehicles, approaching from opposite directions, make direct contact. For example, the front of one vehicle collides with the front of another, or prior to impact, one vehicle skids sideways, causing the side of the skidding vehicle to collide with the front of the other. Sideswipe: One motor vehicle strikes the side of another with a glancing blow. For example, two vehicles are proceeding in the same direction or from opposite directions, and the side of one vehicle strikes the side of the other. Rear End: Two motor vehicles, traveling in the same direction, make direct contact. For example, the front of one vehicle strikes the rear of another vehicle, or Vehicle #1 approaches Vehicle #2 from the rear and skids sideways during a braking action, causing the side of Vehicle #1 to strike the rear of Vehicle #2. Broadside: One motor vehicle strikes another vehicle at an angle greater than that of a sideswipe. Hit Object: A motor vehicle strikes a fixed object or other object. Overturned: A motor vehicle overturns and no prior collision or hitting an object caused the overturning. This would include a motorcyclist losing control, causing the vehicle to lie down on its side. Auto/Ped: A vehicle strikes a pedestrian. Other: A collision not covered in the preceding elements. This entry shall be explained in the narrative, such as a vehicle involved with - a bicycle, train, or animal; an automobile fire; passengers falling or jumping from a vehicle; a vehicle backing; a bicycle involved with a pedestrian or another bicycle, etc. Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 24  Packet Pg. 32 of 517  16 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Table 7: Collision History Summary No St r e e t He a d -On /U n - st a t e d Fa t a l In j u r y 1 Alma Street Avenue to 25 2 11 4 5 2 0 1 0 0 1 5 3 16 2 Birch Street to Oregon 7 1 2 1 1 2 0 0 0 0 0 3 0 4 3 Coyote Hill Road to Hillview 3 0 1 0 1 `0 0 0 1 0 0 1 1 1 4 Embarcadero Road Road to Highway 14 1 5 3 0 4 0 0 1 0 1 3 1 9 5 45 4 13 11 10 4 1 0 2 1 2 15 7 20 6 25 4 4 3 10 3 0 0 1 0 0 9 6 10 7 Middlefield Road Expressway to E 51 3 10 12 18 1 0 6 1 0 0 23 10 18 8 Middlefield Road Road to South 38 2 7 6 12 6 3 0 2 0 1 12 9 16 9 34 3 4 13 11 1 0 0 2 0 0 13 7 14 Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 25  Packet Pg. 33 of 517  17 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Table 8: Collision Rates Summary No. Street Survey Limits No. of Collisions Collision Rate Collision Rate State 1 Alma Street 25 1.12 0.69 No 2 Birch Street 7 3.33 1.18 No 3 Coyote Hill Road 3 0.93 0.89 No 4 14 1.89 0.78 No 5 45 0.67 0.68 Yes 6 25 0.69 0.68 No 7 Middlefield Road 51 1.21 0.70 No 8 Middlefield Road 38 2.26 0.69 No 9 University Avenue 34 1.03 1.10 Yes Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 26  Packet Pg. 34 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 27  Packet Pg. 35 of 517  19 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O 3.0 SPEED LIMIT RECOMMENDATIONS The setting of speed limits requires a rational and defensible procedure to maintain the confidence of the public and legal systems. Speed limit determinations rely on the premise that a reasonable speed limit is one that conforms to the actual behavior of most drivers; one will be able to select a speed limit that is both reasonable and effective by measuring drivers' speeds. The 2014 Edition of the CA MUTCD requires as a standard that a speed limit shall be established at the nearest 5 mph increment of the 85th percentile speed, except that the posted speed may be reduced by 5 mph from the nearest 5 mph increment of the 85th percentile speed in compliance with CVC Sections 627 and CVC 22358.6. According to CVC 22358.6, for cases in which the nearest 5 mph increment of the 85th percentile speed would require rounding up, the speed limit may be rounded down to the nearest 5 mph increment below the 85th percentile speed if no further reduction is used. The following examples are provided to explain the application of these speed limit criteria: • If the 85th percentile speed in a speed survey for a location was 37 mph, then the speed limit would be established at 35 mph since it is the closest 5 mph increment to the 37-mph speed. The 35-mph established speed limit can be reduced by an additional 5 mph to 30 mph if the conditions and justification for using this lower speed limit are documented in the E&TS and approved by a registered Civil or Traffic Engineer; and • If the 85th percentile speed in a speed survey for a location was 33 mph, then the speed limit would be established at 35 mph since it is the closest 5 mph increment to the 33-mph speed. The 35-mph established speed limit can be reduced by 5 mph to 30 mph if the conditions and justification for using this lower speed limit are documented in the E&TS and are approved by a registered Civil or Traffic Engineer. Section 2B.13 of the 2014 CA MUTCD further states that justification for reducing speed limits can be based on residential density, pedestrian/bicyclist safety and other factors not readily apparent to drivers but essential to meet the traffic safety needs of the community. The following factors may be considered to adjust and determine the final speed limits: • Road characteristics, shoulder condition, grade, alignment, and sight distance • 10 mph speed (a 10-mile range in which the highest number of data is recorded) • Roadside development and environment • Parking practices and bicycle/pedestrian activity • Reported crash experience for at least a 12-month period On October 8, 2021, the procedure for establishing local speed limits was changed once again with Assembly Bill No. 43 (AB 43) being signed into law (and later clarified by Assembly Bill 1938 in 2022). Whereas the previous procedure required no further action be taken after rounding down to the nearest 5 mph increment below the 85th percentile speed, AB 43 allows a local authority to use an additional 5 mph reduction if a portion of highway has been designated as a “safety corridor” as is defined by Caltrans in the CA MUTCD or if a portion of highway is adjacent to any land or facility that generates high concentrations of bicyclists or pedestrians, particularly those Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 28  Packet Pg. 36 of 517  20 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O from vulnerable groups such as children, seniors, persons with disabilities, and the unhoused. The procedure is shown in Figure 6. On June 2, 2025, City Council adopted the Palo Alto Safety Action Plan, which identified the City’s high injury network. This network also serves as the City’s “safety corridors” as defined in the California Manual on Uniform Traffic Control Devices (CA-MUTCD). This new document has been included in the analysis in addition to the Assembly Bill 43 and State of California regulations and guidelines. The existing speed limit may also be retained if it was established in the previous E&TS and if a registered traffic engineer has determined that no additional general-purpose lanes have been added to the portion of highway since completion of the previous E&TS. Figure 6: Illustration of Examples of Applicability of Rounding and Speed Limit Reductions on Local Agency Roadways Source: 2014 CA MUTCD, Revision 7, Table 2B-104(CA) The guidelines from the California Manual for Setting Speed Limits published by Caltrans (Rev. March 2025) were also followed in this study. The speed limit recommendations are proposed for nine street segments in the study based on the above discussed guidelines and speed data analysis. The speed limit for each study segment was 30 35 40 45 50 55 85th-Percentile"Critical Speed"(mph) Rounding to nearest5 mph increment(CVC 22358.6(a)) If rounding tonearest is up, mayround down (CVC22358.6(c)) If rounding tonearest is down,may additionallylower by 5 mph(CVC 22358.6(b)) If safety corridor oradjacent to highconcentration ofbicyclists &pedestrians, mayadditionally lowerby 5 mph (CVC22358.7) Sp e e d L i m i t Condition of Rounding 47.5-50.0 mph 45.1-47.4 mph Round down initially Round up initially Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 29  Packet Pg. 37 of 517  21 E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O recommended after determining the average speed, the 85th percentile speed, the pace speed, and considering other significant factors such as existing land use, roadway design characteristics and collision rates. Appendix A presents the recommended speed limit certifications of the traffic survey analyses, which include prevailing speed data, collision history, traffic factors, and roadway conditions. The recommended speed limit for each street segment is also shown with a comment on the rationale for the recommendation. In accordance with Section 40802(a)(2), speed limits on nine study segments are enforceable by radar or other electronic devices, as they have been verified through radar spot speed surveys. Figure 7 illustrates the recommended speed limits at the respective study segments. Table 9 tabulates the recommended speed limits. Based on this study, a revision to the currently posted speed limit is not recommended at any of the of the nine segments. Table 9: Recommended Speed Limits Summary No. Street Survey Limits Limit Speed Speed Limit 1 Alma Street University Avenue to Lincoln Avenue 25 36 25 2 Birch Street 25 23 25 3 Coyote Hill Road Page Mill Road to Hillview Avenue 35 44 35 4 Embarcadero Road to Highway 101 25 39 25 5 Highway 101 to Middlefield Road 25 39 25 6 Middlefield Road to Alma Street 25 34 25 7 25 34 25 8 25 33 25 9 East City Limits to Middlefield Road 25 33 25 Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 30  Packet Pg. 38 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 31  Packet Pg. 39 of 517  A E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Appendix A: Recommended Speed Limit Certifications and Supporting Data (Speed Survey Collection Forms and Average Daily Traffic Volumes) Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 32  Packet Pg. 40 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 33  Packet Pg. 41 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 20 1 21 1 22 23 24 5 25 4 26 2 27 7 28 6 29 4 30 11 31 9 32 4 33 10 34 5 35 10 36 8 37 5 38 3 39 3 40 1 41 1 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 20 - 41 31 mph 36 mph 27 - 36 74 74% 13% / 13 13% / 13 SPEED PARAMETERS Alma St Bet University Ave & Lincoln Ave City of Palo Alto Eastbound & Westbound Spot Speeds 09:30-10:00 04/29/2025 Project #: 25-080145-001 0 5 10 15 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 34  Packet Pg. 42 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_001 NB SB EB WB Total 0 0 11,930 11,869 23,799 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 24 9 33 12:00 171 155 326 00:00 01:00 49 38 87 00:15 8 6 14 12:15 155 186 341 01:00 02:00 19 14 33 00:30 8 12 20 12:30 149 165 314 02:00 03:00 16 21 37 00:45 9 11 20 12:45 176 169 345 03:00 04:00 19 18 37 01:00 8 3 11 13:00 169 151 320 04:00 05:00 26 52 78 01:15 4 5 9 13:15 171 163 334 05:00 06:00 44 166 210 01:30 4 3 7 13:30 187 158 345 06:00 07:00 148 414 562 01:45 3 3 6 13:45 175 171 346 07:00 08:00 443 791 1234 02:00 5 5 10 14:00 192 122 314 08:00 09:00 697 990 1687 02:15 6 3 9 14:15 196 159 355 09:00 10:00 594 954 1548 02:30 5 9 14 14:30 190 157 347 10:00 11:00 578 873 1451 02:45 0 4 4 14:45 206 213 419 11:00 12:00 615 838 1453 03:00 1 4 5 15:00 220 183 403 12:00 13:00 651 675 1326 03:15 5 3 8 15:15 247 183 430 13:00 14:00 702 643 1345 03:30 7 3 10 15:30 249 212 461 14:00 15:00 784 651 1435 03:45 6 8 14 15:45 228 197 425 15:00 16:00 944 775 1719 04:00 5 7 12 16:00 273 226 499 16:00 17:00 1053 854 1907 04:15 5 10 15 16:15 260 185 445 17:00 18:00 1123 883 2006 04:30 10 15 25 16:30 261 215 476 18:00 19:00 872 816 1688 04:45 6 20 26 16:45 259 228 487 19:00 20:00 669 552 1221 05:00 5 17 22 17:00 310 221 531 20:00 21:00 681 353 1034 05:15 7 30 37 17:15 292 225 517 21:00 22:00 628 289 917 05:30 12 48 60 17:30 275 210 485 22:00 23:00 400 141 541 05:45 20 71 91 17:45 246 227 473 23:00 00:00 175 68 243 06:00 19 65 84 18:00 229 216 445 06:15 27 100 127 18:15 223 223 446 NB SB EB WB TOTAL 06:30 40 112 152 18:30 245 196 441 00:00 to 12:00 06:45 62 137 199 18:45 175 181 356 3248 5169 8417 07:00 82 139 221 19:00 189 162 351 08:00 08:30 08:00 07:15 80 189 269 19:15 171 146 317 697 1002 1687 07:30 125 215 340 19:30 166 119 285 0.922 0.921 0.952 07:45 156 248 404 19:45 143 125 268 08:00 177 232 409 20:00 176 87 263 12:00 to 00:00 08:15 189 229 418 20:15 178 84 262 8682 6700 15382 08:30 145 272 417 20:30 163 87 250 16:45 16:30 16:45 08:45 186 257 443 20:45 164 95 259 1136 889 2020 09:00 164 226 390 21:00 172 87 259 0.916 0.975 0.951 09:15 155 247 402 21:15 161 66 227 09:30 130 240 370 21:30 146 83 229 07:00 to 09:00 09:45 145 241 386 21:45 149 53 202 1140 1781 2921 10:00 131 205 336 22:00 142 52 194 08:00 08:00 08:00 10:15 133 223 356 22:15 119 37 156 697 990 1687 10:30 152 211 363 22:30 73 25 98 0.922 0.910 0.952 10:45 162 234 396 22:45 66 27 93 11:00 129 192 321 23:00 54 27 81 16:00 to 18:00 11:15 155 202 357 23:15 42 14 56 2176 1737 3913 11:30 162 198 360 23:30 45 19 64 16:45 16:30 16:45 11:45 169 246 415 23:45 34 8 42 1136 889 2020 TOTALS 0 0 3248 5169 8417 TOTALS 0 0 8682 6700 15382 0.916 0.975 0.951 SPLIT % 0% 0% 39% 61% 35% SPLIT % 0% 0% 56% 44% 65% Volume Prepared by National Data & Surveying Services VOLUME Alma St Bet University Ave & Lincoln Ave 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume 0 200 400 600 800 1000 1200 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 35  Packet Pg. 43 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 36  Packet Pg. 44 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 3 15 3 16 1 17 10 18 14 19 14 20 15 21 11 22 9 23 7 24 3 25 4 26 2 27 2 28 2 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 14 - 28 20 mph 23 mph 15 - 24 90 90% 3% / 3 7% / 7 SPEED PARAMETERS Birch St Bet California Ave & Page Mill Rd City of Palo Alto Eastbound & Westbound Spot Speeds 10:50-11:50 04/29/2025 Project #: 25-080145-002 0 5 10 15 20 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 37  Packet Pg. 45 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_002 NB SB EB WB Total 0 0 1,397 3,866 5,263 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 2 2 4 12:00 14 71 85 00:00 01:00 8 6 14 00:15 4 2 6 12:15 20 63 83 01:00 02:00 8 3 11 00:30 0 1 1 12:30 19 60 79 02:00 03:00 0 5 5 00:45 2 1 3 12:45 25 68 93 03:00 04:00 2 8 10 01:00 4 2 6 13:00 32 94 126 04:00 05:00 2 15 17 01:15 0 0 0 13:15 22 52 74 05:00 06:00 2 37 39 01:30 4 0 4 13:30 15 63 78 06:00 07:00 9 82 91 01:45 0 1 1 13:45 22 72 94 07:00 08:00 14 158 172 02:00 0 1 1 14:00 33 53 86 08:00 09:00 38 298 336 02:15 0 1 1 14:15 25 60 85 09:00 10:00 55 288 343 02:30 0 1 1 14:30 36 50 86 10:00 11:00 56 266 322 02:45 0 2 2 14:45 27 52 79 11:00 12:00 68 226 294 03:00 1 2 3 15:00 27 51 78 12:00 13:00 78 262 340 03:15 1 0 1 15:15 27 50 77 13:00 14:00 91 281 372 03:30 0 3 3 15:30 21 61 82 14:00 15:00 121 215 336 03:45 0 3 3 15:45 24 89 113 15:00 16:00 99 251 350 04:00 1 5 6 16:00 30 56 86 16:00 17:00 109 265 374 04:15 1 1 2 16:15 28 71 99 17:00 18:00 91 331 422 04:30 0 4 4 16:30 27 47 74 18:00 19:00 119 343 462 04:45 0 5 5 16:45 24 91 115 19:00 20:00 112 225 337 05:00 0 4 4 17:00 29 76 105 20:00 21:00 138 140 278 05:15 1 4 5 17:15 12 86 98 21:00 22:00 101 81 182 05:30 0 13 13 17:30 22 80 102 22:00 23:00 51 57 108 05:45 1 16 17 17:45 28 89 117 23:00 00:00 25 23 48 06:00 2 12 14 18:00 40 110 150 06:15 2 13 15 18:15 24 90 114 NB SB EB WB TOTAL 06:30 3 20 23 18:30 30 85 115 00:00 to 12:00 06:45 2 37 39 18:45 25 58 83 262 1392 1654 07:00 3 27 30 19:00 31 62 93 11:00 08:30 08:30 07:15 5 39 44 19:15 21 69 90 68 328 381 07:30 2 43 45 19:30 35 54 89 0.739 0.726 0.768 07:45 4 49 53 19:45 25 40 65 08:00 5 48 53 20:00 28 42 70 12:00 to 00:00 08:15 8 63 71 20:15 38 41 79 1135 2474 3609 08:30 14 74 88 20:30 29 25 54 20:15 17:45 17:45 08:45 11 113 124 20:45 43 32 75 139 374 496 09:00 17 57 74 21:00 29 15 44 0.808 0.850 0.827 09:15 11 84 95 21:15 29 25 54 09:30 12 62 74 21:30 20 17 37 07:00 to 09:00 09:45 15 85 100 21:45 23 24 47 52 456 508 10:00 11 62 73 22:00 17 16 33 08:00 08:00 08:00 10:15 10 72 82 22:15 10 14 24 38 298 336 10:30 16 71 87 22:30 15 12 27 0.679 0.659 0.677 10:45 19 61 80 22:45 9 15 24 11:00 9 57 66 23:00 7 4 11 16:00 to 18:00 11:15 16 36 52 23:15 6 5 11 200 596 796 11:30 20 61 81 23:30 5 7 12 16:00 16:45 17:00 11:45 23 72 95 23:45 7 7 14 109 333 422 TOTALS 0 0 262 1392 1654 TOTALS 0 0 1135 2474 3609 0.908 0.915 0.902 SPLIT % 0% 0% 16% 84% 31% SPLIT % 0% 0% 31% 69% 69% Volume Prepared by National Data & Surveying Services VOLUME Birch St Bet California Ave & Page Mill Rd 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume 0 50 100 150 200 250 300 350 400 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 38  Packet Pg. 46 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 39  Packet Pg. 47 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:35 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 1 27 28 29 30 31 1 32 5 33 3 34 2 35 3 36 7 37 3 38 8 39 13 40 5 41 12 42 9 43 9 44 5 45 6 46 3 47 2 48 3 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 26 - 48 40 mph 44 mph 36 - 45 77 77% 15% / 15 8% / 8 SPEED PARAMETERS Coyote Hill Rd Bet Page Mill Rd/CR G3 & Hillview Ave City of Palo Alto Eastbound & Westbound Spot Speeds 10:30-11:50 04/30/2025 Project #: 25-080145-003 0 5 10 15 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 40  Packet Pg. 48 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_003 NB SB EB WB Total 0 0 1,362 1,235 2,597 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 1 2 3 12:00 24 13 37 00:00 01:00 1 6 7 00:15 0 1 1 12:15 25 14 39 01:00 02:00 1 4 5 00:30 0 2 2 12:30 17 19 36 02:00 03:00 1 8 9 00:45 0 1 1 12:45 16 11 27 03:00 04:00 0 0 0 01:00 0 0 0 13:00 14 19 33 04:00 05:00 3 0 3 01:15 0 1 1 13:15 8 14 22 05:00 06:00 46 1 47 01:30 1 0 1 13:30 8 25 33 06:00 07:00 66 5 71 01:45 0 3 3 13:45 3 36 39 07:00 08:00 134 16 150 02:00 0 0 0 14:00 8 52 60 08:00 09:00 186 21 207 02:15 1 5 6 14:15 9 54 63 09:00 10:00 250 25 275 02:30 0 3 3 14:30 4 64 68 10:00 11:00 320 34 354 02:45 0 0 0 14:45 8 43 51 11:00 12:00 129 38 167 03:00 0 0 0 15:00 5 65 70 12:00 13:00 82 57 139 03:15 0 0 0 15:15 3 45 48 13:00 14:00 33 94 127 03:30 0 0 0 15:30 4 56 60 14:00 15:00 29 213 242 03:45 0 0 0 15:45 6 51 57 15:00 16:00 18 217 235 04:00 0 0 0 16:00 5 59 64 16:00 17:00 17 184 201 04:15 0 0 0 16:15 2 43 45 17:00 18:00 26 135 161 04:30 0 0 0 16:30 6 44 50 18:00 19:00 11 91 102 04:45 3 0 3 16:45 4 38 42 19:00 20:00 2 59 61 05:00 4 0 4 17:00 4 36 40 20:00 21:00 2 16 18 05:15 5 0 5 17:15 8 40 48 21:00 22:00 1 5 6 05:30 9 1 10 17:30 9 23 32 22:00 23:00 3 3 6 05:45 28 0 28 17:45 5 36 41 23:00 00:00 1 3 4 06:00 10 2 12 18:00 3 28 31 06:15 12 0 12 18:15 2 23 25 NB SB EB WB TOTAL 06:30 21 2 23 18:30 4 19 23 00:00 to 12:00 06:45 23 1 24 18:45 2 21 23 1137 158 1295 07:00 30 3 33 19:00 1 17 18 10:00 10:30 10:00 07:15 30 3 33 19:15 1 18 19 320 41 354 07:30 29 1 30 19:30 0 18 18 0.920 0.854 0.912 07:45 45 9 54 19:45 0 6 6 08:00 43 5 48 20:00 0 6 6 12:00 to 00:00 08:15 45 4 49 20:15 1 1 2 225 1077 1302 08:30 45 8 53 20:30 1 3 4 12:00 14:15 14:15 08:45 53 4 57 20:45 0 6 6 82 226 252 09:00 51 8 59 21:00 0 1 1 0.820 0.869 0.900 09:15 48 6 54 21:15 0 0 0 09:30 67 8 75 21:30 1 3 4 07:00 to 09:00 09:45 84 3 87 21:45 0 1 1 320 37 357 10:00 76 8 84 22:00 0 0 0 08:00 07:45 08:00 10:15 71 8 79 22:15 0 0 0 186 26 207 10:30 86 8 94 22:30 2 1 3 0.877 0.722 0.908 10:45 87 10 97 22:45 1 2 3 11:00 45 11 56 23:00 1 3 4 16:00 to 18:00 11:15 29 12 41 23:15 0 0 0 43 319 362 11:30 30 4 34 23:30 0 0 0 17:00 16:00 16:00 11:45 25 11 36 23:45 0 0 0 26 184 201 TOTALS 0 0 1137 158 1295 TOTALS 0 0 225 1077 1302 0.722 0.780 0.785 SPLIT % 0% 0% 88% 12% 50% SPLIT % 0% 0% 17% 83% 50% Volume Prepared by National Data & Surveying Services VOLUME Coyote Hill Rd Bet Page Mill Rd/CR G3 & Hillview Ave 05/06/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume 0 50 100 150 200 250 300 350 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 41  Packet Pg. 49 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 42  Packet Pg. 50 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 20 21 1 22 1 23 2 24 25 26 3 27 5 28 3 29 30 7 31 2 32 8 33 7 34 19 35 5 36 7 37 7 38 3 39 6 40 5 41 1 42 1 43 3 44 2 45 1 46 1 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 21 - 46 34 mph 39 mph 30 - 39 71 71% 15% / 15 14% / 14 SPEED PARAMETERS Embarcadero Rd Bet Embarcadero Wy & US-101/Bayshore Fwy City of Palo Alto Eastbound & Westbound Spot Speeds 12:30-13:00 04/29/2025 Project #: 25-080145-004 0 5 10 15 20 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 43  Packet Pg. 51 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_004 NB SB EB WB Total 0 0 2,443 2,463 4,906 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 1 3 4 12:00 50 58 108 00:00 01:00 7 7 14 00:15 3 2 5 12:15 48 56 104 01:00 02:00 5 7 12 00:30 0 0 0 12:30 39 52 91 02:00 03:00 4 4 8 00:45 3 2 5 12:45 45 52 97 03:00 04:00 9 2 11 01:00 3 4 7 13:00 43 50 93 04:00 05:00 15 3 18 01:15 0 0 0 13:15 37 48 85 05:00 06:00 34 4 38 01:30 1 3 4 13:30 55 53 108 06:00 07:00 129 25 154 01:45 1 0 1 13:45 43 38 81 07:00 08:00 183 43 226 02:00 1 2 3 14:00 27 47 74 08:00 09:00 246 91 337 02:15 1 1 2 14:15 47 53 100 09:00 10:00 231 108 339 02:30 1 1 2 14:30 31 52 83 10:00 11:00 207 129 336 02:45 1 0 1 14:45 41 53 94 11:00 12:00 179 181 360 03:00 0 0 0 15:00 39 80 119 12:00 13:00 182 218 400 03:15 2 0 2 15:15 43 65 108 13:00 14:00 178 189 367 03:30 1 0 1 15:30 35 67 102 14:00 15:00 146 205 351 03:45 6 2 8 15:45 45 47 92 15:00 16:00 162 259 421 04:00 1 1 2 16:00 41 68 109 16:00 17:00 148 252 400 04:15 1 0 1 16:15 43 70 113 17:00 18:00 107 247 354 04:30 3 2 5 16:30 33 58 91 18:00 19:00 107 186 293 04:45 10 0 10 16:45 31 56 87 19:00 20:00 78 157 235 05:00 6 1 7 17:00 24 67 91 20:00 21:00 40 72 112 05:15 6 1 7 17:15 27 63 90 21:00 22:00 23 48 71 05:30 6 0 6 17:30 23 61 84 22:00 23:00 14 19 33 05:45 16 2 18 17:45 33 56 89 23:00 00:00 9 7 16 06:00 22 4 26 18:00 29 69 98 06:15 28 4 32 18:15 27 32 59 NB SB EB WB TOTAL 06:30 33 7 40 18:30 24 38 62 00:00 to 12:00 06:45 46 10 56 18:45 27 47 74 1249 604 1853 07:00 30 3 33 19:00 17 44 61 07:45 11:00 11:00 07:15 45 7 52 19:15 26 42 68 257 181 360 07:30 48 21 69 19:30 18 39 57 0.813 0.838 0.882 07:45 60 12 72 19:45 17 32 49 08:00 59 19 78 20:00 6 21 27 12:00 to 00:00 08:15 59 29 88 20:15 12 20 32 1194 1859 3053 08:30 79 20 99 20:30 14 21 35 12:00 14:45 14:45 08:45 49 23 72 20:45 8 10 18 182 265 423 09:00 60 20 80 21:00 7 21 28 0.910 0.828 0.889 09:15 55 30 85 21:15 7 11 18 09:30 58 30 88 21:30 5 9 14 07:00 to 09:00 09:45 58 28 86 21:45 4 7 11 429 134 563 10:00 52 26 78 22:00 7 9 16 07:45 08:00 07:45 10:15 67 23 90 22:15 5 5 10 257 91 337 10:30 45 36 81 22:30 2 4 6 0.813 0.784 0.851 10:45 43 44 87 22:45 0 1 1 11:00 40 40 80 23:00 3 3 6 16:00 to 18:00 11:15 41 36 77 23:15 1 2 3 255 499 754 11:30 47 54 101 23:30 1 2 3 16:00 16:00 16:00 11:45 51 51 102 23:45 4 0 4 148 252 400 TOTALS 0 0 1249 604 1853 TOTALS 0 0 1194 1859 3053 0.860 0.900 0.885 SPLIT % 0% 0% 67% 33% 38% SPLIT % 0% 0% 39% 61% 62% Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Prepared by National Data & Surveying Services VOLUME Embarcadero Rd Bet Embarcadero Wy & US-101/Bayshore Fwy 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period 0 50 100 150 200 250 300 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 44  Packet Pg. 52 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 45  Packet Pg. 53 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1 25 2 26 4 27 3 28 5 29 4 30 11 31 6 32 10 33 9 34 8 35 4 36 5 37 4 38 6 39 7 40 3 41 4 42 3 43 1 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 24 - 43 33 mph 39 mph 30 - 39 70 70% 19% / 19 11% / 11 SPEED PARAMETERS Embarcadero Rd Bet US-101/Bayshore Fwy & Middlefield Rd City of Palo Alto Eastbound & Westbound Spot Speeds 12:05-12:35 04/30/2025 Project #: 25-080145-005 0 5 10 15 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 46  Packet Pg. 54 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_005 NB SB EB WB Total 0 0 15,398 14,814 30,212 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 48 13 61 12:00 222 243 465 00:00 01:00 119 47 166 00:15 31 12 43 12:15 231 244 475 01:00 02:00 65 28 93 00:30 23 12 35 12:30 241 268 509 02:00 03:00 55 28 83 00:45 17 10 27 12:45 229 251 480 03:00 04:00 38 48 86 01:00 17 10 27 13:00 245 228 473 04:00 05:00 53 216 269 01:15 17 5 22 13:15 218 230 448 05:00 06:00 115 557 672 01:30 17 8 25 13:30 261 245 506 06:00 07:00 246 970 1216 01:45 14 5 19 13:45 261 244 505 07:00 08:00 733 1074 1807 02:00 13 8 21 14:00 261 204 465 08:00 09:00 922 988 1910 02:15 5 2 7 14:15 229 220 449 09:00 10:00 728 885 1613 02:30 26 9 35 14:30 241 204 445 10:00 11:00 773 969 1742 02:45 11 9 20 14:45 233 202 435 11:00 12:00 897 891 1788 03:00 14 7 21 15:00 244 218 462 12:00 13:00 923 1006 1929 03:15 7 8 15 15:15 266 209 475 13:00 14:00 985 947 1932 03:30 9 18 27 15:30 299 217 516 14:00 15:00 964 830 1794 03:45 8 15 23 15:45 284 243 527 15:00 16:00 1093 887 1980 04:00 15 23 38 16:00 274 209 483 16:00 17:00 1108 799 1907 04:15 10 35 45 16:15 264 201 465 17:00 18:00 1140 793 1933 04:30 13 74 87 16:30 267 188 455 18:00 19:00 915 992 1907 04:45 15 84 99 16:45 303 201 504 19:00 20:00 985 673 1658 05:00 14 107 121 17:00 310 185 495 20:00 21:00 934 443 1377 05:15 23 97 120 17:15 277 187 464 21:00 22:00 744 355 1099 05:30 30 164 194 17:30 269 188 457 22:00 23:00 485 244 729 05:45 48 189 237 17:45 284 233 517 23:00 00:00 378 144 522 06:00 48 193 241 18:00 255 258 513 06:15 44 228 272 18:15 228 258 486 NB SB EB WB TOTAL 06:30 69 265 334 18:30 248 230 478 00:00 to 12:00 06:45 85 284 369 18:45 184 246 430 4744 6701 11445 07:00 112 261 373 19:00 250 217 467 07:45 06:45 07:30 07:15 165 262 427 19:15 248 177 425 1001 1088 2019 07:30 192 281 473 19:30 247 141 388 0.948 0.958 0.945 07:45 264 270 534 19:45 240 138 378 08:00 261 270 531 20:00 271 117 388 12:00 to 00:00 08:15 248 233 481 20:15 214 102 316 10654 8113 18767 08:30 228 242 470 20:30 235 109 344 16:45 12:00 15:15 08:45 185 243 428 20:45 214 115 329 1159 1006 2001 09:00 226 240 466 21:00 211 100 311 0.935 0.938 0.949 09:15 185 204 389 21:15 200 91 291 09:30 165 221 386 21:30 173 82 255 07:00 to 09:00 09:45 152 220 372 21:45 160 82 242 1655 2062 3717 10:00 184 240 424 22:00 158 80 238 07:45 07:15 07:30 10:15 209 219 428 22:15 123 71 194 1001 1083 2019 10:30 180 246 426 22:30 114 54 168 0.948 0.964 0.945 10:45 200 264 464 22:45 90 39 129 11:00 207 229 436 23:00 66 53 119 16:00 to 18:00 11:15 203 231 434 23:15 124 29 153 2248 1592 3840 11:30 244 205 449 23:30 115 37 152 16:45 16:00 17:00 11:45 243 226 469 23:45 73 25 98 1159 799 1933 TOTALS 0 0 4744 6701 11445 TOTALS 0 0 10654 8113 18767 0.935 0.956 0.935 SPLIT % 0% 0% 41% 59% 38% SPLIT % 0% 0% 57% 43% 62% Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Prepared by National Data & Surveying Services VOLUME Embarcadero Rd Bet US-101/Bayshore Fwy & Middlefield Rd 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period 0 200 400 600 800 1000 1200 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 47  Packet Pg. 55 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 48  Packet Pg. 56 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 2 20 2 21 2 22 3 23 1 24 5 25 8 26 5 27 12 28 5 29 6 30 7 31 10 32 8 33 8 34 4 35 6 36 4 37 38 39 1 40 1 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 19 - 40 29 mph 34 mph 24 - 33 74 74% 10% / 10 16% / 16 SPEED PARAMETERS Embarcadero Rd Bet Middlefield Rd & Alma St City of Palo Alto Eastbound & Westbound Spot Speeds 10:15-10:45 04/29/2025 Project #: 25-080145-006 0 5 10 15 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 49  Packet Pg. 57 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_006 NB SB EB WB Total 0 0 13,070 13,434 26,504 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 44 9 53 12:00 186 242 428 00:00 01:00 105 38 143 00:15 32 8 40 12:15 207 218 425 01:00 02:00 59 25 84 00:30 17 10 27 12:30 209 248 457 02:00 03:00 56 30 86 00:45 12 11 23 12:45 175 230 405 03:00 04:00 34 47 81 01:00 16 5 21 13:00 217 223 440 04:00 05:00 42 198 240 01:15 14 6 20 13:15 199 213 412 05:00 06:00 96 543 639 01:30 12 8 20 13:30 236 201 437 06:00 07:00 203 910 1113 01:45 17 6 23 13:45 204 206 410 07:00 08:00 572 951 1523 02:00 13 6 19 14:00 225 187 412 08:00 09:00 692 1014 1706 02:15 6 5 11 14:15 200 208 408 09:00 10:00 561 854 1415 02:30 29 11 40 14:30 224 193 417 10:00 11:00 647 903 1550 02:45 8 8 16 14:45 219 181 400 11:00 12:00 734 878 1612 03:00 16 6 22 15:00 226 173 399 12:00 13:00 777 938 1715 03:15 4 8 12 15:15 218 218 436 13:00 14:00 856 843 1699 03:30 8 18 26 15:30 251 202 453 14:00 15:00 868 769 1637 03:45 6 15 21 15:45 249 195 444 15:00 16:00 944 788 1732 04:00 13 20 33 16:00 217 221 438 16:00 17:00 1008 693 1701 04:15 8 39 47 16:15 274 162 436 17:00 18:00 971 661 1632 04:30 12 68 80 16:30 280 154 434 18:00 19:00 846 822 1668 04:45 9 71 80 16:45 237 156 393 19:00 20:00 908 545 1453 05:00 11 108 119 17:00 260 165 425 20:00 21:00 752 383 1135 05:15 23 97 120 17:15 226 141 367 21:00 22:00 613 292 905 05:30 29 152 181 17:30 252 162 414 22:00 23:00 412 208 620 05:45 33 186 219 17:45 233 193 426 23:00 00:00 314 101 415 06:00 39 178 217 18:00 213 196 409 06:15 35 223 258 18:15 213 213 426 NB SB EB WB TOTAL 06:30 54 254 308 18:30 195 222 417 00:00 to 12:00 06:45 75 255 330 18:45 225 191 416 3801 6391 10192 07:00 90 234 324 19:00 221 169 390 10:45 08:15 08:15 07:15 109 230 339 19:15 222 157 379 749 1063 1729 07:30 173 210 383 19:30 243 103 346 0.909 0.846 0.918 07:45 200 277 477 19:45 222 116 338 08:00 194 174 368 20:00 211 101 312 12:00 to 00:00 08:15 152 255 407 20:15 168 99 267 9269 7043 16312 08:30 146 314 460 20:30 218 87 305 16:15 12:00 15:15 08:45 200 271 471 20:45 155 96 251 1051 938 1771 09:00 168 223 391 21:00 182 80 262 0.938 0.946 0.977 09:15 142 194 336 21:15 189 69 258 09:30 121 223 344 21:30 124 72 196 07:00 to 09:00 09:45 130 214 344 21:45 118 71 189 1264 1965 3229 10:00 138 199 337 22:00 135 61 196 07:30 07:45 07:45 10:15 148 209 357 22:15 106 62 168 719 1020 1712 10:30 155 249 404 22:30 96 48 144 0.899 0.812 0.897 10:45 206 246 452 22:45 75 37 112 11:00 184 228 412 23:00 60 34 94 16:00 to 18:00 11:15 163 205 368 23:15 85 22 107 1979 1354 3333 11:30 196 209 405 23:30 105 25 130 16:15 16:00 16:00 11:45 191 236 427 23:45 64 20 84 1051 693 1701 TOTALS 0 0 3801 6391 10192 TOTALS 0 0 9269 7043 16312 0.938 0.784 0.971 SPLIT % 0% 0% 37% 63% 38% SPLIT % 0% 0% 57% 43% 62% Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Prepared by National Data & Surveying Services VOLUME Embarcadero Rd Bet Middlefield Rd & Alma St 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period 0 200 400 600 800 1000 1200 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 50  Packet Pg. 58 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 51  Packet Pg. 59 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 20 21 22 2 23 2 24 7 25 7 26 3 27 9 28 13 29 9 30 5 31 7 32 9 33 10 34 6 35 4 36 3 37 38 3 39 1 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 22 - 39 29 mph 34 mph 24 - 33 79 79% 4% / 4 17% / 17 SPEED PARAMETERS Middlefield Rd Bet Oregon Expy & E Charleston Rd City of Palo Alto Eastbound & Westbound Spot Speeds 09:35-10:10 04/30/2025 Project #: 25-080145-007 0 5 10 15 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 52  Packet Pg. 60 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_007 NB SB EB WB Total 0 0 6,932 6,838 13,770 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 6 9 15 12:00 98 96 194 00:00 01:00 16 22 38 00:15 5 6 11 12:15 86 111 197 01:00 02:00 9 8 17 00:30 4 4 8 12:30 98 118 216 02:00 03:00 6 6 12 00:45 1 3 4 12:45 102 90 192 03:00 04:00 8 11 19 01:00 1 4 5 13:00 73 101 174 04:00 05:00 7 12 19 01:15 4 2 6 13:15 81 82 163 05:00 06:00 23 19 42 01:30 0 2 2 13:30 96 109 205 06:00 07:00 64 87 151 01:45 4 0 4 13:45 102 83 185 07:00 08:00 266 301 567 02:00 2 1 3 14:00 114 93 207 08:00 09:00 627 600 1227 02:15 1 5 6 14:15 92 109 201 09:00 10:00 447 381 828 02:30 2 0 2 14:30 119 132 251 10:00 11:00 335 316 651 02:45 1 0 1 14:45 127 109 236 11:00 12:00 342 333 675 03:00 1 7 8 15:00 161 120 281 12:00 13:00 384 415 799 03:15 1 2 3 15:15 167 148 315 13:00 14:00 352 375 727 03:30 2 1 3 15:30 198 179 377 14:00 15:00 452 443 895 03:45 4 1 5 15:45 174 145 319 15:00 16:00 700 592 1292 04:00 0 3 3 16:00 165 141 306 16:00 17:00 767 633 1400 04:15 2 1 3 16:15 165 135 300 17:00 18:00 895 770 1665 04:30 2 3 5 16:30 228 167 395 18:00 19:00 500 556 1056 04:45 3 5 8 16:45 209 190 399 19:00 20:00 341 383 724 05:00 1 2 3 17:00 234 177 411 20:00 21:00 166 253 419 05:15 4 4 8 17:15 226 178 404 21:00 22:00 114 188 302 05:30 2 5 7 17:30 243 204 447 22:00 23:00 71 95 166 05:45 16 8 24 17:45 192 211 403 23:00 00:00 40 39 79 06:00 10 16 26 18:00 147 181 328 06:15 14 17 31 18:15 130 154 284 NB SB EB WB TOTAL 06:30 14 22 36 18:30 106 124 230 00:00 to 12:00 06:45 26 32 58 18:45 117 97 214 2150 2096 4246 07:00 32 54 86 19:00 110 125 235 08:00 08:00 08:00 07:15 43 50 93 19:15 90 110 200 627 600 1227 07:30 63 78 141 19:30 74 62 136 0.896 0.862 0.881 07:45 128 119 247 19:45 67 86 153 08:00 135 174 309 20:00 60 68 128 12:00 to 00:00 08:15 175 173 348 20:15 44 69 113 4782 4742 9524 08:30 166 115 281 20:30 30 59 89 16:45 17:15 17:00 08:45 151 138 289 20:45 32 57 89 912 774 1665 09:00 129 123 252 21:00 42 62 104 0.938 0.917 0.931 09:15 107 96 203 21:15 24 56 80 09:30 110 78 188 21:30 26 47 73 07:00 to 09:00 09:45 101 84 185 21:45 22 23 45 893 901 1794 10:00 71 81 152 22:00 29 43 72 08:00 08:00 08:00 10:15 99 93 192 22:15 19 26 45 627 600 1227 10:30 78 69 147 22:30 15 12 27 0.896 0.862 0.881 10:45 87 73 160 22:45 8 14 22 11:00 82 82 164 23:00 14 8 22 16:00 to 18:00 11:15 89 79 168 23:15 8 12 20 1662 1403 3065 11:30 87 80 167 23:30 12 8 20 16:45 17:00 17:00 11:45 84 92 176 23:45 6 11 17 912 770 1665 TOTALS 0 0 2150 2096 4246 TOTALS 0 0 4782 4742 9524 0.938 0.912 0.931 SPLIT % 0% 0% 51% 49% 31% SPLIT % 0% 0% 50% 50% 69% Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Prepared by National Data & Surveying Services VOLUME Middlefield Rd Bet Oregon Expy & E Charleston Rd 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period 0 100 200 300 400 500 600 700 800 900 1000 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 53  Packet Pg. 61 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 54  Packet Pg. 62 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Eastbound & Westbound DATE: Location: TIME: Posted Speed:25 MPH Weathe : Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 3 27 11 28 14 29 10 30 13 31 19 32 11 33 10 34 9 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 26 - 34 30 mph 33 mph 25 - 34 100 100% 0% / 0 0% / 0 SPEED PARAMETERS Middlefield Rd Bet E Charleston Rd & San Antonio Rd City of Palo Alto Eastbound & Westbound Spot Speeds 14:30-16:00 05/29/2025 Project #: 25-080215-001 0 5 10 15 20 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 55  Packet Pg. 63 of 517  Day:Thursday City:Palo Alto Date:Project #:CA25_080214_001 NB SB EB WB Total 0 0 8,461 8,798 17,259 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 3 7 10 12:00 113 120 233 00:00 01:00 13 29 42 00:15 4 6 10 12:15 124 113 237 01:00 02:00 10 14 24 00:30 4 7 11 12:30 127 115 242 02:00 03:00 6 7 13 00:45 2 9 11 12:45 121 109 230 03:00 04:00 8 8 16 01:00 2 5 7 13:00 117 99 216 04:00 05:00 10 35 45 01:15 3 2 5 13:15 106 117 223 05:00 06:00 34 69 103 01:30 1 5 6 13:30 108 127 235 06:00 07:00 82 181 263 01:45 4 2 6 13:45 113 112 225 07:00 08:00 387 508 895 02:00 1 3 4 14:00 171 152 323 08:00 09:00 798 763 1561 02:15 2 2 4 14:15 132 143 275 09:00 10:00 510 478 988 02:30 1 2 3 14:30 153 156 309 10:00 11:00 414 465 879 02:45 2 0 2 14:45 125 159 284 11:00 12:00 434 392 826 03:00 2 1 3 15:00 166 169 335 12:00 13:00 485 457 942 03:15 3 2 5 15:15 169 193 362 13:00 14:00 444 455 899 03:30 1 3 4 15:30 217 180 397 14:00 15:00 581 610 1191 03:45 2 2 4 15:45 217 167 384 15:00 16:00 769 709 1478 04:00 1 6 7 16:00 214 210 424 16:00 17:00 801 823 1624 04:15 3 10 13 16:15 188 174 362 17:00 18:00 892 926 1818 04:30 2 5 7 16:30 189 203 392 18:00 19:00 732 706 1438 04:45 4 14 18 16:45 210 236 446 19:00 20:00 411 509 920 05:00 3 13 16 17:00 213 223 436 20:00 21:00 310 316 626 05:15 5 12 17 17:15 217 239 456 21:00 22:00 188 166 354 05:30 12 24 36 17:30 197 218 415 22:00 23:00 97 113 210 05:45 14 20 34 17:45 265 246 511 23:00 00:00 45 59 104 06:00 12 38 50 18:00 265 233 498 06:15 11 36 47 18:15 161 173 334 NB SB EB WB TOTAL 06:30 28 42 70 18:30 145 157 302 00:00 to 12:00 06:45 31 65 96 18:45 161 143 304 2706 2949 5655 07:00 34 83 117 19:00 116 168 284 07:45 07:45 07:45 07:15 45 100 145 19:15 123 128 251 831 821 1652 07:30 78 122 200 19:30 98 115 213 0.851 0.946 0.920 07:45 230 203 433 19:45 74 98 172 08:00 144 217 361 20:00 87 86 173 12:00 to 00:00 08:15 213 196 409 20:15 72 88 160 5755 5849 11604 08:30 244 205 449 20:30 61 70 131 17:15 17:15 17:15 08:45 197 145 342 20:45 90 72 162 944 936 1880 09:00 138 141 279 21:00 53 47 100 0.891 0.951 0.920 09:15 104 107 211 21:15 57 42 99 09:30 134 114 248 21:30 37 41 78 07:00 to 09:00 09:45 134 116 250 21:45 41 36 77 1185 1271 2456 10:00 123 131 254 22:00 37 35 72 07:45 07:45 07:45 10:15 93 107 200 22:15 31 42 73 831 821 1652 10:30 100 107 207 22:30 24 15 39 0.851 0.946 0.920 10:45 98 120 218 22:45 5 21 26 11:00 103 82 185 23:00 16 12 28 16:00 to 18:00 11:15 111 94 205 23:15 11 25 36 1693 1749 3442 11:30 101 100 201 23:30 9 14 23 17:00 17:00 17:00 11:45 119 116 235 23:45 9 8 17 892 926 1818 TOTALS 0 0 2706 2949 5655 TOTALS 0 0 5755 5849 11604 0.842 0.941 0.889 SPLIT % 0% 0% 48% 52% 33% SPLIT % 0% 0% 50% 50% 67% Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Prepared by National Data & Surveying Services VOLUME Middlefield Rd Bet E Charleston Rd & San Antonio Rd (37.418393,-122.107724) 05/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period 0 100 200 300 400 500 600 700 800 900 1000 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 56  Packet Pg. 64 of 517  Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 57  Packet Pg. 65 of 517  Day:Tuesday City:Palo Alto Date:Project #:CA25_080144_009 NB SB EB WB Total 8,394 9,031 0 0 17,425 TIME NB SB EB WB TOTAL TIME NB SB EB WB TOTAL NB SB EB WB TOTAL 00:00 30 8 38 12:00 112 154 266 00:00 01:00 77 36 113 00:15 15 11 26 12:15 112 113 225 01:00 02:00 65 16 81 00:30 19 9 28 12:30 151 129 280 02:00 03:00 47 20 67 00:45 13 8 21 12:45 150 135 285 03:00 04:00 26 37 63 01:00 18 4 22 13:00 142 113 255 04:00 05:00 22 151 173 01:15 18 5 23 13:15 161 120 281 05:00 06:00 54 297 351 01:30 16 1 17 13:30 150 109 259 06:00 07:00 122 530 652 01:45 13 6 19 13:45 142 128 270 07:00 08:00 289 696 985 02:00 9 3 12 14:00 163 98 261 08:00 09:00 385 818 1203 02:15 10 5 15 14:15 169 94 263 09:00 10:00 359 697 1056 02:30 19 6 25 14:30 142 132 274 10:00 11:00 387 524 911 02:45 9 6 15 14:45 133 127 260 11:00 12:00 421 586 1007 03:00 6 6 12 15:00 153 104 257 12:00 13:00 525 531 1056 03:15 3 13 16 15:15 143 109 252 13:00 14:00 595 470 1065 03:30 9 7 16 15:30 150 129 279 14:00 15:00 607 451 1058 03:45 8 11 19 15:45 144 130 274 15:00 16:00 590 472 1062 04:00 3 13 16 16:00 145 141 286 16:00 17:00 502 470 972 04:15 6 26 32 16:15 105 111 216 17:00 18:00 451 486 937 04:30 7 51 58 16:30 116 113 229 18:00 19:00 545 567 1112 04:45 6 61 67 16:45 136 105 241 19:00 20:00 548 342 890 05:00 8 33 41 17:00 141 116 257 20:00 21:00 610 318 928 05:15 10 59 69 17:15 106 112 218 21:00 22:00 570 233 803 05:30 14 93 107 17:30 90 134 224 22:00 23:00 373 196 569 05:45 22 112 134 17:45 114 124 238 23:00 00:00 224 87 311 06:00 28 83 111 18:00 176 126 302 06:15 23 131 154 18:15 111 141 252 NB SB EB WB TOTAL 06:30 38 156 194 18:30 138 155 293 00:00 to 12:00 06:45 33 160 193 18:45 120 145 265 2254 4408 6662 07:00 46 164 210 19:00 130 109 239 11:00 08:00 08:00 07:15 65 179 244 19:15 136 92 228 421 818 1203 07:30 73 179 252 19:30 147 70 217 0.957 0.974 0.955 07:45 105 174 279 19:45 135 71 206 08:00 91 210 301 20:00 154 74 228 12:00 to 00:00 08:15 86 206 292 20:15 162 72 234 6140 4623 10763 08:30 105 210 315 20:30 161 84 245 13:30 18:00 18:00 08:45 103 192 295 20:45 133 88 221 624 567 1112 09:00 79 153 232 21:00 145 58 203 0.923 0.915 0.921 09:15 93 175 268 21:15 149 65 214 09:30 95 168 263 21:30 144 61 205 07:00 to 09:00 09:45 92 201 293 21:45 132 49 181 674 1514 2188 10:00 99 139 238 22:00 104 60 164 07:45 08:00 08:00 10:15 94 133 227 22:15 108 49 157 387 818 1203 10:30 95 126 221 22:30 84 43 127 0.921 0.974 0.955 10:45 99 126 225 22:45 77 44 121 11:00 103 137 240 23:00 63 23 86 16:00 to 18:00 11:15 107 148 255 23:15 59 28 87 953 956 1909 11:30 110 134 244 23:30 67 20 87 16:00 17:00 16:00 11:45 101 167 268 23:45 35 16 51 502 486 972 TOTALS 2254 4408 0 0 6662 TOTALS 6140 4623 0 0 10763 0.866 0.907 0.850 SPLIT % 34% 66% 0% 0% 38% SPLIT % 57% 43% 0% 0% 62% Peak Hour Peak Volume Peak Hour Factor Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Peak Hour Peak Volume Peak Hour Factor Peak Period Volume Prepared by National Data & Surveying Services VOLUME University Ave & Bet Chauser St & Middlefield Rd 04/29/2025 DAILY TOTALS DAILY TOTALS 15-Minutes Interval Hourly Intervals TIME STATISTICS Peak Period 0 100 200 300 400 500 600 700 800 900 00 : 0 0 01 : 0 0 02 : 0 0 03 : 0 0 04 : 0 0 05 : 0 0 06 : 0 0 07 : 0 0 08 : 0 0 09 : 0 0 10 : 0 0 11 : 0 0 12 : 0 0 13 : 0 0 14 : 0 0 15 : 0 0 16 : 0 0 17 : 0 0 18 : 0 0 19 : 0 0 20 : 0 0 21 : 0 0 22 : 0 0 23 : 0 0 NB SB EB WB Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 58  Packet Pg. 66 of 517  Spot Speed Study Prepared by: National Data & Surveying Services Northbound & Southbound DATE: Location: TIME: Posted Speed:25 MPH Weather: Clear/Dr Speed mph ALL Vehicles <=10 11 12 13 14 15 16 17 18 1 19 3 20 2 21 3 22 2 23 2 24 5 25 7 26 7 27 6 28 9 29 8 30 7 31 10 32 8 33 10 34 5 35 3 36 37 1 38 1 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 >=70 Class Count Range 50th Percentile 85th Percentile 10 MPH Pace # in Pace Percent in Pace % / # Below Pace % / # Above Pace ALL 100 18 - 38 29 mph 33 mph 24 - 33 77 77% 13% / 13 10% / 10 SPEED PARAMETERS University Ave Bet Chauser St & Middlefield Rd City of Palo Alto Northbound & Southbound Spot Speeds 09:00-09:30 04/29/2025 Project #: 25-080145-009 0 5 10 15 70 68 66 64 62 60 58 56 54 52 50 48 46 44 42 40 38 36 34 32 30 28 26 24 22 20 18 16 14 12 10 Sp e e d - M P H Number of Vehicles Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 59  Packet Pg. 67 of 517  B E N G I N E E R I N G A N D T R A F F I C S U R V E Y | C I T Y O F P A L O A L T O Appendix B: Collision Data Item 4 Attachment A - 2025 Engineering and Traffic Survey        Item 4: Staff Report Pg. 60  Packet Pg. 68 of 517  City of Palo Alto Raw Collision Data case_id accident_yproc_date juris collision_dcollision_tiofficer_id reporting_day_of_wechp_shift population cnty_city_lspecial_cobeat_type chp_beat_city_divisiochp_beat_beat_numprimary_rdsecondarydistance direction intersectioweather_1 weather_2 state_hwycaltrans_ccaltrans_distate_routroute_suffipostmile_ppostmile location_tramp_inteside_of_h tow_away collision_snumber_kinumber_inparty_couprimary_cpcf_code_pcf_viol_capcf_violatipcf_viol_shit_and_rutype_of_c mviw ped_actionroad_surfaroad_condroad_condlighting control_dechp_road_pedestrianbicycle_acmotorcycletruck_accinot_privatalcohol_instwd_vehtchp_vehtycount_sevcount_visicount_comcount_pedcount_pedcount_bicycount_bicycount_mccount_mc primary_rasecondarylatitude longitude local_repo82306219 2024 20240206 4312 20240125 1632 808239 80600 4 5 5 4312 0 0 0 0 PA2 ADDISON ALMA STR 0 Y A - N N 0 0 0 2 A - 08 22107 N D C A A H - A A 0 Y A 07 0 0 0 0 0 0 0 0 0 - -24-0031782333005 2024 20240308 4312 20240222 2029 808948 80600 4 5 5 4312 0 0 0 0 PA2 FOREST AV ALMA STR 5 E N A - N N 4 0 1 2 A - - N D G A A E H C D 0 Y Y - - 0 0 1 0 0 0 1 0 0 - -24-0069082418952 2024 20240620 4312 20240617 2359 809425 1 5 5 4312 0 0 0 0 PA2 ALMA ST ADDISON 59 N N A - N N 0 0 0 2 A - 08 22107 N B C A A H - A D 0 Y Y C 02 0 0 0 0 0 0 0 0 0 - -24-0219084383328 2024 20240906 4312 20240904 1845 808733 3 5 5 4312 0 0 0 0 PA2 ALMA ST ADDISON 0 Y A - N N 3 0 1 2 A - 09 21802 A N D C A A H - A D 0 Y A 01 0 1 0 0 0 0 0 0 0 - -24-032939018280 2020 20200117 4312 20200106 2500 5623 4312 1 5 5 4312 0 0 0 0 ALMA ST CHANNING 108 S N A - N N 0 0 0 2 D - 00 M B E A A H - A D 0 Y - - 0 0 0 0 0 0 0 0 0 - -20-01179056424 2020 20200323 4312 20200226 1927 02308 CITY 3 5 5 4312 0 0 0 0 002 ALMA ST FOREST AV 3 S N A - N N 0 0 0 2 A - 03 22350 N C C A A H - C A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-10519073062 2020 20200516 4312 20200229 1835 04456 6 5 5 4312 0 0 0 0 ALMA ST HAMILTON 300 N N A - N N 0 0 0 2 A - 07 21658 A N B C A A H - C D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-11049082171 2020 20200625 4312 20200322 857 8734 7 5 5 4312 0 0 0 0 ALMA ST UNIVERSIT 29 S N A - N N 0 0 0 1 A - 08 22107 N E I A A H - A A 0 Y Y G 25 0 0 0 0 0 0 0 0 0 - -20-14029107865 2020 20200730 4312 20200629 1039 7816 1 5 5 4312 0 0 0 0 002 ALMA ST CHANNING 15 S N A - N N 0 0 0 2 A - 03 22350 N B E A A H - A D 0 Y J 48 0 0 0 0 0 0 0 0 0 - -20-24439117651 2020 20200902 4312 20200518 1443 03422 4312 1 5 5 4312 0 0 0 0 001 ALMA ST CHANNING 110 N N A - N N 0 0 0 2 A - 07 21658 A N B C A A H - A A 0 Y A 07 0 0 0 0 0 0 0 0 0 - -20-23099127743 2020 20201014 4312 20200730 1515 8702 4312 4 5 5 4312 0 0 0 0 002 ALMA ST CHANNING 72 N N A - N N 0 0 0 2 A - 08 22107 M B C A A H - A D 0 Y Y F 26 0 0 0 0 0 0 0 0 0 - -20-28969156260 2020 20201203 4312 20200912 1305 5241 4312 6 5 5 4312 0 0 0 0 002 CHANNINGALMA ST 59 E N A - N N 0 0 0 2 A - 03 22350 N B C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-35809172824 2022 20220628 4312 20220514 1812 56802 80600 6 5 5 4312 0 0 0 0 PA2 ALMA ST FOREST AV 0 Y A - N N 3 0 1 2 A - 10 21950 A N G B B A H - A D 0 Y Y J 48 0 1 0 0 1 0 0 0 0 - -22-026449191801 2020 20210203 4312 20201130 1620 8734 SANTA 1 5 5 4312 0 0 0 0 ALMA ST HAMILTON 0 Y A - N N 2 0 1 2 A - 12 21453 A N A G A A H - A A 0 Y Y A 01 1 0 0 0 0 0 1 0 0 - -20-47409208221 2020 20210302 4312 20201215 1058 02308 4312 2 5 5 4312 0 0 0 0 002 ALMA ST HAMILTON 160 N N A B N N 0 0 0 2 A - 09 21801 A N D C A A H - - D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-49829209021 2020 20210216 4312 20201229 1225 6910 2 5 5 4312 0 0 0 0 ALMA ST LINCOLN A 9 S N A - N Y 4 0 1 2 A - 08 22107 N B C A A H - A D 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-51869212259 2021 20210311 4312 20210116 1540 7189 6 5 5 4312 0 0 0 0 ALMA ST UNIVERSIT 50 S N A - N N 0 0 0 1 A - 08 22107 N A I A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-01599235037 2021 20210419 4312 20210302 1440 04807 2 5 5 4312 0 0 0 0 002 ALMA ST CHANNING 30 N N A - N N 0 0 0 2 A - 08 22107 N B E A A H - A D 0 Y Y F 26 0 0 0 0 0 0 0 0 0 - -21-06189274971 2021 20210702 4312 20210622 1743 4263 2 5 5 4312 0 0 0 0 ALMA ST HAMILTON 40 S N A - N 0 0 0 2 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-18669354188 2021 20211202 4312 20211024 2200 7467 7 5 5 4312 0 0 0 0 002 ALMA ST FOREST AV 230 S N B C N N 0 0 0 3 A - 07 21658 A M B E A B H - C D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-34659360905 2021 20211229 4312 20211115 1747 8793 1 5 5 4312 0 0 0 0 ALMA ST CHANNING 0 Y A - N N 3 0 1 2 A - 03 22350 N C G A A H - C D 0 Y Y A 01 0 1 0 0 0 0 1 0 0 - -21-37469413672 2022 20220223 4312 20220209 918 808733 80500 3 5 5 4312 0 0 0 0 PA2 ALMA ST HAMILTON 0 Y A - N N 3 0 1 2 A - 03 22350 N D C A A H - A A 0 Y - 0 1 0 0 0 0 0 0 0 - -37.44267 122.1628 22-004049426509 2022 20220406 4312 20220225 1324 808914 80500 5 5 5 4312 0 0 0 0 PA2 HAMILTONALMA ST 0 Y A - N N 3 0 1 2 A - 08 22107 N B G A A H - A A 0 Y Y A 01 0 1 0 0 0 0 1 0 0 - -22-005809472333 2022 20220722 4312 20220625 2500 807190 80600 6 5 5 4312 0 0 0 0 PA2 ADDISON ALMA ST 10 E N A - N N 0 0 0 1 A - 03 22350 N E I A A H - A D 0 Y - 0 0 0 0 0 0 0 0 0 - -22-020379480106 2022 20220720 4312 20220623 1739 805859 08500 4 5 5 4312 0 0 0 0 PA2 ALMA ST HAMILTON 75 S N A - N N 4 0 1 3 A - 03 22350 N C C A A H - A D 0 Y A 01 0 0 1 0 0 0 0 0 0 - -22-020099026768 2020 20200224 4312 20200129 1030 8395 3 5 5 4312 0 0 0 0 001 CALIFORNIBIRCH RD 0 Y A - N N 0 0 0 1 A - 03 22350 N B I A A H - A D 0 Y - 0 0 0 0 0 0 0 0 0 - -20-05399064065 2020 20200509 4312 20200304 925 4598 3 5 5 4312 0 0 0 0 CALIFORNIBIRCH ST 150 W N A - N N 0 0 0 2 A - 03 22350 N C C A A H - A D 0 Y - 0 0 0 0 0 0 0 0 0 - -20-11649195043 2020 20210115 4312 20201128 416 8442 6 5 5 4312 0 0 0 0 001 BIRCH ST SHERIDAN 75 S N A - N Y 3 0 1 1 A - 01 23152 A N A I A A H - C D 0 Y Y A 01 0 1 0 0 0 0 0 0 0 - -20-47029241814 2021 20210420 4312 20210309 1245 3422 2 5 5 4312 0 0 0 0 002 BIRCH ST CALIFORNI 160 S N A B N N 0 0 0 1 A - 08 22107 N E J A A H - - A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-06839367794 2021 20211216 4312 20211102 612 1514 2 5 5 4312 0 0 0 0 001 BIRCH ST SHERMAN 68 N N B - N Y 3 0 1 1 A - 08 22107 N E I A A H - C D 0 Y A 01 0 1 0 0 0 0 0 0 0 - -21-35709472338 2022 20220722 4312 20220625 2143 808680 81300 6 5 5 4312 0 0 0 0 PA1 PAGE MILL BIRCH AV 25 W N A - N N 0 0 0 2 D - 00 N B - A A H - C A 0 Y - - 0 0 0 0 0 0 0 0 0 - -22-020389482086 2022 20220812 4312 20220724 1248 807754 81300 7 5 5 4312 0 0 0 0 PA1 BIRCH ST SHERIDAN 120 S N A - N Y 3 0 3 2 A - 03 22350 N D C A A H - A D 0 Y A 01 0 3 0 0 0 0 0 0 0 - -22-0239191367182 2020 20201215 9330 20201205 1730 022504 6 2 4 4305 0 3 5 2 007 PAGE MILL COYOTE H 0 Y A - N Y 0 0 0 2 A - 12 21453 A N D C A A H - B A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -37.40291 122.157 9330-202091571453 2021 20210916 9330 20210903 1510 022053 5 2 9 4300 0 3 5 2 007 PAGE MILL COYOTE HI 200 W N A - N Y 4 0 3 4 A - 03 22350 N B C A A H - A A 0 Y A 01 0 0 3 0 0 0 0 0 0 - -37.4026 122.157 9330-202192314750 2024 20240215 9330 20240205 1420 023587 1 2 9 4300 0 1 1 2 074 PAGE MILL COYOTE HI 0 Y B - N Y 3 0 1 2 A - 09 21800 D N D C A A H - A B 0 Y A 01 0 1 0 0 0 0 0 0 0 - -37.40289 122.1571 9330-20249018284 2020 20200121 4312 20200103 905 8239 PALOA 5 5 5 4312 0 0 0 0 002 FABER PL EMBARCA 360 S N A - N N 0 0 0 2 A - 08 22107 M C E A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-00549083731 2020 20201023 4312 20200326 1338 4130 4 5 5 4312 0 0 0 0 EMBARCAEMBARCA 0 Y A - N N 0 0 0 1 A - 03 22350 N E J A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -37.45463 122.1099 20-14299177867 2020 20210111 4312 20201027 1805 8702 4312 2 5 5 4312 0 0 0 0 002 BAYSHORE EMBARCA 220 N A - N N 4 0 1 2 A - 04 21703 F C C A A H - B D 0 Y - 99 0 0 1 0 0 0 0 0 0 - -20-42399208277 2020 20210204 4312 20201022 2 7190 4 5 5 4312 0 0 0 0 002 EAST BAYSEMBARCA 365 N N A - N Y 2 0 1 1 A - 03 22350 N - I A A H - C B 0 Y Y C 02 1 0 0 0 0 0 0 0 1 - -20-41579208693 2021 20210315 4312 20210104 1312 7113 1 5 5 4312 0 0 0 0 EAST BAYSEMBARCA 1056 N N C - N N 0 0 0 1 A - 03 22350 M E I A B H - A A 0 Y A 07 0 0 0 0 0 0 0 0 0 - -21-00389235260 2021 20210417 4312 20210331 640 8142 3 5 5 4312 0 0 0 0 002 EMBARCAEAST BAYS 0 Y A - N N 0 0 0 1 A - 08 22107 M E I A A H - B A 0 Y - 0 0 0 0 0 0 0 0 0 - -21-09249242522 2021 20210421 4312 20210301 822 7113 1 5 5 4312 0 0 0 0 002 BAYSHORE EMBARCA 100 N N A - N N 0 0 0 2 D - 00 N B C A A H - A A 0 Y - - 0 0 0 0 0 0 0 0 0 - -21-06019266784 2021 20210608 4312 20210525 1034 8142 2 5 5 4312 0 0 0 0 002 FABER PL EMBARCA 380 S N A - N N 3 0 1 2 A - 09 21801 A N E I A A H - A D 0 Y Y A 01 0 1 0 0 0 0 1 0 0 - -21-15379274970 2021 20210702 4312 20210618 1243 02308 4312 5 5 5 4312 0 0 0 0 002 EMBARCAEAST BAYS 77 W N A - N N 0 0 0 2 D - 00 N B C A A H - A A 0 Y - - 0 0 0 0 0 0 0 0 0 - -21-18169323339 2021 20211016 4312 20210916 1215 8069 4 5 5 4312 0 0 0 0 002 EMBARCAEAST BAYS 150 W N A - N N 0 0 0 2 A - 08 22107 M B C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -37.44948 122.1204 21-29719353574 2021 20211106 4312 20211028 1145 7816 PALO 4 5 5 4312 0 0 0 0 002 EMBARCAEAST BAYS 0 W N A - N N 3 0 1 3 A - 03 22350 F C C A A H - A D 0 Y - 0 1 0 0 0 0 0 0 0 - -21-35159380356 2021 20220118 4312 20211222 941 807894 80100 3 5 5 4312 0 0 0 0 PA2 EAST BAYSEMBARCA 123 N C - N N 0 0 0 2 A - 08 22107 N A D A B H - A D 0 Y D 22 0 0 0 0 0 0 0 0 0 - -37.44974 122.1197 21-042179389043 2022 20220128 4312 20220108 305 808794 80100 6 5 5 4312 0 0 0 0 PA2 EMBARCABAYSHORE 730 W N A - N N 0 0 0 2 A - 09 21804 A M B C A A H - C D 0 Y A 08 0 0 0 0 0 0 0 0 0 - -22-000769450918 2022 20220712 4312 20220513 819 808914 80100 5 5 5 4312 0 0 0 0 PA2 FABER PL EMBARCA 1056 S N A - N N 3 0 1 2 D - 00 N B - A A H - A D 0 Y Y - - 0 1 0 0 0 0 1 0 0 - -37.44973 122.1153 22-0149082376632 2024 20240429 4312 20240410 1354 808993 87200 3 5 5 4312 0 0 0 0 PA2 COWPER SEMBARCA 0 Y A - N N 4 0 1 2 A - 09 21802 A N D C A A D - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -24-0132382430557 2024 20240704 4312 20240701 258 809071 1 5 5 4312 0 0 0 0 PA2 MIDDLEFIE EMBARCA 0 Y A - N N 3 0 2 2 A - 12 21453 A N D C A A H - C A 0 Y - - 0 1 1 0 0 0 0 0 0 - -24-0239084410258 2024 20240927 4312 20240910 1600 807494 2 5 5 4312 0 0 0 0 PA2 EMBARCAMIDDLEFIE 0 Y A - N N 3 0 1 2 A - 00 21650 6 N B G A A H - A A 0 Y Y L 04 0 1 0 0 0 0 1 0 0 - -24-33589018272 2020 20200117 4312 20200107 2500 5623 4312 2 5 5 4312 0 0 0 0 EMBARCAWEBSTER 0 Y A - N Y 0 0 0 2 A - 03 22350 N D C A A H - C A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-01519018305 2020 20200121 4312 20200109 931 8068 4 5 5 4312 0 0 0 0 002 EMBARCACOWPER S 0 Y B - N Y 4 0 1 2 A - - N D C A B H - A A 0 Y - - 0 0 1 0 0 0 0 0 0 - -20-01829025508 2020 20200317 4312 20200116 1700 5623 PAPD 4 5 5 4312 0 0 0 0 EMBARCAMIDDLEFIE 49 W N C - N N 0 0 0 2 A - 03 22350 N C C A B H - B A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -2003299025520 2020 20200317 4312 20200115 702 8137 3 5 5 4312 0 0 0 0 002 ALMA ST EMBARCA 0 E N A - N N 0 0 0 1 D - 00 M E I A - H - D D 0 Y - - 0 0 0 0 0 0 0 0 0 - -20-02919035464 2020 20200826 4312 20200731 434 8442 5 5 5 4312 0 0 0 0 002 EMBARCABRYANT ST 0 Y A - N N 0 0 0 2 A - 08 22100 A N B A A - H - C A 0 Y J 48 0 0 0 0 0 0 0 0 0 - -20-29049131887 2020 20201006 4312 20200724 957 02308 4312 5 5 5 4312 0 0 0 0 002 EMBARCACOWPER S 0 Y A - N Y 3 0 2 2 A - 09 21802 A N D C A A H - A D 0 Y A 01 0 1 1 0 0 0 0 0 0 - -20-27919139767 2020 20201109 4312 20200806 1129 04807 4 5 5 4312 0 0 0 0 002 EMBARCACOWPER S 0 Y A - N Y 0 0 0 2 A - 09 21802 A N D C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-29949156175 2020 20201119 4312 20200919 1400 7200 4312 6 5 5 4312 0 0 0 0 002 EMBARCAMIDDLEFIE 30 E N A - N N 3 0 1 2 A - 03 22350 F C C A A H - A A 0 Y A 07 0 1 0 0 0 0 0 0 0 - -20-37009163900 2020 20201002 4312 20200914 2022 8733 1 5 5 4312 0 0 0 0 002 EMBARCABRYANT ST 0 Y A - N 3 0 3 2 A - 08 22101 D N D C A A D - C A 0 Y A 07 0 3 0 0 0 0 0 0 0 - -20-36219237614 2021 20210413 4312 20210228 110 7754 4312 7 5 5 4312 0 0 0 0 002 EMBARCAHIGH ST 174 E N A - N N 3 0 2 2 A - 05 21651 A N A C A A H - D D 0 Y Y Y A 01 0 2 0 0 0 0 0 0 1 - -21-05939237684 2021 20210407 4312 20210228 1536 8734 7 5 5 4312 0 0 0 0 MIDDLEFIE EMBARCA 327 N N A - N N 0 0 0 1 D - 00 M E I A A H - A D 0 Y - - 0 0 0 0 0 0 0 0 0 - -21-05969247542 2021 20210423 4312 20210406 942 8142 PALO 2 5 5 4312 0 0 0 0 002 EMBARCAEMERSON 0 Y A - N N 4 0 2 2 A - 03 22350 M C C A A H - A A 0 Y A 01 0 0 2 0 0 0 0 0 0 - -21-09869255191 2021 20210510 4312 20210322 1736 8130 1 5 5 4312 0 0 0 0 HIGH ST EMBARCA 0 Y A - N N 3 0 1 2 A - 05 21650 1 N D G A A H - A D 0 Y Y L 04 0 1 0 0 0 0 1 0 0 - -21-08319275530 2021 20210722 4312 20210630 850 7815 PALO 3 5 5 4312 0 0 0 0 002 EMBARCAMIDDLEFIE 24 W N A - N N 0 0 0 2 D - 00 N B C A A H - A A 0 Y Y - - 0 0 0 0 0 0 0 0 0 - -21-19759284634 2021 20210723 4312 20210618 617 6911 5 5 5 4312 0 0 0 0 EMBARCAKINGSLEY 0 Y A - N Y 4 0 1 1 A - 08 22107 N A I A A H - A A 0 Y Y F 27 0 0 1 0 0 0 0 0 0 - -21-18139290395 2021 20210908 4312 20210720 926 04807 2 5 5 4312 0 0 0 0 002 ALMA ST EMBARCA 9 N N A - N N 0 0 0 1 A - 08 22107 N E I A A H - A D 0 Y Y F 26 0 0 0 0 0 0 0 0 0 - -21-22449313079 2021 20211004 4312 20210817 1940 8536 PALOA 2 5 5 4312 0 0 0 0 002 EMBARCACOWPER S 0 Y A - N Y 3 0 2 2 A - 09 21802 A N D C A A H - A A 0 Y A 01 0 1 1 0 0 0 0 0 0 - -21-26039327404 2021 20211021 4312 20210925 1616 8680 4312 6 5 5 4312 0 0 0 0 002 BRYANT ST EMBARCA 0 Y A - N N 0 0 0 1 A - 08 22107 N - I A A H - A A 0 Y E 22 0 0 0 0 0 0 0 0 0 - -21-30919380600 2022 20220127 4312 20220103 1218 803422 87200 1 5 5 4312 0 0 0 0 PA2 EMBARCAWAVERLEY 0 - G - N N 3 0 1 2 A - 12 21453 A N A A A - - - E A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -37.4403 122.1496 22-000149450919 2022 20220617 4312 20220516 1520 804456 83200 1 5 5 4312 0 0 0 0 PA2 MIDDLEFIE EMBARCA 450 N N A - N Y 4 0 2 2 A - 05 21460 A N A C A A H - A D 0 Y A 01 0 0 2 0 0 0 0 0 0 - -37.44272 122.1446 22-015359451249 2022 20220617 4312 20220501 1451 808130 87200 7 5 5 4312 0 0 0 0 PA2 EMBARCACOWPER S 0 Y A - N N 0 0 0 2 A - 09 21801 A N D D A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -22-013349493524 2022 20220915 4312 20220810 750 805859 87200 3 5 5 4312 0 0 0 0 PA2 BRYANT ST EMBARCA 85 S N A - N N 4 0 1 2 A - 17 22517 N B G A A H - A D 0 Y Y A 01 0 0 1 0 0 0 1 0 0 - -37.43968 122.1517 22-0261182430557 2024 20240704 4312 20240701 258 809071 1 5 5 4312 0 0 0 0 PA2 MIDDLEFIE EMBARCA 0 Y A - N N 3 0 2 2 A - 12 21453 A N D C A A H - C A 0 Y - - 0 1 1 0 0 0 0 0 0 - -24-0239082444242 2024 20240722 4312 20240713 128 809217 6 5 5 4312 0 0 0 0 PA2 1000 BLOCGREER RO 225 E N A - N Y 3 0 2 2 A - 01 23152 A N B C A A H - C D 0 Y Y A 01 0 1 1 0 0 0 0 0 0 - -24-0256784410258 2024 20240927 4312 20240910 1600 807494 2 5 5 4312 0 0 0 0 PA2 EMBARCAMIDDLEFIE 0 Y A - N N 3 0 1 2 A - 00 21650 6 N B G A A H - A A 0 Y Y L 04 0 1 0 0 0 0 1 0 0 - -24-33589025508 2020 20200317 4312 20200116 1700 5623 PAPD 4 5 5 4312 0 0 0 0 EMBARCAMIDDLEFIE 49 W N C - N N 0 0 0 2 A - 03 22350 N C C A B H - B A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -2003299026948 2020 20200529 4312 20200202 1057 8137 7 5 5 4312 0 0 0 0 002 NORTH CAEMBARCA 6 S N A - N N 3 0 1 2 A - 12 22450 A N D B B A H - A D 0 Y Y A 01 0 1 0 0 1 0 0 0 0 - -20-06029037378 2020 20200228 4312 20200117 825 4598 5 5 5 4312 0 0 0 0 EMBARCAGREER RD 0 Y B - N N 0 0 0 2 A - 12 21453 A N D C A B H - A A 0 Y - 0 0 0 0 0 0 0 0 0 - -20-03359043551 2020 20200515 4312 20200211 916 8142 2 5 5 4312 0 0 0 0 002 EMBARCAWALNUT D 0 Y A - N Y 0 0 0 2 A - 08 22107 N A C A A H - A D 0 Y - 0 0 0 0 0 0 0 0 0 - -20-07619043578 2020 20200528 4312 20200209 1725 6986 7 5 5 4312 0 0 0 0 EMBARCAGREER RD 0 Y A - N Y 4 0 2 2 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 2 0 0 0 0 0 0 - -20-07369061757 2020 20200623 4312 20200306 755 1514 CO 5 5 5 4312 0 0 0 0 002 EMBARDASAINT FRA 40 W N A - N N 4 0 1 3 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-11889082175 2020 20200713 4312 20200319 155 7815 4312 4 5 5 4312 0 0 0 0 002 EMBARCAGREER RD 0 Y A - N Y 3 0 3 2 A - 09 21801 A N A C A B H - C A 0 Y Y A 01 0 2 1 0 0 0 0 0 0 - -20-13849094806 2020 20200814 4312 20200321 1159 4741 6 5 5 4312 0 0 0 0 WEST BAYEMBARCA 200 E N B - N N 0 0 0 1 A - 05 21651 B M E I A A H - A D 0 Y Y - 0 0 0 0 0 0 0 0 0 - -20-14009096819 2020 20200724 4312 20200116 755 8137 4 5 5 4312 0 0 0 0 002 GREER RD EMBARDA 6 N A - N N 0 0 0 2 A - 08 22107 N B C A B H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-03169123750 2020 20200916 4312 20200625 432 8063 PALOA 4 5 5 4312 0 0 0 0 002 EMBARCAWILDWOO 30 E N A - N Y 2 0 1 1 A - 01 23152 A N F I A A H - C D 0 Y Y A 01 1 0 0 0 0 0 0 0 0 - -20-23919139846 2020 20201016 4312 20200812 1530 7189 3 5 5 4312 0 0 0 0 EMBARCAGREER RD 0 Y A - N N 3 0 1 2 A - 09 21801 A N D C A A H - A A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -20-31229141118 2020 20200930 4312 20200825 2300 7754 4312 2 5 5 4312 0 0 0 0 002 EMBARCAHEATHER L 0 Y - - N N 3 0 1 2 D - 00 F - G A - - - - A 0 Y Y - - 0 1 0 0 0 0 1 0 0 - - 20 - 33059156175 2020 20201119 4312 20200919 1400 7200 4312 6 5 5 4312 0 0 0 0 002 EMBARCAMIDDLEFIE 30 E N A - N N 3 0 1 2 A - 03 22350 F C C A A H - A A 0 Y A 07 0 1 0 0 0 0 0 0 0 - -20-37009160408 2020 20210107 4312 20201012 1350 7467 1 5 5 4312 0 0 0 0 002 EMBARCAGUINDA S 10 W N A - N N 0 0 0 4 A - 03 22350 N C C A A H - A D 0 Y A 08 0 0 0 0 0 0 0 0 0 - -20-40149182474 2020 20210208 4312 20201108 2126 7754 4312 7 5 5 4312 0 0 0 0 002 EMBARCAMORTON S 64 W N A - N Y 3 0 1 2 A - 01 23152 A N C E A A H - D D 0 Y Y A 01 0 1 0 0 0 0 0 0 0 - -20-44069193474 2020 20210126 4312 20201127 2053 8793 5 5 5 4312 0 0 0 0 EMBARCASAINT FRA 100 W N A - N N 0 0 0 2 A - 08 22107 N B C A A H - C D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-47009193478 2020 20210126 4312 20201125 1352 8702 4312 3 5 5 4312 0 0 0 0 002 EMBAR CAWEST BAY 75 W N A - N N 0 0 0 2 A - 08 22107 N B C A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-46799223077 2020 20210219 4312 20201219 1820 8702 4312 6 5 5 4312 0 0 0 0 002 EMBARCAWALNUT D 10 E N A - N Y 0 0 0 3 A - 08 22107 N B C A A H - C D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-50519234213 2021 20210325 4312 20210205 1638 8702 4312 5 5 5 4312 0 0 0 0 002 EMBARCAST FRANCI 275 E N A - N Y 0 0 0 2 A - 08 22107 N B C A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-03739237684 2021 20210407 4312 20210228 1536 8734 7 5 5 4312 0 0 0 0 MIDDLEFIE EMBARCA 327 N N A - N N 0 0 0 1 D - 00 M E I A A H - A D 0 Y - - 0 0 0 0 0 0 0 0 0 - -21-05969239390 2021 20210422 4312 20210330 123 8536 2 5 5 4312 0 0 0 0 EMBARCAST FRANCI 30 W N A - N Y 4 0 1 1 A - 03 22350 N A I A A H - C A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -21-09139248477 2021 20220525 4312 20210313 1810 8130 6 5 5 4312 0 0 0 0 002 NEWELL REMBARCA 260 N N A - N Y 0 0 0 1 A - 01 23152 A N E I A A H - C D 0 Y Y A 01 0 0 0 0 0 0 0 0 0 - -21-07259265918 2021 20210602 4312 20210512 817 8794 4312 3 5 5 4312 0 0 0 0 002 EMBARCAGREER RD 200 W N A - N Y 0 0 0 2 A - 06 21750 A N B E A A H - A D 0 Y I 11 0 0 0 0 0 0 0 0 0 - -21-13909265996 2021 20210527 4312 20210517 259 7754 4312 1 5 5 4312 0 0 0 0 002 EMBARCAGREER RD 386 W N A - N Y 3 0 1 2 A - 08 22107 N C E A A H - C D 0 Y A 01 0 1 0 0 0 0 0 0 0 - -21-14429275530 2021 20210722 4312 20210630 850 7815 PALO 3 5 5 4312 0 0 0 0 002 EMBARCAMIDDLEFIE 24 W N A - N N 0 0 0 2 D - 00 N B C A A H - A A 0 Y Y - - 0 0 0 0 0 0 0 0 0 - -21-19759279020 2021 20210709 4312 20210605 1204 8680 6 5 5 4312 0 0 0 0 002 EMBARCAGREER RD 0 Y A - N N 4 0 1 2 A - 09 21801 N D G A A - - A A 0 Y Y A 01 0 0 1 0 0 0 1 0 0 - -21-16599279173 2021 20210712 4312 20210614 937 03422 1 5 5 4312 0 0 0 0 002 EMBARCASAINT FRA 360 E N A - N N 0 0 0 2 A - 07 21658 A N B C A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-17679284097 2021 20210720 4312 20210628 1625 4598 1 5 5 4312 0 0 0 0 EMBARCAGUINDA S 25 W N A - N Y 0 0 0 2 A - 21 22106 N B C A A H - A D 0 Y - 0 0 0 0 0 0 0 0 0 - -21-19499313143 2021 20210921 4312 20210815 1543 5661 SANTA 7 5 5 4312 0 0 0 0 SANTAC EMBARCAFULTON ST 0 Y A - N N 0 0 0 2 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-25759318303 2021 20211104 4312 20210901 1903 8536 4312 3 5 5 4312 0 0 0 0 002 EMBARCAGREER RD 22 W N A - N Y 3 0 1 2 A - 03 22350 A N C C A A H - A A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -21-27909343017 2021 20211019 4312 20210925 2339 8734 4312 6 5 5 4312 0 0 0 0 EMBARCAGREER RD 0 Y A - N N 2 0 1 2 A - 17 21451 A N D C A A H - C A 0 Y Y A 01 1 0 0 0 0 0 0 0 1 - -21-30949354750 2021 20211101 4312 20211019 1410 5900 2 5 5 4312 0 0 0 0 EMBARCAGREER RD 0 Y A - N Y 3 0 2 2 A - 09 21801 N D C A A H - A A 0 Y A 07 0 1 1 0 0 0 0 0 0 - -21-34119370771 2021 20220111 4312 20211205 1220 808069 87100 7 5 5 4312 0 0 0 0 PA2 EMBARCASAINT FRA 0 Y B - N N 3 0 2 2 A - 12 21453 A N D C A A H - A A 0 Y A 01 0 1 1 0 0 0 0 0 0 - -37.44687 122.1266 21-039919371899 2021 20220316 4312 20211230 1055 56841 87100 4 5 5 4312 0 0 0 0 PA2 NEWELL R EMBARCA 0 Y A - N Y 3 0 5 2 C - 18 N D C A A H - C A 0 Y - - 0 5 0 0 0 0 0 0 0 - -37.44311 122.1397 21-074009389043 2022 20220128 4312 20220108 305 808794 80100 6 5 5 4312 0 0 0 0 PA2 EMBARCABAYSHORE 730 W N A - N N 0 0 0 2 A - 09 21804 A M B C A A H - C D 0 Y A 08 0 0 0 0 0 0 0 0 0 - -22-000769450919 2022 20220617 4312 20220516 1520 804456 83200 1 5 5 4312 0 0 0 0 PA2 MIDDLEFIE EMBARCA 450 N N A - N Y 4 0 2 2 A - 05 21460 A N A C A A H - A D 0 Y A 01 0 0 2 0 0 0 0 0 0 - -37.44272 122.1446 22-015359482087 2022 20220812 4312 20220720 1349 808068 83200 3 5 5 4312 0 0 0 0 PA2 EMBARCANEWELL R 266 W N A - N N 4 0 1 2 A - 03 22350 N C C A A H - A D 0 Y A 01 0 0 1 0 0 0 0 0 0 - -22-023589484397 2022 20220817 4312 20220717 2100 808069 80200 7 5 5 4312 0 0 0 0 PA2 EMBARCASAINT FRA 500 E N A - N N 0 0 0 2 A - 08 22107 N B C A A H - C D 0 Y A 07 0 0 0 0 0 0 0 0 0 - -22-023169484398 2022 20220817 4312 20220721 1232 808914 83200 4 5 5 4312 0 0 0 0 PA2 NEWELL REMBARCA 300 N N A - N N 0 0 0 1 A - 03 22350 N E I A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -37.44408 122.1392 22-023679493525 2022 20220919 4312 20220819 1857 808906 80200 5 5 5 4312 0 0 0 0 PA2 EMBARCAWILDWOO 90 W N A - N N 3 0 2 1 A - 03 22350 A N H - A A H - A D 0 Y Y C 02 0 2 0 0 0 0 0 0 2 - -22-027269493529 2022 20220915 4312 20220816 1745 808069 87100 2 5 5 4312 0 0 0 0 PA2 GREER RD EMBARCA 0 Y A - N N 4 0 3 3 A - 09 21801 A N D C A A H - A A 0 Y A 01 0 0 3 0 0 0 0 0 0 - -22-026839786040 2024 20250318 4312 20240219 2106 805241 87100 1 5 5 4312 0 0 0 0 PA2 EMBARCANEWELL R 21 W N C - N Y 1 1 0 3 A - 05 21202 A F C G A C H - C A 0 Y Y L 04 0 0 0 0 0 1 0 0 0 - -37.44311 122.1397 24-0065481479891 2021 20210524 4307 20210414 1342 S097 LG305 3 5 4 4307 0 0 0 0 003 UNIVERSITW CURB LI 5 W - A - N N 0 0 0 1 A - 16 24002 A N H C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -37.22655 121.9803 21-063883097291 2024 20240801 4312 20240726 1202 808993 5 5 5 4312 0 0 0 0 PA2 UNIVERSITCENTER D 181 E N A - N N 0 0 0 2 A - 03 22350 N C C A A D - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -24-0275584472280 2024 20241118 4312 20241113 1800 809422 3 5 5 4312 0 0 0 0 PA2 UNIVERSITMIDDLEFIE 0 Y A - N Y 3 0 2 2 A - 09 21801 A N A C A A H - C A 0 Y A 01 0 2 0 0 0 0 0 0 0 - -24-42319018294 2020 20200121 4312 20200104 850 8239 PALOA 6 5 5 4312 0 0 0 0 002 UNIVERSITCRESCENT 130 W N A - N Y 4 0 1 2 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-00779026960 2020 20200529 4312 20200205 650 8142 3 5 5 4312 0 0 0 0 002 MIDDLEFIE UNIVERSIT 130 N N A - N N 3 0 1 2 A - 03 22350 N C C A A H - B A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -20-06529037277 2020 20200305 4312 20200127 1840 04456 1 5 5 4312 0 0 0 0 UNIVERSITHALE ST 320 E N A - N Y 4 0 1 3 A - 03 22350 N C C A A H - C A 0 Y - 0 0 1 0 0 0 0 0 0 - -20-05069067619 2020 20200713 4312 20200310 822 8068 2 5 5 4312 0 0 0 0 002 GUINDA SUNIVERSIT 126 N N A - N N 0 0 0 2 A - 08 22107 N B E A A H - A A 0 Y A 08 0 0 0 0 0 0 0 0 0 - -20-12669095757 2020 20200730 4312 20200417 744 8239 PALOA 5 5 5 4312 0 0 0 0 002 UNIVERSITMIDDLEFIE 0 Y A - N Y 4 0 1 3 A - 12 21453 A N D C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-15819106343 2020 20200821 4314 20200529 1531 5603 5 5 6 4314 0 0 0 0 LINCOLN AUNIVERSIT 50 S N A - N Y 0 0 0 2 A - 03 22350 N C E A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-20659106344 2020 20200814 4312 20200528 1617 8680 4 5 5 4312 0 0 0 0 002 UNIVERSITLINCOLN S 50 E N A - N N 0 0 0 2 A - 03 22350 M C C A A H - A A 0 Y Y A 07 0 0 0 0 0 0 0 0 0 - -20-20529125188 2020 20200916 4312 20200710 755 8142 5 5 5 4312 0 0 0 0 002 UNIVERSITCENTER D 60 E N A - N Y 4 0 1 2 A - 03 22350 N C C A A H - A D 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-25829141632 2020 20201013 4312 20200822 1558 8680 6 5 5 4312 0 0 0 0 002 UNIVERSITMIDDLE FI 0 Y A - N Y 3 0 2 3 A - 12 21453 A N D C A A H - A A 0 Y D 23 0 1 1 0 0 0 0 0 0 - - 20 32749182475 2020 20210203 4312 20201103 1148 8755 2 5 5 4312 0 0 0 0 UNIVERSITUNIVERSIT 223 E N A - N N 3 0 1 2 A - 03 22350 N C C A A H - - D 0 Y A 01 0 1 0 0 0 0 0 0 0 - -20-43309195044 2020 20210115 4312 20201130 1252 8794 1 5 5 4312 0 0 0 0 UNIVERSITMIDDLEFIE 0 Y A - N N 3 0 1 2 A - 09 21801 A N D G A A H - A A 0 Y Y A 01 0 1 0 0 0 0 1 0 0 - -20-48089208223 2020 20210302 4312 20201229 1929 8755 2 5 5 4312 0 0 0 0 UNIVERSITCENTER D 154 W N A - N N 0 0 0 1 C - 18 M E H A A H - D D 0 Y - - 0 0 0 0 0 0 0 0 0 - -20-51929222727 2021 20210324 4312 20210115 1217 8680 4312 5 5 5 4312 0 0 0 0 002 UNIVERSITLINCOLN A 0 Y A - N Y 4 0 4 2 A - 09 21801 A N D C A A H - A A 0 Y A 01 0 0 4 0 0 0 0 0 0 - -21-01509234171 2021 20210402 4312 20210208 1853 8472 1 5 5 4312 0 0 0 0 002 UNIVERSITLINCOLN A 48 E N A - N Y 3 0 2 1 C - 18 N - I A A H - C A 0 Y - - 0 1 1 0 0 0 0 0 0 - -21-03999235280 2021 20210426 4312 20210327 1641 8750 6 5 5 4312 0 0 0 0 002 UNIVERSITCHAUCER 0 Y A - N Y 0 0 0 2 A - 08 22107 N B C A A H - A A 0 Y A 08 0 0 0 0 0 0 0 0 0 - -21-08759241672 2021 20210417 4312 20210318 1134 8680 4 5 5 4312 0 0 0 0 002 UNIVERSITGUINDA S 0 Y C - N N 3 0 1 2 A - 09 21801 A N D C A B H - A A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -21-07779267232 2021 20210608 4312 20210524 1641 8130 PALOA 1 5 5 4312 0 0 0 0 002 UNIVERSITW CRESCE 100 S N A - N Y 0 0 0 3 A - 03 22350 N C C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -21-15309267274 2021 20210702 4312 20210524 1559 8130 1 5 5 4312 0 0 0 0 UNIVERSITW CRESCE 75 S N A - N N 0 0 0 2 A - 03 22350 N C C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -9275797 2021 20210628 4312 20210615 1652 6647 PALO 2 5 5 4312 0 0 0 0 002 UNIVERSITMARLOWE 20 E N A - N Y 0 0 0 2 A - 08 22107 N D I A A H - A A 0 Y A 07 0 0 0 0 0 0 0 0 0 - -21-17869279022 2021 20210707 4312 20210609 1315 8239 4312 3 5 5 4312 0 0 0 0 002 UNIVERSITPALM ST 55 E N A - N Y 4 0 1 1 C - 18 N A I A A H - A A 0 Y - - 0 0 1 0 0 0 0 0 0 - -21-16989312838 2021 20210918 4312 20210802 1932 8792 1 5 5 4312 0 0 0 0 UNIVERSITCHAUCER 0 Y A - N Y 0 0 0 2 D - 00 N D C A A H - A A 0 Y - - 0 0 0 0 0 0 0 0 0 - -21-24239375025 2021 20211214 4312 20211129 1304 8733 SANTA 1 5 5 4312 0 0 0 0 002 UNIVERSITUNIVERSIT 0 - A - N Y 3 0 2 2 A - 09 21804 A N D C A A H - A D 0 Y A 08 0 2 0 0 0 0 0 0 0 - -21-39149378271 2021 20220121 4312 20211224 1328 808792 8310 5 5 5 4312 0 0 0 0 PA2 UNIVERSITCHAUCER 0 Y A - N N 3 0 1 2 A - 10 21950 A N A B B A H - A A 0 Y Y A 01 0 1 0 0 1 0 0 0 0 - -37.45555 122.152 21-042539378274 2021 20220121 4312 20211221 1223 802308 8310 2 5 5 4312 0 0 0 0 PA2 UNIVERSITPALM AV 65 W N B - N Y 3 0 1 3 A - 03 22350 N C C A A H - A A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -37.45585 121.8521 21-042079417704 2022 20220516 4312 20220401 1640 806195 5 5 5 4312 0 0 0 0 PA2 UNIVERSITCENTER D 0 Y A - 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N Y 3 0 1 2 A - 09 21801 A N D C A A H - C A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -20-09509061753 2020 20200623 4312 20200306 1021 6200 5 5 5 4312 0 0 0 0 003 MIDDLEFIE SAN ANTO 63 S N A - N N 4 0 1 2 A - 03 22350 N C C A A H - A A 0 Y A 07 0 0 1 0 0 0 0 0 0 - -20-12039062119 2020 20200323 4312 20200224 1325 5623 4312 1 5 5 4312 0 0 0 0 003 SAN ANTOMIDDLEFIE 1319 E N A - N N 4 0 1 2 A - 08 22107 F B C A A H - A D 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-10159118407 2020 20200902 4312 20200619 1138 5726 5 5 5 4312 0 0 0 0 003 CHARLESTMIDDLEFIE 0 Y A - N N 4 0 2 3 A - 08 22107 N G B B A H - A A 0 Y Y A 01 0 0 2 0 2 0 0 0 0 - -20-23049127334 2020 20200930 4312 20200716 1239 04807 4 5 5 4312 0 0 0 0 003 E CHARLESMIDDLEFIE 21 E N A - N Y 4 0 1 2 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-26799147637 2020 20201021 4312 20200820 1130 7467 4 5 5 4312 0 0 0 0 003 SAN ANTOMIDDLEFIE 30 W N A - N N 0 0 0 2 A - 08 22107 N B C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-32479152834 2020 20201130 4312 20200908 1222 7815 2 5 5 4312 0 0 0 0 SAN ANTOMIDDLEFIE 7 W N B - N N 0 0 0 2 A - 08 22107 N B E A A D - A A 0 Y Y F 26 0 0 0 0 0 0 0 0 0 - -20-35049187114 2020 20210129 4312 20201027 942 03422 2 5 5 4312 0 0 0 0 003 SAN ANTOMIDDLEFIE 12 E N A - N N 0 0 0 2 A - 08 22107 N B C A A H - A A 0 Y D 22 0 0 0 0 0 0 0 0 0 - -20-42329226534 2021 20210330 4312 20210224 1056 8680 3 5 5 4312 0 0 0 0 003 SAN ANTOMIDDLEFIE 0 Y A - N Y 4 0 2 3 A - 09 21453 C N D C A A H - A A 0 Y A 01 0 0 2 0 0 0 0 0 0 - -21-05589239389 2021 20210422 4312 20210325 1445 7815 4 5 5 4312 0 0 0 0 SAN ANTOMIDDLEFIE 20 W N A - N Y 2 0 1 2 A - 12 21453 A N D G A A H - A A 0 Y Y L 04 1 0 0 0 0 0 1 0 0 - -21-08619255698 2021 20210506 4311 20210323 536 L3953 2 5 5 4311 0 0 0 0 003 OLD MIDDMIDDLEFIE 0 Y A - N Y 0 0 0 2 A - 12 21453 A N B C A A H - B A 0 Y A 07 0 0 0 0 0 0 0 0 0 - -21001503-9268675 2021 20210629 4311 20210407 750 N6205 3 5 5 4311 0 0 0 0 003 W MIDDLEOLD MIDD 44 W - A - N Y 3 0 2 2 A - 12 21453 A N D C A A H - A A 0 Y A 01 0 1 1 0 0 0 0 0 0 - -21001759 -9312693 2021 20210927 4312 20210803 1602 8320 2 5 5 4312 0 0 0 0 003 SAN ANTOMIDDLEFIE 19 W N A - 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N N 3 0 3 2 A - 08 22101 D N A C A A H - A A 0 Y A 01 0 3 0 0 0 0 0 0 0 - -24-031619719514 2024 20240802 4311 20240603 300 57100 5416 1 5 5 4311 0 0 0 0 MV3 W MIDDLEOLD MIDD 0 Y A - N Y 0 0 0 1 A - 05 21650 N E I A A H - C A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -24-030669719677 2024 20240909 4311 20240707 1506 56842 5416 7 5 5 4311 0 0 0 0 MV3 OLD MIDDW MIDDLE 0 Y A - N N 3 0 2 3 A - 12 21453 A N A C A A H - A A 0 Y A 08 0 2 0 0 0 0 0 0 0 - -24-037249762989 2024 20250127 4311 20241227 1237 53580 5416 5 5 5 4311 0 0 0 0 MV3 OLD MIDDMIDDLEFIE 60 E N A - N N 0 0 0 1 A - 05 21650 N E I A A H - A A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -24074059775878 2024 20250128 4311 20241226 1713 57073 5416 4 5 5 4311 0 0 0 0 MV3 W MIDDLESAN ANTO 575 E N C - N Y 3 0 2 2 A - 09 21804 B N D C A B H - C D 0 Y A 01 0 2 0 0 0 0 0 0 0 - -24-0739282351427 2024 20240401 4312 20240315 1136 804807 89100 5 5 5 4312 0 0 0 0 PA3 MIDDLEFIE LOMA VER 0 Y A - N Y 4 0 1 2 A - 12 21453 A N D C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -24-0101882418953 2024 20240620 4312 20240617 1905 809217 1 5 5 4312 0 0 0 0 PA3 600 BLOCK MIDDLEFIE 12 W N A - N N 4 0 1 2 A - 00 22350 3 N C C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -24-021958947622 2020 20200930 4312 20200709 1300 06235 4312 4 5 5 4312 0 0 0 0 003 COLORADMIDDLEFIE 0 Y A - N N 3 0 1 2 A - 17 22517 N D G A A H - A D 0 Y Y D 22 0 1 0 0 0 0 1 0 0 - -20-25849018314 2020 20200121 4312 20200106 1230 8002 PALOA 1 5 5 4312 0 0 0 0 003 MIDDLEFIE MIDDLEFIE 20 W N A - N N 3 0 1 2 - - - N G B F A H - A D 0 Y Y - - 0 1 0 0 1 0 0 0 0 - -20-01119025117 2020 20200311 4312 20200111 1147 6200 6 5 5 4312 0 0 0 0 003 MIDDLEFIE LAYNE CT 84 N N A - N Y 0 0 0 3 A - 08 22107 N C E A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-02259026956 2020 20200529 4312 20200203 1456 03422 1 5 5 4312 0 0 0 0 003 MIDDLEFIE SAINT CLAI 0 Y A - N Y 3 0 1 2 A - 08 22107 N D C A A H - A A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -20-06219037403 2020 20200228 4312 20200122 1649 6986 3 5 5 4312 0 0 0 0 MIDDLEFIE MAYVIEW 127 S N A - N Y 0 0 0 3 A - 08 22107 N B C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-4129038985 2020 20200303 4312 20200127 1800 6911 1 5 5 4312 0 0 0 0 MIDDLEFIE WELLSBUR 5 N N A - N N 3 0 1 2 A - 00 21538 A N D G A A H - C A 0 Y Y L 04 0 1 0 0 0 0 1 0 0 - -20-05039039023 2020 20200227 4312 20200124 1945 7754 4312 5 5 5 4312 0 0 0 0 002 OREGON EMIDDLEFIE 57 W N A - N N 0 0 0 2 A - 09 21453 B N B C A A H - C A 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-04669043570 2020 20200528 4312 20200208 1245 4598 6 5 5 4312 0 0 0 0 MIDDLEFIE EAST MEA 0 Y A - N N 3 0 1 2 A - 12 21453 A N D G A A H - A A 0 Y Y L 04 0 1 0 0 0 0 1 0 0 - -20-07259043582 2020 20200528 4312 20200210 1914 02308 4312 1 5 5 4312 0 0 0 0 003 MIDDLEFIE COLORAD 0 Y A - N N 3 0 1 2 A - 10 21950 A N G B B A H - C A 0 Y Y A 01 0 1 0 0 1 0 0 0 0 - -20-07539118300 2020 20200915 4312 20200625 1104 04807 4 5 5 4312 0 0 0 0 002 MIDDLEFIE OREGON E 8 S N A - N N 0 0 0 2 A - 03 22350 N C C A A H - A A 0 Y A 08 0 0 0 0 0 0 0 0 0 - -20-23949118407 2020 20200902 4312 20200619 1138 5726 5 5 5 4312 0 0 0 0 003 CHARLESTMIDDLEFIE 0 Y A - N N 4 0 2 3 A - 08 22107 N G B B A H - A A 0 Y Y A 01 0 0 2 0 2 0 0 0 0 - -20-23049125189 2020 20200916 4312 20200714 2143 8442 2 5 5 4312 0 0 0 0 003 MIDDLEFIE COLORAD 0 Y A - N Y 4 0 1 2 A - 08 22107 N A C A A H - C A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-26469127334 2020 20200930 4312 20200716 1239 04807 4 5 5 4312 0 0 0 0 003 E CHARLESMIDDLEFIE 21 E N A - N Y 4 0 1 2 A - 03 22350 N C C A A H - A A 0 Y A 01 0 0 1 0 0 0 0 0 0 - -20-26799140726 2020 20201014 4312 20200815 2125 8002 PALO 6 5 5 4312 0 0 0 0 003 MIDDLEFIE COLORAD 0 Y A - N Y 3 0 1 2 A - 09 21801 A N D C A A H - C A 0 Y A 01 0 1 0 0 0 0 0 0 0 - -20-31629140729 2020 20201014 4312 20200817 1217 02308 4312 1 5 5 4312 0 0 0 0 003 MIDDLEFIE COLORAD 0 Y B - N N 3 0 1 2 A - 10 21950 A N G B B A H - A A 0 Y Y A 07 0 1 0 0 1 0 0 0 0 - -20-3186 Item 4Attachment A - 2025Engineering and TrafficSurvey       Item 4: Staff Report Pg. 61  Packet Pg. 69 of 517  City of Palo Alto Raw Collision Data 91412234 2021 20210222 9330 20210210 805 022101 3 1 5 4312 1 4 S 2 901 MIDDLEFIE COLORAD 0 Y A - N Y 3 0 3 2 A - 12 21453 A N D C A A H - A A 0 Y Y F 25 0 3 0 0 0 0 0 0 0 - -37.43303 122.1287 9330-20219148552 2020 20201026 4312 20200831 1912 8068 1 5 5 4312 0 0 0 0 003 COLORADMIDDLEFIE 0 Y A - N N 4 0 1 2 A - 09 21801 A N D G A A H - A A 0 Y Y A 01 0 0 1 0 0 0 1 0 0 - -20-33919151738 2020 20201119 4312 20200903 1357 04807 4312 4 5 5 4312 0 0 0 0 003 MIDDLEFIE LOMA VER 100 N N A - N Y 0 0 0 2 A - 09 21801 A N D C A A H - A D 0 Y A 07 0 0 0 0 0 0 0 0 0 - -20-34379160464 2020 20210109 4312 20201008 730 7815 4 5 5 4312 0 0 0 0 MIDDLEFIE MIDDLEFIE 0 Y A - N N 3 0 1 2 A - 11 21954 A N G B E A H - A D 0 Y Y N 60 0 1 0 0 1 0 0 0 0 - -20-394991803528 2022 20220627 9330 20220615 1315 022774 3 1 5 4312 1 4 S 2 901 MIDDLEFIE LOMA VER 0 Y A - N N 0 0 0 1 A - 08 22107 N E I A A H - A D 0 Y H 17 0 0 0 0 0 0 0 0 0 - -37.4292 122.1224 9330-20229182692 2020 20210217 4312 20201110 213 8793 2 5 5 4312 0 0 0 0 MIDDLEFIE CHRISTINE 20 N N A - N Y 0 0 0 3 A - 05 21460 A N A E A A H - C D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -20-443491908859 2022 20221103 9330 20220718 1255 022785 1 1 5 4312 0 2 S 2 901 MIDDLEFIE OREGON E 20 S N A - N N 0 0 0 2 A - 08 22107 M B C A A H - A D 0 Y D 22 0 0 0 0 0 0 0 0 0 - -37.43557 122.1328 9330-20229209023 2020 20210224 4312 20201214 1325 6910 1 5 5 4312 0 0 0 0 OREGON EMIDDLEFIE 0 Y A - 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05 21460 A M D C A A H - A D 0 Y A 01 0 0 0 0 0 0 0 0 0 - -22-018749472713 2022 20220721 4312 20220523 1159 808914 88300 1 5 5 4312 0 0 0 0 PA3 MIDDLEFIE LOMA VER 2 S N A - N Y 3 0 2 1 A - 08 22100 A N A I A A H - A A 0 Y A 01 0 2 0 0 0 0 0 0 0 - -22-016329480104 2022 20220719 4312 20220623 805 801514 88200 4 5 5 4312 0 0 0 0 PA3 MIDDLEFIE COLORAD 0 Y A - N N 3 0 1 2 D - 00 N D G A A H - A A 0 Y Y - - 0 1 0 0 0 0 1 0 0 - -37.43297 122.1287 22-020009484303 2022 20220902 4312 20220712 1010 808914 88100 2 5 5 4312 0 0 0 0 PA3 MORENO MIDDLEFIE 0 Y A - N N 0 0 0 2 A - 03 22350 N C C A A H - A D 0 Y A 07 0 0 0 0 0 0 0 0 0 - -22-02229 Item 4Attachment A - 2025Engineering and TrafficSurvey       Item 4: Staff Report Pg. 62  Packet Pg. 70 of 517  NOT YET APPROVED Attachment B 1 Ordinance No. _____ Ordinance of the Council of the City of Palo Alto Amending Sections of Chapter 10.56 (“Special Speed Zones”) of Title 10 (Vehicles and Traffic) to Reflect the 2025 Traffic Survey The Council of the City of Palo Alto ORDAINS as follows: SECTION 1. Findings and Declarations. The City Council finds and declares as follows: A. In conjunction with this ordinance, the City Council approved the “Engineering & Traffic Survey”, dated September 2025, (Traffic Survey) for the City of Palo Alto. The Traffic Survey was conducted by TJKM under contract by the City. B. Based on the findings of the Traffic Survey, the City now desires to amend the Palo Alto Municipal Code (PAMC) through this ordinance to indicate the latest survey completion date for nine road segments. SECTION 2. Chapter 10.56.010 of the Palo Alto Municipal Code is hereby amended to read as follows (new text is underlined, deleted text is in strikethrough): 10.56.010 Twenty-five miles per hour prima facie speed limit justified. It is determined that the state twenty-five miles per hour prima facie speed limit for business or residence districts is justified, as required by state law, with respect to the following streets or portions of streets by engineering and traffic surveys conducted by the city and completed on the dates shown below: Road Segment Name Survey Completion Date Alma St from El Camino Real to University Ave September 2023 Amaranta Ave from Los Robles Ave to Maybell Ave November 2017 Arboretum Rd from Sand Hill Rd to Quarry Rd November 2017 Birch St from California Ave to Page Mill Exp April 2025November 2017 California Ave from El Camino Real to Hanover St November 2017 Charleston Rd from Fabian Way to South City Limit September 2023 Charleston Rd from Middlefield Rd to Fabian Way September 2023 Charleston Rd from El Camino Real to Alma St September 2023 Channing Ave from W Bayshore Rd to Newell Rd November 2017 Channing Ave from Newell Rd to Guinda Ave November 2017 Channing Ave from Guinda Ave to Alma St November 2017 Churchill Ave from Embarcadero Rd to Alma St November 2017 Item 4 Attachment B - Ordinance Amending PAMC Chapter 10.56 to Establish Speed Limits        Item 4: Staff Report Pg. 63  Packet Pg. 71 of 517  NOT YET APPROVED Attachment B 2 Churchill Ave from Alma St to El Camino Real November 2017 Colorado Ave from W Bayshore Rd to Middlefield Rd November 2017 E Meadow Dr from Louis Rd to Alma St November 2017 El Camino Way from Los Robles Ave to Maybell Ave September 2023 Embarcadero Rd from Embarcadero Rd to Highway 101 April 2025 Embarcadero Rd from Middlefield Rd to Alma St April 2025 Embarcadero Rd from El Camino Real to Alma St October 2023 Guinda Ave from Lytton Ave to Channing Ave November 2017 Hamilton Ave from Middlefield Rd to Alma St November 2017 High St from Lytton Ave to Channing Ave November 2017 Homer Ave from Guinda Ave to Alma St November 2017 Laguna Ave from Matadero Ave to Los Robles Ave November 2017 Loma Verde Ave from W Bayshore Rd to Middlefield Rd November 2017 Loma Verde Ave from Middlefield Rd to Alma St November 2017 Los Robles Ave from Laguna Ave to El Camino Real November 2017 Louis Rd from Oregon Exp to Loma Verde Rd September 2023 Louis Rd from Loma Verde Rd to Charleston Rd September 2023 Lytton Ave from Alma St to Middlefield Rd November 2017 Matadero Ave from El Camino Real to Laguna Ave November 2017 Middlefield Rd from University Ave to Embarcadero Rd September 2023 Middlefield Rd from University Av to Northern City Limits September 2023 Middlefield Rd from Embarcadero Rd to Oregon Exp November 2017 Middlefield Rd from E Charleston Rd to South City Limits April 2025 Newell Rd from East City Limit to Channing Ave November 2017 Newell Rd from Channing Ave to Embarcadero Rd November 2017 N California Ave from Middlefield Rd to Alma St November 2017 Park Blvd from California Ave to Lambert Ave September 2023 Peter Coutts Rd from Stanford Ave to Page Mill Rd November 2017 Porter Dr from Hillview Ave to Page Mill Rd September 2023 Quarry Rd from El Camino Real to Campus Dr October 2023 Item 4 Attachment B - Ordinance Amending PAMC Chapter 10.56 to Establish Speed Limits        Item 4: Staff Report Pg. 64  Packet Pg. 72 of 517  NOT YET APPROVED Attachment B 3 Stanford Ave from El Camino Real to Peter Coutts Rd November 2017 Stanford Ave from Peter Coutts Rd to Junipero Serra Blvd November 2017 University Ave from Middlefield Rd to Alma St November 2017 Waverley St from Lytton Ave to Channing Ave November 2017 Waverley St from Channing Ave to Embarcadero Rd November 2017 SECTION 3. Chapter 10.56.015 of the Palo Alto Municipal Code is hereby amended to read as follows: 10.56.015 Thirty miles per hour prima facie speed limit. It is determined and justified upon the basis of engineering and traffic surveys that a speed greater than the twenty-five miles per hour prima facie speed limit set forth in Section 22352 of the Vehicle Code of the state, would facilitate the orderly movement of vehicular traffic and would be reasonable and safe under the conditions found to exist upon the streets, or portions thereof, set forth in this section, and it is hereby declared that thirty miles per hour shall be the prima facie speed limit upon these streets, or portions thereof, except for school zones, as shown below: Road Segment Name Survey Completion Date Coyote Hill Rd from Page Mill Rd to Hillview Ave April 2025 Fabian Way from Charleston Rd to W Bayshore Rd September 2023 Hansen Way from El Camino Real to Page Mill Exp September 2023 Hanover St from Page Mill Rd to Hillview Ave September 2023 Hillview Ave from Hanover St to Foothill Exp September 2023 W Bayshore Rd from Oregon Exp to Colorado Ave November 2017 SECTION 4. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid. SECTION 5. The Council finds that this ordinance is categorically exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15301 of the CEQA Guidelines as a minor alteration to the existing street system. Item 4 Attachment B - Ordinance Amending PAMC Chapter 10.56 to Establish Speed Limits        Item 4: Staff Report Pg. 65  Packet Pg. 73 of 517  NOT YET APPROVED Attachment B 4 SECTION 6. This ordinance shall be effective 31 days after adoption. INTRODUCED: PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: ____________________________ ____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: ____________________________ ____________________________ Assistant City Attorney City Manager ____________________________ Chief Transportation Official Item 4 Attachment B - Ordinance Amending PAMC Chapter 10.56 to Establish Speed Limits        Item 4: Staff Report Pg. 66  Packet Pg. 74 of 517  1 6 9 5 4 7 8 2 3 22 7 1 3 19 17 10 21 4 2 15 13 11 8 12 18 16 20 5 23 6 14 Study Segements Phase 1 9 Item 4 Attachment C - Study Segments Phase 1&2        Item 4: Staff Report Pg. 67  Packet Pg. 75 of 517  City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Planning and Development Services Meeting Date: November 10, 2025 Report #:2510-5321 TITLE Approval of a Budget Amendment in the General Fund for the Planning and Development Services Department’s Deposit-Based Fee Program for Private Development Studies for a Net Zero Impact. CEQA Status: Not a Project RECOMMENDATION Staff recommends that the City Council amend the Fiscal Year 2026 Budget Appropriation Ordinance (Requires 2/3 Vote) for the General Fund by: 1. Increasing Permits and Licenses revenue estimate in the Planning and Development Services Department by $350,000; and 2. Increasing Contract Services expense appropriation in the Planning and Development Services Department by $350,000. BACKGROUND The Planning and Development Services Department provides a service for private development projects using full cost recovery deposit-based contracts. The department utilizes the expertise of outside consultants to augment and expedite entitlement studies such as historic, environmental, and zoning compliance. Due to the highly specialized nature of these studies, City employees lack in-house expertise. Applicants pay upfront for contract services related to their project, and funding is held in a deposit account until services are performed. The number of projects that use this program fluctuates annually, and associated revenue and expense are realized in the Planning and Development Services operating budget when incurred, which sometimes, necessitates a net-zero budget action to ensure continuity of service. No general fund monies are utilized for this program, and all expenditures are supported by offsetting revenue. This action is required for the department to meet its contractual obligations and continue paying for cost-recovery services. Item 5 Item 5 Staff Report        Item 5: Staff Report Pg. 1  Packet Pg. 76 of 517  ANALYSIS 1 outlines the City’s deposit-based policies and procedures. This program provides the City with additional resources to meet the development needs of the community by utilizing outside consultant services related to historic, environmental, and compliance review studies for private development projects. Applicants submit funds to cover anticipated program costs, including a charge for the City’s administration of the program. Firms conducting these studies are selected based on their experience and expertise in the respective areas of study. Historically, the City has received approximately 50 to 75 projects annually, ranging in complexity from single-family dwellings to mixed-use projects. Private development services related contracts are exempted from competitive solicitation per Municipal Code Section 2.30.3602 as they are funded wholly by private developers. Therefore, these deposit contracts do not come before the City Council. Staff conducts an informal solicitation to select the firms that are best qualified based on a variety of factors. The results of the consultant’s work are generally presented to Commissions or City Council through staff reports, such as environmental reports or specific studies. This net-zero action is needed now as there was a technical system error during the Fiscal Year 2026 budget adoption process where the anticipated activity level for deposit-based contracts was not reflective of recent trends. This resulted in a lower annual allocation of both revenues and expenses for this work in FY 2026 that needs to be remedied. As of September 30, 2025, 84% of the approved budget of $207,000 has already been utilized. If additional revenue and corresponding expense increases are not approved, the City will not be able to meet its contractual obligations and the deposit-based recovery program will be suspended until additional budget appropriation is approved. FISCAL/RESOURCE IMPACT 1 Planning Application: https://www.paloalto.gov/files/assets/public/v/2/planning-amp-development- services/application-form-08-14-2025.pdf 2 Municipal Code: https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-61990 Item 5 Item 5 Staff Report        Item 5: Staff Report Pg. 2  Packet Pg. 77 of 517  STAKEHOLDER ENGAGEMENT Given that this is an internal budgeting action, stakeholder involvement has primarily been limited to the Planning and Development Services and Administrative Services departments. ENVIRONMENTAL REVIEW Council action on this item is not a project as defined by CEQA because this budget amendment is a government funding mechanism or fiscal activity which does not involve any commitment to any specific project which may result in a potentially significant physical impact on the environment. CEQA Guidelines section 15378(b)(4). APPROVED BY: Jonathan Lait, Planning and Development Services Director Item 5 Item 5 Staff Report        Item 5: Staff Report Pg. 3  Packet Pg. 78 of 517  City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: November 10, 2025 Report #:2507-4975 TITLE PUBLIC HEARING / QUASI-JUDICIAL. 660 University Ave [21PLN-00341]: Request for Approval of a Planned Home Zoning (PHZ) on Three Parcels (511 Byron Street, 660 University Avenue, 680 University Avenue/500 Middlefield Road), to Demolish Existing Buildings and Provide a New Six Story Mixed-Use Building with Approximately 1,900 Square Feet of Office, 70 Multi-Family Residential Units, and a Two Level Below-Grade Parking Garage. CEQA Status: A Draft Environmental Impact Report Circulated for Public Review Beginning on April 2, 2024, and Ending on May 17, 2024. The City published a Final EIR in March 2025 and a revised Final EIR in October 2025. Zoning District: RM-20 (Multi-Family Residential). RECOMMENDATION Staff recommends the City Council take the following actions: 1. Adopt the Resolution in Attachment B certifying the EIR and Adopting the Mitigation Monitoring and Reporting Program (MMRP); 2. Adopt the Resolution in Attachment C amending the Comprehensive Plan Land Use Element to modify the allowable uses in the Multiple Family Land Use Designation; 3. Adopt the Planned Community (PC) Ordinance in Attachment D rezoning the subject property and approving the development plan, uses, and public benefits; and 4. Approve the Record of Land Use Action in Attachment E with approval findings and conditions of approval. EXECUTIVE SUMMARY The applicant proposes to deconstruct two existing medical office buildings (9,216 square feet) at 511 Byron Street and 680 University and rezone three existing parcels (511 Byron Street, 660 University Avenue, and 680 University Avenue/500 Middlefield Road) from RM-20 to Planned Home Zoning (PHZ) in accordance with Palo Alto Municipal Code (PAMC) Chapter 18.38 (Planning Community Zoning). The parcels would be merged under a separate application, and the resulting parcel would be redeveloped with a new six-story mixed-use building with 1,984 square feet of ground floor office and 66,754 square feet of multiple-family residential use. The residential component, as recommended by the Planning and Transportation Commission Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 1  Packet Pg. 79 of 517  (PTC), will include 66 units (19 studios, 39 one-bedroom, and eight two-bedroom units). One unit will be designated as a manager’s unit. Thirteen of the units would be provided as below market rate (BMR) units (20%), though Staff recommends a slightly modified distribution of the BMR units. Parking spaces will be provided in a two-story below-grade parking garage with 78 parking spaces. The project also includes a Comprehensive Plan Amendment to allow office use in the Multiple-Family Land Use Designation in limited circumstances as detailed further in this report. BACKGROUND October 25, 20211: City Council prescreened a conceptual four-story mixed-use project (65 units; ~9,000 sf office). 1 October 25, 2021, Council Report: bit.ly/3NTpv3J Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 2  Packet Pg. 80 of 517  December 21, 2021: Applicant submitted a formal application. Staff completed initial review; resubmittals followed in May 2022 and August 2022 to address departmental comments. November 16, 20223: Planning & Transportation Commission (PTC) held an initial review and recommended forwarding the project to the Architectural Review Board (ARB) under the Planned Community (PC) rezoning process. December 1, 20224: ARB provided initial comments. Applicant later relocated the garage entry from Middlefield Road to Byron Street and made additional revisions in response to FEMA’s suspension of LOMR-F (Letters of Map Revision based on fill) processing. The transportation analysis and arborist report were updated and incorporated into the Draft EIR prior to publication. September 2, 2023: Applicant resubmitted; additional submittals occurred October 2023–February 2024 responding to staff comments. April 18, 20245: ARB reviewed the revised project during Draft EIR circulation and recommended Council approval with conditions. June 12, 2024: Scheduled PTC review was cancelled at the applicant’s request to allow further revisions. October 1, 2024: Applicant submitted a revised project adding two stories and relocating office use to the sixth floor. December 5, 20246: ARB reviewed the revised design and unanimously recommended Council approval, including return of specified items to an ARB Ad Hoc Committee and two additional conditions. Most ARB comments were addressed in the 2025 redesign (see below). Review by the PTC and ARB in 2025 are described in more detail below. Prior PTC Motion On March 12, 20257, the PTC reviewed a version of the project that had 66 residential units, 9,115 square feet of office use, and six stories, and asked for staff to return with more information and analysis on the following items: 3 November 16, 2022, PTC Report: 4 December 1, 2022, ARB Report: 5 April 18, 2024, ARB Report: 6 December 5, 2024, ARB Report: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=13940 7 March 12, 2025 PTC Staff Report: Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 3  Packet Pg. 81 of 517  1. Consideration of the impacts of the proposed Comprehensive Plan Amendment. 2. Consideration of tying the price of the parking spaces to the cost of an RPP permit 3. Consideration of the engineering and potential use of the special setback for multi- modal use. 4. Consideration to remove asphalt around Tree #10 after construction. 5. Consideration of bird friendly glass on 6th floor and balconies. 6. Clarification from PWE on the FEMA requirements. After this hearing, the applicant made major design changes that necessitated returning the project to the ARB. This included reducing the office space from 9,115 square feet to 1,984 square feet and moving the office use to the ground floor while adding residential units (increased to 70 total units) to the sixth floor. This also reconfigured the useable outdoor space, and increased the protrusion into the daylight plane, though the overall height decreased approximately two feet. ARB Recommendation On August 21, 2025, following the voluntary redesign, the ARB held a hearing13 and voted 3-2 (Jojarth and Hirsch no) to recommend approval of the project to Council with one additional recommendation for a condition of approval to, “Remove the balconies within the H2 units on the 2nd-6th floor (5 units) facing the Oak tree, or stepping the units back to reduce the encroachment into the TPZ if balconies are provided within the 30-foot radius of the tree.” In speaking to their dissent, both Jojarth and Hirsch explained that although they both would like to see the project move forward conceptually, they feel that additional architectural changes are warranted. PTC Recommendation On October 8, 2025, following preparation of a revised Final EIR, the PTC reviewed a 70-unit, 1,984 square foot office plan. The applicant presented an additional option for the PTC’s consideration to address the ARB comments through their presentation, which returned the unit count to 66-units, but removed the balconies located within the area of the tree canopy. The PTC voted 5-1-1 (Hechtman dissenting, James absent) to recommend approval of the project to Council with the following changes: Address the ARB recommendation through the 66-unit option presented or otherwise remove the balconies encroaching into the TPZ as recommended by the ARB Add the following five conditions of approval to the Record of Land Use Action: o Establish an easement on the Middlefield side for dimensions of the Special Setback to a depth of 20 feet below grade. If the City chooses to use this area, the applicant will not be responsible for replacing the parking. 13 August 21, 2025 ARB Report: https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16792 Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 4  Packet Pg. 82 of 517  o Beginning two years after building occupancy, report to OOT the number of parking spaces being leased. o As part of the TDM plan, the OOT will develop a method to assess spillover parking created by the project and will impose incentives or penalties when spillover is excessive. o Remove paving around the deck after construction, to the satisfaction of the Urban Forester. 1. Add Bird Safe Glass for the two units at the corners, Unit E and F2, on the sixth floor. Designate that the approximately 1,900 square feet commercial space be for neighborhood serving use The analysis section of the staff report goes into further detail on how these recommendations have been incorporated. The PTC also identified in their discussion some typos and clarifications in the attachments, which have been addressed. The dissenting commissioner cited opposition to reducing the unit count and requested a separate vote on the condition regulating on-site versus off-site parking pricing. While supportive of collecting parking utilization data, the commissioner viewed reducing the on-site parking cost from $150/month to the RPP rate of $56/year as financially infeasible for the applicant. The commissioner nevertheless supported forwarding the project to Council and expressed a desire for eventual approval. PROJECT DESCRIPTION The project, as currently proposed, includes deconstruction of the existing medical office buildings (9,216 square feet of medical office use) and rezoning of three existing parcels (511 Byron St, 660 University Ave, and 680 University Ave/500 Middlefield Rd) from RM-20 to Planned Community (also referred to as “Planned Home Zone” (PHZ). The parcels would be merged under a separate subdivision map process, and the resulting parcel would be redeveloped with a new six-story mixed-use building with 66 residential rental units and 1,984 square feet of office on the ground floor. The project would have two levels of below grade parking with 78 parking spaces. Because office use is not an allowed use within the multi-family land use designation, the project proposed a narrow Comprehensive Plan Amendment to allow commercial use in the Multiple-Family Land Use Designation on Planned Community parcels that propose a housing development project. A location map is included in Attachment A and the project plans are included in Attachment I. Requested Entitlements, Findings, and Purview: The following discretionary applications are being requested and subject to Council purview: Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 5  Packet Pg. 83 of 517  Planned Community (PC/PHZ): The process for evaluating this type of application is set forth in PAMC Chapter 18.38. The Planned Community Zone District is intended to accommodate all types of developments, including combinations of uses appropriately requiring flexibility under controlled conditions not otherwise attainable under other districts. The planned community district is particularly intended for unified, comprehensively planned developments that are of substantial public benefit and which conform with and enhance the policies and programs of the Palo Alto Comprehensive Plan. The application requires initial review by the PTC, followed by review by the ARB. Upon recommendation from the ARB, the draft ordinance for the project is presented along with the development plan to the PTC for recommendation to the City Council for final action. Comprehensive Plan Amendment: The steps for processing a request for a Comprehensive Plan amendment are set forth in PAMC Chapter 19.04. The PTC considers the amendment and forwards its recommendation to the City Council for final action. This is done in parallel with the application to rezone the subject property. ANALYSIS Staff’s review of the project finds it to be in compliance with applicable municipal code requirements or, through the requested entitlements, compliant if deviating from certain requirements. Comprehensive Plan The Comprehensive Plan land use designation for the project site is Multiple-Family Residential, which prescribes a density range of eight to 40 dwelling units per acre, with higher densities allowed where measurable community benefits will be derived, and services and facilities are available. The project has a density of 132 dwelling units per acre, and the Downtown location is sufficient to support this density. Further analysis is provided in the Findings (Attachments D and E). However, in order to retain some of the existing office square footage, this mixed-use project also includes a ground floor office use where office is not permitted within this land use designation. The project is requesting a Comprehensive Plan Text Amendment to modify the allowable uses in the Multiple Family Land Use Designation in limited circumstances. In its previous review the PTC requested additional information on how the Comprehensive Plan amendment could affect other properties within this land use designation. As written, the Comprehensive Plan Amendment is narrow as it would allow office uses only on sites that are zoned Planned Community, proposing a housing development project, and with an existing nonconforming office use. Any future proposals would be considered based on the individual context and appropriateness of commercial in each specific location, with fully discretionary review by both PTC and Council. Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 6  Packet Pg. 84 of 517  The proposed language is shown in underline below: 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 may be allowed where measurable community benefits will be derived, services and 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. Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 7  Packet Pg. 85 of 517  • Density (126.9 dwelling units per acre where a maximum of 20 dwelling units per acre is allowed) • Useable Open Space (86.2 square feet per unit where a minimum 150 square feet is required) • Setbacks encroachments: o Middlefield Special Setback – 0 feet below grade where 24 feet is required o Byron street side yard – 12 feet above grade, 0 feet below grade where 16 feet is required o University street side yard – 7 feet above grade, 0 feet below grade where 16 feet is required o Interior side yard – ramp to garage is 2 feet setback where 10 feet is required • Daylight plane (fourth through sixth floors encroach into the 10 foot, 45-degree angle daylight plane adjacent to RM-20 zoned properties). (See Attachment I, plan set pages A3.3B and A3.3C for section diagrams.) • Parking (78 parking spaces where 89 are required) In the RM-20 zoning district, office is a non-conforming use that would not be allowed to be demolished and redeveloped. As a part of the rezoning process, the applicant requests that office be a permitted use of the PC Ordinance, consistent with the development plans. In accordance with the PTC’s motion, additional neighborhood-serving uses have been incorporated into the PC Ordinance (Attachment D) for this project. Builder’s Remedy Alternative The proposed project serves as an alternative to a Builder’s Remedy application that includes 88 units and 9,215 square feet of office, for which a Senate Bill (SB) 330 pre-application was last filed on June 11, 2024, and for which the applicant submitted a formal application for on September 3, 2024. The Builder’s Remedy application has been paused in accordance with a tolling agreement between the Applicant and the City, which is valid through the end of the year. A member of the public has pointed out that the formal application on file does not contain enough units to take advantage of the Builder‘s Remedy. However, under the tolling agreement, the applicant retains the ability to amend its formal application to include the necessary number of units (ranging from 89 to 131 units). Protection of Tree #10 It is a stated priority of the City, neighbors, and the applicant to preserve the Coast Live Oak tree on the adjacent property and overhangs the project site. Several arborist reports were prepared to analyze this tree, and a condition of approval is proposed to require a security deposit for 200% of the appraised value of the tree. This security deposit shall be returned to the applicant upon survival of the tree for five years past the certificate of occupancy being granted for the project. Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 8  Packet Pg. 86 of 517  The tree is primarily adjacent to an existing parking lot on the project site, meaning the area around the root zone is paved. The plans show the asphalt below the proposed wooden deck, within the dripline of the Oak tree, would remain to minimize root disturbance. Future Use of the Special Setback Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 9  Packet Pg. 87 of 517  construction fees. The developer shall accept financial responsibility for any such relocation or retrofit required by future City projects.” This expands the area of the easement beyond what is shown in the current plan set. The project proposes required stairs to the garage which are within this area. To move the stairs would require a further loss of parking and may affect the overall circulation. Specifically, the location of the ramp cannot be moved as it is designed around the Tree Protection Zone of a significant Oak tree and was moved from Middlefield Road to Byron Avenue in the initial design review stages to address safety concerns raised by the OOT. Council may consider exempting the stair from the easement area or requiring more significant design changes to the parking garage. Balconies The ARB and PTC both recommend removing the balconies from within the Tree Protection Zone, though Urban Forestry staff confirms that the balconies do not affect the anticipated health of the tree. As a result, the applicant has opted to reduce the proposed number of units from 70 proposed to ARB and PTC to 66 units shown in the current plan set. This allows for a balcony to be provided for each unit. The alternative would have been to maintain a 70 unit design, but not provide private useable outdoor space in six of the units. Both options result in minor reductions to the total availability of useable open space on a per-unit basis. Onsite Parking, Residential Preferential Parking (RPP), and Transportation Demand Management Plan The project requests a parking reduction of 8%, which is reduced from 30% in prior iterations of the project. 78 parking spaces are proposed. A transportation demand management (TDM) plan has been prepared (Attachment I). Some of the TDM policies include: • Transit subsidies are made available to all employees • Carpool/vanpool spaces for the office use • An information kiosk and webpages for multi-modal transportation options including clipper card discounts for low-income residents • On site bike repair tools for residents The TDM plan is designed to reduce the number of trips by 20%, as required by the Comprehensive Plan. This will accommodate both the 8% current proposed reduction, and the potential reduction that would result from use of the Special Setback easement as described previously. Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 10  Packet Pg. 88 of 517  The project is not subject to AB 2097, though future residents may walk or bike 0.6 miles to the Caltrain station. There is a SamTrans bus stop at University Avenue and Middlefield Road and a VTA bus stop at Channing Avenue and Middlefield Road, however neither bus stop provides sufficient service to qualify as a high-quality transit stop under AB 2097. This project is not located along a Safe Route to School, but future residents could easily access Webster Street, which is a Safe Route to School for Addison Elementary School and Greene Middle School. It is within walking distance of many Downtown businesses, shops, and restaurants. 15 As such, a future resident of this development could purchase a permit to park on local streets. The cost of this permit is currently $56 per year, plus $5 for daily visitor permits. There is a maximum of 50 daily permits per year, and they do not permit overnight parking. o Beginning two years after building occupancy, the property owner shall report to the Office of Transportation the number of parking spaces being leased. This shall be compared to the number of RPP permits issued to residents of this building, for the purpose of determining if resident parking is spilling over into the neighborhood.” Bird Friendly Glass 15 Additional information on the RPP program is located here: https://www.paloalto.gov/Departments/Transportation/Parking/Parking-for-Residents/Downtown-Residential- Parking-Permits Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 11  Packet Pg. 89 of 517  changed to proposed residential units, rather than office, the residential unit windows were proposed to be clear glass, with bird safe glass on the balconies. sixth floor in areas where the corners create a “see-though” effect that could result in a higher likelihood of bird strikes. The applicant has incorporated this into all four corner units, as the condition facing Byron Street is the same as facing Middlefield Road. 17 The proposed meets the weighted 20% as shown below. 660 UNIVERSITY BELOW MARKET RATE UNIT CALCULATION Income Level Area Median Income Weighted Value Number of Units % of Actual Units Weighted % Total FISCAL/RESOURCE IMPACT 17 September 21, 2020, Council Staff Report - https://bit.ly/PHZ-CouncilReport Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 12  Packet Pg. 90 of 517  project is also subject to Development Impact Fees, currently estimated at $3,063,197.53. The project proposes on-site Public Art. STAKEHOLDER ENGAGEMENT Daily Post on October 31, 2025 which is 10 days in advance of the meeting. Postcard mailing occurred on October 29, 2025 which is 12 days in advance of the meeting. ENVIRONMENTAL REVIEW Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 13  Packet Pg. 91 of 517  Because the project does not result in any significant impacts, findings of overriding consideration are not required. However, the Resolution in Attachment B certifies the EIR and sets forth the Mitigation Monitoring and Reporting Program for the proposed project required to ensure that impacts remain less than significant. ATTACHMENTS APPROVED BY: Item 6 Item 6 Staff Report        Item 6: Staff Report Pg. 14  Packet Pg. 92 of 517  30 24 24 24 24 30 24 24 First United_Methodist Church Alain Pinel Realtor Lytton Gardens 50.0' 200.0' 50.0' 200.0' 200.0' 50.0' 200.0' 200.0' 100.0' 100.0' 250.0' 225.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 200.0' 152.5' 19.3'3.0' 47.7' 25.2' 67.0' 22.2' 100.0' 125.0' 140.0' 112.5'140.0' 112.5' 160.0' 112.5' 160.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 50.0' 112.5' 100.0' 100.0' 100.0' 100.0' 100.0' 25.0' 100.0' 25.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 100.0' 50.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0'100.0' 59.0' 100.0' 59.0' 100.0' 66.0' 100.0' 66.0' 50.0' 125.0' 50.0' 125.0' 50.0' 95.0' 50.0' 95.0' 50.0' 100.0' 50.0' 100.0' 100.0' 100.0' 100.0' 100.0' 147.5' 400.0' 174.7' 47.8' 3.0'19.3'22.2' 133.0' 150.0' 112.5'150.0' 112.5' 75.0' 125.0' 50.0' 150.0' 75.0' 150.0' 75.0' 151.5' 75.0' 151.5' 75.0' 48.5' 7.0'1.5' 150.0' 50.0' 143.0' 75.0' 125.0' 75.0' 125.0' 48.5' 82.0' 48.5' 82.0' 35.0' 100.0' 35.0' 100.0' 40.0' 100.0' 40.0' 100.0'100.0' 35.0' 100.0' 57.5' 125.0' 57.5' 125.0' 67.5' 125.0' 67.5' 125.0' 50.0' 90.0' 75.0' 150.0' 75.0' 150.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 151.5' 75.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 200.0' 225.0' 250.0' 130.0' 50.0' 95.0' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 150.0' 112.5'150.0' 112.5' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 250.0' 225.0' 25.0' 50.0' 100.0' 100.0'75.0' 75.0' 578 642-652630-640 600-610 415 405 434 765 750-798 482 486 490 483 547 526 649 625523 518 610 600 616 624 630 511 517 524 500 680 725 478 499 489 435 428 422 416 724 425 555 530 575 555 536 518 720 500 498 755 515 537 543539 720 519 UNIVERSITY AVENUE UNI V E R S I T Y A V E N U E BYR O N S T R E E T MIDDLEFIELD ROAD FULTON STREET MIDDLEFIELD ROAD WEBSTER STREET FULTON STREET HAMILTON AVENUE RM-20 PC-4173 This map is a product of the City of Palo Alto GIS This document is a graphic representation only of best available sources. Legend Project Site Current Features Search Polygon 0' 68' Attachment A Location Map 660 University CITY OF PALO ALTO INCORP O RATED CALIFORNIA P a l o A l t oT h e C i t y o f APRIL 16 1894 The City of Palo Alto assumes no responsibility for any errors. ©1989 to 2016 City of Palo Alto ekallas, 2024-03-21 09:04:52Attachment A. Location Map (\\cc-maps\Encompass\Admin\Personal\Planning.mdb) Item 6 Attachment A - Location Map        Item 6: Staff Report Pg. 15  Packet Pg. 93 of 517  1 Resolution No. ___ Resolution of the Council of the City of Palo Alto Certifying the Adequacy of the Final Environmental Impact Report for the 660 University Mixed-Use Project, and Adopting the Mitigation Monitoring and Reporting Program, All Pursuant to the California Environmental Quality Act RECITALS A. On December 21, 2021, Lund Smith of Smith Development (“Applicant”) submitted an application to rezone the subject parcels located at 511 Byron St, 660 University Ave, and 680 University Ave/500 Middlefield Rd (the “Subject Property,” more particularly described in Exhibit A) from RM-20 to Planned Community/Planned Home Zoning (PC/PHZ) and to deconstruct two existing medical office buildings (9,216 square feet) and redevelop the subject property with a mixed use development including 9,115 square feet of office space and 63 multi-family residential units, fourteen of which would be below market rate (the “Project”). The applicant proposes to merge the three existing lots at the Subject Property through a separate application. B. Approval of the Development Agreement Project would constitute a project under the provisions of the California Environmental Quality Act of 1970, together with related state and local implementation guidelines promulgated thereunder (“CEQA”). C. The City is the Lead Agency pursuant to Public Resources Code section 21067 as it has the principal responsibility to approve and regulate the Development Agreement Project. D. The City, in compliance with CEQA, prepared an Environmental Impact Report (EIR) to provide an assessment of the potential environmental consequences of approving and constructing the Project. E. The City circulated a Draft Environmental Impact Report (“Draft EIR”) for public review from April 2, 2024, to May 17, 2024. The Architectural Review Board held a public hearing during this review period on April 18, 2024, to receive comments on the Draft EIR. The Draft EIR evaluated a 63-unit development with 9,115 sf of office. F. The City considered the comments received during the Draft EIR public review period and prepared a Final Environmental Impact Report (“Final EIR”) in March, 2025, which evaluated a 63-unit development with 9,115 sf of office. Following modifications to the design, a the City released a Revised Final EIR on October 1, 2025, which evaluated a 70- unit development with 1,984 square feet of office. The Revised Final Environmental Impact Report is comprised of the Draft EIR and its Attachments A-E, together with the Revised Final Responses to Comments, Revised Revisions to the Draft EIR and CEQA Implications of Changes to the Proposed Project, and its Attachments A-E published on Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 16  Packet Pg. 94 of 517  2 October 1, 2025 (collectively, all of said documents are referred to herein as the “EIR”). G. The Council is the decision-making body for approval of the Development Agreement Project. H. CEQA requires that in connection with approval of a project for which an environmental impact report has been prepared that identifies one or more significant environmental effects of the project, the decision-making body of a public agency make certain findings regarding those effects. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF PALO ALTO AS FOLLOWS: SECTION 1. Certification and General Findings The City Council, in the exercise of its independent judgment, makes and adopts the following findings to comply with the requirements of CEQA, including Sections 15091, 15092, and 15093 of the CEQA Guidelines, based upon the entire record of proceedings for the Project. All statements set forth in this Resolution constitute formal findings of the City Council, including the statements set forth in this paragraph and in the recitals above. 1. The City Council was presented with, and has independently reviewed and analyzed, the EIR and other information in the record, and has considered the information contained therein prior to acting upon and approving the Project. The City Council bases the findings stated below on such review. 2. The EIR provides an adequate basis for considering and acting upon the Project. The City Council has considered all of the evidence and arguments presented during consideration of the Project and the EIR. In determining whether the Project may have a significant impact on the environment, and in adopting the findings set forth herein, the City Council certifies that it has complied with Public Resources Code Sections 21081, 21081.5, and 21082.2. 3. The City Council agrees with the characterization of the EIR with respect to all impacts initially identified as “less than significant” and finds that those impacts have been described accurately and are less than significant as so described in the EIR. This finding does not apply to impacts identified as significant or potentially significant that are reduced to a less than significant level by mitigation measures included in the EIR. The disposition of each of those impacts and the mitigation measures adopted to reduce them are addressed specifically in the findings below. 4. Mitigation measures associated with the potentially significant impacts of the Project will be implemented through the Mitigation Monitoring and Reporting Program (MMRP) described below, which is the responsibility of the City to enforce. Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 17  Packet Pg. 95 of 517  3 5. The EIR considers a reasonable range of potentially feasible alternatives, sufficient to foster informed decision making, public participation and a reasoned choice, in accordance with CEQA. 6. The Revised Final EIR contains responses to comments received on the Draft EIR. The Revised Final EIR also contains corrections and clarifications to the text and analysis of the Draft EIR where warranted. The City Council does hereby find that such changes and additional information are not significant new information under CEQA because such changes and additional information do not indicate that any of the following would result from approval and implementation of the Project: (i) any new significant environmental impact or substantially more severe environmental impact (not already disclosed and evaluated in the Draft EIR) would result from the project or from a new mitigation measure proposed to be implemented, (ii) any feasible mitigation measure considerably different from those analyzed in the Draft EIR that would lessen a significant environmental impact of the Project has been proposed and would not be implemented, (iii) any feasible alternative considerably different from those analyzed in the Draft EIR that would lessen a significant environmental impact of the Project has been proposed that would not be implemented, or (iv) the Draft EIR was fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. The City Council does find and determine that recirculation of the Revised Final EIR for further public review and comment is not warranted or required under the provisions of CEQA. 7. The City Council finds and certifies that the EIR has been prepared and completed in compliance with CEQA and reflects the City of Palo Alto’s independent judgment and analysis. 8. The City Council makes findings in this resolution with respect to significant effects on the environment of the Project, as identified in the EIR, with the understanding that all of the information in this Resolution is intended as a summary of the full administrative record supporting the EIR, which full administrative record should be consulted for the full details supporting these findings. SECTION 2. Significant Impacts Reduced to Less than Significant. Pursuant to Public Resources Code Section 21081 and CEQA Guidelines Section 15091, the City Council hereby makes these findings with respect to the potential for significant environmental impacts from approval and implementation of the Project and the means for mitigating those impacts. These findings do not attempt to describe the full analysis of each environmental impact contained in the EIR. Instead, the findings provide a summary description of each impact, describe the applicable mitigation measures identified in the EIR and adopted by the City, and state the findings on the significance of each impact after imposition of the adopted mitigation measures. A full explanation of these environmental findings and conclusions can be found in Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 18  Packet Pg. 96 of 517  4 the EIR. These findings hereby incorporate by reference the discussion and analysis in the EIR that support the EIR's determinations regarding significant project impacts and mitigation measures designed to address those impacts. The facts supporting these findings are found in the record as a whole for the Project. In making these findings, the City ratifies, adopts, and incorporates into these findings the analysis and explanation in the EIR, and ratifies, adopts, and incorporates into these findings the determinations and conclusions of the EIR relating to environmental impacts and mitigation measures, except to the extent that any such determinations and conclusions are specifically and expressly modified by these findings. The EIR identified a number of significant and potentially significant environmental impacts that the Project will cause or to which the Project would contribute. The following significant effects can be fully addressed and reduced to less than significant through the adoption and implementation of standard project requirements incorporated as part of the Project and feasible mitigation measures. Those impacts, along with the standard project requirements and mitigation measures to reduce them to less than significant, are listed below as referenced in the EIR. Air Quality Impact AQ-1: The project may potentially impact sensitive receptors nearby from carbon monoxide hotspots and toxic air contaminants. a) Potential Impact. The impact identified above is described and discussed in Section 3 of the Initial Study (Attachment B to the Draft EIR) and Section 5 of the Revised Final EIR. b) Mitigation Measures. The following mitigation measure will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings: AQ-1. Construction Emissions Reduction. Prior to construction activity and issuance of grading and building permits, the property owner or their designee shall ensure that the following specifications are detailed in the grading plan, building plan, and any contractor agreements and ensure that they be implemented during construction: • All mobile off-road equipment (wheeled or tracked) used during construction activities over 25 horsepower shall meet the USEPA Tier 4 final standards. Tier 4 certification can be for the original equipment or equipment that is retrofitted to meet the Tier 4 Final standards. • All mobile off-road equipment (wheeled or tracked) used during construction activities under 25 horsepower, such as generators, pumps, forklifts, cement and mortar mixes, and plate compactors shall be equipped with Level 3 diesel Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 19  Packet Pg. 97 of 517  5 particulate filters. c) Findings and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Construction emissions after implementation of Mitigation Measures AQ-1 were estimated using CalEEMod. Table 8 shows the health risks associated with the project’s construction activity after incorporation of Tier 4 engines and Level 3 diesel particulate filters on-site construction equipment pursuant to Mitigation Measure AQ-1. As shown in Table 8, the use of Tier 4 engines pursuant to Mitigation Measure AQ-1 reduces the excess cancer risk at the nearest sensitive receptor to below the project-level 10 in one million significance threshold and reduces PM2.5 emissions below the increase of > 0.3 µg/m3 annual average. Therefore, individual health risk impacts would be less than significant after mitigation. d) Remaining Impact. Mitigation Measure AQ-1 specified above would reduce all potential impacts to less than significant. Biological Resources Impact BIO-1: The project may result in impacts to protected nesting bird species. a) Potential Impact. The impact identified above is described and discussed in Section 4.1.3 of the Draft EIR. b) Mitigation Measures. The following mitigation measure will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings: BIO-1 Nesting Bird Surveys and Avoidance. Construction of the project and other site disturbing activities that would involve vegetation or tree removal shall be prohibited during the general avian nesting season (February 1 – August 31), if feasible. If nesting season avoidance is not feasible, the applicant shall retain a qualified biologist, as approved by the City of Palo Alto, to conduct a preconstruction nesting bird survey to determine the presence/absence, location, and activity status of any active nests on or adjacent to the project site. The extent of the survey buffer area surrounding the site shall be established by the qualified biologist to ensure that direct and indirect effects to nesting birds are avoided. To avoid the destruction of active nests and to protect the reproductive success of birds protected by the MBTA and CFGC, nesting bird surveys shall be performed not more than 14 days prior to scheduled vegetation clearance and structure demolition. In the event that active nests are discovered, a suitable buffer (typically a minimum buffer of 50 feet for passerines and a minimum buffer of 250 feet for raptors) shall be established around such active nests and no construction shall be allowed within the buffer areas until a qualified biologist has determined that the nest is Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 20  Packet Pg. 98 of 517  6 no longer active (i.e., the nestlings have fledged and are no longer reliant on the nest). Nesting bird surveys are not required for construction activities occurring between August 31 and February 1. c) Finding and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. The only wildlife that is anticipated to be present within the project area is wildlife associated with the built urban environment such native and migratory birds. Implementation of Mitigation Measure BIO-1 would ensure protection of nesting birds that may be affected during construction activities. This measure would reduce the potentially significant impact to special-status species and wildlife movement to a less than significant level. d) Remaining Impact. Mitigation Measure BIO-1 specified above would reduce all potential impacts to less than significant. Impact BIO-2: Construction activities near adjacent trees, specifically the heritage protected oak tree located on the adjacent parcel, could impact protected trees and conflict with the city’s local tree and landscape preservation and management ordinance. a) Potential Impact. The impact identified above is described and discussed in Section 4.1.3 of the Draft EIR and Sections 4 of the Revised Final EIR. b) Mitigation Measures. The following mitigation measure will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings: BIO-2. Tree Protection Plan. During the project design phase, the project applicant shall comply with and implement design guidelines listed in Section 6.1 of the February 7, 2024 Arborist Report prepared by David L. Babby. Guidelines include delineation of tree protection zones, specific actions related to grading and excavation, specifications for new paving and hardscape, and erosion control and landscaping requirements, among others., the project applicant shall comply with tree protection measures listed in Section 6.2 of the Arborist Report. Guidelines include a review of tree protection and construction processes, inspections and supervisions under direction of the project arborist, and installation of TPZs, among others. During demolition, grading, and construction, the project applicant shall comply with tree protection measures listed in Section 6.3 of the Arborist Report. Guidelines include specific actions related to demolition, excavation, and trenching, supervisions under direction of the project arborist, and disposal requirements, among others. A qualified arborist shall be retained and present for any activity that could impact trees on- and off-site. BIO-3. Oak Tree Pruning and Protection. Larger roots shall be pruned using a fine-tooth saw, and smaller roots shall be pruned using a hand looper. If roots are to be left Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 21  Packet Pg. 99 of 517  7 exposed for long periods of time, especially in warm weather, they must be covered in burlap cloth and kept wet. Branch pruning shall be highly selective and limited to avoid significant cuts. A qualified arborist shall be present on site to oversee any root pruning activities, as well as any branch pruning activities and shall provide guidance regarding which branches to cut. The qualified arborist shall also perform annual inspections for five to 10 years following building occupancy. Branch pruning work shall be performed by a tree service with an ISA Certified Arborist in a supervisory role on-site. c) Finding and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. The neighboring Coast Live Oak tree is planned to be protected during construction through the mitigation measures and project-specific conditions of approval. Implementation of mitigation measures BIO-2 and BIO-3 would ensure the protection of on- and offsite trees, especially the protected oak tree, and reduce impacts to a less than significant level. d) Remaining Impact. Mitigation Measures BIO-2 and BIO-3 specified above would reduce all potential impacts to less than significant. Cultural Resources Impact CR-1: Construction of the proposed project would involve ground-disturbing activities such as grading and surface excavation, which have the potential to unearth or adversely impact previously unidentified archaeological resources. a) Potential Impact. The impact identified above is described and discussed in Section 5 of the Initial Study (Attachment B of the Draft EIR) and further discussed in Section 5 of the Revised Final EIR. b) Mitigation Measures. The following mitigation measure will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings: CUL-1. Worker’s Environmental Awareness Program. The property owner or their designee shall retain a qualified archaeologist to conduct a Worker’s Environmental Awareness Program (WEAP) training for archaeological sensitivity for all construction personnel prior to the commencement of any ground disturbing activities. Archaeological sensitivity training shall include a description of the types of cultural material that may be encountered, cultural sensitivity issues, regulatory issues, the proper protocol for treatment of the materials in the event of a find, and an outline of the penalties for the willful and intention damage of cultural resources. CUL-2. Unanticipated Discovery of Archaeological Resources. In the event that archaeological resources are unearthed during project construction, all earth- Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 22  Packet Pg. 100 of 517  8 disturbing work near the find must be temporarily suspended or redirected until an archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology (NPS 1983) has evaluated the nature and significance of the find. If the discovery proves to be significant under CEQA (Section 15064.5f; PRC 21082), additional work, such as preservation in place or archaeological data recovery, shall occur as recommended by the archeologist in coordination with City staff and if applicable, the most likely descendants. Once the resource has been properly treated or protected, work in the area may resume. A Native American representative shall be retained to monitor mitigation work associated with Native American cultural material. c) Findings and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. By implementing Mitigation Measure CUL-1 and CUL-2, the City would evaluate and require steps to protect or treat significant archaeological resources if encountered during construction, and would require archaeological sensitivity training for construction personnel, resulting in a less than significant impact. d) Remaining Impact. Mitigation Measures CUL-1 and CUL-2 specified above would reduce all potential impacts to less than significant. Geology and Soils Impact GEO-1. Construction of the proposed project would involve ground-disturbing activities such as grading and surface excavation, which have the potential to unearth or adversely impact unique paleontological resources. a) Potential Impact. The impact identified above is described and discussed in Section 7 of the Initial Study (Attachment B of the Draft EIR). b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings. GEO-1. Paleontological Resources Monitoring and Mitigation. Qualified Professional Paleontologist. Prior to excavation, the project applicant shall retain a Qualified Professional Paleontologist (defined by the SVP (2010) as an individual, preferably with an M.S. or Ph.D. in paleontology or geology, who is experienced with paleontological procedures and techniques, who is knowledgeable in the geology of California, and who has worked as a paleontological mitigation project supervisor for at least two years). The Qualified Professional Paleontologist shall direct all mitigation measures related to paleontological resources. Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 23  Packet Pg. 101 of 517  9 Paleontological Worker Environmental Awareness Program. Prior to the start of construction, the Qualified Professional Paleontologist or their designee shall conduct a paleontological Worker Environmental Awareness Program (WEAP) training for construction personnel regarding the appearance of fossils and the procedures for notifying paleontological staff should fossils be discovered by construction staff. Paleontological Monitoring. Full-time paleontological monitoring shall be conducted during ground disturbing construction activities reaching more than 5 feet below the ground surface in areas mapped as Quaternary coarse-grained alluvium and ground. Paleontological monitoring shall be conducted by a paleontological monitor with experience with collection and salvage of paleontological resources and who meets the minimum standards of the SVP (2010) for a Paleontological Resources Monitor. The duration and timing of the monitoring will be determined by the Qualified Professional Paleontologist based on the observation of the geologic setting from initial ground disturbance, and subject to the review and approval by the City of Palo Alto. If the Qualified Professional Paleontologist determines that full-time monitoring is no longer warranted, based on the specific geologic conditions once the full depth of excavations has been reached, they may recommend that monitoring be reduced to periodic spot- checking or ceased entirely. Monitoring shall be reinstated if any new ground disturbances are required, and reduction or suspension shall be reconsidered by the Qualified Professional Paleontologist at that time. In the event of a fossil discovery by the paleontological monitor or construction personnel, the following measures shall apply: • Fossil Salvage. If fossils are discovered, the paleontological monitor shall have the authority to halt or temporarily divert construction equipment within 50 feet of the find until the paleontological monitor and/or Qualified Professional Paleontologist evaluate the discovery and determine if the fossil may be considered significant. Typically, fossils can be safely salvaged quickly by a single paleontological monitor and not disrupt construction activity. In some cases, larger fossils (such as complete skeletons or large mammal fossils) require more extensive excavation and longer salvage periods. Bulk matrix sampling may be necessary to recover small invertebrates or microvertebrates from within paleontologically sensitive deposits. • Fossil Preparation and Curation. Once salvaged, significant fossils shall be identified to the lowest possible taxonomic level, prepared to a curation-ready condition, and curated in a museum repository with a permanent paleontological collection along with all pertinent field notes, photos, data, and maps. Fossils of undetermined significance at the time of collection may also warrant curation at the discretion of the Qualified Professional Paleontologist. • Final Paleontological Mitigation Report. Upon completion of ground disturbing activity (and curation of fossils if necessary) the Qualified Professional Paleontologist shall prepare a final report describing the results of the Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 24  Packet Pg. 102 of 517  10 paleontological monitoring efforts associated with the project. The report shall include a summary of the field and laboratory methods, an overview of the project geology and paleontology, a list of taxa recovered (if any), an analysis of fossils recovered (if any) and their scientific significance, and recommendations. The report shall be submitted to the City of Palo Alto Director of Planning and Development Services. If the monitoring efforts produced fossils, then a copy of the report shall also be submitted to the designated museum repository. c) Finding and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Implementation of Mitigation Measure GEO-1 would require a paleontological WEAP as well as paleontological monitoring and reporting which would reduce impacts related to paleontological resources to a less than significant level. This measure will be included in the EIR’s executive summary and mitigation monitoring and reporting program. Therefore, the impacts would be less than significant with mitigation incorporated. d) Remaining Impact. Mitigation Measure GEO-1 specified above would reduce all potential impacts to less than significant. Noise and Vibrations Impact N-1. Construction and demolition activities associated with the proposed project would intermittently generate noise adjacent to the project site. These construction noise levels would not exceed the applicable noise level thresholds. Noise associated with operation of the project would be generally similar to existing noise generated by nearby residential and commercial uses and would not cause a significant change in ambient noise levels. This impact would be less than significant, however mitigation measures are recommended. a) Potential Impact. The impact identified above is described and discussed in Section 4.2 of the Draft EIR and further discussed in Section 5 of the Revised Final EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings. N-1. Construction Noise Reduction Measures. The construction contractor shall prepare a Construction Noise Control Plan prior to issuance of a grading permit. The Construction Noise Control Plan shall specify the noise reduction measures to be implemented during project construction to ensure noise levels are reduced at nearby residences. The measures specified in the Construction Noise Control Plan shall be included on the building and grading plans and shall be implemented by the Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 25  Packet Pg. 103 of 517  11 construction contractor during construction. At a minimum, the Construction Noise Control Plan shall include the following measures: 1. Construction Operating Hours. Limit all construction activities to the hours of 8:00 a.m. to 6:00 p.m. on weekdays and 9:00 a.m. to 6:00 p.m. on Saturdays. Construction activity shall be prohibited on Sundays and national holidays. 2. Mufflers. During all construction phases, all construction equipment, fixed or mobile, shall be operated with closed engine doors and shall be equipped with properly operating and maintained mufflers consistent with manufacturers’ standards. 3. Silencing. Power construction equipment (including combustion engines), fixed or mobile, shall be equipped with silencing devices consistent with manufacturer’s standards, if available. Equipment shall be properly maintained, and the project applicant or owner shall require any construction contractor to keep documentation on-site during any earthwork or construction activities demonstrating that the equipment has been maintained in accordance with manufacturer’s specifications. 4. Stationary Equipment. All stationary construction equipment shall be placed so that emitted noise is directed away from the nearest sensitive receptors. 5. Signage and Noise Complaint Coordinator. The project applicant shall designate an on-site construction project manager who shall be responsible for responding to any complaints about construction noise. This person shall be responsible for responding to concerns of neighboring properties about construction noise disturbance and shall be available for responding to any construction noise complaints during the hours that construction is to take place. They shall also be responsible for determining the cause of the noise complaint (e.g., bad silencer) and shall require that reasonable measures be implemented to correct the problem. A toll-free telephone number shall be posted at construction site entrances for the duration of construction and provided in all notices (mailed, online website, and construction site postings) for receiving questions or complaints during construction and shall also include procedures requiring that the on-site construction manager to respond to callers. The on-site construction project manager shall be required to track complaints pertaining to construction noise, ongoing throughout demolition, grading, and/or construction and shall notify the City’s Community Development Director of each complaint occurrence. 6. Smart Back-Up Alarms. Mobile construction equipment shall have smart back- up alarms that automatically adjust the sound level of the alarm in response to ambient noise levels. 7. Equipment Idling. Construction vehicles and equipment shall not be left idling for longer than five minutes when not in use. 8. Temporary Noise Barriers. Erect a temporary noise barrier along the eastern project boundary, and the southern and western project boundaries, where feasible, during demolition and grading/excavation phases. Temporary noise Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 26  Packet Pg. 104 of 517  12 barriers shall be constructed with solid materials (e.g., wood) with a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier at a minimum height of 12 feet. Where a solid barrier is not feasible, sound blankets affixed to the construction fencing shall be used. If a sound blanket is used, the sound blanket must have a density of at least 1 pound per square foot with no gaps from the ground to the top of the construction fencing, and the sound blank shall be rated sound transmission class (STC) 32 or higher. c) Finding and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. As stated in Section 9.10.060 of the PAMC, the noise level at the property line may not exceed 110 dBA. Noise during the highest intensity phase of construction would be below the City’s Municipal Code threshold of 110 dBA. Nevertheless, if uncontrolled, construction activity may cause a temporary increase of noise levels in the project vicinity. Therefore, Mitigation Measure N-1 is recommended to further reduce noise levels during construction. Therefore, impacts would be less than significant with mitigation incorporated. d) Remaining Impact. There is no significant impact, however Mitigation Measure N-1 specified above would further reduce any potential impacts. Impact N-1. Construction activities associated with the proposed project would intermittently generate groundborne vibration at residential receptors adjacent to the project site. Vibration could exceed FTA standards for potential damage to the adjacent residential building to the southeast, due to the proximity of construction equipment. However, this impact would be less than significant with implementation of mitigation measure N-2. a) Potential Impact. The impact identified above is described and discussed in Section 4.2 of the Draft EIR and further discussed in Section 5 of the Revised Final EIR. b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings. N-2. Construction Vibration Control Plan. The construction contractor shall prepare a Vibration Control Plan prior to issuance of a grading permit. The Construction Vibration Control Plan shall specify the vibration reduction measures to be implemented during project construction to ensure vibration levels are reduced to 0.2 in/sec PPV at nearby residences. The measures specified in the Construction Vibration Control Plan shall be included on the building and grading plans and shall be implemented by the construction contractor during construction. At a minimum, the Construction Vibration Control Plan shall include the following measures: Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 27  Packet Pg. 105 of 517  13 1. For paving activities within 25 feet of offsite residences, a static roller shall be used in lieu of a vibratory roller. 2. For grading and earthwork activities (not including the drop-bucket or scoop) within 15 feet of offsite residences, off-road equipment shall be limited to 100 horsepower or less. c) Finding and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Mitigation Measure N-2 would require that use of a static roller in lieu of a vibratory roller is used within 25 feet of off-site receptors to reduce construction-related vibration. Specifically, use of a static roller would generate vibration levels of approximately 0.05 in/sec PPV at a distance of 25 feet (McIver 2012). Additionally, Mitigation N-2 would require that alternative equipment is used near off- site receptors to reduce construction related vibration. Grading and earthwork equipment, such as a small bulldozer, that is limited to 100 horsepower or less would generate less than 0.01 in/sec PPV within 15 feet of the adjacent sensitive receptor. With implementation of Mitigation Measure N-2, project groundborne vibration would be less than the significance threshold of 0.2 in/sec PPV at the adjacent off-site residence to the southeast. Therefore, with mitigation, project construction vibration impacts at all surrounding sensitive receptors would be less than significant. d) Remaining Impact. Mitigation Measure N-2 specified above would reduce all potential impacts to less than significant. Tribal Cultural Resources Impact TRC-1. There is potential to uncover buried archaeological and tribal cultural resources during ground disturbing activities, which could potentially be considered tribal cultural resources eligible for listing in the CRHR or a local register or be considered tribal cultural resources. Should project construction activities encounter and damage or destroy a tribal cultural resource or resources. a) Potential Impact. The impact identified above is described and discussed in Section 18 of the Initial Study (Attachment B of the Draft EIR). b) Mitigation Measures. The following mitigation measures will be adopted and will be implemented as provided in the MMRP, and as further described in the remainder of these findings. TCR-1. Unanticipated Discovery of Tribal Cultural Resources. In the event that cultural resources of Native American origin are identified during implementation of the proposed project, all earth-disturbing work within 50 feet of the find shall be temporarily suspended or redirected until an archaeologist and culturally affiliated Native American representative have evaluated the nature and significance of the find. Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 28  Packet Pg. 106 of 517  14 If the City, in consultation with local Native Americans, determines that the resource is a tribal cultural resource and thus significant under CEQA, a mitigation plan shall be prepared and implemented in accordance with state guidelines and in consultation with local Native American group(s). The plan shall include avoidance of the resource or, if avoidance of the resource is infeasible, the plan shall outline the appropriate treatment of the resource in coordination with the culturally affiliated local Native American tribal representative and, if applicable, a qualified archaeologist. Examples of appropriate mitigation for tribal cultural resources include, but are not limited to, protecting the cultural character and integrity of the resource, protecting traditional use of the resource, protecting the confidentiality of the resource, or heritage recovery. c) Finding and Rationale. Changes or alterations have been required in, or incorporated into, the project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Implementation of Mitigation Measure TCR-1 would ensure that any unanticipated discoveries of tribal cultural resources are avoided or, where avoidance is infeasible, mitigated to a less than significant level. Therefore, with implementation of Mitigation Measure TCR-1, impacts to tribal cultural resources would be reduced to a less than significant level. d) Remaining Impact. Mitigation Measure TRC-1 specified above would reduce all potential impacts to less than significant. SECTION 3. Project Alternatives. Public Resources Code section 21002 prohibits a public agency from approving a project if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of the project. When a lead agency finds, even after the adoption of all feasible mitigation measures, that a project will still cause one or more significant environmental effects that cannot be substantially lessened or avoided, it must, prior to approving the project as mitigated, first determine whether there are any project alternatives that are feasible and that would substantially lessen or avoid the project's significant impacts. Because all of the Project’s impacts are being mitigated through the adoption of mitigation measures described above, and because the Project will thus not result in any significant environmental effects, the City Council finds that there is no need to further consider the feasibility of any of the alternatives identified in the Final EIR. SECTION 4. Mitigation Monitoring and Reporting Program (a) CEQA requires the lead agency approving a project to adopt a Mitigation Monitoring and Reporting Program (MMRP) for the changes made to the project that it has adopted in order to mitigate or avoid significant effects on the environment. An MMRP has been prepared and is recommended for adoption by the City Council concurrently with the adoption of these findings to ensure Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 29  Packet Pg. 107 of 517  15 compliance with standard project requirements incorporated as part of the project and mitigation measures during Project implementation. As required by Public Resources Code section 21081.6, the MMRP designates responsibility and anticipated timing for the implementation of the mitigation measures recommended in the Final EIR. The MMRP will remain available for public review during the compliance period. (b) The City Council hereby adopts the MMRP for the Project attached hereto as Exhibit A and incorporated by reference, and finds, determines, and declares that the adoption of the MMRP will ensure enforcement and continued imposition of the mitigation measures recommended in the Final EIR, and set forth in the MMRP, in order to mitigate or avoid significant impacts on the environment. / / / / / / / / / / / / / / / / / / / / / / / / SECTION 5. Location and Custodian of Records. The documents and other materials that constitute the record of proceedings on which the City Council based the foregoing findings and approval of the Project are located at the Department of Planning and Community Environment, 250 Hamilton Avenue, Palo Alto, CA 94301. The official custodian of the record is the Planning Director at the same address. Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 30  Packet Pg. 108 of 517  16 PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: APPROVED: __________________________ _____________________________ City Clerk Mayor APPROVED AS TO FORM: APPROVED: __________________________ _____________________________ Assistant City Attorney City Manager _____________________________ Director of Public Works _____________________________ Director of Planning and Development Services Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 31  Packet Pg. 109 of 517  MITIGATION MONITORING + REPORTING PROGRAM City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 1 PROJECT NAME 660 University Avenue Mixed-Use Project APPLICATION NUMBER 21PLN-00341 APPLICANT AGREEMENT [INSERT Signature] DATE 10/1/2025 APPROVED BY [INSERT Signature] APPLICANT/OWNER Smith Development 682 Villa Street, Suite G Mountain View, California 94041 The Final Revised Environmental Impact Report (EIR) for the 660 University Avenue Mixed-Use Project identifies the mitigation measures that must be implemented to reduce the environmental impacts associated with the project. California Environmental Quality Act (CEQA) Section 21081.6 requires a public agency to adopt a monitoring and reporting program for assessing and ensuring compliance with any required mitigation measures applied to proposed development. As stated in section 21081.6(a)(1) of the Public Resources Code: ... the public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. Section 21081.6 also provides general guidelines for implementing mitigation monitoring programs and indicates that specific reporting and/or monitoring requirements, to be enforced during project implementation, shall be defined as part of adopting an EIR. The mitigation monitoring table lists those mitigation measures that would be included as conditions of approval for the project. To ensure that the mitigation measures are properly implemented, a monitoring program has been devised which identifies the timing and responsibility for monitoring each measure. Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 32  Packet Pg. 110 of 517  MITIGATION MONITORING + REPORTING PROGRAM City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 2 Mitigation Measure Implementation Compliance Implementation AIR QUALITY AQ-1. Construction Emissions Reduction. Prior to construction activity and issuance of grading and building permits, the property owner or their designee shall ensure that the following specifications are detailed in the grading plan, building plan, and any contractor agreements and ensure that they be implemented during construction:  All mobile off-road equipment (wheeled or tracked) used during construction activities over 25 horsepower shall meet the USEPA Tier 4 final standards. Tier 4 certification can be for the original equipment or equipment that is retrofitted to meet the Tier 4 Final standards.  All mobile off-road equipment (wheeled or tracked) used during construction activities under 25 horsepower, such as generators, pumps, forklifts, cement and mortar mixes, and plate compactors shall be equipped with Level 3 diesel particulate filters. Project Applicant/ verified by the Planning & Development Services Department Prior to the initiation of construction activities During grading and construction City of Palo Alto Planning & Development Services Department Biological Resources BIO-1. Nesting Bird Surveys and Avoidance. Construction of the project and other site disturbing activities that would involve vegetation or tree removal shall be prohibited during the general avian nesting season (February 1 – August 31), if feasible. If nesting season avoidance is not feasible, the applicant shall retain a qualified biologist, as approved by the City of Palo Alto, to conduct a preconstruction nesting bird survey to determine the presence/absence, location, and activity status of any active nests on or adjacent to the project site. The extent of the survey buffer area surrounding the site shall be established by the qualified biologist to ensure that direct and indirect effects to nesting birds are avoided. To avoid the destruction of active nests and to protect the reproductive success of birds protected by the MBTA and CFGC, nesting bird surveys shall be performed not more than 14 days prior to scheduled vegetation clearance and structure demolition. In the event that active nests are discovered, a suitable buffer (typically a minimum buffer of 50 feet for Project Applicant/ verified by the Planning & Development Services Department Not more than 14 days prior to scheduled vegetation clearance and structure demolition, if construction proposed during the general avian nesting season City of Palo Alto Planning & Development Services Department Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 33  Packet Pg. 111 of 517  City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 3 Mitigation Measure Implementation Compliance Implementation passerines and a minimum buffer of 250 feet for raptors) shall be established around such active nests and no construction shall be allowed within the buffer areas until a qualified biologist has determined that the nest is no longer active (i.e., the nestlings have fledged and are no longer reliant on the nest). Nesting bird surveys are not required for construction activities occurring between August 31 and February 1. During project construction BIO-2. Tree Protection Plan. During the project design phase, the project applicant shall comply with and implement design guidelines listed in Section 6.1 of the February 7, 2024 Arborist Report prepared by David L. Babby. Guidelines include delineation of tree protection zones, specific actions related to grading and excavation, specifications for new paving and hardscape, and erosion control and landscaping requirements, among others., the project applicant shall comply with tree protection measures listed in Section 6.2 of the Arborist Report. Guidelines include a review of tree protection and construction processes, inspections and supervisions under direction of the project arborist, and installation of TPZs, among others. During demolition, grading, and construction, the project applicant shall comply with tree protection measures listed in Section 6.3 of the Arborist Report. Guidelines include specific actions related to demolition, excavation, and trenching, supervisions under direction of the project arborist, and disposal requirements, among others. A qualified arborist shall be retained and present for any activity that could impact trees on- and off-site. Project Applicant/ verified by the Planning & Development Services Department During project design Prior to demolition, grading, and construction During demolition, grading, and construction City of Palo Alto Planning & Development Services Department BIO-3. Oak Tree Pruning and Protection. Larger roots shall be pruned using a fine- tooth saw, and smaller roots shall be pruned using a hand looper. If roots are to be left exposed for long periods of time, especially in warm weather, they must be covered in burlap cloth and kept wet. Branch pruning shall be highly selective and limited to avoid significant cuts. A qualified arborist shall be present on site to oversee any root pruning activities, as well as any branch pruning activities and shall provide guidance regarding which branches to cut. The qualified arborist shall also perform annual inspections for five to 10 years following building occupancy. Branch pruning work shall be performed by a tree service with an ISA Certified Arborist in a supervisory role on-site. Project Applicant/ verified by the Planning & Development Services Department During pruning activities City of Palo Alto Planning & Development Services Department Cultural Resources and Tribal Cultural Resources CUL-1. Worker’s Environmental Awareness Program. The property owner or their designee shall retain a qualified archaeologist to conduct a Worker’s Environmental Awareness Program (WEAP) training for archaeological sensitivity for all construction personnel prior to the commencement of any ground disturbing activities. Archaeological sensitivity training shall include a description of the types of cultural Project Applicant/ verified by the Planning & Development Services Prior to the commencement of any ground disturbing activities City of Palo Alto Planning & Development Services Department Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 34  Packet Pg. 112 of 517  City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 4 Mitigation Measure Implementation Compliance Implementation material that may be encountered, cultural sensitivity issues, regulatory issues, the proper protocol for treatment of the materials in the event of a find, and an outline of the penalties for the willful and intention damage of cultural resources. Department CUL-2. Unanticipated Discovery of Archaeological Resources. In the event that archaeological resources are unearthed during project construction, all earth- disturbing work near the find must be temporarily suspended or redirected until an archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology (NPS 1983) has evaluated the nature and significance of the find. If the discovery proves to be significant under CEQA (Section 15064.5f; PRC 21082), additional work, such as preservation in place or archaeological data recovery, shall occur as recommended by the archeologist in coordination with City staff and if applicable, the most likely descendants. Once the resource has been properly treated or protected, work in the area may resume. A Native American representative shall be retained to monitor mitigation work associated with Native American cultural material. Project Applicant/ verified by the Planning & Development Services Department During ground disturbing activities City of Palo Alto Planning & Development Services Department GEOLOGY AND SOILS GEO-1. Paleontological Resources Monitoring and Mitigation. Qualified Professional Paleontologist. Prior to excavation, the project applicant shall retain a Qualified Professional Paleontologist (defined by the SVP (2010) as an individual, preferably with an M.S. or Ph.D. in paleontology or geology, who is experienced with paleontological procedures and techniques, who is knowledgeable in the geology of California, and who has worked as a paleontological mitigation project supervisor for at least two years). The Qualified Professional Paleontologist shall direct all mitigation measures related to paleontological resources. Paleontological Worker Environmental Awareness Program. Prior to the start of construction, the Qualified Professional Paleontologist or their designee shall conduct a paleontological Worker Environmental Awareness Program (WEAP) training for construction personnel regarding the appearance of fossils and the procedures for notifying paleontological staff should fossils be discovered by construction staff. Paleontological Monitoring. Full-time paleontological monitoring shall be conducted during ground disturbing construction activities reaching more than 5 feet below the ground surface in areas mapped as Quaternary coarse-grained alluvium and ground. Paleontological monitoring shall be conducted by a paleontological monitor with experience with collection and salvage of paleontological resources and who meets the minimum standards of the SVP (2010) for a Paleontological Resources Monitor. Project Applicant/ verified by the Planning & Development Services Department Prior to the start of grading or construction activities and during construction activities City of Palo Alto Planning & Development Services Department Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 35  Packet Pg. 113 of 517  City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 5 Mitigation Measure Implementation Compliance Implementation Professional Paleontologist based on the observation of the geologic setting from initial ground disturbance, and subject to the review and approval by the City of Palo Alto. If the Qualified Professional Paleontologist determines that full-time monitoring is no longer warranted, based on the specific geologic conditions once the full depth of excavations has been reached, they may recommend that monitoring be reduced to periodic spot-checking or ceased entirely. Monitoring shall be reinstated if any new ground disturbances are required, and reduction or suspension shall be reconsidered by the Qualified Professional Paleontologist at that time. In the event of a fossil discovery by the paleontological monitor or construction personnel, the following measures shall apply:  Fossil Salvage. If fossils are discovered, the paleontological monitor shall have the authority to halt or temporarily divert construction equipment within 50 feet of the find until the paleontological monitor and/or Qualified Professional Paleontologist evaluate the discovery and determine if the fossil may be considered significant. Typically, fossils can be safely salvaged quickly by a single paleontological monitor and not disrupt construction activity. In some cases, larger fossils (such as complete skeletons or large mammal fossils) require more extensive excavation and longer salvage periods. Bulk matrix sampling may be necessary to recover small invertebrates or microvertebrates from within paleontologically sensitive deposits  Fossil Preparation and Curation. Once salvaged, significant fossils shall be identified to the lowest possible taxonomic level, prepared to a curation-ready condition, and curated in a museum repository with a permanent paleontological collection along with all pertinent field notes, photos, data, and maps. Fossils of undetermined significance at the time of collection may also warrant curation at the discretion of the Qualified Professional Paleontologist.  Final Paleontological Mitigation Report. Upon completion of ground disturbing activity (and curation of fossils if necessary) the Qualified Professional Paleontologist shall prepare a final report describing the results of the paleontological monitoring efforts associated with the project. The report shall include a summary of the field and laboratory methods, an overview of the project geology and paleontology, a list of taxa recovered (if any), an analysis of fossils recovered (if any) and their scientific significance, and recommendations. The report shall be submitted to the City of Palo Alto Director of Planning and Development Services. If the monitoring efforts produced fossils, then a copy of the report shall also be submitted to the designated museum repository. Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 36  Packet Pg. 114 of 517  City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 6 Mitigation Measure Implementation Compliance Implementation Noise Recommmended Measure N-1. Construction Noise Reduction Measures. The construction contractor shall prepare a Construction Noise Control Plan prior to issuance of a grading permit. The Construction Noise Control Plan shall specify the noise reduction measures to be implemented during project construction to ensure noise levels are reduced at nearby residences. The measures specified in the Construction Noise Control Plan shall be included on the building and grading plans and shall be implemented by the construction contractor during construction. At a minimum, the Construction Noise Control Plan shall include the following measures: 1. Construction Operating Hours. Limit all construction activities to the hours of 8:00 a.m. to 6:00 p.m. on weekdays and 9:00 a.m. to 6:00 p.m. on Saturdays. Construction activity shall be prohibited on Sundays and national holidays. 2. Mufflers. During all construction phases, all construction equipment, fixed or mobile, shall be operated with closed engine doors and shall be equipped with properly operating and maintained mufflers consistent with manufacturers’ standards. 3. Silencing. Power construction equipment (including combustion engines), fixed or mobile, shall be equipped with silencing devices consistent with manufacturer’s standards, if available. Equipment shall be properly maintained, and the project applicant or owner shall require any construction contractor to keep documentation on-site during any earthwork or construction activities demonstrating that the equipment has been maintained in accordance with manufacturer’s specifications. 4. Stationary Equipment. All stationary construction equipment shall be placed so that emitted noise is directed away from the nearest sensitive receptors. 5. Signage and Noise Complaint Coordinator The project applicant shall designate an on-site construction project manager who shall be responsible for responding to any complaints about construction noise. This person shall be responsible for responding to concerns of neighboring properties about construction noise disturbance and shall be available for responding to any construction noise complaints during the hours that construction is to take place. They shall also be responsible for determining the cause of the noise complaint (e.g., bad silencer) and shall require that reasonable measures be implemented to correct the problem. A toll-free telephone number shall be posted at construction site entrances for the duration of construction and provided in all notices (mailed, Project Applicant/ verified by the Planning & Development Services Department Prior to issuance of a grading permit During grading and construction City of Palo Alto Planning & Development Services Department Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 37  Packet Pg. 115 of 517  City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 7 Mitigation Measure Implementation Compliance Implementation complaints during construction and shall also include procedures requiring that the on-site construction manager to respond to callers. The on-site construction project manager shall be required to track complaints pertaining to construction noise, ongoing throughout demolition, grading, and/or construction and shall notify the City’s Community Development Director of each complaint occurrence. 6. Smart Back-Up Alarms. Mobile construction equipment shall have smart back-up alarms that automatically adjust the sound level of the alarm in response to ambient noise levels. 7. Equipment Idling. Construction vehicles and equipment shall not be left idling for longer than five minutes when not in use. 8. Temporary Noise Barriers. Erect a temporary noise barrier along the eastern project boundary, and the southern and western project boundaries, where feasible, during demolition and grading/excavation phases. Temporary noise barriers shall be constructed with solid materials (e.g., wood) with a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier at a minimum height of 12 feet. Where a solid barrier is not feasible, sound blankets affixed to the construction fencing shall be used. If a sound blanket is used, the sound blanket must have a density of at least 1 pound per square foot with no gaps from the ground to the top of the construction fencing, and the sound blank shall be rated sound transmission class (STC) 32 or higher. N-2. Construction Vibration Control Plan. The construction contractor shall prepare a Vibration Control Plan prior to issuance of a grading permit. The Construction Vibration Control Plan shall specify the vibration reduction measures to be implemented during project construction to ensure vibration levels are reduced to 0.2 in/sec PPV at nearby residences. The measures specified in the Construction Vibration Control Plan shall be included on the building and grading plans and shall be implemented by the construction contractor during construction. At a minimum, the Construction Vibration Control Plan shall include the following measures: 1. For paving activities within 25 feet of offsite residences, a static roller shall be used in lieu of a vibratory roller. 2. For grading and earthwork activities (not including the drop-bucket or scoop) within 15 feet of offsite residences, off-road equipment shall be limited to 100 Project Applicant/ verified by the Planning & Development Services Department Prior to issuance of a grading permit During grading and construction City of Palo Alto Planning & Development Services Department Tribal Cultural Resources TCR-1. Unanticipated Discovery of Tribal Cultural Resources. In the event that Project Applicant/ During ground City of Palo Alto Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 38  Packet Pg. 116 of 517  City of Palo Alto  Mitigation Monitoring + Reporting Program P a g e | 8 Mitigation Measure Implementation Compliance Implementation the proposed project, all earth-disturbing work within 50 feet of the find shall be temporarily suspended or redirected until an archaeologist and culturally affiliated Native American representative have evaluated the nature and significance of the find. If the City, in consultation with local Native Americans, determines that the resource is a tribal cultural resource and thus significant under CEQA, a mitigation plan shall be prepared and implemented in accordance with state guidelines and in consultation with local Native American group(s). The plan shall include avoidance of the resource or, if avoidance of the resource is infeasible, the plan shall outline the appropriate treatment of the resource in coordination with the culturally affiliated local Native American tribal representative and, if applicable, a qualified archaeologist. Examples of appropriate mitigation for tribal cultural resources include, but are not limited to, protecting the cultural character and integrity of the resource, protecting traditional use of the resource, protecting the confidentiality of the resource, or heritage recovery. Planning & Development Services Department Services Department Item 6 Attachment B - Resolution Certifying the Environmental Impact Report and Adopting the MMRP        Item 6: Staff Report Pg. 39  Packet Pg. 117 of 517  9 4 8 8 *Not Yet Adopted* Item 6 Attachment C - Draft Comprehensive Plan Amendment Resolution        Item 6: Staff Report Pg. 40  Packet Pg. 118 of 517  9 4 8 8 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. The proposed amendment would allow for i a mix of new housing, amenity space, and retention of commercial uses. This would maintain the existing character of the neighborhoods in which the uses are located. Policy L-1.5: Regulate land uses in Palo Alto according to the land use definitions in this Element and Map L-6 The proposed amendments ensure compliance with this policy and modify the land use map to align with past, current, and future uses of the site in order to address current inconsistencies between the map and existing uses and to facilitate future mixed-use projects utilizing the Planned Community process. Policy L-1.6: Encourage land uses that address the needs of the community and manage change and development to benefit the community. The proposed amendment takes into consideration the needs of the community by maintaining existing uses, including medical offices and neighborhood serving businesses within walking distance of residences. 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. The amendments allows for extended access to services and jobs within walking distance of residences, that cater to the daily needs to residents. Policy L-2.6: Create opportunities for new mixed-use development consisting of housing and retail. The comprehensive plan amendment would allow for a mix of uses on a site where currently only residential uses are allowed. SECTION 3. The City Council hereby amends the description of the Multiple-Family Land Use Designation in the City of Palo Alto Comprehensive Plan Land Use and Community Design Element to read as follows: 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 may be allowed where measurable community benefits will be derived, services and 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. Item 6 Attachment C - Draft Comprehensive Plan Amendment Resolution        Item 6: Staff Report Pg. 41  Packet Pg. 119 of 517  9 4 8 8 As part of a Planned Community zone, or in accordance with retail preservation requirements, existing commercial square footage may be maintained or rebuilt, as part of a housing development project. SECTION 4. In conformance with the California Environmental Quality Act (CEQA), the environmental impacts of this Resolution were evaluated in an Environmental Impact Report for the 660 University Project, which the Council considered and adopted, together with the related Mitigation Monitoring and Reporting Plan (MMRP) on ______________ in accordance with Resolution ___________. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: __________________________ _____________________________ City Clerk Mayor __________________________ __________________________ APPROVED AS TO FORM: APPROVED: Assistant City Attorney City Manager Item 6 Attachment C - Draft Comprehensive Plan Amendment Resolution        Item 6: Staff Report Pg. 42  Packet Pg. 120 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 1 Ordinance No. ____ Ordinance of the Council of the City of Palo Alto Amending Section 18.08.040 of the Palo Alto Municipal Code (The Zoning Map) to Change the Classification of Property Located at 511 Byron St, 660 University Ave, and 680 University Ave/500 Middlefield Rd from RM-20 Low Density Multiple-Family Residential (RM-20) to Planned Community (PC) The Council of the City of Palo Alto ORDAINS as follows: SECTION 1. Findings and Declarations. (a) On December 21, 2021, Lund Smith of Smith Development (“Applicant”) submitted an application for Rezoning to Planned Community/Planned Home Zoning (PHZ) to deconstruct two existing medical office buildings (9,216 square feet) and redevelop the site at 511 Byron St, 660 University Ave, and 680 University Ave/500 Middlefield Rd (the “Subject Property,” more particularly described in Exhibit A) with a residential mixed use development. Following several revisions, the project includes a new six-story mixed-use building with 66 multi-family residential units and 1,984 square feet of commercial office space, plus ground floor resident common space, an office lobby, and a fitness area for residents and office tenants. The 66 units include 19 studios, 39 one-bedroom and eight two-bedroom units and a two level below-grade parking garage. This project also includes a Request for a Comprehensive Plan Amendment to allow commercial use to replace existing medical office in the Multiple Family Residential Land Use Designation. (the “Project”). The applicant proposes to merge the three existing lots at the Subject Property through a separate application. (b) Following Staff Review, the Planning and Transportation Commission (“PTC” or “Commission”) reviewed the project on November 16, 2022 and forwarded the project to the Architectural Review Board. (c) The Architectural Review Board (“ARB” or “Board”) initially reviewed the project on December 1, 2022 and, following applicant modifications, reviewed the project again on April 18, 2024 and recommended approval of the project to the City Council. (d) Following the ARB’s April 2024 recommendation, the applicant again made modifications to the plans. The ARB reviewed further revised plans on December 5, 2024 and recommended approval of the project to the City Council. (e) The PTC reviewed the revised project on March 12, 2025; and continued the hearing to date uncertain. (f) Following the PTC’s March 2025 hearing, the applicant made substantial modifications to the plans. The ARB again reviewed further revised plans on August 21, 2025 and recommended approval of the project to the City Council. Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 43  Packet Pg. 121 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 2 (g) The PTC reviewed the revised project on October 8, 2025 and recommended approval of the project to the City Council with conditions. (h) Approval of the Planned Community Project would constitute a project under the provisions of the California Environmental Quality Act of 1970, together with related state and local implementation guidelines promulgated thereunder (“CEQA”). (i) The City is the Lead Agency pursuant to Public Resources Code section 21067 as it has the principal responsibility to approve and regulate the Planned Community Project. (j) The City, in compliance with CEQA, prepared a Draft Environmental Impact Report for the project. The Draft EIR was circulated for public review from April 2, 2024 to May 17, 2024. The Draft EIR found there are no significant and unavoidable environmental impacts. A response to comments and Final EIR, published in March 2025, maintained there are no significant and unavoidable impacts associated with the revisions made to the design. A revised Final EIR, published in September 2025, did not result in any change to these conclusions. (k) The Council is the decision-making body for approval of the Planned Community Project. (l) The site is so situated, and the use or uses proposed for the site are of such characteristics that the application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development. Specifically, the project proposes mixed use development with a XXX FAR and a 73.6 foot height, setbacks ranging from zero to sixteen feet, reduced open space and a parking reduction in excess of what is permitted by code. The existing RM-20 zoning does not allow the proposed commercial use and no other existing zoning district would permit the project as proposed. In order to provide the floor area, lot coverage, setbacks, and other standards that allow for development of the project as proposed, a planned community rezoning is necessary. (m) Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts, as set forth in Section 6 of this ordinance. (n) The use or uses permitted, and the site development regulations applicable within the district are consistent with the Palo Alto Comprehensive plan, as amended, and compatible with existing and potential uses on adjoining sites or within the general vicinity, as set forth in the Record of Land Use Action (Exhibit B) accompanying this ordinance. SECTION 2. Amendment of Zoning Map. Section 18.08.040 of the Palo Alto Municipal Code, the “Zoning Map,” is hereby amended by changing the zoning of Subject Property from Low Density Multiple-Family Residential (RM-20) to “Planned Community Zone (PC) _____”. SECTION 3. Project Description. Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 44  Packet Pg. 122 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 3 The Project as a whole is described in the Development Plan, titled “660 University Avenue, Palo Alto, CA” and uploaded to the Palo Alto Online Permitting Services Citizen Portal on October 22, 2025. With respect to the Subject Property, the project comprises the uses included in this Ordinance, depicted on the Development Plans, incorporated by reference, including the following components: (a) Redevelopment of the Subject Property, as described in more detail in the Development Plan, including deconstruction of two existing medical office buildings, and construction of a new six-story mixed- use building with 70 residential rental units, approximately 1,984 square feet of office, and a two level below-grade parking garage. Fourteen of the proposed residential units will be deed restricted to be rented at below market rates as follows: Studio Unit One Bedroom Two Bedroom Extremely Low Income Very Low Income 1 1 Low Income 2 2 1 Moderate Income 1 4 1 Totals 4 7 2 (b) Merger of three existing lots through a separate application. SECTION 4. Land Uses (a) The following land uses shall be permitted: (1) Multi-family residential; (2) Up to 1,984 square feet, as depicted in the project plans, of office uses and neighborhood-serving uses, as defined in Palo Alto Municipal Code Section 18.16.030; (3) Accessory facilities and uses customarily incidental to permitted uses. SECTION 5. Site Development Regulations and Development Schedule (a) Development Standards: Development standards for the Subject Property shall be those conforming to the Development Plans. (b) Parking and Loading Requirements: Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 45  Packet Pg. 123 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 4 The Owner shall provide parking and loading as set forth in the Development Plan. Specifically, the Owner shall provide 78 parking spaces. (c) Modifications to the Development Plan, Land Uses and Site Development Regulations: Once the project has been constructed consistent with the approved Development Plan, any modifications to the exterior design of the Development Plan or any new construction not specifically permitted by the Development Plan or the site development regulations contained in Section 5 (a) – (b) above shall require an amendment to this Planned Community zone. Any use not specifically permitted by this ordinance shall require an amendment to the PC ordinance, as required by Palo Alto Municipal Code 18.38.050. (g) Development Schedule: The project is required to include a Development Schedule pursuant to PAMC §18.38.100. The applicant has indicated that development is anticipated to begin in June 2027 and conclude in May 2028. Notwithstanding the above, construction of the project shall commence within two years of the effective date of this ordinance. Prior to expiration of this timeline, the Owner may seek a one- year extension from the Director of Planning and Development Services. All construction and development of the project shall be complete within 3 years of the start of construction. SECTION 6. Public Benefits. (a) Public Benefits Development of the Project Site under the provisions of the PC Planned Community District will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. The public benefit provided by the Project is fourteen dwelling units at below market rates as further described in Section 3. This exceeds the base requirement in Palo Alto Municipal Code Chapter 16.65 and the onsite rental requirement set forth in Ordinance 5623, Section 3. SECTION 7. Environmental Review The City, in compliance with CEQA, prepared a Draft Environmental Impact Report for the project. The Draft EIR was circulated for public review from April 2, 2024 to May 17, 2024. The Draft EIR found there are no significant and unavoidable environmental impacts. A response to comments and Revised Final EIR published October 1, 2025 maintained there are no significant and unavoidable impacts associated with the revisions made to the design. // // Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 46  Packet Pg. 124 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 5 SECTION 8. Effective Date This ordinance shall be effective on the thirty-first day after the date of its adoption (second reading). INTRODUCED: PASSED: AYES: NOES: ABSTENTIONS: ABSENT: ATTEST: APPROVED: __________________________ City Clerk APPROVED AS TO FORM: __________________________ Assistant City Attorney _________________________ Mayor _________________________ City Manager __________________________ Director of Planning and Development Services Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 47  Packet Pg. 125 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 6 Exhibit A Legal Description REAL PROPERTY IN THE CITY OF PALO ALTO, COUNTY OF SANTA CLARA, STATE OF CALIFORNIA, DESCRIBED AS FOLLOWS: Parcel 1: All of Lots 59 and 60, and the Southwesterly 9 feet, front and rear measurements of lot 58, as shown on the map of MAP OF NELSON J. BIRD'S SUBDIVISION OF BLOCK 42, UNIVERSITY PARK (NOW PALO ALTO), which map was filed for record in the Office of the Recorder of the County of Santa Clara, State of California, November 23, 1889 in Book D of Maps, Page 149. Parcel 2: All of Lots 56 and 57, and the Northeasterly 16 feet, front and rear measurements of lot 58, as shown on the MAP OF NELSON J. BIRD'S SUBDIVISION OF BLOCK 42, UNIVERSITY PARK (NOW PALO ALTO), which map was filed for record in the Office of the Recorder of the County of Santa Clara, State of California, November 23, 1889 in Book D of Maps, Page 149. Parcel 3: Lots 52, 53, 54 and 55, MAP OF NELSON J. BIRD'S SUBDIVISION OF BLOCK 42, UNIVERSITY PARK, filed November 23, 1889 in Book D of Maps, Page 149, Santa Clara County Records. APN: 120-03-042 (Affects Parcel 1); 120-03-043 (Affects Parcel 2); and 120-03-044 (Affects Parcel 3) Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 48  Packet Pg. 126 of 517  *NOT YET APPROVED* 0290177_20251030_ay16 7 Exhibit B Record of Land Use Action Item 6 Attachment D - Draft PC Ordinance        Item 6: Staff Report Pg. 49  Packet Pg. 127 of 517  Page 1 of 21 6 2 2 7 APPROVAL NO. 2025-____ On _______, the City Council of the City of Palo Alto (“City Council”) approved a Comprehensive Plan Text Amendment and Planned Community Rezoning, making the following findings, determinations, and declarations: SECTION 1. Background. A. On December 21, 2021 Architect Amanda Borden, on behalf of Smith Properties and Palo Alto Dental Research A Corp (“Applicant”) applied for a Planned Community Rezoning and Comprehensive Plan Text Amendment to construct a residential mixed-use building. As the result of several revisions, the project includes a new six-story mixed-use building with 66 multi-family residential units and 1,984 square feet of commercial office space, plus ground floor resident common space, an office lobby, and a fitness area for residents and office tenants. The 66 units include 19 studios, 39 one-bedroom and eight two-bedroom units and a two level below-grade parking garage. This project also includes a Request for a Comprehensive Plan Amendment to allow commercial use to replace existing medical office in the Multiple Family Residential Land Use Designation. B. The project site consists of three existing parcels located at 511 Byron Street, 0 University Avenue, and 680 University-500 Middlefield (APNs 120-03-042, 120-03-043, 120-03-044) totaling 0.52 acres. Existing improvements include two existing medical office buildings totaling 9,216 sf, and associated parking. C. On October 25, 2021 Council conducted a prescreening review of the proposed legislative actions in accordance with PAMC 18.79. D. On November 16, 2022 the Planning and Transportation Commission held a duly noticed public hearing and recommended that the applicant submit the proposed plans to the Architectural Review Board based on the conceptual design and proposed project in accordance with the Planned Community Rezoning process. E. Following the Planning and Transportation Commission’s initial review, the Architectural Review Board held a duly noticed public hearing on December 1, 2022 to provide feedback and allow for public comment on the proposed project. After receiving ARB and PTC comments at hearings set forth below, the plans were resubmitted in October and December 2023, February and May 2024, and June 23, 2025. F. On April 18, 2024, December 5, 2024, and August 21, 2025, the ARB held duly noticed public hearings on project revisions and on each occasion recommended approval of the proposed project. I. On March 12, 2025 and October 8, 2025 PTC reviewed the project plans as revised and the associated Planned Community Ordinance and Comprehensive Plan Amendment, and on each occasion recommended approval. J. On November 11, 2025 the City Council reviewed the request for a Comprehensive Plan Amendment and Planned Community rezoning. After hearing public testimony, the Council voted to approve/adopt: Resolution _______adopting the EIR; Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 50  Packet Pg. 128 of 517  Page 2 of 21 6 2 2 7 Resolution _______amending the Comprehensive Plan Text; and Ordinance________ amending the zoning of the proposed resulting parcel to Planned Community This Record of Land Use Action K. This application is subject to the conditions set forth in Section 6 of this Record of Land Use Action. SECTION 2. Environmental Review. In accordance with the California Environmental Quality Act (CEQA) the City prepared an Environmental Impact Report (“EIR”) for the 660 University Avenue Mixed-Use Project to provide an assessment of the potential environmental consequences of approving and constructing the Project. A Draft EIR was circulated for public review for a 45-day period from April 2, 2024, through May 17, 2024. A Final EIR was prepared to respond to comments and published on October 1, 2025. The City Council certified and made related findings by Resolution No ________on November 11, 2025, prior to approval of the decision that is the subject of this RLUA. All mitigation measures as stated in the approved Mitigation Monitoring and Reporting Program (MMRP) have been incorporated into the conditions of approval. The MMRP is included in Exhibit A of this Record of Land Use Action. SECTION 3. PLANNED COMMUNITY FINDINGS Finding #1: The site is so situated, and the use or uses proposed for the site are of such characteristics that the application of general districts or combining districts will not provide sufficient flexibility to allow the proposed development. The project is consistent with Finding #1 because: The proposed project includes a density of units for the site that exceed what is allowed by the RM-20 zoning. It has street frontage on three sides, and a protected Oak tree overhanging the fourth side, which results in larger setbacks and a smaller buildable area than other (interior) lots of a similar size. Finding #2: Development of the site under the provisions of the PC planned community district will result in public benefits not otherwise attainable by application of the regulations of general districts or combining districts. In making the findings required by this section, the planning commission and city council, as appropriate, shall specifically cite the public benefits expected to result from use of the planned community district. The project is consistent with Finding #2 because: The primary public benefit for this project is additional housing units to assist the City in reaching their Regional Housing Needs Assessment goals. Under the RM-20 zoning, the maximum development potential of this property would be 10 units, but through this PC application, the project proposes 66 units. The project proposes 20% (13) of the units to be designated Below Market Rate, half of which are allocated to Very Low Income and Low Income households. Finding #3: The use or uses permitted, and the site development regulations applicable within the district shall be consistent with the Palo Alto Comprehensive Plan, and shall be compatible with existing and potential uses on adjoining sites or within the general vicinity. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 51  Packet Pg. 129 of 517  Page 3 of 21 6 2 2 7 The project is consistent with Finding #3 because: This project requires approval of the proposed Comprehensive Plan Amendment to allow maintaining the existing office use. The project is otherwise compatible with the Comprehensive Plan as detailed further in Section 4 Finding #1 below. The proposed uses are compatible with the surrounding neighborhood, as it is primarily multiple-family housing and small offices. Additional care has been taken to ensure viability of the neighboring Oak tree. SECTION 4. ARCHITECTURAL REVIEW FINDINGS Finding #1: The design is consistent with applicable provisions of the Palo Alto Comprehensive Plan, Zoning Code, coordinated area plans (including compatibility requirements), and any relevant design guides. The project is consistent with Finding #1 because: With approval of the requested Comprehensive Plan Amendment and Planned Community Rezoning in accordance with Ordinance _______ and _______, the proposed project complies with the zoning code and Comprehensive Plan. The project is not located within a coordinated area plan area. The proposed project is consistent with relevant goals and policies set forth in the Comprehensive Plan. Below is an analysis of the applicable goals and policies: Comp Plan Goals and Policies How project adheres or does not adhere to Comp Plan The Comprehensive Plan land use designation for the site is Multiple Family Residential. The project proposes high-density housing in an area designated for high-density housing. The project includes a Comprehensive Plan text amendment to allow for existing non-conforming office uses to be redeveloped when part of a new mixed-use development. This would align the proposed project with the underlying comprehensive plan land use designation. Land Use Element 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. This project proposes to redevelop two existing medical office buildings into a mixed-use, office and multiple-family residential rental building within the Downtown neighborhood. 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. This project includes 13 BMR units, which is 20% of the 66 provided housing units. Policy L-2.11 Encourage new development and redevelopment to incorporate greenery and natural features such as green rooftops, pocket parks, plazas and rain gardens. The proposed building includes a deck area for the office and individual balconies for the residents, in keeping with the urban character of the project and neighborhood. Greenery is incorporated into the ground level planters. Policy L-6.1 Promote high-quality design and site The proposed residential building will act as a Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 52  Packet Pg. 130 of 517  Page 4 of 21 6 2 2 7 planning that is compatible with surrounding development and public spaces. gateway to the Downtown area and meets the Architectural Review Board findings for approval. 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. The proposed project is six stories, two stories taller than the nearby Lytton Gardens and The Hamilton residences. While it will be the tallest building in the immediate area, overall it is compatible with the Downtown neighborhood. Policy T-1.19 Provide facilities that encourage and support bicycling and walking. The project includes sufficient short and long term bicycle parking in compliance with the code requirements. Finding #2: The project has a unified and coherent design, that: a. creates an internal sense of order and desirable environment for occupants, visitors, and the general community, b. preserves, respects and integrates existing natural features that contribute positively to the site and the historic character including historic resources of the area when relevant, c. is consistent with the context-based design criteria of the applicable zone district, d. provides harmonious transitions in scale, mass and character to adjacent land uses and land use designations, e. enhances living conditions on the site (if it includes residential uses) and in adjacent residential areas. The project is consistent with Finding #2 because: There is internal order between the ground floor lobby and amenity spaces, ground floor office, and upper floor residences. There are separate, defined entrances for the residents and office tenants. There are no historic resources on this property. The context-based design criteria do not apply. However, the project incorporates many of the design intents and is consistent with the Architectural Review findings for approval. The six-story building is taller than nearby four-story buildings. However, this is to accommodate the mixed use ground floor for flood zone requirements, and to respect the Middlefield special setback. It will enhance the residential options Downtown by providing additional units at various sizes. Finding #3: The design is of high aesthetic quality, using high quality, integrated materials and appropriate construction techniques, and incorporating textures, colors, and other details that are compatible with and enhance the surrounding area. The project is consistent with Finding #3 because: The project incorporates a variety of materials, including gray cast concrete, wood tone panels, painted siding, glass, and landscape elements that are of high quality and that integrate well to create a cohesive design. The project proposes on site Public Art, which will also enhance the design. The project will stand out from other nearby buildings, because it uses a variety of materials to break up the massing and add visual interest. Most other buildings in the area use a more limited palette. Finding #4: The design is functional, allowing for ease and safety of pedestrian and bicycle traffic and providing Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 53  Packet Pg. 131 of 517  Page 6 of 21 6 2 2 7 for elements that support the building’s necessary operations (e.g. convenient vehicle access to property and utilities, appropriate arrangement and amount of open space and integrated signage, if applicable, etc.). The project is consistent with Finding #4 because: The driveway to the below grade garage is located on Byron St. due to traffic limitations on University Avenue and Middlefield Road. The bike rooms are located below grade and are accessible by stair or by elevator. Building operations such as refuse collection and utilities have been designed to be oriented towards the side streets to create a cohesive façade along University Ave. Pedestrian access is clear and a separate entrance is provided for the residents and office users. The project is consistent with Finding #5 because: The project is consistent with the finding in that the project provides landscaped area around the perimeter wherever possible, including 9 new trees, and 4 new street trees (13 trees total), as well as in planter boxes on the rooftop garden. The project will protect the Coast Live Oak and provides measures to ensure the tree’s protection through construction. All plants proposed are very low to moderate water use, as well as native or regionally adapted. The project is consistent with Finding #6 because: In accordance with the City’s Green Building Regulations, the building will satisfy the requirements for CALGreen Mandatory + Tier 2. The project proposed an all electric design and will be consistent with Model Water Efficiency Landscape Ordinance (MWELO) requirements. SECTION 5. Conditions of Approval. 1. CONFORMANCE WITH PLANS: Construction and development shall conform to the approved plans entitled, "660 University Ave., Palo Alto, CA,” uploaded to the Palo Alto Online Permitting Services Citizen Portal on October 21 and 22, 2025, as modified by these conditions of approval. 2. BUILDING PERMIT: Apply for a building permit and meet any and all conditions as contained in this document. 3. BUILDING PERMIT PLAN SET: A copy of this cover letter and conditions of approval shall be printed on the second page of the plans submitted for building permit. 4. PROJECT MODIFICATIONS: All modifications to the approved project shall be submitted for review and approval prior to construction. If during the Building Permit review and construction phase, the project Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 54  Packet Pg. 132 of 517  Page 7 of 21 6 2 2 7 is modified by the applicant, it is the responsibility of the applicant to contact the Planning Division/project planner directly to obtain approval of the project modification. It is the applicant’s responsibility to highlight any proposed changes to the project and to bring it to the project planner’s attention. 5. ENTITLEMENT EXPIRATION. The project approval shall be valid for a period of two years from the date of issuance of the entitlement. If within such one/two years period, the proposed use of the site or the construction of buildings has not commenced, the Planning entitlement shall expire. Application for a one year extension of this entitlement may be made prior to expiration. 6. MITIGATION MONITORING AND REPORTING PROGRAM. The Mitigation Monitoring and Reporting Program (MMRP) associated with the project and attached here as Exhibit A is incorporated by reference and all mitigation measures shall be implemented as described in said document. Prior to requesting issuance of any related demolition and/or construction permits, the applicant shall meet with the Project Planner to review and ensure compliance with the MMRP, subject to the satisfaction of the Director of Planning of Planning and Development Services. 7. LANDSCAPE PLAN. Plantings shall be installed in accordance with the approved plan set and shall be permanently maintained and replaced as necessary. 8. BASEMENT EXCAVATION: Any retaining wall required for basement excavation shall not prevent the planting and future growth of required landscaping. This shall be review by the Project Planner prior to issuance of a Building permit. 9. NOISE THRESHOLDS ON RESIDENTIAL PROPERTY. In accordance with PAMC Section 9.10.030, No person shall produce, suffer or allow to be produced by any machine, animal or device, or any combination of same, on residential property, a noise level more than six dB above the local ambient at any point outside of the property plane. All noise producing equipment shall be located outside of required setbacks. 10. OPEN AIR LOUDSPEAKERS (AMPLIFIED MUSIC). In accordance with PAMC Section 9.12, no amplified music shall be used for producing sound in or upon any open area, to which the public has access, between the hours of 11:00pm and one hour after sunrise. 11.NOISE REPORT AT BUILDING STAGE. An analysis of the proposed project’s compliance with the City’s noise requirements for the proposed HVAC was prepared as part of the documentation to support a Class 32 categorical exemption. At the time of building permit issuance for new construction or for installation of any such mechanical equipment, if the proposed equipment exceeds the anticipated noise level that was analyzed or is proposed in a location that is closer to the property line, the applicant shall submit an acoustical analysis by an acoustical engineer demonstrating projected compliance with the Noise Ordinance. The analysis shall be based on acoustical readings, equipment specifications and any proposed sound reduction measures, such as equipment enclosures or insulation, which demonstrate a sufficient degree of sound attenuation to assure that the prescribed noise levels will not be exceeded. 12. LIGHTING. For the office use only, between the hours of 10:00pm-6:00am (normal cessation of business hours), lighting within the building or on the property shall be reduced to its minimum necessary to facilitate security, in order to minimize light glare at night. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 55  Packet Pg. 133 of 517  Page 8 of 21 6 2 2 7 13. WINDOW SHADES. For the office use only, between the hours of 10:00pm-6:00am (normal cessation of business hours), automatic shades shall be utilized to further reduce the light visible from the exterior at night. 14. SIGN APPROVAL NEEDED. No signs are approved at this time. All signs shall conform to the requirements of Title 16.20 of the Palo Alto Municipal Code (Sign Code) and shall be subject to approval by the Director of Planning. 15. AFFORDABLE HOUSING REQUIREMENT (RENTAL PROJECT). This project is subject to the affordable housing requirements set forth in Section 16.65.040 of the Palo Alto Municipal Code, and has chosen alternative compliance as a part of the Planned Home Zoning (PHZ) approval. Per the PHZ, at least 20% of the units shall be affordable to very low, low, or moderate income such that the income restricted units average out to no more than 80% AMI. The proposed project is required to contain no less than thirteen (13) below market rate units, allocated as described in the Planned Community (PC) Ordinance. 16.AFFORDABLE HOUSING PLAN AND AGREEMENT. The applicant shall prepare an affordable housing plan. An affordable housing agreement, reviewed and approved by the City of Palo Alto, shall be recorded prior to the approval of any final or parcel map or building permit for the development project (PAMC 16.65.090). 17.BELOW MARKET RATE (BMR) HOUSING. A Regulatory Agreement in a form acceptable to the City Attorney for the 13 BMR units shall be executed and recorded prior to final map approval or building permit issuance, whichever occurs first. All BMR units constructed under this condition shall be in conformance with the City’s BMR Program rules and regulations. Failure to comply with the timing of this condition and any adopted BMR Program rules and regulations shall not waive its later enforcement. Failure to comply with the timing of this condition and any adopted BMR Program rules and regulations shall not waive its later enforcement. 18. TRASH ROOM. The trash room shall be used solely for the temporary storage of refuse and recycling that is disposed on a regular basis and shall be closed and locked during non-business hours. 19. REFUSE. All trash areas shall be effectively screened from view and covered and maintained in an orderly state to prevent water from entering into the garbage container. No outdoor storage is allowed/permitted unless designated on the approved plan set. Trash areas shall be maintained in a manner to discourage illegal dumping. 20. MECHANICAL LIFT PARKING. Up to 46 required parking spaces may be provided in a puzzle parking system, which allows independent access to each vehicle. The property owner shall have a maintenance agreement with the lift system manufacturer and the system shall be operational at all times. All new renters/employees shall be given instructions on how to operate the lift system. If the lift system is out of operation for any reason, anyone who is not able to retrieve their vehicle within a 10-minute period shall be reimbursed by the property owner or their designee for travel expenses up to $50 per occurrence. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 56  Packet Pg. 134 of 517  Page 9 of 21 6 2 2 7 21. UTILITY LOCATIONS. In no case shall utilities be placed in a location that requires equipment and/or bollards to encroach into a required parking space. In no case shall a pipeline be placed within 10 feet of a proposed tree and/or tree designated to remain. 22. EASEMENT REQUEST. Prior to building permit issuance, the applicant shall dedicate a Public Access Easement over a portion of the 24-foot front yard special setback, including to a depth of 20 feet, for multi-modal transportation improvements in a form acceptable to the Planning and Development Services Director, Public Works Director, and City Attorney. Any future easement may require the removal of site improvements to facilitate multi-modal transportation improvements or Transportation Element Comprehensive Plan policies, except to the extent that the features required for site circulation and egress shall be allowed to remain. The City accepts this may reduce parking from 78 to 72 parking spaces. If future City projects or utility needs require removal or relocation of facilities within this setback, the property owner/developer shall be responsible for all associated costs, including administrative processing and construction fees. The developer shall accept financial responsibility for any such relocation or retrofit required by future City projects. 23. SUBDIVISION MAP. The Lot Merger shall be recorded prior to building permit issuance. 24. ESTIMATED IMPACT FEE: Development Impact Fees, currently estimated in the amount of $3,063,197.53 plus the applicable public art fee, per PAMC 16.61.040, shall be paid prior to the issuance of the related building permit. 25. REQUIRED PUBLIC ART. In conformance with PAMC 16.61, and to the satisfaction of the Public Art Commission, the property owner and/or applicant shall select an artist and received final approval of the art plan, or pay the in-lieu fee equivalent to 1% of the estimated construction valuation, prior to obtaining a Building permit. All required artwork shall be installed as approved by the Public Art Commission and verified by Public Art staff prior to release of the final Use and Occupancy permit. 26. IMPACT FEE 90-DAY PROTEST PERIOD. California Government Code Section 66020 provides that a project applicant who desires to protest the fees, dedications, reservations, or other exactions imposed on a development project must initiate the protest at the time the development project is approved or conditionally approved or within ninety (90) days after the date that fees, dedications, reservations or exactions are imposed on the Project. Additionally, procedural requirements for protesting these development fees, dedications, reservations and exactions are set forth in Government Code Section 66020. IF YOU FAIL TO INITIATE A PROTEST WITHIN THE 90-DAY PERIOD OR FOLLOW THE PROTEST PROCEDURES DESCRIBED IN GOVERNMENT CODE SECTION 66020, YOU WILL BE BARRED FROM CHALLENGING THE VALIDITY OR REASONABLENESS OF THE FEES, DEDICATIONS, RESERVATIONS, AND EXACTIONS. If these requirements constitute fees, taxes, assessments, dedications, reservations, or other exactions as specified in Government Code Sections 66020(a) or 66021, this is to provide notification that, as of the date of this notice, the 90-day period has begun in which you may protest these requirements. This matter is subject to the California Code of Civil Procedures (CCP) Section 1094.5; the time by which judicial review must be sought is governed by CCP Section 1094.6. 27. INDEMNITY. To the extent permitted by law, the Applicant shall indemnify and hold harmless the City, its City Council, its officers, employees and agents (the “indemnified parties”) from and against any Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 57  Packet Pg. 135 of 517  Page 10 of 21 6 2 2 7 claim, action, or proceeding brought by a third party against the indemnified parties and the applicant to attack, set aside or void, any permit or approval authorized hereby for the Project, including (without limitation) reimbursing the City for its actual attorneys’ fees and costs incurred in defense of the litigation. The City may, in its sole discretion, elect to defend any such action with attorneys of its own choice. 28. FINAL INSPECTION: A Planning Division Final inspection will be required to determine substantial compliance with the approved plans prior to the scheduling of a Building Division final. Any revisions during the building process must be approved by Planning, including but not limited to; materials, landscaping and hard surface locations. Contact your Project Planner, Emily Kallas at emily.kallas@cityofpaloalto.org to schedule this inspection. BUILDING 29. A building permit is required for the scope of work shown. Note that Building permit submission after 12/31/25 shall follow the 2025 CA Building Standards Code amended by the City. 30. At time of building permit, the following items shall be reviewed in detail. a. Building and site accessibility per CBC 11A, 11B b. Regular and van accessible spaces including EV per CBC and PAMC c. Building Code analysis d. Fire-rating and protection of opening at roof, floors, and walls e. Green building compliance. f. Structural design calculations, plans, and details. g. Refer to https://www.paloalto.gov/Departments/Planning-Development-Services/Development- Services/Apply-for-a-Permit/Apply-for-a-Building-Permit for building permit submittal requirements. 31. At building permit, provide structural design of the basement wall and parking. Future building permits shall be required for any future city improvements within the Special Setback. PUBLIC WORKS ZERO WASTE 32. Project will be required to submit a salvage survey prior to receiving the building permit. Please anticipate meeting PAMC 5.24 Deconstruction and Construction Materials Management requirements. 33. The following comments below are part of the Palo Alto Municipality Code. If your scope of work includes internal and external bins then cut-sheets for the color-coded internal and external containers, related color-coded millwork, and it’s colored signage must be included in the building plans prior to receiving approval from Zero Waste. Please see below for more details. As per Palo Alto Municipal Code 5.20.108 the site is required to have color-coded refuse containers, related color-coded millwork, and colored signage. The three refuse containers shall include recycle (blue container), compost (green container), and garbage (black container). Applicant shall present on the plan the locations and quantity of both (any) internal and external refuse containers, it’s millwork, along with the signage. This requirement applies to any external or internal refuse containers located in common Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 58  Packet Pg. 136 of 517  Page 11 of 21 6 2 2 7 areas such as entrances, conference rooms, open space, lobby, garage, mail room, gym, and etc. except for restrooms, copy area, and mother’s room. Millwork to store the color-coded refuse containers must have a minimum of four inches in height worth of color-coding, wrapping around the full width of the millwork. Signage must be color coded with photos or illustrations of commonly discarded items. Restrooms must have a green compost container for paper towels and an optional black landfill container if applicable. Copy area must have either a recycle bin only or all three refuse receptacles (green compost, blue recycle, and black landfill container). Mother’s room must minimally have a green compost container and black landfill container. Please refer to PAMC 5.20.108 and the Internal Container Guide. Examples of appropriate signage can be found in the Managing Zero Waste at Your Business Guide. Electronic copies of these signage can be found on the Zero Waste Palo Alto’s website, https://www.cityofpaloalto.org/Departments/Public-Works/Zero-Waste/What-Goes- Where/Toolkit#section-2 and hard copies can be requested from the waste hauler, Greenwaste of Palo Alto, (650) 493-4894. TRANSPORTATION 34. MECHANICAL LIFT: The applicant shall submit an analysis and report, prepared by a qualified professional for review and approval by the Director of Planning and Development Services, that demonstrates the effectiveness of the proposed parking lift system with respect to operational details, identifies a regular and emergency maintenance schedule, and procedures and backup systems for tenants prior to building permit issuance. The applicant agrees to maintain a maintenance service contract with a certified individual/organization that will provide a prompt response (same day) to address system issues. An annual audit of the system must be provided to Planning/Transportation staff of the system to ensure the system operates effectively. If the audit or performance reports reveal that the system is not functioning or is failing to meet required operational standards, the applicant will be required to take corrective measures. Failure to address identified issues may result in penalties or restrictions, including but not limited to enforcement actions under local code enforcement procedures. 35. TDM PROGRAM. The applicant shall abide by the Final Transportation Demand Management (TDM) plan, entitled “660 University Avenue, Transportation Demand Management Prepared for Smith Development”, dated October 24, 2025 or as updated to the satisfaction of the Office of Transportation prior to issuance of the building permit. 36.TDM ANNUAL REPORTING REQUIREMENT. The TDM plan shall include measures and programs to achieve a reduction in single-occupancy vehicle trips to the site by a minimum of 20%, in conformance with the City’s Comprehensive Plan. The TDM plan shall include an annual monitoring plan to document mode split and trips to the project site. The TDM annual report shall be submitted to the Chief Transportation Official. Monitoring and reporting requirements may be revised in the future if the minimum reduction is not achieved through the measures and programs initially implemented. Projects that do not achieve the required reduction may be subject to daily penalties as set forth in the City’s fee schedule. 37. TDM PLAN MONITORING. The Owner and any subsequent Owner(s) of the property, including their successors, assigns, or agents, shall comply with all Transportation Demand Management (TDM) measures set forth in this approval. Monitoring reports shall be submitted to the Chief Transportation Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 59  Packet Pg. 137 of 517  Page 11 of 21 6 2 2 7 Official on an annual basis, demonstrating adherence to the approved TDM measures. Should the Owner fail to meet the established targets and goals of the TDM Plan, the director may require program modifications and may impose administrative penalties if identified deficiencies are not addressed within six months. URBAN FORESTRY a diameter ≥2 inches, shift the hole over by 12 inches and repeat the process. certified arborist in a supervisory role. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 60  Packet Pg. 138 of 517  Page 13 of 21 6 2 2 7 e. All pruning work on oak #10 shall be supervised directly by the project arborist. Any authorized digging within the TPZ shall be supervised directly by the project arborist. Roots encountered with diameters of ≥2 inches shall be retained and protected. Once exposed, cover with wet burlap and keep continually moist until they can be assessed by the project arborist; once assessed, cleanly sever at 90° to the angle of root growth against the cut line using a fine tooth saw, and then immediately after, bury the cut end with soil or keep continually moist by burlap until the dug area is backfilled. Roots encountered with diameters <2 inches can be cleanly severed at a 90° angle to the direction of root growth. f. Removing existing asphalt and base material located beyond the proposed deck and within #10's TPZ shall be performed after all other construction is completed, and under direct supervision by the project arborist. g. Once work is completed, restrict heavy equipment from traveling over the newly exposed ground, manually spread a 4- to 6-inch layer of coarse wood chips (or as determined by the project arborist), and expand protection fencing. The removal of any existing plant material within a TPZ must be manually performed, and the work reviewed with the project arborist beforehand. 44. Expected impacts to neighboring protected coast live oak tree #10 as described in the C8 updated consulting arborist report from David Babby and from the ground penetrating radar study provided by consulting arborist Robert Booty, are within acceptable parameters of industry standards, provided that all mitigation methods outlined in the consulting arborist report are followed during construction. In addition, prior to the applicant receiving building permit approval, a security bond will be placed on the neighboring coast live oak tree (Quercus agrifolia) 50" DBH tree #10 for 200% of the appraised replacement value of the tree. The security deposit duration period shall be five years from the date of final occupancy. See language below pertaining to the tree bond as specified in the Palo Alto Tree Technical Manual: 45. TREE APPRAISAL & SECURITY DEPOSIT AGREEMENT. (Reference: CPA Tree Technical Manual, Section 6.25). Prior to the issuance of a grading or building permit, the applicant shall work with the Urban Forestry Section to prepare and secure a tree appraisal and security deposit agreement stipulating its duration and a monitoring program. For the purposes of a security deposit agreement, the monetary market or replacement value shall be determined using the most recent version of the “Guide for Plant Appraisal”. The appraisal shall be performed at the applicant’s expense, and the appraiser shall be subject to the approval of the Urban Forester. a. SECURITY DEPOSIT AGREEMENT. Prior to grading or building permit issuance, as a condition of development approval, the applicant shall post a security deposit for 200% of the appraised replacement value of the following protected status tree: Tree #10, 50" DBH Quercus agrifolia on the neighboring property. The security may be a cash deposit, letter of credit, or surety bond and shall be filed with the Revenue Collections/Finance Department or in a form satisfactory to the City Attorney. b. SECURITY DEPOSIT & MONITORING PROGRAM. The applicant (or new property owner should the property change hands) shall provide to the City of Palo Alto an annual tree evaluation report prepared by the project arborist or other qualified certified arborist, assessing the condition and providing recommendations to correct potential tree decline. The monitoring program shall end three years from date of final occupancy. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 61  Packet Pg. 139 of 517  Page 13 of 21 6 2 2 7 c. SECURITY DEPOSIT DURATION. The security deposit duration period shall be five years from the date of final occupancy. Return of the security guarantee shall be subject to City approval of the final monitoring report. A tree shall be considered dead when the main leader has died back, 25% of the crown is dead or if major trunk or root damage is evident. Should the tree die, a new tree of equal or greater appraised value shall be planted in the same area by the applicant (or new property owner should the property change hands) with permission of the tree owner at 517 Byron Street. Landscape area and irrigation shall be adapted to provide optimum growing conditions for the replacement tree at applicants expense. The replacement tree that is planted shall be subject to a new three-year establishment and monitoring program. The applicant shall provide an annual tree evaluation report as originally required. d. FORFEIT OF DEPOSIT. The City may determine that if the tree should die (as defined above) and an agreement on a replacement tree cannot be reached with the tree owner at 517 Byron Street, it will constitute a forfeit of the deposit equal to the appraised value. Any forfeit will be deposited into the Forestry Fund to plant new trees elsewhere. Issues causing forfeit of any portion of the deposit may also be subject to remedies described in Palo Alto Municipal Code. PUBLIC WORKS ENGINEERING 46. PUBLIC WORKS APPLICATIONS, FORMS, AND DOCUMENTS: Applicant shall be advised that most forms, applications, and informational documents related to Public Works Engineering conditions can be found at the following link: https://www.cityofpaloalto.org/Departments/Public-Works/Engineering-Services/Forms-and-Permits 47. PARCEL MAP: This project is subject to, and contingent upon the approval of and recordation of a parcel map. The submittal, approval and recordation of the Map shall be in accordance with the provisions of the California Subdivision Map Act and Palo Alto Municipal Code Title 21 Subdivision requirements. All existing and proposed property lines, easements, dedications shown on the parcel map are subject to City’s technical review and staff approval during the map process prior to issuance of any construction permits. 48. MAP THIRD-PARTY REVIEW: The City contracts with a third-party surveyor that will review and provide approval of the map’s technical correctness as the City Surveyor, as permitted by the Subdivision Map Act. The Public Works Department will forward a Scope & Fee Letter from the third-party surveyor and the applicant will be responsible for payment of the fee’s indicated therein, which is based on the complexity of the map. 49. STREETWORK PERMIT: The applicant shall obtain a Streetwork Permit from the Department of Public Works for all public improvements. 50. GRADING AND EXCAVATION PERMIT: A Grading Permit is required per PAMC Chapter 16.28. The permit application and all applicable documents (see Section H of application) shall be submitted to Public Works Engineering. Add the following note: “THIS GRADING PERMIT WILL ONLY AUTHORIZE GENERAL GRADING AND INSTALLATION OF THE STORM DRAIN SYSTEM. OTHER BUILDING AND UTILITY IMPROVEMENTS ARE SHOWN FOR REFERENCE INFORMATION ONLY AND ARE SUBJECT TO SEPARATE BUILDING PERMIT APPROVAL.” Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 62  Packet Pg. 140 of 517  Page 14 of 21 6 2 2 7 51. ROUGH GRADING: provide a Rough Grading Plan for the work proposed as part of the Grading and Excavation Permit application. The Rough Grading Plans shall including the following: pad elevation, elevator pit elevation, ground monitoring wells, limits of over excavation, stockpile area of material, overall earthwork volumes (cut and fill), temporary shoring for any existing facilities, ramps for access, crane locations (if any), tree protection measures, etc. 52. CIVIL ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide an as-graded grading plan prepared by the civil engineer that includes original ground surface elevations, as-graded ground surface elevations, lot drainage patterns and locations and elevations of all surface and subsurface drainage facilities. The civil engineer shall certify that the work was done in accordance with the final approved grading plan. 53. SOILS ENGINEER CERTIFICATION: Upon completion of the rough grading work and at the final completion of the work, applicant shall provide a soil grading report prepared by the soils engineer, including locations and elevation of field density tests, summaries of field and laboratory tests and other substantiating data, and comments on any changes made during grading and their effect on the recommendations made in the soils engineering investigation report. The soils engineer shall certify as to the adequacy of the site for the intended use. 54. SHORING & TIEBACKS: Provide a shoring plan showing the existing utilities (if needed), to clearly indicate how the new structures will be constructed while protecting the existing utilities (if any). If tiebacks are proposed they shall not extend onto adjacent private property, existing easements or into the City’s right- of-way without having first obtained written permission from the private property owners and/or an encroachment permit from Public Works. 55. GEOTECHNICAL ENGINEER STATEMENT: The grading plans shall include the following statement signed and sealed by the Geotechnical Engineer of Record: “THIS PLAN HAS BEEN REVIEWED AND FOUND TO BE IN GENERAL CONFORMANCE WITH THE INTENT AND PURPOSE OF THE GEOTECHNICAL REPORT”. 56. CONSTRUCTION DEWATERING: At the time of building permit submittal, the applicant shall submit a recent groundwater level reading. This project may be subjected to a dewatering permit during construction due to the groundwater level relative to the depth of excavation. 57. FLOOD ZONE: This project is in a FEMA Special Flood Hazard Area and shall comply with the requirements in Palo Alto Municipal Code Chapter 16.52. 58. DRY-FLOODPROOFING PLAN INSERT: Insert the “Plan Insert for Dry Floodproofed Non-Residential and Mixed-Use Buildings” sheet into the plan set. 59. FLOODPROOFING CERTIFICATE: A Floodproofing Certificate (FEMA Form FF-206-FY-22-153, also formerly known as 086-0-34) shall be completed by a licensed professional engineer prior to building permit approval. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 63  Packet Pg. 141 of 517  Page 15 of 21 6 2 2 7 60. FLOODPROOFING PLANS REQUIRED: Prior to building permit final, a licensed professional engineer shall submit a (1) Flood Emergency Operations Plan and (2) Inspection and Maintenance Plan. Additional information may be obtained from Section 5.5 of FEMA Technical Bulletin 3, dated January 2021. 61. OPERATIONS AND MAINTENANCE AGREEMENT: Prior to Public Works final inspection, the owner shall enter into an Operations and Maintenance Agreement to ensure that the Flood Emergency Operations Plan, and the Inspection and Maintenance Plan are followed for the life of the structure and that the agreement will be transferred to future owners and/or leaseholders. This agreement shall be notarized and recorded with the County of Santa Clara and passed on to all subsequent owners. 62. ENCROACHMENT PERMIT: Prior to any work in the public right-of-way, the applicant shall obtain an encroachment permit from the Public Works Department for any work that encroaches onto the City right-of-way. 63. LOGISTICS PLAN: A construction logistics plan shall be provided addressing all impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit. 64. STORMWATER POLLUTION PREVENTION: All improvement plan sets shall include the “Pollution Prevention – It’s Part of the Plan” sheet. 65. C.3 THIRD-PARTY CERTIFICATION: Applicant shall provide certification from a qualified third-party reviewer that the proposed permanent storm water pollution prevention measures comply with the requirements of Provision C.3 and Palo Alto Municipal Code Chapter 16.11. 66. Submit the following: a. Stamped and signed C.3 data form (April 2023 version) from SCVURPPP. https://scvurppp.org/wp-content/uploads/2023/04/SCVURPPP-C.3-Data-Form-_-updated__4- 12-2023_clean_fillable.pdf b. Final stamped and signed letter confirming which documents were reviewed and that the project complies with Provision C.3 and PAMC 16.11. 67. C.3 STORMWATER AGREEMENT: The applicant shall enter into a Stormwater Maintenance Agreement with the City to guarantee the ongoing maintenance of the permanent storm water pollution prevention measures. The City will inspect the treatment measures yearly and charge an inspection fee. The agreement shall be executed by the applicant team prior to building permit final. 68. C.3 FINAL THIRD PARTY CERTIFICATION PRIOR TO OCCUPANCY: Within 45 days of the installation of the required storm water treatment measures and prior to the issuance of an occupancy permit for the Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 64  Packet Pg. 142 of 517  Page 16 of 21 6 2 2 7 building, the third-party reviewer shall submit to the City a certification verifying that all the permanent storm water pollution prevention measures were installed in accordance with the approved plans. WATERSHED PROTECTION Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 65  Packet Pg. 143 of 517  Page 17 of 21 6 2 2 7 75. Stormwater quality protection a. Temporary and permanent waste, compost and recycling containers shall be covered to prohibit fly-away trash and having rainwater enter the containers. b. Drain downspouts to landscaping (outward from building as needed). c. Drain HVAC fluids from roofs and other areas to landscaping. d. Offsite downgrade storm drain inlets shall also be identified on this plan set and protected. If City staff removes protection from an inlet in the ROW during a rain event, the contractor shall replace the inlet protection by the end of the following business day. 76. All proposed Stormwater treatment measures should have a detail on this detail sheet. Provide a standard detail for the pervious pavers. 77. Alternative Compliance for Stormwater Treatment: The applicant and the City shall enter into an agreement acceptable to the Public Works Director or designated representative to provide alternative compliance as either approved equivalent treatment area or with payment of in-lieu fees to comply with the regulated projects stormwater treatment obligations. FIRE 78. Include the following notes in the Building Permit plan set: a. Install a NFPA 13 fire sprinkler, NFPA 14 standpipe, NFPA 20 fire pump and NFPA 72 fire alarm system. b. This building shall be evaluated for an Emergency Responder Radio System. ELECTRICAL UTILITIES 79. UTILITIES APPLICATION. Changes to existing electric utilities equipment on site, such as the transformer, will require a utilities application. Submit a utilities application and obtain City of Palo Alto Utilities Electrical Engineering approval for the modifications to the electrical system. 80. UTILITY EASEMENT REQUIRED. Prior to energization, a public utility easement is required to provide access to the proposed transformer. This can either be provided through separate instrument and documented on the tentative and final map or dedicated through the tentative and final map process. 81. UTILITY DISCONNECT. The applicant shall submit a request to disconnect all existing utility services proposed for removal, including a signed affidavit of vacancy, on the form provided by the Building Inspection Division. Utilities will be disconnected or removed within 10 working days after receipt of request. The demolition permit will be issued after all utility services and/or meters have been disconnected and, as applicable, removed. 82. SPECIAL STREET LIGHT: This project is located within the Downtown area and shall install decorative streetlights as shown in the Special Street Light Style Placement Guide. https://www.paloalto.gov/files/assets/public/v/1/planning-amp-development-services/current- planning/pw-style-placement-guide-2020.pdf 83. Install 1-2" conduit from the MPOE to existing CPAU cabinet. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 66  Packet Pg. 144 of 517  Page 18 of 21 6 2 2 7 WATER-GAS-WASTEWATER UTILITIES PRIOR TO ISSUANCE OF DEMOLITION PERMIT 84. The applicant shall submit a request to disconnect utility services and remove meters. The utility demo is to be processed within 10 working days after receipt of the request. The demolition permit will be issued by the building inspection division after all utility services and/or meters have been disconnected and removed. FOR BUILDING PERMIT (WGW Utility Engineering) 85. The applicant shall submit a completed water-gas-wastewater service connection application - load sheet for the City of Palo Alto Utilities. The applicant must provide all the information requested for utility service demands (water in fixture units/g.p.m. and sewer in fixture units/g.p.d.). The applicant shall provide the existing (prior) loads, the new loads, and the combined/total loads (the new loads plus any existing loads to remain). 86. The applicant shall submit improvement plans for utility construction. The plans must show the size and location of all underground utilities within the development and the public right of way including meters, backflow preventers, fire service requirements, sewer mains, sewer cleanouts, sewer lift stations and any other required utilities. Plans for new wastewater laterals and mains need to include new wastewater pipe profiles showing existing potentially conflicting utilities especially storm drain pipes, electric and communication duct banks. Existing duct banks need to be daylighted by potholing to the bottom of the ductbank to verify cross section prior to plan approval and starting lateral installation. Plans for new storm drain mains and laterals need to include profiles showing existing potential conflicts with sewer, water and gas. 87. The applicant must show on the site plan the existence of any auxiliary water supply, (i.e. water well, gray water, recycled water, rain catchment, water storage tank, etc). 88. The applicant shall be responsible for installing and upgrading the existing utility mains and/or services, and laterals as necessary to handle anticipated peak loads. This responsibility includes all costs associated with the design and construction for the installation/upgrade of the utility mains and/or services/laterals. 89. An approved reduced pressure principle assembly (RPPA backflow preventer device) is required for all existing and new water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPPA shall be installed on the owner's property and directly behind the water meter within 5 feet of the property line. RPPA’s for domestic service shall be lead-free. Show the location of the RPPA on the plans. An approved reduced pressure detector assembly (RPDA backflow preventer device, STD. WD-12A or STD. WD-12B) is required for all existing and new fire water connections from Palo Alto Utilities to comply with requirements of California administrative code, title 17, sections 7583 through 7605 inclusive. The RPDA shall be installed on the owner's property and directly behind the City owned meter, within 5’ (feet) of the property line or City Right of Way. 90. All backflow preventer devices shall be approved by the WGW engineering division. Inspection by the city inspector is required for the supply pipe between the meter and the assembly. Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 67  Packet Pg. 145 of 517  Page 20 of 21 6 2 2 7 91. The applicant shall pay the capacity fees and connection fees associated with new utility service/s or added demand on existing services. The approved relocation of services, meters, hydrants, or other facilities will be performed at the cost of the person/entity requesting the relocation. 92. If a new water service line installation for fire system usage is required. Show the location of the new water service on the plans. The applicant shall provide to the engineering department a copy of the plans for fire system including all fire department's requirements. If the existing fire service to remain. Applicant to sign an application for CPAU connection for & agree to operate the fire service in accordance with these rules & regulations. Applicant needs to verify whether the existing water supply can meet the current & anticipated fire flows at the site & all equipment for the sprinkler system is in accordance with the fire department requirements. 93. Each unit or building shall have its own water meter shown on the plans. Each parcel shall have its own water service and sewer lateral connection shown on the plans. 94. A sewer lateral per lot is required. Show the location of the sewer lateral on the plans. Existing sewer laterals (city's co to sewer main) if determined to be in poor condition shall be replaced at the owner's expense. A video inspection and full evaluation of the lateral will be performed by WGW utilities operations. The applicant will be informed of the sewer lateral assessment and need to install a new lateral. If a new sewer lateral is required, a profile of the sewer lateral is required showing any possible conflicts with storm, electric/communications ductbanks or other utilities. 95. All existing water and wastewater services/laterals that will not be reused shall be abandoned at the main per the latest WGW utilities standards. 96. Utility vaults, transformers, utility cabinets, concrete bases, or other structures cannot be placed over existing water, gas, or wastewater mains/services. Maintain 1’ horizontal clear separation from the vault/cabinet/concrete base to existing utilities as found in the field. If there is a conflict with existing utilities, Cabinets/vaults/bases shall be relocated from the plan location as needed to meet field conditions. Trees may not be planted within 10 feet of existing water, gas, and wastewater mains/laterals/water services/or meters. New water or wastewater services/laterals/meters may not be installed within 10’ of existing trees. Maintain 10’ between new trees and new water and wastewater services/laterals/meters. 97. The applicant shall provide to the WGW Utility Engineering department a copy of the plans for the fire system including all fire department's requirements prior to the actual service installation. 98. All utility installations shall be in accordance with the City of Palo Alto utility standards for water, gas, & wastewater. 99. The contractor is to temporary plug the sewer lateral during construction. (by using t cone plug: expandable pipe plug with no metal parts) Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 68  Packet Pg. 146 of 517  Page 21 of 21 6 2 2 7 SECTION 7. Term of Approval. Planned Community Development Schedule. Sixty days prior to the expiration of the development schedule, the director shall notify the property owner in writing of the date of expiration and advise the property owner of Section 18.38.130. Failure to meet the approved development schedule, including an extension, if granted, shall result in: Item 6 Attachment E - Draft Record of Land Use Action        Item 6: Staff Report Pg. 69  Packet Pg. 147 of 517  6 1 0 8 ATTACHMENT F ZONING COMPARISON TABLE 660 University Avenue, 21PLN-00341 Table 1: COMPARISON WITH CHAPTER 18.13 (RM-20 DISTRICT) AND PROPOSED Regulation Required RM-20 Proposed PHZ Minimum/ Maximum Site Area, Width and Depth 8,500 sf area, 70 foot width, 100 foot depth 103 feet by 225 feet; 22,526 sf (0.52 acre) Minimum Front Yard (Middlefield) 24 foot Special Setback along Middlefield Road 24 feet above grade 0 feet below grade, 17’8” for garage stair Street Rear Yard (Byron)16 feet 12 feet above grade 0 feet below grade and for garage stair Street Side Yard (University)16 feet 7 feet above grade 0 feet below grade Interior Side Yard (for lots greater than 70 feet in width) 10 feet 27 feet 6 inches 2’2” for garage ramp Max. Building Height 30 feet 71’2” at six story parapet 79’8” at elevator overrun Interior Side Yard Daylight Plane 10 feet at interior side lot line then 45 degree angle Partial 4th floor – 6th floor encroachment Max. Site Coverage 35% (plus an additional 5% for covered patios or overhangs) (7,884 + 1,126 = 9,010 sf) 53.3% (12,001 sf) Max. Total Floor Area Ratio 0.5:1 (11,263 sf) 3.05:1 (68,738 sf) Mixed-Use; Replacement Office: 1,984 sf Residential: 66,754 sf Residential Density 11 to 20 units per acre (5 to 10 units)66 DU on 0.52 acre = 126.9 units per acre Minimum Usable Open Space 150 sf per unit 10,500 sf Ground level patio: 735 sf Balconies: ~60 sf per unit (typical), 4,955 sf total Total 86.2 per unit Minimum Common Open Space 75 sf per unit Ground level patio: 735 sf 10.5 sf per unit Minimum Private Open Space 50 sf per unit Every unit has a balcony ranging from 60 sf to >400 sf Item 6 Attachment F - Zoning Consistency Analysis        Item 6: Staff Report Pg. 70  Packet Pg. 148 of 517  6 1 0 8 Table 2: CONFORMANCE WITH CHAPTER 18.38.150 SPECIAL REQUIREMENTS FOR PC Requirement when Adjacent to RE, R-1, R-2, RM or applicable PC district Proposed (b) The maximum height within 150 feet of any RE, R-1, R-2, RMD, RM, or applicable PC district shall be 35 feet 71’2” at six story parapet (c) A minimum interior yard of 10 feet shall be required, and a solid wall or fence between 5 and 8 feet in height shall be constructed and maintained along the common site line. Interior setback 27’6”, project shall include interior fence. (d) A minimum street-side or front yard of 10 feet shall be required. For housing projects, the minimum yard requirement shall be at least as restrictive as the yard requirements of the most restrictive residential district opposite such site line. The minimum yard shall be planted and maintained as a landscaped screen, excluding areas required for access to the site. Setbacks on street frontages range from 7 ft to 25 ft above grade, all are 0 ft below grade (e) A maximum height established by a daylight plane beginning at a height of ten feet at the applicable side or rear site lines and increasing at a slope of three feet for each six feet of distance from the side or rear site lines until intersecting the height limit otherwise established for the PC district; for housing projects, the daylight planes may be identical to the daylight plane requirements of the most restrictive residential district abutting each such side or rear site line until intersecting the height limit otherwise established for the PC district. If the residential daylight plane, as allowed in this section, is selected, the setback regulations of the same adjoining residential district shall be imposed. This project may use the RM-20 daylight plane (10 feet, 45-degree angle) along the interior lot line. However, this project does not comply with PC or RM-20 daylight plane. Table 3: CONFORMANCE WITH CHAPTER 18.52 Off-Street Parking for Multiple-Family Residential Type Required Proposed Office 8 parking spaces 8 parking spacesVehicle Parking Housing 76 parking spaces 70 parking spaces 8% reduction Loading Space for Office None None Proposed Loading Space for Residential One required Off site street space proposed Bicycle Parking Long Term 66 residential 1 office In secure enclosures 80 residential 8 office In secure enclosures Bicycle Parking Short Term 7 rack spaces residential 1 rack space office 8 rack spaces residential 2 rack spaces office Item 6 Attachment F - Zoning Consistency Analysis        Item 6: Staff Report Pg. 71  Packet Pg. 149 of 517  349 Sutter Street San Francisco California 94108 KSH Architects | 349 Sutter Street San Francisco California 94108 | 415.954.1960 PROJECT DESCRIPTION – 660 UNIVERSITY AVE, PALO ALTO Located on a prominent site in Palo Alto, the 660 University project is situated on University Avenue between Middlefield Road and Byron Street. The project proposes a mixed-use 6-story building with two (2) levels of below-grade parking and includes the following: 1,984 square feet of office space on the ground floor; 66 residential units (1 employee unit + 65 rentable units) with an entry lobby; a shared fitness center for office and residential uses; and parking to service both uses. The residential and office entrances are located on University Avenue with recessed alcoves designed to welcome tenants, connected to the sidewalk grade via ramps and stairs. Separate elevators are also provided for each use and are accessible from the below grade parking levels. Natural finishes have been selected for the exterior of the building, including clear glass, board- formed concrete, simulated wood panels and horizontal siding. The residential elevator tower on University Avenue, as well as the stair towers on Middlefield Road and Byron Street, are expressed as sculptural forms highlighted by extensive landscaping at the edges of the site. Changes in plane, setbacks, and projecting balconies further contribute to the character and texture of the proposed building. Three parcels will be combined and two existing office buildings on the site will be demolished in order for this project to proceed. We are estimating that the approximate start date for construction will be 06/01/2027, and the approximate end date for construction will be 05/01/2028. On sheet A0.1 of this submittal package (Project Information), detailed information is provided regarding Land Use, FAR, Unit Counts, Building Area, Density, Parking Counts, Site Coverage, Open Space, Building Height and Setbacks, which is also summarized below for reference. Context The project is designed to be a high-quality addition to Palo Alto. Features include changes in plane, the expression of varied heights in the building volumes, material and color variation, recessed windows and projecting balconies with glass railings. In addition to the private balconies, a terrace for residents is proposed at the ground floor, to provide common open space. The project has taken steps to respond to the surrounding context of the site. The form of the building steps down toward the adjacent residence located at 524 Middlefield Road and responds to the context of the neighboring single-family use lot through setbacks along the common property line. The shared fence between the neighboring property and the site will be updated based on multiple discussions with the resident of 542 Middlefield Road, and the proposal has been received positively by the neighbor. To avoid heavy congestion along Middlefield Road, trash staging has been located on Byron Street for both residential and office uses. The vehicular entry to the parking garage is also located on Byron Street to avoid further congestion along Middlefield Road. The preservation of a large oak tree, located on an adjacent parcel, is incorporated into the design, and conforms to all recommendations and setbacks prescribed by a city approved arborist. An outdoor deck will also be constructed beneath the existing oak tree without disturbing the existing Item 6 Attachment G - Applicant’s Letter        Item 6: Staff Report Pg. 72  Packet Pg. 150 of 517  349 Sutter Street San Francisco California 94108 KSH Architects | 349 Sutter Street San Francisco California 94108 | 415.954.1960 conditions of the root system. The team for this project successfully designed & constructed a similar project at 250 Bryant in Mountain View (3 stories with two levels of below grade parking) around an existing oak tree and has experience with this type of installation. The project front yard (Middlefield Rd) has a special 24 ft. setback that is required per the current zoning map. The design seeks to comply with the 24 ft. setback, but proposes added height in order to deliver the needed housing to Palo Alto. The current 25 ft. setback consists of a landscaped area with trees to transition between the sidewalk and the building. Combined with the 12 ft. sidewalk width, the proposed building is located approximately 37 ft. from the face of the curb on Middlefield Road. The street side yard setback (University Ave.) requires a 16 ft. setback per zoning, or a 0-20’ setback on arterial roadways. The project proposes a 7 ft. setback, and combined with a 12 ft. wide sidewalk, places the building 19 ft. from the face of curb on University Ave. Similarly, the street rear yard (Byron St) proposes a 11 ft. setback where 16 ft. is required. With the 10 ft. sidewalk width, the face of the proposed building is 21 ft. from the face of the curb on Byron Street. The interior side yard requires a 10 ft setback. To accommodate the existing oak tree canopy, our building proposes a 26.5 ft. minimum setback, and a 28.5 ft. maximum setback with additional insets. In addition, while the form of the building steps down to respond to the single family residence at 534 Middlefield Rd., it does not fully comply with the daylight plane condition. This is shown on Sheets A3.3B and A3.3C in the drawing set. Open Space – 35% min. required The proposed design provides 11,144 SF (49.5%) ground level open space as well as the following: 735 SF of private (residential) common terrace area at the ground floor; 4,955 SF of private (residential) balcony area; and 1,067 SF of private (residential) terrace area on the fourth floor (subdivided for the 2 units adjacent). In total, 5,690 SF of private residential balcony & private/common terrace area is provided where 9,900 SF is required. All units are provided with private balconies of minimum 60 square feet each. The ground floor terrace will provide a private space that allows for small and large gatherings, and acts as an extension of the indoor residential lounge directly adjacent. FAR – 0.5:1 max, min. 11 units – max 20 units / acre The proposed non-residential FAR is 0.437 & the proposed residential FAR is 2.614 (66 units for ~ 0.5 acres where 10 are allowed) for a combined proposed FAR of 3.051. This residential FAR calculation includes the proposed units, stairs, elevators, MEP rooms, lobby, and other residential amenities to support the residential units. The project seeks to exceed the allowable FAR in order to provide much needed housing within the downtown community. Item 6 Attachment G - Applicant’s Letter        Item 6: Staff Report Pg. 73  Packet Pg. 151 of 517  349 Sutter Street San Francisco California 94108 KSH Architects | 349 Sutter Street San Francisco California 94108 | 415.954.1960 Jobs/Housing Ratio The existing combined office area (to be removed) on the subject parcels is 9,216 SF, of which 1,984 SF (7,232 SF decrease) is proposed to be replaced within the current project. In addition, the project seeks to provide 66 new housing units (combination of studios, 1-BRs & 2-BRs) to the community. Parking With the proposed project being less than a mile from the University Ave. Caltrain station, the project has proposed a TDM plan to allow for a parking reduction of 8% overall. In addition, the residential parking is composed primarily of independent mechanical stackers with pits (2 vehicles per stall) to limit the below grade scope to two levels and minimize the amount of below grade excavation and potential dewatering that may be required. Affordability The project sponsor is also including the housing affordability component for this project and was planning to distribute the 20% inclusionary requirement across three income levels. Here would be the breakdown of the 13 affordable units (20% of total rentable units): Income Level A (STU) C (1BR) D1 (1BR) D2 (1BR) E (2BR) G1 (STU) G2 (STU) H2 (1BR) K1 (1BR) Total BMR Units (13 total) Very low income 1 1 2 Low Income 1 1 1 1 1 5 Moderate Income 1 1 1 1 1 1 6 Total 13 Unit Type Studio: Unit Type A, B, G1/G2, J (412 – 698 SF) 1 Bedroom: Unit Type C, D1/D2, F1, H1/H2, K1/K2 (568 – 805 SF) 2 Bedroom: Unit Type E, F2 (819 – 880 SF) Item 6 Attachment G - Applicant’s Letter        Item 6: Staff Report Pg. 74  Packet Pg. 152 of 517  349 Sutter Street San Francisco California 94108 KSH Architects | 349 Sutter Street San Francisco California 94108 | 415.954.1960 Unit Design A large variety of different unit plans will be provided, ranging from 412 SF to 880 SF. All units will be provided with at least one private balcony of minimum 60 SF. Two units at the fourth floor (1 1BR unit and 1 2BR unit) provided with larger private terraces of at least ~375 SF each. Each unit will include a full-size ADA compliant bathroom & kitchen with a full-size stacking or side-by-side washer/dryer. Approximately 71% of the units will be 1BR & 2BR, with the remainder provided as studios. Floor Unit A STU Unit B STU Unit C 1BR Unit D1 1BR Unit D2 1BR Unit E 2BR Unit F1 1BR Unit F2 2BR Unit G1 STU Unit G2 STU Unit H1 1BR Unit H2 1BR Unit J STU Unit K1 STU Unit K2 STU Total per Floor Second 2 1 1 1 1 1 1 2 1 2 1 1 1 15 Third 2 1 1 1 1 1 1 2 1 2 1 2 15 Fourth 1 1 1 1 1 1 1 1 2 1 2 12 Fifth 1 1 1 1 1 1 1 1 2 1 2 12 Sixth 1 1 1 1 1 1 1 1 2 1 2 12 Total per Unit 4 2 5 5 2 5 3 3 5 7 5 10 1 5 9 66 RM-20 Zoning compliance The proposed project requests City Council consideration of the following adjustments under a PC application, to approve 66 new units to the RM-20 district: 1. Increased height: The max building height allowed for RM-20 is 30’. The proposed project seeks to provide a 6-story building with max. 54’-11” height to the top of the occupied sixth floor (56’-8 ½” from grade), or 67’-11” height to top of the roof slab (69’-8 ½” from grade). 2. Increased FAR: 0.5 to 3.051 as noted above, including increased density of 66 units from 10/0.5 acre allowed. 3. Reduced parking: 84 stalls are required (8 office + 76 residential, which includes assigned + 2 unassigned ADA). The proposed project seeks to provide a minimum of 78 stalls utilizing a 8% TDM reduction. 4. Open Space: 9,900 SF of private and common residential open space is required. The proposed project seeks to provide less open space than required for the residential tenants (5,690 SF). 5. Daylight Plane: Allowance to not comply with the daylight plane condition adjacent to the single family residence at 534 Middlefield Rd. Item 6 Attachment G - Applicant’s Letter        Item 6: Staff Report Pg. 75  Packet Pg. 153 of 517  1 Kallas, Emily From:Kinsey haffner <haffner_fk@hotmail.com> Sent:Thursday, October 30, 2025 12:23 AM To:Yang, Albert; Kallas, Emily Subject:680 University, the alternative to 660 University, Does Not Qualify For Builder’s Remedy CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. I request that this email and its companion previous email communications on this topic be considered and made a part of the official records and deliberations for the 660 University project (660 Project). The threat of the 680 University project (680 Project) as a Builder’s Remedy (BR) alternative heavily and overtly influenced the PTC decision to approve the 660 University project (660 Project), as the public record of the Commissioner’s questions, comments and concerns makes obvious. Some even went so far as to say that although they had serious concerns and issues about the 660 Project, they voted to advance it because a BR would be worse. Although the 660 Project is independent of the 680 Project, whether or not the 680 Project has BR status has a powerful effect on the considerations and decisions applicable to the 660 Project. This email examines whether the 680 Project qualifies for BR. The correct conclusion is that (1) the 680 Project has lost its status as, and currently is not, a BR application and (2) due to the intervening certification of Palo Alto’s housing element by the State, the defects that cause that outcome cannot be corrected in a way that restores its BR status. With regard to the 680 Project:  The 680 Project’s Section 69541.1(a) preliminary application (CL_680_University_APPLY4) specified 110 residential units but its Section 69541.1(e)(1) full application (24-LN-00239) reduced the number of residential units to 88 (a 20% change).  CL_680_University_APPLY4 was filed before the date the State certified the housing element for Palo Alto (City). 24-LN-00239 was filed after the certification date.  Subsection 69541.1(d) provides: “After submittal of all of the information required by subdivision (a), if the development proponent revises the project such that the number of residential units or square footage of construction changes by 20 percent or more…the housing development project shall not be deemed to have submitted a preliminary application that satisfies this section until the development proponent resubmits the information required by subdivision (a) so that it reflects the revisions.” This means that CL_680_University APPLY4 may be relied on only for a BR project with 89 to 129 residential units, inclusive.  The 88 residential units specified by 24PLN-00239 is outside this required range, so the 680 Project, automatically and by operation of law, does not have either the complete prerequisite preliminary application per subsection (d) or a deemed completion date per Subsection 65589.5(h)(5). Therefore, the 680 Project currently does not qualify for BR status or treatment. From Assistant City Attorney’s email attached below, the City does not dispute this point. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 76  Packet Pg. 154 of 517  2  The sole remaining question is whether the defect caused by 24PLN-00239 can be remedied in a way that reestablishes BR status for the 680 Project. The answer, as is explained below, is no. BR status of the 680 Project cannot be restored or resurrected. The City and the developer entered into a Tolling Agreement (TA) purportedly relating the 680 Project. It is not clear that the TA actually applies to this situation. The TA recites that “Applicant submitted a preliminary application (“the BR Preliminary Application”)…for development of a mixed-use building include [sic] 88 residential units…(the “BR Project”) and thereafter submitted a formal development permit application…. (the “BR Application”). The Applicant maintains that the BR Preliminary Application vested the then-existing Municipal Code requirements and Housing Element status pursuant to SB 330, specifically including the ability to pursue use of the Builder’s Remedy for the BR Project.” This wording creates the following problem:  The pertinent obligations in the TA (its Section 2) are specifically limited to the “BR Project.” However, the BR Project as defined in the TA is not the project described by CL_680_University_APPLY4, and a “BR Preliminary Application” for an 88 residential unit project (I.e., as that term is defined in the TA) actually does not exist. The scope of the TA, by its terms, is limited to 24LPN-00239, and CL_680_University_APPLY4 is neither referenced or covered by the TA.  Subsection 69541.1(d), discussed below, does not allow an application for a project with only 88 residential units to link back to CL_680_University_APPLY4 for BR purposes .  24PLN-00239 needs to be amended to be an 89 residential unit project or to disappear and be replaced by a new 89 residential unit project, to avoid the adverse effects of Subsection (d). If it is amended, then it is outside the TA because it no longer is the “BR Project” as defined. If it disappears, the TA disappears with it.  Note neither of the above effects would happen if the TA defined “BR Project” in terms of CL_680_University_APPLY4. Assistant City Attorney Yang, ignoring the drafting problems of the TA, makes a two pronged argument: (1) the Tolling Agreement creates a window of opportunity for the developer to make a further filing file under Subsection 69541.1(e)(1) and (2) the Subsection 69541.1(d) problem can be resolved via that mechanism. Unfortunately for preserving the BR for the 680 Project, the second prong of Yang’s argument is not correct. The first problem with Yang’s argument is that the developer actually already has made the required subsection (e)(1) filing and the City timely responded with a list of deficiencies per subsection (e)(2). The only open time window obligation still remaining under Section 69541.1 is the developer’s obligation to respond to the City’s list of deficiencies per subsection (e)(2). Additional changes to 24PLN00239 also can be made, but that is true whether or not the TA exists. Assuming the Tolling Agreement actually has application to a filing obligation that already has been timely met and that Yang’s first prong argument about subsection (e)(1) is valid, there are only two ways to correct the Subsection 69541.1(d) problem per his second prong: (1) 24PLN-00239 is amended to change the number of residential units to 89 or (2) 24PLN-00239 is superseded or replaced by a new application for 89 residential units. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 77  Packet Pg. 155 of 517  3  The wording of Subsection 69541.1(d) expressly and explicitly provides both that filiing 24PLN- 00239 with 88 residential units caused CL_680_University_APPLY4 to be incomplete as a preliminary application BR filing and that this incompleteness persists unless and until a appropriately revised preliminary application is resubmitted. This statutory wording does not refer to or authorize any other method of resolving the disconnect in number of residential units caused by the 20% change. In particular, subsection (d) does not mention or authorize the alternative to resubmission that makes up the second prong of Yang’s argument. A resubmission will create an application completion date per Subsection 65589.5(h)(5) that is after the date of certification of the City’s housing element (barring BR as an option for the 680 Project).  The Legislature extensively revised the BR statute (Section 65589.5), effective 1/1/2025. As part of that revision, the Legislature added a new provision to Section 65589.5 that relates specifically to Subsection 69541.1(d) in ways not applicable to these facts. The Legislature also revised the parts of Section 69541.1 relating the payment of fees. Most importantly, no changes were made to the text of either Subsection 65589.5(d) or Subsection 65589.5(h)(5). This legislative history is a powerful statement that the Legislature did not have any intention to modify those two pertinent provisions.  The TA only allows/forgives a “late’” filing; it’s only legal effect is to eliminate a claim of invalidity due to lateness. Thus the TA permits and makes timely an action that otherwise would be barred by the passage of time, but that permission does not change the legal effects and consequences that result from its occurrence.  Amending 24PLN-00239 to change it to 89 residential units is permissible without regard to the TA. However, a resubmission still is required per the express wording of subsection (d) or the amendment to 24PLN-00239 is deemed to be, or to obviate the need for, the required resubmission because the amendment eliminates the need for CL_680_University_APPLY4 to be revised. Either way, CL_680_University_AAPLY4 is deemed an incomplete preliminary application per subsection (d) until that corrective action occurs. The result is a new deemed completion date per Subsection 65589.5((h)(5) that is after the certification of the City’s housing element.  Superseding or replacing 24PLN-00239, as opposed to amending it, does not produce a different result. CL_680_University_APPLY4 is deemed incomplete until that corrective action occurs, same as in the amendment alternative, and that date is after the certification of the City’s housing element. A variation is to argue that withdrawing or abandoning 24PLN-00239 has the effect of leaving CL_680_University_APPLY4 standing alone with its original effective date. This argument also fails.  This outcome is not reconcilable with subsection (d), which expressly states that the CL_680_University_APPLY4 continues to exist as an incomplete pending resolution of discontinuity in the number of residential units.  In addition, Subsection 65589.5(o)(2)(E) demonstrates that this result is not the Legislature’s intention. That subsection provides that the 680 Project can be made subject to ordinances, policies, and standards adopted after the preliminary application was submitted pursuant to Section 65941.1 in a variety of circumstances, specifically including if “…the housing development project is revised following submittal of a preliminary application pursuant to Section 65941.1 such that the number of residential units or square footage of construction changes by 20 percent or more….” Subsection (o)(2)(E) supports and validates the notion that subsection (d) puts a preliminary application in suspension by subsection 65941.1(d) until the reason subsection (d) applies is resolved. If that were not the case, the application would not be subject to changes in the law enacted after the date the preliminary application was filed. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 78  Packet Pg. 156 of 517  4  It is settled law that a valid and continuing Subsection 69541.1(a) preliminary application creates a “vested right” to BR as of its deemed completion date. This vested right must also shift forward in time, if subsection 69541.1(d) applies, to the date the relevant residential unit discontinuity is resolved. In other words, resolving that discontinuity results in a new, later, vesting date. Any other result puts the “vested right” and Subsection (o)(2)(E) in a conceptual conflict that is irreconcilable. Kinsey Haffner Get Outlook for iOS From: Kinsey haffner <haffner_fk@hotmail.com> Sent: Thursday, October 9, 2025 11:24 AM To: Yang, Albert <Albert.Yang@paloalto.gov> Cc: Kallas, Emily <Emily.Kallas@paloalto.gov> Subject: Re: 680 University Does Not Qualify For Builder’s Remedy Thank you, Albert, for taking the time last night to reply to my email. First, some clarifications. I actually agree with your description of the process state of the 680 applications and the “correction path” the developer probably will take (both already are in my email, though not very overtly). The difference is that we reach opposite conclusions as to the outcome. While I doubt the developer actually relied on the Tolling Agreement for reasons I can explain, but I too am positive that they will claim they did. Your comment (very politely expressed!) about my perhaps misconception isn’t correct, though I understand why you might conclude so from the way my email is written. Unfortunately, the issue at hand is nuanced and not simple and the required analysis is complex. Procedure/process needs to be considered separately from its outcome, the preliminary application needs to be considered separately from the formal application, and the two applications need to be considered separately from the proposed project itself. Then each of the above needs to be matched up against the statutory schema, taking into account the actual phrasing of relevant provisions looked at in the context of a non-obvious aspect of the relevant statutory history. Successfully navigating the above is necessary because the correct answer to the BR status of 660/680 University is pivotal, as last night’s Commissioner questions and comments made obvious. Our doing so via an email exchange will be difficult and time consuming, and a collegial phone call or F2F meeting will be faster with a better outcome. I hasten to add, and it goes without saying, that “better outcome” does not mean we end up in agreement. Doing so will be excellent, regardless of whose view prevails, but correctly understanding the other’s positions and conclusions will suffice. A long way, for which I apologize, to request some dates and times when we can speak by phone or meet. I presume sooner is better than later. My calendar is open with a few exceptions next week every day excluding 10/12. I am unavailable all of the week following due to travel plans. After that, only phone would work, as I will be in Idaho. Best regards, Kinsey Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 79  Packet Pg. 157 of 517  5 Get Outlook for iOS From: Yang, Albert <Albert.Yang@paloalto.gov> Sent: Wednesday, October 8, 2025 10:49 PM To: Kinsey haffner <haffner_fk@hotmail.com> Cc: Kallas, Emily <Emily.Kallas@paloalto.gov> Subject: RE: 680 University Does Not Qualify For Builder’s Remedy Mr. Haffner, Thanks for your email and your comments to the PTC. My response to the PTC was based in Government Code section 65941.1, subdivision (e), which grants an applicant 180 days to submit a formal application consistent with a preliminary application containing the information in subdivision (a). For the 680 University “Builder’s Remedy” project, a preliminary application was submitted on June 11, 2024. Therefore, the applicant had until December 8, 2024 to submit a formal application that is consistent with the June 11, 2024 preliminary application. The City and the applicant entered into a tolling agreement on December 4, 2024 that tolls any and all submittal deadlines related to the Builder’s Remedy project, which includes the 180 day deadline for the applicant to submit a formal application. The fact that the applicant submitted an 88-unit formal application in September 2024 does not preclude them from submitting another formal application for 89-131 units within the 180 day timeline (as extended by the tolling agreement). I expect the applicant would assert that their failure to submit such an application was in reliance on the tolling agreement. I believe your analysis may misconstrue the impact of changes to a development proposal on a preliminary application. If an applicant submits a preliminary application for 100 units and subsequently submits a formal application for 50 units, this does not have any effect on the 100-unit preliminary application. It simply means that the 50-unit project cannot claim the benefits of the 100-unit preliminary application. Under subdivision (d), the 50-unit project “shall not be deemed to have submitted a preliminary application” until a new preliminary application for 50 units is submitted. But the applicant could still, within 180 days of the 100-unit preliminary application, submit another formal application for 81 units or 119 units and take advantage of its protections. Best, Albert S. Yang | Assistant City Attorney 250 Hamilton Avenue | Palo Alto, CA 94301 P: 650.329.2171 | E: albert.yang@paloalto.gov This message contains information that may be confidential and privileged. Unless you are the addressee, you may not use, copy or disclose the message or any information contained in the message. If you received the message in error, please notify the sender and delete the message. From: Kinsey haffner <haffner_fk@hotmail.com> Sent: Wednesday, October 8, 2025 8:46 PM To: Yang, Albert <Albert.Yang@paloalto.gov> Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 80  Packet Pg. 158 of 517  6 Cc: Kallas, Emily <Emily.Kallas@paloalto.gov> Subject: Fw: 680 University Does Not Qualify For Builder’s Remedy CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hello Albert, I spoke tonight about the Builder's Remedy for 680 University. Attached below is my detailed analysis of this issue, which I suspect you have not yet seen. My belief is that your quick legal advice is not entirely right. If you want to, and are allowed to, discuss this with me. I will be happy to do so. Your answer in public forum to the question posed to you included that the BR defect identified can be remedied. The answer is no in my view, but even if yes, any corrective action at this point (even an amendment to the formal application if it is deemed a resubmission) at this point would create a deemed completed date after, not before, the certification of the City's housing element.. The reason is that Gov. Code Section 69541.1(d) specifically both requires the preliminary application to be resubmitted and provides the deemed effective date for the preliminary application is the date of the resubmission. The defect cannot be remedied by amending the formal full application, because the wording of subsection (d) does not recognize that as an allowable way to remedy the defect. You also referred to the Tolling Agreement. However, the Tolling Agreement does not apply. First, the defect is caused by what was filed and not by a failure to make a timely filing, which makes the Tolling Agreement inapplicable. Second, all of the pertinent events occurred before the Tolling Agreement was signed, and that agreement is not retroactive. Third, the Tolling Agreement states it applies to non- submissions, etc. made "in reliance on" the Tolling Agreement, a predicate event that is not in play here because the necessary reliance did not happen. Finally, the defect arose by the filing of the formal application, which occurred after the certification. Regards (and fellow Stanford Law grad), Kinsey Haffner Get Outlook for iOS From: Kinsey haffner <haffner_fk@hotmail.com> Sent: Wednesday, October 8, 2025 3:11 PM To: Kallas, Emily <emily.kallas@paloalto.gov>; planning.commission@paloalto.gov <planning.commission@paloalto.gov> Cc: Raybould, Claire <claire.raybould@paloalto.gov>; Christopher Ream <ream@reamlaw.com>; The Hamilton Sharon Fees <sharon@thehamilton.net>; carole.gilbert@icloud.com <carole.gilbert@icloud.com> Subject: Re: 680 University Does Not Qualify For Builder’s Remedy Resend of my 7/7/2025memail addressed to Emily Kallas, with typos corrected. No substantive changes. Hi Emily, Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 81  Packet Pg. 159 of 517  7 This email examines the current Builder’s Remedy (BR) status of the pending application for the 680 University project (680 Project). I apologize for its length, but the issue is involved and complex. Also, thank you in advance for including this email in the official records for 680 Project. I also request it become part of the official records for the companion 660 University project application, as a matter of creating notice. Although 660 University is a standalone project independent of the 680 Project, whether or not the 680 Project has BR status has an indirect effect on the considerations and decisions applicable to 660 University. If the City Attorney has any opinion, reaction or response to this email, please communicate the same to me so that I may reply. Question posed: Is the 680 Project and its application entitled to Builder's Remedy (BR) treatment under Gov. Code Section 65589.5? Answer: The answer to the question posed is no (more precisely, no because of, and from and after the filing date of, 24PLN-00239). Timelines and facts: Document C1_680_University_APPLY4 was filed on 6/11/2024 as the informational preliminary application under Gov. Code Section 69541.1(a). Document 24PLN-00239 was filed on 9/3/2024 as the formal full BR application for the 680 Project under Section 69541.1(e). In the interim between those two filings (on 8/3/2024), HCD certified the City's housing element. In October 2024, City issued comments on 24PLN-00239. Applicant has not responded to those comments and has not made any additional filings with respect to the 680 Project. City and the applicant entered into a Tolling Agreement on 12/2/2024, which put the 680 Project on hold from a time deadline/passage of time perspective. C1_680_University_APPLY4, which meet the requirements of Section 65541.1(a), specified 110 residential units for the 680 Project. However, 24PLN-00239 specified only 88 residential units, exactly a 20% decrease from the 110 residential units specified by C1_680_University_APPLY4. Reasoning and analysis: A complete, filed preapplication complying with Section 69541.1(a) (and, if applicable, Section 69541.1(d)) plus a complete, filed formal full application based on the preapplication complying with Section 69541.1(e) are prerequisites for BR treatment of the 680 Project under Gov. Code Section 65589.5. The version of Section 65589.5 in effect when C1_680_University_APPLY4 and 24PLN-00239 were filed (the 2024 Version) was significantly amended by a new version that went into effect on January 1, 2025 (the 2025 Version). Section 69541.1 also was amended effective January 1, 2025, but not in ways that are pertinent to the BR status of the 680 Project. Per both the 2024 Version and the 2025 Version, BR is not available for the 680 Project unless its preliminary application under Section 65941.1(a) has a “deemed completion date” that is prior to the date of certification of the City’s housing element. Section 65589.5(h)(5), which also is the same in both the 2024 Version and the 2025 Version, provides a two alternative definitions of "deemed complete": "'deemed complete' means [1st alternative] the applicant has submitted a preliminary Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 82  Packet Pg. 160 of 517  8 application pursuant to Section 65941.1 or [2nd alternative], if the applicant has not submitted a preliminary application, has submitted a complete application pursuant to Section 65943." In the case of the 680 Project, operation of Section 65589.5(h)(5) turns on the effect on the 680 Project application of Section 69541.1(d). Section 69541.1(d) requires an applicant to resubmit the informational preliminary application under Gov. Code Section 69541.1(a) if the overall size of the preapplication project (measured by the number of residential units in this case) “changes by 20% or more” . Section 69541.1(d) further provides “the housing development project shall not be deemed to have submitted a preliminary application that satisfies this section until the development proponent resubmits the information required by subdivision (a) so that it reflects the [excessive] revision.” Another way to look at how subsection (d) applies to the 680 Project is that, in effect, the 680 Project may relate back to and rely on CL_680_University_APPLY4 only if the number of residential units in 24PLN-00239 is within 89 to 121 units, inclusive. The 20% decrease in the number of residential units in the 680 Project made by 24PLN-00239 as filed (110 units down to 88 units) is outside this range. Turning back to Section 65589.5(h)(5):  The 1st alternative definition of “deemed complete” is not met by the 680 Project because the resubmission requirement of Section 69541.1(d) means, CL_680_University_APPLY4 notwithstanding, applicant has not submitted a complete preliminary application in compliance with Section 65941.1(a). In that regard, amending or replacing 24PLN-00239 to achieve the requisite minimum of 89 residential units does not satisfy Section 65941.1(d) since that subsection explicitly requires a Section 65491.1(a) resubmission, not a conforming change to the application to bring it within the allowed range of residential units. Also, 24PLN-00239 itself, even if so amended, would not meet the informational requirements of Section 69541.1(a).  The 2nd alternative definition is not met by Project 680 either, since 24PLN-00239 is not a complete application under Section 65941.1.  Wthdrawing and replacing 24PLAN-00239 with a new application for 89 residential units that responds to all of City’s comments is not a viable solution. First, the new filing would not be allowed by the 180-day filing requirement under Section 69541.1(e)(1) (plus, the Tolling Agreement does not apply here; see the discussion below). Second, even if legally possible, the resulting deemed completion date would be after the date that City’s housing element was certified by HCD. Amending 24PLN-00239 to respond as needed to the City’s comments and increase the number of residential units to 89 also would be a moot point, for the same reason.  In any event, any action taken now to meet either definition of "deemed complete" would result in a deemed completion date that is after the date City's housing element was certified by HCD. The combined effect of Sections 65941.1(a), 69541.1(d) and 65589.5(h)(5) can be summarized as follows:  C1_680_University_APPLY4 satisfied the filing requirements of Section 69541.1(a), thereby initially creating a vested right to BR status for the 680 Project with a deemed complete date of 6/11/2024.  The number of residential units for the 680 University Project was changed by 24PLN-00239, effective as of its filing date, from 110 units to 88 units (a 20% reduction). Per Section 69541.1(d), this 20% change rendered C1_680_University_APPLY4 incomplete for purposes of Section 69541.1(a), automatically by operation of law and not as a discretionary matter. As a result, the vested right to BR status for the 680 Project was lost, also automatically, upon the filing of 24PLN- 00239. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 83  Packet Pg. 161 of 517  9  Per Section 69541.1(d), the preliminary application under Section 69541.1(a) for the 680 Project could be reinstated by a resubmission (and potentially perhaps in other ways, as discussed above), but the deemed complete date for the reinstated preapplication would be when that outcome was accomplished, not C1_680_Univerity_APPLY4’s original filing date of 6/11/2024, which renders that stratagem moot. In any event the resubmission or reinstatement did not occur.  Although neither the 680 Project nor its application is entitled to BR status or treatment under Section 65589.5, 24PLN-00239 probably still survives and can be processed, as a "regular" (i.e., non-BR) application. However, the Tolling Agreement would not apply to that re-constituted application, since the Tolling Agreement is limited by its terms to BR issues. The inevitable conclusion, and the singularly important fact, is that there is no completed preliminary BR application for the 680 Project under Section 69541.1(a) with a deemed completion date before the date the City’s housing element (or, for that matter, before 1/1/2025). Therefore, no BR vested right or status exists for the 680 Project and the 2025 Version does not apply. Supplemental points: Tolling Agreement: The Tolling Agreement has no effect on the above discussion or its outcome. The purpose and subject matter of the Tolling Agreement is pausing, for BR application purposes, the running of all filing and/or submittal and review deadlines applicable to the 680 Project. Application of Section 69541(d) discussed above was triggered by a status event (change in the number of residential units) not a timing event (failure to meet a filing, submission, or review deadline requirement). Also, the Tolling Agreement is inapplicable to any failure or omission to make a timely filing or submission with respect to Section 69541.1, since the Tolling Agreement requires reliance on the Agreement to excuse any such failure or omission — which is impossible since all the events and acts here relevant to that Section occurred before the Tolling Agreement was signed. Definitional requirements: C1_680_University_APPLY4 specifies sufficient low-income units to satisfy the definition of a BR project under the 2024 Version but not the 2025 Version. 24PLN-00239, on the other hand, fails to designate sufficient low-income units to meet the definition of a BR project under either the 2024 Version or the 2025 Version. The reason is that 24PLN-00239 counted/included BMR units for moderate income, which is compliant with PAMC BMR requirements but irrelevant to satisfying the statutory BR requirements. Although 24PLN-00239 can be amended to correct this error, given the resubmission requirement applicable to C1_680_University_APPLY4, the change would not requalify the 680 Project for BR treatment with a deemed effective date before the date the City's housing element was certified by HCD. Section 65589.5(f)(7)(B): As discussed above, the 2025 Version does not apply to the 680 Project. Even if it did, Section 65589.5(f)(7)(B) of the 2025 Version may not be relied upon to resurrect BR treatment of the 680 Project. First, by its terms, this Section is available only for a "housing development project [application] deemed complete before January 1, 2025" and the 680 Project does not meet this threshold requirement. Second, the provision only permits applicants "to revise their application so that the project is a builder’s remedy project, without being required to resubmit a preliminary application, even if the revision results in the number of residential units or square footage of construction changing by 20 percent or more." In this case, the “revise the application” wording of the subsection is blocking, since the problem stems from the application (24PLN-00239) itself, not a revision to an application that creates the 20% change. In addition, the wording of subsection (f)(7)(B) explicitly refers to changing an existing application that is not for BR project to convert it into one that is for a BR project. Any change in Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 84  Packet Pg. 162 of 517  10 reliance on this subsection with respect to the 680 Project would create a BR application whose deemed effective date is after the date City's housing element was certified by HCD. Kinsey Haffner 555 Byron Street #210, Palo Alto, CA Get Outlook for iOS Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 85  Packet Pg. 163 of 517  1 Kallas, Emily From:Tina Frisco <tfrisco@sonic.net> Sent:Tuesday, October 14, 2025 11:33 AM To:Council, City Cc:Kallas, Emily Subject:660 Universty Avenue CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. To: Palo Alto City Counsel From: Tina Frisco, RN, PA Resident Re: Proposed Apt. Complex at 660 University Date: October 14, 2025 I am a resident at Lytton Gardens, 649 University Avenue. I have serious concerns regarding the proposed apartment complex at 660 University. My balcony and windows face University Avenue, as do those of many other residents residing here. We won’t be able to open our windows during construction (which will take months, if not years) due not only to exceedingly loud noise, but also to the amount of dust and dirt that will enter. Keeping the windows closed will keep out only some of the dust and dirt, which can enter even when windows are closed. I know this because when I lived by the train station, soot built up on my windowsills even though the windows were closed. I have asthma, and daily exposure to dust over an extended period of time will negatively impact my health. I could very well end up being hospitalized and requiring IV medication to assist me in breathing, which in turn could lead to intubation for a respirator, which in turn could lead to death. Aside from health concerns, there also are traffic issues. University Avenue is already congested most of the time, especially since it’s a direct thoroughfare to Stanford Hospital. We must contend with myriad traffic noises daily: ambulances, fire trucks, buses, recycling and garbage pickup, street cleaning, loud (VERY LOUD) motorcycles, and much more. Adding at least 66 more vehicles to this area will impose severe if not dangerous risks on our community. I think it’s commendable that the city is pursuing affordable housing projects. However, 660 University is not the place for this. My health will take a nosedive both during and after construction, as will that of many other residents here. Please let me know when this issue will be placed on your agenda and opened to the public for discussion. Thank you. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 86  Packet Pg. 164 of 517  2 Tina Frisco, RN 649 University Avenue Palo Alto, CA 94301 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 87  Packet Pg. 165 of 517  1 Kallas, Emily From:Steven Atneosen <atneosen@hotmail.com> Sent:Wednesday, October 8, 2025 1:51 PM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address. Mark Safe Report Powered by Mimecast Hello Palo Alto PTC, we are Steven Atneosen and Caroline Dahllof, and we live in the Crescent Park neighborhood. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation, especially the 14 affordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community. We hope the PTC will allow this project to move forward to council without further delay or modification. Thank you for your leadership to support homes for all in our community, Steven Atneosen Caroline Dahllof atneosen@hotmail.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 88  Packet Pg. 166 of 517  1 Kallas, Emily From:Rob Schreiber <r_schreiber_98@yahoo.com> Sent:Wednesday, October 8, 2025 1:13 PM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address.  This is their first mail to some recipients. Mark Safe Report Powered by Mimecast Dear members of the commission, I support the 660 University project. While I live at the other end of Palo Alto, I am a frequent visitor to and patron of business in downtown. I appreciate the pressures from various directions and quarters concerning its evolution. Downtown Palo Alto clearly needs to change with the times. The pace is too slow. The need for housing near jobs and transit, housing for people who can not buy at the price levels of current Palo Alto housing, and additional people of a range of ages and income brackets -- these are overwhelming, and they are made more so by the dramatic changes in the area's economy which contrasts to the slow pace of change in Palo Alto's plan, goals, vision, and processes. As a dear friend and long-time Greenmeadow neighbor and leader said to me, "It's a city, not a museum." Our views, policies, and imagination must change with the deep and dramatic changes to the economics and demographics of the area. They have not. Put simply, we remain stuck, or nearly so, despite some changes that the city has instituted. By the way, as a southerner I want to point out that the situation along El Camino in south Palo Alto remains dismal. On the southwest side of the road, between Page Mill and Arastradero, one still finds ancient decrepit one story commercial spaces, quonset huts, and at least four weed covered vacant properties. At $10 million per acre, this is a mind-boggling waste. Seventy years ago, builders and developers built the south Palo Alto that we live in to meet the needs of that time. That 1950s cityscape no longer meets the social needs. We have to let the market, developers and buyers, have a say in how to take these invaluable but underutilized spaces and put them to viable use. We have to do better. Despite my desire to see changes happen faster, I remain grateful to you for your work and service to the community, Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 89  Packet Pg. 167 of 517  2 Rob Schreiber Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 90  Packet Pg. 168 of 517  1 Kallas, Emily From:Rachel Miller <rlhello@yahoo.com> Sent:Wednesday, October 8, 2025 4:24 PM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organiza on. Be cau ous of opening a achments and clicking on links. Hello Palo Alto PTC, my name is Rachel Miller and I live in Miranda Green. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transporta on, especially the 14 affordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing op ons to our community. I hope the PTC will allow this project to move forward to council without further delay or modifica on. Thank you for your leadership to support homes for all in our community, Rachel Miller Sent from my iPhone Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 91  Packet Pg. 169 of 517  1 Kallas, Emily From:Owen Byrd <owenbyrd@gmail.com> Sent:Wednesday, October 8, 2025 11:48 AM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address.  This is their first email to your company. Mark Safe Report Powered by Mimecast Hello Palo Alto PTC, my name is Owen Byrd and I live in Downtown North. I am also a former member of the PTC. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community. I am disappointed by opposition to the project from some residents of The Hamilton and hope you will not be swayed by it. I remember when The Hamilton was proposed in the 1990s and was vigorously opposed by neighbors. I supported its development then, just as I support 660 University now, for the same reason -- we need more multi-family housing, especially downtown. I hope the PTC will enable this project to move forward to the City Council without further delay or modification. Thank you for your leadership to support homes for all in our community, Owen Byrd Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 92  Packet Pg. 170 of 517  1 Kallas, Emily From:Mert Dikmen <mertdikmen@gmail.com> Sent:Wednesday, October 8, 2025 11:29 AM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address.  This is their first mail to some recipients. Mark Safe Report Powered by Mimecast Hello Palo Alto PTC, my name is Mert Dikmen and I live in Crescent Park. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation.This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community. As an owner of a home within three blocks of this development, I eagerly await its completion. It will anchor the downtown, increase retail foot traffic and will add to the vibrant character of the neighborhood. I hope the PTC will allow this project to move forward to council without further delay or modification. Thank you for your leadership to support homes for all in our community, Mert Dikmen Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 93  Packet Pg. 171 of 517  1 Kallas, Emily From:Mary Beth Train <mbt3305@yahoo.com> Sent:Wednesday, October 8, 2025 4:59 PM To:Planning Commission Cc:Council, City; Co-Presidents Lisa Ratner and Hannah Lu; Steve Levy; palo.alto.fwd@gmail.com Subject:660 University mixed-use project - YES CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address.  This is their first mail to some recipients. Mark Safe Report Powered by Mimecast I am writing to support the staff recommendation to move the 660 University mixed-use project forward to Council. The project proposes 70 residential units, including 14 BMR units. As noted in a letter from Lisa Ratner and Hannah Lu, Co-Presidents, LWV Palo Alto, .."This proposal maintains the city's base requirement of 20% allocation to BMR units, with 2 very low income, 5 low income, and 7 moderate income units (studio, one and two bedrooms.) The downtown location close to shopping, dining, services, jobs and transit allows many residents to take downtown trips by walking and biking--a plus for the environment. Building 100% affordable units in Palo Alto by a non-profit developer would cost nearly $1million per unit and likely take more than 4 years. Building mixed income housing, as this project does following the city's inclusionary requirements, is currently the fastest way to increase BMR units." This looks like the best iteration of this project yet, and I urge your support and action of the City Council to go forward with it. Palo Alto needs diversity in housing stock and in demographics. This project is a step in that direction. With downtown so close, residents will liven up the downtown as they use its businesses. Thank you for your consideration, Mary Beth Train Resident - 850 Webster Street, Apt. 420. Property owner - 3305 Middlefield Road Mary Beth Train - Home office phone 650-324-7346 *voice only, not text* - mbt3305@yahoo.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 94  Packet Pg. 172 of 517  1 Kallas, Emily From:Kinsey haffner <haffner_fk@hotmail.com> Sent:Wednesday, October 8, 2025 3:12 PM To:Kallas, Emily; Planning Commission Cc:Raybould, Claire; Christopher Ream; The Hamilton Sharon Fees; carole.gilbert@icloud.com Subject:Re: 680 University Does Not Qualify For Builder’s Remedy CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Resend of my 7/7/2025memail addressed to Emily Kallas, with typos corrected. No substantive changes. Hi Emily, This email examines the current Builder’s Remedy (BR) status of the pending application for the 680 University project (680 Project). I apologize for its length, but the issue is involved and complex. Also, thank you in advance for including this email in the official records for 680 Project. I also request it become part of the official records for the companion 660 University project application, as a matter of creating notice. Although 660 University is a standalone project independent of the 680 Project, whether or not the 680 Project has BR status has an indirect effect on the considerations and decisions applicable to 660 University. If the City Attorney has any opinion, reaction or response to this email, please communicate the same to me so that I may reply. Question posed: Is the 680 Project and its application entitled to Builder's Remedy (BR) treatment under Gov. Code Section 65589.5? Answer: The answer to the question posed is no (more precisely, no because of, and from and after the filing date of, 24PLN-00239). Timelines and facts: Document C1_680_University_APPLY4 was filed on 6/11/2024 as the informational preliminary application under Gov. Code Section 69541.1(a). Document 24PLN-00239 was filed on 9/3/2024 as the formal full BR application for the 680 Project under Section 69541.1(e). In the interim between those two filings (on 8/3/2024), HCD certified the City's housing element. In October 2024, City issued comments on 24PLN-00239. Applicant has not responded to those comments and has not made any additional filings with respect to the 680 Project. City and the applicant entered into a Tolling Agreement on 12/2/2024, which put the 680 Project on hold from a time deadline/passage of time perspective. C1_680_University_APPLY4, which meet the requirements of Section 65541.1(a), specified 110 residential units for the 680 Project. However, 24PLN-00239 specified only 88 residential units, exactly a 20% decrease from the 110 residential units specified by C1_680_University_APPLY4. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 95  Packet Pg. 173 of 517  2 Reasoning and analysis: A complete, filed preapplication complying with Section 69541.1(a) (and, if applicable, Section 69541.1(d)) plus a complete, filed formal full application based on the preapplication complying with Section 69541.1(e) are prerequisites for BR treatment of the 680 Project under Gov. Code Section 65589.5. The version of Section 65589.5 in effect when C1_680_University_APPLY4 and 24PLN-00239 were filed (the 2024 Version) was significantly amended by a new version that went into effect on January 1, 2025 (the 2025 Version). Section 69541.1 also was amended effective January 1, 2025, but not in ways that are pertinent to the BR status of the 680 Project. Per both the 2024 Version and the 2025 Version, BR is not available for the 680 Project unless its preliminary application under Section 65941.1(a) has a “deemed completion date” that is prior to the date of certification of the City’s housing element. Section 65589.5(h)(5), which also is the same in both the 2024 Version and the 2025 Version, provides a two alternative definitions of "deemed complete": "'deemed complete' means [1st alternative] the applicant has submitted a preliminary application pursuant to Section 65941.1 or [2nd alternative], if the applicant has not submitted a preliminary application, has submitted a complete application pursuant to Section 65943." In the case of the 680 Project, operation of Section 65589.5(h)(5) turns on the effect on the 680 Project application of Section 69541.1(d). Section 69541.1(d) requires an applicant to resubmit the informational preliminary application under Gov. Code Section 69541.1(a) if the overall size of the preapplication project (measured by the number of residential units in this case) “changes by 20% or more” . Section 69541.1(d) further provides “the housing development project shall not be deemed to have submitted a preliminary application that satisfies this section until the development proponent resubmits the information required by subdivision (a) so that it reflects the [excessive] revision.” Another way to look at how subsection (d) applies to the 680 Project is that, in effect, the 680 Project may relate back to and rely on CL_680_University_APPLY4 only if the number of residential units in 24PLN-00239 is within 89 to 121 units, inclusive. The 20% decrease in the number of residential units in the 680 Project made by 24PLN-00239 as filed (110 units down to 88 units) is outside this range. Turning back to Section 65589.5(h)(5):  The 1st alternative definition of “deemed complete” is not met by the 680 Project because the resubmission requirement of Section 69541.1(d) means, CL_680_University_APPLY4 notwithstanding, applicant has not submitted a complete preliminary application in compliance with Section 65941.1(a). In that regard, amending or replacing 24PLN-00239 to achieve the requisite minimum of 89 residential units does not satisfy Section 65941.1(d) since that subsection explicitly requires a Section 65491.1(a) resubmission, not a conforming change to the application to bring it within the allowed range of residential units. Also, 24PLN-00239 itself, even if so amended, would not meet the informational requirements of Section 69541.1(a).  The 2nd alternative definition is not met by Project 680 either, since 24PLN-00239 is not a complete application under Section 65941.1.  Wthdrawing and replacing 24PLAN-00239 with a new application for 89 residential units that responds to all of City’s comments is not a viable solution. First, the new filing would not be Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 96  Packet Pg. 174 of 517  3 allowed by the 180-day filing requirement under Section 69541.1(e)(1) (plus, the Tolling Agreement does not apply here; see the discussion below). Second, even if legally possible, the resulting deemed completion date would be after the date that City’s housing element was certified by HCD. Amending 24PLN-00239 to respond as needed to the City’s comments and increase the number of residential units to 89 also would be a moot point, for the same reason.  In any event, any action taken now to meet either definition of "deemed complete" would result in a deemed completion date that is after the date City's housing element was certified by HCD. The combined effect of Sections 65941.1(a), 69541.1(d) and 65589.5(h)(5) can be summarized as follows:  C1_680_University_APPLY4 satisfied the filing requirements of Section 69541.1(a), thereby initially creating a vested right to BR status for the 680 Project with a deemed complete date of 6/11/2024.  The number of residential units for the 680 University Project was changed by 24PLN-00239, effective as of its filing date, from 110 units to 88 units (a 20% reduction). Per Section 69541.1(d), this 20% change rendered C1_680_University_APPLY4 incomplete for purposes of Section 69541.1(a), automatically by operation of law and not as a discretionary matter. As a result, the vested right to BR status for the 680 Project was lost, also automatically, upon the filing of 24PLN- 00239.  Per Section 69541.1(d), the preliminary application under Section 69541.1(a) for the 680 Project could be reinstated by a resubmission (and potentially perhaps in other ways, as discussed above), but the deemed complete date for the reinstated preapplication would be when that outcome was accomplished, not C1_680_Univerity_APPLY4’s original filing date of 6/11/2024, which renders that stratagem moot. In any event the resubmission or reinstatement did not occur.  Although neither the 680 Project nor its application is entitled to BR status or treatment under Section 65589.5, 24PLN-00239 probably still survives and can be processed, as a "regular" (i.e., non-BR) application. However, the Tolling Agreement would not apply to that re-constituted application, since the Tolling Agreement is limited by its terms to BR issues. The inevitable conclusion, and the singularly important fact, is that there is no completed preliminary BR application for the 680 Project under Section 69541.1(a) with a deemed completion date before the date the City’s housing element (or, for that matter, before 1/1/2025). Therefore, no BR vested right or status exists for the 680 Project and the 2025 Version does not apply. Supplemental points: Tolling Agreement: The Tolling Agreement has no effect on the above discussion or its outcome. The purpose and subject matter of the Tolling Agreement is pausing, for BR application purposes, the running of all filing and/or submittal and review deadlines applicable to the 680 Project. Application of Section 69541(d) discussed above was triggered by a status event (change in the number of residential units) not a timing event (failure to meet a filing, submission, or review deadline requirement). Also, the Tolling Agreement is inapplicable to any failure or omission to make a timely filing or submission with respect to Section 69541.1, since the Tolling Agreement requires reliance on the Agreement to excuse any such failure or omission — which is impossible since all the events and acts here relevant to that Section occurred before the Tolling Agreement was signed. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 97  Packet Pg. 175 of 517  4 Definitional requirements: C1_680_University_APPLY4 specifies sufficient low-income units to satisfy the definition of a BR project under the 2024 Version but not the 2025 Version. 24PLN-00239, on the other hand, fails to designate sufficient low-income units to meet the definition of a BR project under either the 2024 Version or the 2025 Version. The reason is that 24PLN-00239 counted/included BMR units for moderate income, which is compliant with PAMC BMR requirements but irrelevant to satisfying the statutory BR requirements. Although 24PLN-00239 can be amended to correct this error, given the resubmission requirement applicable to C1_680_University_APPLY4, the change would not requalify the 680 Project for BR treatment with a deemed effective date before the date the City's housing element was certified by HCD. Section 65589.5(f)(7)(B): As discussed above, the 2025 Version does not apply to the 680 Project. Even if it did, Section 65589.5(f)(7)(B) of the 2025 Version may not be relied upon to resurrect BR treatment of the 680 Project. First, by its terms, this Section is available only for a "housing development project [application] deemed complete before January 1, 2025" and the 680 Project does not meet this threshold requirement. Second, the provision only permits applicants "to revise their application so that the project is a builder’s remedy project, without being required to resubmit a preliminary application, even if the revision results in the number of residential units or square footage of construction changing by 20 percent or more." In this case, the “revise the application” wording of the subsection is blocking, since the problem stems from the application (24PLN-00239) itself, not a revision to an application that creates the 20% change. In addition, the wording of subsection (f)(7)(B) explicitly refers to changing an existing application that is not for BR project to convert it into one that is for a BR project. Any change in reliance on this subsection with respect to the 680 Project would create a BR application whose deemed effective date is after the date City's housing element was certified by HCD. Kinsey Haffner 555 Byron Street #210, Palo Alto, CA Get Outlook for iOS Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 98  Packet Pg. 176 of 517  1 Kallas, Emily From:Hillary Thagard <hthagard@gmail.com> Sent:Wednesday, October 8, 2025 1:52 PM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organiza on. Be cau ous of opening a achments and clicking on links. Hello Palo Alto PTC, my name is Hillary Thagard and I live in Midtown. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transporta on, especially the 14 affordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing op ons to our community. This project was introduced in 2021. It is me to act and end the delays. I hope the PTC will allow this project to move forward to council without further delay or modifica on. Thank you for your leadership to support homes for all in our community, Hillary Thagard Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 99  Packet Pg. 177 of 517  1 Kallas, Emily From:Heather Stewart-Bhardwaj <heatherlstewart87@gmail.com> Sent:Wednesday, October 8, 2025 4:39 PM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address.  This is their first mail to some recipients. Mark Safe Report Powered by Mimecast Hello Palo Alto PTC, my name is Heather Stewart and I live in Crescent Park. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation, especially the 14 affordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community. In the last year, I’ve talked to 4 childcare workers who care for my kids at the Ross road YMCA, my nanny, my son’s preschool, and Duveneck Elementary and they were struggling to find housing, live 30 miles away, or were rent burdened. This is a real problem and they work in our community. Just yesterday the person I spoke with at Duveneck Elementary PACCC told me he drives in from Dublin which takes him TWO HOURS one way on a workday. He can’t afford rent around here. The man who handles permits for city parks and rec lives in Pleasanton and drives in. If Palo Alto is actually serious about reducing carbon emissions and cares about people who work in our community and who want to be our neighbors, permit more housing. I know many more people than childcare workers struggle with rent and this is ethically wrong. We need to make Palo Alto more inclusive and offer more housing for all income levels and stages of life, from college kids to affluent tech workers to middle income workers to elderly people who have to downsize. I welcome neighbors of all stripes and support adding affordable housing, irrespective of location and height. It’s the ethical, economically smart, and environmentally friendly thing to do for the long term health of our community. I hope the PTC will allow this project to move forward to council without further delay or modification. It is imperative to build more housing and I am not sympathetic to complaints about housing being in the wrong context or too tall. We need it and it must happen regardless of neighbor concerns. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 100  Packet Pg. 178 of 517  2 Please permit more and more housing so I don’t have to go through the heartbreak of trying to help my favorite ~65 year old childcare worker at the PA YMCA find an affordable apartment again. Thank you for your leadership to support homes for all in our community, Heather Stewart LinkedIn Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 101  Packet Pg. 179 of 517  1 Kallas, Emily From:Angela He <angelahe101@gmail.com> Sent:Wednesday, October 8, 2025 12:00 PM To:Planning Commission Cc:Council, City Subject:Support for Housing at 660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. i This message needs your attention  This is a personal email address.  This is their first mail to some recipients. Mark Safe Report Powered by Mimecast Hello Palo Alto PTC, My name is Angela He, and I am a resident of Palo Alto. Please support the proposal for 70 homes at 660 University Ave. We need more housing near retail and transportation, especially the 14 affordable homes. This project will promote sustainable lifestyles, support local businesses, and bring much needed housing options to our community. I hope the PTC will allow this project to move forward to council without further delay or modification. Thank you for your leadership to support homes for all in our community, Angela He Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 102  Packet Pg. 180 of 517  1 Kallas, Emily From:Christopher Ream <ream@reamlaw.com> Sent:Tuesday, October 7, 2025 12:53 PM To:Kallas, Emily Subject:660 University - PowerPoint Slide Show Attachments:660 University - Ream - 20251006.pptx CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Emily, Attached is a copy of my PowerPoint presentation for tomorrow’s PTC Hearing. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 103  Packet Pg. 181 of 517  10/27/2025 1 Save the magnificent Coast Live Oak Tree The Tree is defined by CPA as a PROTECTED TREE. It has a 50-inch diameter trunk, is around 60 feet tall, and has a mostly balanced canopy spreading nearly 90 feet across. Applicant’s Tree Protection Report, filed March 3, 2025, page 3 90 ft Diameter Canopy is at the full 45 feet from the tree trunk The CPA’s Tree Protection Zone (“TPZ”) standard is 41 feet for the Tree. 1 2 3 4 5 6 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 104  Packet Pg. 182 of 517  10/27/2025 2 Canopy if it were sliced off at the 41-foot TPZ However, Applicant has arbitrarily decided to pretend that 30 feet, not 41 feet, is a TPZ for this project. Applicant will cut back the canopy to 30 feet from the trunk, which will leave it touching the face of the building. If Canopy is sliced off at 30 feet from the trunk to meet the face of the building Applicant won’t stop there. They will slice back another 6 feet to make room to install 6-foot deep balconies for every apartment. If Canopy is sliced back another 6 feet to clear the balconies – now 24 feet from the trunk And the residents will demand that the canopy be cut back further to give clearance so that the residents and their guests can enjoy them without getting poked by branches. Assume another 5 feet of pruning. 7 8 9 10 11 12 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 105  Packet Pg. 183 of 517  10/27/2025 3 Trim back another 5 feet to give clearance for the residents on their balconies Count them – 30 feet to the face of the building minus 6 feet for balconies and construction minus 5 feet clearance for people on the balconies brings us to only 19 feet of canopy from the Tree trunk remaining –- compared to the 45 feet we started with The Tree trunk, the small dark circle in the middle of the canopy, holds the limbs in place; in return each limb exerts a force trying to pull the Tree over. How strong those forces are depends on how much leverage each half of the canopy has – Leverage = weight x distance from trunk I will mention North and South frequently. North is the top of plan drawings, while South is the bottom. Moving North is going toward University Avenue. Moving South is going toward Hamilton Avenue and The Hamilton. The canopy extending over the property for the proposed project is all on the North side of the Tree. All of the canopy removal will be from the canopy on the North side of the Tree. The canopy on the South side of the Tree is all on the property of the neighboring dental office. There will be no removal at all from the canopy on the South side. There is general agreement by the project’s arborist and the arborist retained by The Hamilton that 25% of the whole canopy will be removed. But that 25% will all be removed from the canopy extending over the project’s property on the North side of the Tree. 13 14 15 16 17 18 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 106  Packet Pg. 184 of 517  10/27/2025 4 As you can see, there will be a major imbalance in the canopy trying very hard to tip the Tree over to the South, towards The Hamilton. Will the Tree be held up by its roots on the North side ? . Arborist OnSite® Horticultural Consulting, Inc. ISA Certified Arborist Report Submitted To: Rincon Consultants, Inc. 449 15th Street, Suite 303 Oakland, California 94612 Project Location: 660 University Avenue Palo Alto, California Submitted By: Robert Booty, Registered Member # 487 ISA Qualified Tree Risk Assessor The American Society of Consulting Arborists ISA Certified Arborist WC-4286 May 23, 2022 102030405060708090 102030405060708090 TYP. 17 ' - 8 1 / 2 " TY P . 30'-0" OFFSET TREE PROTECTION ZONE 9'-0TYP 3 STALLSEVSE(INDEPENDENT PUZZLE) 5 STALLS(INDEPENDENTPUZZLE) FUTUEVS R15'-0" 15' MIN. / 30' MAX.) 19 20 21 22 23 24 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 107  Packet Pg. 185 of 517  10/27/2025 5 It gets worse – Applicant has said that for ground intrusions, it is okay to attack roots as close as only 20 feet from the Tree. “Roots The 20-foot setback from #10's trunk for ground disturbance applies to any soil compaction, grading, subexcavation, overexcavation, trenching, drilling/auguring, storm drains, swales, etc.” Applicant’s Tree Protection Report, filed March 3, 2025, page 10 102030405060708090 TYP. 17 ' - 8 1 / 2 " TY P . 30'-0" OFFSET TREE PROTECTION ZONE 9'-0TYP 3 STALLSEVSE(INDEPENDENT PUZZLE) 5 STALLS(INDEPENDENTPUZZLE) FUTUEVS R15'-0" 15' MIN. / 30' MAX.) 102030405060708090 203040506070809010 0 5050 60 70 80 90 100 10203040506070809010 0 Fe e t Roots now. 51 ft radius. Actually, the roots extend out well beyond the 51 feet recorded. Roots after construction. 20 ft radius Area is a direct function of the square of the radius. 51 x 51 = 2601 20 x 20 = 400 400 / 2601 = 15.4% 25 26 27 28 29 30 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 108  Packet Pg. 186 of 517  10/27/2025 6 Moving on to other concerns we have about this project. Parking – 89 stalls required – 69 stalls actually provided 20 cars roaming around looking for parking RED FLAG –NOTEALL INTERIOR DEMISING AND PARTITION WALL SUBJECT TO CHANGE PRIOR TO PERMIT SUBMITTAL AND APPROVAL 29 more cars roaming after office space adjustment. Applicant’s plans for the First Floor appear to grant Applicant the option to configure 7,131 sq ft of more office space in the future after receiving approval of its plans without that additional office space. In other words, Applicant gets the high rental office space without providing the 29 parking spaces to go with it. A GRAVE, UNNECESSARY, INEXCUSABLE * * DANGER * * 36 BALCONIES OVER THE UNIVERSITY AVENUE SIDEWALK 31 32 33 34 35 36 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 109  Packet Pg. 187 of 517  10/27/2025 7 As David Hirsch so succinctly stated at the December 1, 2022 Architectural Review Board Hearing on this project: “This is too much building in too small of a space.” 37 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 110  Packet Pg. 188 of 517  1 Kallas, Emily From:Christopher Ream <ream@reamlaw.com> Sent:Sunday, October 5, 2025 10:08 PM To:Planning Commission; Kallas, Emily Subject:Re: 660 University - SECOND LETTER re Other than Tree Attachments:Ream Letter re Other Than Tree - 20251005.pdf Importance:High CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Commissioners and Emily Kallas, Attached is my 6-page comment letter regarding concerns about the proposed development at 660 University Avenue where Smith Development proposes to build a development much too big for that small lot. This is a second letter from me after my letter two days ago regarding the magnificent Coast Oak Tree. Emily, could you please ensure that all the Commissioners are provided with this sufficiently before the PTC Hearing on Wednesday that they have adequate time to review it. Thank you. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 111  Packet Pg. 189 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com October 5, 2025 Commissioners Planning and Transportation Commission City of Palo Alto, California Via: Planning.Commission@PaloAlto.gov Emily.Kallas@PaloAlto.gov Re: PTC Meeting on October 8, 2025 660 University Project SECOND LETTER – Comments on Other than the Tree Commissioners, The Hamilton is a senior living (55+) condominium development which shares a small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all our neighbors. • Balconies over University Avenue • Byron Street Jammed – Traffic Congestion • Parking Basic Count Mechanical Lifts Parking for Office Size Adjustment ? No Parking for Fitness Center • Setbacks • Daylight Plane Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 112  Packet Pg. 190 of 517  Ream – More Comments re the 660 University Project October 5, 2025 Page 2 of 6 Balconies over University Avenue Applicant shows 6-foot to 7-foot setbacks for the above-ground building along University Avenue. There are 36 balconies from the Second Floor to the Sixth Floor sticking out six feet into that “setback” so they come right to the edge of the public sidewalk or within one foot of it. They will have a clear glass railing set 3½ feet off the deck, with a clear glass sheet between the railing and the deck of the balcony. On warm, sunny Friday or weekend afternoons and evenings, there are going to be young people socializing on these balconies. The 3½ foot railing is an inviting place to rest your forearm as you hold a soft drink, a beer or a glass of wine. Geometry dictates that the drink is now another 6 - 12 inches closer to the sidewalk floors below. Many residents in The Hamilton get some exercise by walking around our small block and their walk will pass under these balconies. I frequently see seniors from other parts of “Senior Corner” including this sidewalk as part of their walk. Please don’t drop a glass – you may kill someone. This is a grave, inexcusable, unnecessary danger. Those balconies must be removed or the building moved back away from the sidewalk. Byron Street Jammed – Traffic Congestion There is no parking on either University Avenue or Middlefield Road near the project. The Hamilton is on the short block of Byron between University and Hamilton and sees the parking problem every day. It is a narrow street to start with, but on every workday, every single parking spot on both sides of the street is filled all day long. This narrows the drivable room so that two cars going in opposite directions cannot pass. Every time a delivery vehicle stops on Byron Street during the day, it clogs and backs up Byron. The project does not provide any short-term parking for delivery vehicles, and with 70 rental units in the project’s building, most of which are 1BR or Studio, there are going to be a lot of deliveries, so Byron is going to get clogged and backed up many times a day. When The Hamilton was built in the 1990’s, they foresaw this problem and moved the front of the building back away from Byron Street and constructed a circular driveway that is wide enough and deep enough that a delivery van or Uber/Lyft car can park on the driveway, and then a second vehicle can park behind it or drive past it; the whole time leaving Byron Street free and clear. Byron Street Building on the right is where project would be. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 113  Packet Pg. 191 of 517  Ream – More Comments re the 660 University Project October 5, 2025 Page 3 of 6 Parking Basic Count Parking in downtown Palo Alto is a problem the City has been dealing with for years and continues to deal with. Applicant calculates that according to PAMC 18.52.040 a total of 81 parking stalls are required to serve the residents of the 70 residential units and 8 parking stalls to serve the workers in the non-residential office space on the ground floor, for a total of 89 stalls. But then Applicant invokes several arguments to reduce the number of stalls it is required to provide, starting with a 13% reduction claimed by TDM, down to only 69 actual parking stalls. Has the city staff carefully reviewed the TDM Applicant has submitted? Will it actually reduce the need for parking or is it only designed to reduce the daily use of cars: Is it designed to reduce the number of daily automotive commutes a person takes, while that person still owns a car to be used for weekend activity. Even though it may reduce daily congestion, that car still needs a place to park. Bottom Line – Applicant has cleverly eliminated 20 parking stalls (89 – 69 = 20). Those 20 stalls may have been eliminated in the project’s garage, but the cars have not been eliminated and the 20 cars that can’t find an empty stall in the project’s garage will be driving around downtown, commercial and residential, looking for a parking space and causing congestion that the TDM was supposed to reduce. My granddaughters and other family members might not come to visit me because of the inability to park nearby and friends will not want to come over as much as they used to. Mechanical Lifts Of the 69 actual stalls Applicant intends to provide, 54 of them are mechanical lifts where raising or lowering your car, or someone else’s car, is required. Now, 46 of those 54 lifts are “Stackers” on the second (bottom) floor of the underground garage. They are reasonably straight forward, but there is potential for operator error, and the likelihood of mechanical failure from time to time. Sheet A2.PO-C in Applicant’s PLAN 2 dated 08.08.2025 describes the system. The other 8 stalls come from a five-car “Puzzle” and a three-car “Puzzle” on the first floor. These are complex mechanical structures in which cars, your car and other people’s cars, are lifted and lowered, shifted to the left and shifted to the right. It seems almost inevitable that there will be operator error and somebody’s car will be damaged, probably not the then temporary operator’s car. And mechanical failure is almost certain. Interestingly, Applicant has not included any description of these “Puzzles.” Parking for Office Size Adjustment ? Applicant has shown only 1,984 ft2 of non-residential office space on the First Floor (see Sheet A2.1) and has calculated that the code requirement for that is the 8 parking stalls I referred to in the above section. Last year, up until Applicant added a Fifth and a Sixth Floor in October 2024, Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 114  Packet Pg. 192 of 517  Ream – More Comments re the 660 University Project October 5, 2025 Page 4 of 6 the non-residential office space on the First Floor was 9,115 ft2 which calculated to a code requirement of 37 parking stalls, 29 more stalls than the current plans call for (37–8 = 29). I accept Applicant’s calculation of only 8 parking stalls as the First Floor is configured now. Last Year – 9,115 ft2 Light blue is office space Current – 1,984 ft2 Light blue is office space But, there is a warning flag – Applicant has inserted a notice on Sheet A2.1: ALL INTERIOR DEMISING AND PARTITION WALLS SUBJECT TO CHANGE PRIOR TO PERMIT SUBMITTAL AND APPROVAL If Applicant’s plans get approved, will Applicant then go back to the configuration of the First Floor it had last year and collect a lot of monthly rent on the additional 7,131 ft2 of office space without incurring the obligation for the additional 29 parking stalls? It will be tempting to Applicant. Emily Kallas, the City Planner on this project has informally told me that Applicant could only make minor adjustments not to exceed a total of 100 ft2. If this project is going to be approved, I strongly urge that the City Attorney get a binding written contract that limits Applicant to Ms. Kallas’s understanding of a maximum of 100 ft2 in adjustments. Without such a contract, we might have another 29 cars wandering around in addition to the 20 cars in the Basic Count section above. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 115  Packet Pg. 193 of 517  Ream – More Comments re the 660 University Project October 5, 2025 Page 5 of 6 No Parking for Fitness Center Applicant has said that the 1,829 ft2 Fitness Center on the First Floor will be exclusively for use by tenants in the building (residential and office), and thus no need to calculate any additional parking stalls. So, while the City Attorney is at it, get a written contract affirming that the Fitness Center will remain exclusive to tenants. Setbacks At the April 18, 2024 and again at the December 5, 2024 ARB meetings on this project, there was a lot of discussion about the lack of proper setback along Middlefield Road. Applicant has moved the above grade portion of the building back to form a 25-foot setback along Middlefield as requested, but the underground garage still extends right up to the property line with ZERO setback and a minimal amount of soil fill above the garage structure. (See Sheet A3.3A.) Will the City of Palo Alto be able to make improvements to Middlefield Road in the future with this garage flush up against the road? Not likely. Applicant has offered to provide a small area at the Middlefield/University corner of the property as an “accommodation” if the City were to want to make improvements along Middlefield Road. Any improvement would most likely be to improve travel along Middlefield Road. But Applicant’s offer is only for 27 feet along Middlefield Road from the corner, leaving 46.5 feet still obstructed by the garage. (See Sheet A1.1A.) Applicant needs to make the offer to the City for the entire length of the property along Middlefield. This brings out the fact that the garage also abuts both University Avenue and Byron Street under ground with zero setbacks. Is this standard and acceptable? Daylight Plane There is a single family, one-story residence zoned RM-20 at 524 Middlefield Road adjacent to the project. Upon a 1/21/2022 review of Applicant’s initial filing, Samuel Gutierrez advised Applicant of the requirement to observe a 45° daylight plane. Applicant complied, and in the next submission of plans, cut back the portion of the Fourth Floor next to the neighboring house. The Fourth Floor has remained cut back and compliant with the daylight plane in all subsequent plans submitted by Applicant including the current submission. But Applicant has now added two additional stories onto the building raising the height up to 82 feet and disregarded the fact that these additional floors egregiously violate the daylight plane. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 116  Packet Pg. 194 of 517  Ream – More Comments re the 660 University Project October 5, 2025 Page 6 of 6 The following is from Applicant’s submission. I have enhanced it to make the line of the daylight plane and the location of the neighboring house more visible. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Commission to require action to correct. Thank you for your consideration, Christopher Ream 3/32"=1'-0" PL PL OFFICE LOBBY SPEED RAMP DOWNTO P2 LEVEL UNIVERSITY AVE. 10'- 0 " 10 ' - 6 " OFFICE PARKING RESIDENTIAL PARKING STAIRBEYOND 7'-9 " T Y P . 45.0° 55' - 0 " LINE O F D A Y L I G H T P L A N E 3'-6 " 3'-6 " 9'-9 " 13 ' - 6 " 10' - 6 " 14' - 6 " 7'-0 " FEN C E 7'-0 " 9'- 9 " EL. -1'-6" (NAVD 88 EL. 45.5') NEIGHBORINGPROPERTY GRADE P1 LEVEL P2 LEVEL LIFT PIT SECOND FLOOREL. 14'-8" THIRD FLOOR FOURTH FLOOR EL. 24'-5" EL. 34'-2" FIRST FLOOR EL. 1'-2" (NAVD 88 EL. 48.16') BASE FLOOD ELEV. EL. 0'-0" (NAVD 88 EL. 47') 1'-2 " 12 ' - 8 1 / 2 " ± 8'-4 1 / 4 " 7'-6 " M I N . EL. -12'-1 1/8" ± EL. -26'-7 1/8" ± EL. -33'-7 1/8" ± CORR.TYP.9'-9 " 12 ' - 3 " 55' - 5 " 1'-6 " FIFTH FLOOREL. 43'-11" SIXTH FLOOREL. 56'-2" T.O. ROOF SLABEL. 70'-2" 14 ' - 0 " T.O. PARAPET / ELEV. EL. 71'-8" OVERRUN / STAIRS T.O. RAILINGEL. 73'-8"T.O. MECH. SCREENEL. 80'-2" 3'-6 " 6'-6 " MECHANICALSCREEN 54'- 6 " + / - 3'-6 " 2'-2" SHORING/SOLDIER BREAMS 1/32"=1'-0" 3/- UNIVERSITY AVE MID D L E F I E L D R O A D BYR O N S T R E E T 64G CARTCOMPOST64G CARTCOMPOSTRC64G CARTCOMPOST 64G CARTCOMPOST 96G CARTWASTE96G CARTRECYCLING 96G CARTWASTE 96G CARTRECYCLING ARCHITECTSKORTH SUNSERI HAGEY SHEET NUMBER SCALE PROJECT NUMBER SHEET TITLE DATENO. ISSUES AND REVISIONS DESCRIPTION ARCHITECTSKORTH SUNSERI HAGEY 21003 PLANNING SUBMITTAL12.01.22 PLANNING RESUBMITTAL #105.13.22 PLANNING RESUBMITTAL #208.15.22 PLANNING RESUBMITTAL #408.28.23 PLANNING RESUBMITTAL #510.31.23 PLANNING RESUBMITTAL #612.20.23 PLANNING RESUBMITTAL #702.07.24 AD HOC REVISIONS05.02.24 PLANNING RESUBMIITTAL #809.30.24 524 MIDDLEFIELD A3.3B ENHANCEMENT OF VISIBILITY OF LINE OF DAYLIGHT PLANE AND 524 MIDDLEFIELD MADE BY CHRISTOPHER REAM Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 117  Packet Pg. 195 of 517  1 Kallas, Emily From:Christopher Ream <chrisshop@reamlaw.com> Sent:Saturday, October 4, 2025 4:47 PM To:Planning Commission; Kallas, Emily Subject:660 University - "Protect the Coast Live Oak" Attachments:Ream Letter re Tree - 20251003.pdf Importance:High CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. ! This message could be suspicious  Similar name as someone you've contacted.  This is their first email to your company. Mark Safe Report Powered by Mimecast Commissioners and Emily Kallas, Attached is my 5-page comment letter regarding the magnificent Coast Live Oak next to the property on which Smith Development proposes to build a development much too big for that small lot. There are three attachment to the letter; all together with the letter totaling 33 pages. Emily, could you please ensure that all the Commissioners are provided with this sufficiently before the PTC Hearing on Wednesday that they have adequate time to review it. Thank you. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 chrisshop@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 118  Packet Pg. 196 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com October 3, 2025 Commissioners Via: Planning.Commission@PaloAlto.gov Planning and Transportation Commission Emily.Kallas@PaloAlto.gov City of Palo Alto, California Re: PTC Meeting on October 8, 2025 660 University Project Protect the Coast Live Oak Commissioners, My wife Anne and I have been Palo Alto residents for more than 54 years and have been residents of The Hamilton for the past seven years. The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (“HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block. David Babby, Applicant’s arborist, correctly reports the Tree’s trunk is 50 inches in diameter and its mostly uniform canopy stretches out 90 feet in diameter and is approximately 60 feet high. The Tree is on 517 Byron Street but abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is much larger. The Tree is several hundred years old and is deemed a protected tree by the City of Palo Alto. The Tree brings shade and joy to us and everyone else on the block. Applicant’s proposal to build a large building close to the Tree will put it in grave danger, and we need to protect it. There are three Attachments to this letter: A – Impact Analysis of Proposed 660 University Project, dated September 25, 2025, by Walter Levison Consulting Arborist (hereinafter referred to as “Levison Analysis”). B – Selected pages from Robert Booty’s GRP Scan, May 23, 2022 C – Mathematical Calculations of Circle Segments Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 119  Packet Pg. 197 of 517  660 University Project Protect the Coast Live Oak October 3, 2025 Page 2 of 5 TPZ – Tree Protection Zone Applicant’s arborist David Babby prepared a “Tree Protection Report” dated November 19, 2021 which was filed with Applicant’s original application in December 2021, and was updated with an updated version dated February 7, 2024 which Applicant has included with all subsequent sets of plans filed with the City. (I will refer to that report as “Babby Report”.) The Babby Report acknowledges that the Tree is a “protected tree” under PAMC 8.10 because of its 50-inch trunk and discusses the Tree repeatedly. The Palo Alto Tree Technical Manual, Section 1.36 requires a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Applicant acknowledges this 41-foot TPZ requirement (Babby Report, p. 9), but notwithstanding that, Applicant has gone ahead and arbitrarily drawn a deficient TPZ of only 30 feet on its plans and positioned its proposed building right next to that 30 feet. That is 11 feet less than the protection required by the City of Palo Alto. Canopy The Tree has a beautiful canopy that stretches over the site, a mostly balanced canopy spreading nearly 90 feet across. Babby Report, p.3. With a 90-foot diameter, the canopy has a radius of 45 feet and because the Tree abuts the property line, its canopy stretches that 45 feet over the proposed site. The TPZ applies to the canopy as well as the root structure, but Applicant has used its fake 30-foot TPZ to bring the exterior wall of the building up to 30 feet from the trunk of the Tree, slicing off 15 feet of canopy. But then Applicant’s plans show that every apartment has at least one balcony sticking out six feet from the exterior wall. First, Applicant will need to slice off another 6 feet of the canopy to make room for those balconies. Then, the building’s residents are not going to tolerate the Tree intruding their balconies, so the Tree will be pruned back to provide airspace clearance to maintain a free and clear space around the balcony, and you can be sure the Applicant will cut the Tree back so that there is at least 5 feet of clearance between those balconies and the Tree. The result – Tree’s beautiful canopy now stretching 45 feet over Applicant’s property will be cut back 26 feet or more (15 + 6 + 5) and will then extend only 19 feet towards the proposed building. Applicant says it will cut back 15% of the canopy to clear the proposed building and then another 10% to allow room for construction, for a total of 25%. Babby Report, p.10. Walter Levison Consulting Arborist retained by the Hamilton Homeowners Association estimates 20% to 30% of the canopy will be removed. See Attachment A, the “Impact Analysis of Proposed 660 University Project,” dated September 25, 2025, by Walter Levison Consulting Arborist, p. 8 (hereinafter referred to as “Levison Analysis”). So, we have a basic agreement that the proposed project will cause an estimated 25% of the canopy to be lost. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 120  Packet Pg. 198 of 517  660 University Project Protect the Coast Live Oak October 3, 2025 Page 3 of 5 Applicant admits it will have to cut off many limbs and branches, a 17-inch diameter limb, an 8- inch diameter limb, a dozen or so smaller branches ranging in size from 1 to 6 inches in diameter. Babby Report, p.10. This will raise a serious risk of infection. “Internodal cuts performed on the subject oak will have a severe negative effect on the tree’s overall health and structure, since relatively large diameter internodal cuts are subject to decay and dieback over time, with pests and pathogens able to enter into the pruning cut faces whereby wood decay progresses downward and into the remaining stem cross sectional area, further reducing tree stability and health (vigor).” Levison Analysis, p.8 Root Structure Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reported that his GPR (ground penetrating radar) root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment B). This is consistent with the general assumption that a tree’s roots extend out 2x to 3x the drip line of its canopy (Levison Analysis, p.3) which would mean the Tree’s roots are going on out to 90 feet to 135 feet. But the Tree’s root structure on the north side, the side facing the proposed project, will be boxed in and severely cut back by the proposed two-story underground garage: auto ramp 32 feet to the west, subterranean exterior wall of the garage 36 feet to the north, and another auto ramp 30 feet to the east. See Sheet A2.P1 of Applicant’s plans. In addition, notwithstanding Applicant drawing a 30-foot radius circle on its plans, the Babby Report discloses that Applicant intends to disregard even that fake TPZ and there will be only a 20-foot setback from the Tree’s trunk for any “ground disturbance and that applies to any soil compaction, grading, subexcavation, overexcavation, drenching, and drilling/auguring.” Babby Report, p.10. In other words, if a construction crew is at least 20 feet from the Tree, they will be free to rip out as many roots as they like notwithstanding the deadly effect on the Tree. The most optimistically possible outcome for Applicant would be they end up with a semicircle of roots on the north side of the Tree with a radius of 25 feet (though nothing is stopping them from cutting that radius down to 20 feet, the 20-foot setback.). Even if we pretend that the Tree’s roots all stopped at 51 feet rather than extending out to the normal 90 feet or 135 feet, the root structure on the north side of the Tree would be reduced to only 25% of what it is now, a loss of 75% of those roots. ((∏x25x25)/(∏x51x51) = 24%) And those numbers are based upon the current root structure stopping at 51 feet; it would be much worse if we used the more likely 90 to 135 feet. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 121  Packet Pg. 199 of 517  660 University Project Protect the Coast Live Oak October 3, 2025 Page 4 of 5 Tree Failure “It is WLCA’s [Walter Levison Consulting Arborist] professional opinion that the tree’s vigor would be negatively impacted to a “severe” degree as a direct result of proposed site work as currently described on the June and August 2025 sets of plan sheets, resulting in tree #10 potentially falling into a spiral of condition decline from which it cannot recover.” Levison Analysis, p.13. Levison’s prediction of a spiral of condition decline comes from the significant reduction of the water, minerals and sunlight the Tree needs. I also see a possibility of a sudden, radical failure – the Tree toppling over in a windstorm. As Applicant’s arborist reports, the Tree now has a balanced canopy. Babby Report, p.3. That balance will be completely lost if 25% of the canopy is sliced off. That is 25% of the whole canopy, but all of the removal is going to be from the north half of the canopy. Simple math tells you that 25% of the whole will be 50% of the north half. With the south half of the canopy now twice as large as the north, the Tree will want to tip over to the south towards The Hamilton. It gets worse: Leverage. The force effect of the weight of the canopy is a straight function of how far out that weight is from the Tree trunk: the further away from the trunk, the more force it will be exerting. You remember playing on a seesaw as kid: you could balance with your friend who weighed more or less than you by the heavier one sliding in towards the fulcrum (pivot point) and/or the lighter one sliding back away from it. Or if you don’t remember that, reach out and grab that water glass. When your arm is out straight away from your body it feels heavy, but when you pull your arm back in close to your body it feels much lighter. Applicant cutting back the canopy on the north side results in the canopy that is left there being close to the Tree’s trunk. The lighter kid has slid towards the fulcrum, not away from it. The dominance of the south side force over the north side force is even greater. I did some calculations of south side vs. north side and the results are in the table on the next page. “25% Agreement” is both arborists estimating a 25% cutback, and “Cutback to give balcony clearance” is my explanation on page 2 above of the need to maintain a free and clear space around each balcony. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 122  Packet Pg. 200 of 517  660 University Project Protect the Coast Live Oak October 3, 2025 Page 5 of 5 See Attachment C for the details of how I calculated this. How could the Tree possibly survivor such radical, unbalanced decimation of its canopy? Maybe, just maybe, nature gave it a strong root structure on the north side to hold up the against the force trying to tip it over to the south. We know from Robert Booty’s GRP Scan (Attachment B) that there is a strong root structure on the north side extending out to at least 51 feet and probably more to maybe 90 feet or even 135 feet. But wait, Applicant plans to cut off those roots, none to survive past 30 feet, many cut off at 20 feet. That will reduce the root structure down to 25% of what it is now, probably less. See page 3 above. There is no way the Tree will survive if Applicant is allowed to go forward with its plans. Conclusion If Applicant’s plans are approved and it goes forward, how soon will the Tree topple over and crash into The Hamilton and others? It would destroy the Cardinal Dental office next to it and badly injure and maybe kill anyone in those offices at the time. The Hamilton community strongly opposes this application for over-excessive development on our small block and urges the Commission to require action to correct Thank you for your consideration, Christopher Ream Ratio of South’s Unbalanced Tipping Force To North’s Partial CounterBalance Force South North 25% Agreement Area of remaining canopy after segment is cut off 3,181 1,591 Distance from center of remaining canopy to tree trunk 18.18 8.9 FORCE (Area x Distance) 59,803 14,155 4.2 : 1 Cutback to give balconies clearance Area of remaining canopy after segment is cut off 3,181 1,658 Distance from center of remaining canopy to tree trunk 18.18 9.3 FORCE (Area x Distance) 59,803 15,419 3.9 : 1 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 123  Packet Pg. 201 of 517  660 University Project Ream – Protect the Coast Live Oak October 3, 2025 A"achment A Walter Levison Consul0ng Arborist Impact Analysis of Proposed 660 University Project September 25, 2025 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 124  Packet Pg. 202 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 1 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Date: 12/15/2023 Revised: 9/25/2025 Impact Analysis of Proposed 660 University, Palo Alto Site Plan Project Work on One (1) Off-Site Coast Live Oak (Quercus agrifolia) Specimen (Project Tree #10, Palo Alto City Tree Tag #1572) at 517 Byron Palo Alto, CA Mr. Chris Ream, President The Hamilton Homeowners Association 555 Byron Palo Alto, CA ream@reamlaw.com Dear Mr. Ream, The following written letter report is the single deliverable prepared by Walter Levison, Consulting Arborist (WLCA) per your request as an association with members residing immediately adjacent to the proposed multi-story 660 University project. The original letter report submitted by WLCA was dated 12/15/2023 as noted on this page. The following reported information has been updated as of 9/25/2025, after WLCA’s thorough review of the most currently available plan sheets that are public record, accessible via City of Palo Alto’s official download site, such as June and August 2025 iterations of the applicant’s plan sheets: https://aca- prod.accela.com/paloalto/Cap/CapDetail.aspx?Module=Planning&TabName=Planning&capID1=21PLN&capID2=00000&capID3=00 341&agencyCode=PALOALTO&IsToShowInspection=no (Record 21PLN-00341) WLCA also reviewed: A. City of Palo Alto Urban Forestry Staff Catherine Mondkar’s testimony via Youtube, available as public record, from a formal hearing that occurred on 4/18/2024. B. David Babby Consulting Arborist’s most current arborist report iteration 2/07/2024, noted in this report as the “DB” report. C. Robert Booty arborist report dated 5/23/2022 which analyzed woody root extent using ground penetrating radar (GPR) machine, noted in this report as the “RB” report. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 125  Packet Pg. 203 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 2 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Background and Assignment The proposed private development project stated above proposes to demolish various existing office buildings and parking lot areas, and build an underground parking facility with residential facility direction over the garage footprint. WLCA’s assignment was to determine whether the site work as currently proposed per the set of plan sheets (dated 2025) would cause severe or otherwise irreversible injury to the subject oak specimen to such as degree that it would be expected to fall into a spiral of decline from which it could not recover, as a direct result of the proposed site redevelopment work. WLCA visited the site on 12/13/2023 to archive digital images, create a tree map markup showing actual site-verified canopy dimensions (rough approx.), and confirm existing site conditions. A written report was originally submitted in 2023. The project encompasses three lots, 660 University, 680 University, and 511 Byron. An adjacent lot at 517 Byron just south of the proposed work area exhibits a relatively very large “veteran tree” coast live oak (Quercus agrifolia) referenced by David Babby (the DB report) as tree #10 (City tag #1572), a specimen in good overall condition (62% out of 100% possible) as visually assessed by WLCA, with a canopy spread that is equal to the largest coast live oak specimens ever assessed in the author’s entire 25 year professional consulting career (see digital images below in this report showing the +/- 90 foot diameter spread canopy). WLCA originally reviewed the private development proposed plan sheets dated 10/31/2023 (planning resubmittal #5) which were downloaded from the City of Palo Alto website, and an arborist report by DB dated 11/19/2021, which does not actually contain any site plan sheets (DB used a topographic survey sheet for his initial site tree map markup). WLCA subsequently reviewed 2025 iterations of the project plans downloaded from the City of Palo Alto, as noted above in this letter report, as well as an updated DB Consulting Arborist report dated 2/07/2024, which I will refer to as the “DB” report. That DB report includes the City-required tree protection plan sheets often referred to as the “T” set of sheets, that detail project arborist recommendations as well as City standard tree protection methods required to be implemented as project conditions of approval (PCOA), which are legally binding conditions required to be performed by applicant project teams applying for site entitlements. Digital images archived by WLCA in December 2023 are included in this report for reference of pre-project conditions. Basic Data Diameter: Assume 50 inches, per DB report. (+/- 4 feet). Spread: Approximately 90 feet total diameter, per DB and WLCA reporting. Health (Vigor): 70% per DB, 80% per WLCA. Structure: 40% per DB, 50% per WLCA. Overall Condition Rating: 50% (fair) per DB, 62% (good) per WLCA. Live Twig Density and Live Foliar Density: Good. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 126  Packet Pg. 204 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 3 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Additional Tree Information per WLCA’s Visual Tree Assessment (VTA) 12/13/2023 and Research Foliage hangs down to 15 to 25 feet above grade at 45 feet radius north of mainstem edge. Multiple mainstems exhibit wide angle saddle shaped (i.e.”normal”) attachment forks between 10 and 15 feet elevation above grade. These stems are somewhat upward oriented. Buttress root flares at root crown appear normal, though root system extent and condition are essentially unknowable due to hardscape presence over a large percentage of actual root zone. It is hypothesized that the actual extent of root zone is at least 2x to 3x the 45 foot canopy radius in terms of lateral distance in most directions out from trunk1, based on both Arboriculture 4th Edition (2004), and on WLCA’s past 25 years of construction site consulting experience with coast live oak specimens on older sites with older less-compacted root zone conditions, where historical building foundations and parking lot baserock base sections were constructed to far less strict standards than modern engineer specifications. There may be extensive rooting occurring out through various private lots that adjoin the 517 Byron lot on which tree #10 stands, with lateral woody roots extending from tree #10 underneath various retaining wall footings and building footings, out to underneath existing asphalt parking lot surfacing, etc. (Refer to the RB report detailing roots mapped via use of a ground penetrating radar GPR machine). Per USGS local quadrangle soils map, tree #10 is growing in the “Qoa” unit, which is defined as an older alluvium (oa): a gravelly riparian soil that is derived from stream associated movements, and typically contains smooth rocky material that drains relatively well, and is excellent for development of deep, elongated native oak tree root systems (based on WLCA’s professional experience and research). This Palo Alto site probably has one of the best soils in the entire Bay Area in terms of allowing for fast growth of native oaks. See the digital images section of this report for an overlay map created by WLCA using various online sources and the USGS soil map shows how groundwater at this location is relatively high in elevation (25 foot groundwater contour), and shows existing roads, historical streams, and red dot plots where a past survey by others indicated locations of extremely old native valley oak specimens for reference. What this all means is that the proposed project site has very good growing conditions for native oaks with a high groundwater table elevation contour and gravelly alluvium soil associated with historical waterways which drains relatively quickly and may also exhibit relatively good aeration related to the larger material components of the soil. Expected Construction-Related Tree Root Zone Impact and Canopy Impact Analysis Based on the most current 2025 Set of Proposed Plan Sheets • Canopy: Expect 20% to 30% of canopy live wood and foliage to be removed to clear southward-extended balcony construction, garage vertical wall construction, foundation footing construction for main building structure, vertical exterior walls along the south side of the residential structure, and an additional +/- 10 feet of horizontal width required to be totally cleared up to roof peak elevations as a “construction corridor” airspace for exterior work, scaffold erection, and bucket lift machinery use (based on WLCA’s past projects to date, which required between 6 feet and 15 feet of horizontal clearance as construction corridors around building exterior walls, between soil surface grade and the roof peaks). 1 Per Harris et. al. 2004. Arboriculture 4th Edition. Prentice Hall. Upper Saddle River, New Jersey, USA. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 127  Packet Pg. 205 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 4 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Note that the curvilinear section of garage entry ramp, although it is below grade elevation, may actually require tall vertical machinery clearance directly above the proposed retaining wall excavation cut locations, resulting in further clearance pruning of the tree #10 northwest corner of canopy (not verified). This is based on past projects overseen by WLCA involving underground parking garage retaining wall construction in the Bay Area. Total expected canopy loss will likely result in a remnant canopy with 20 to 25 feet of north, northeast, and northwest extension from mainstem base, whereas existing canopy is +/- 45 feet radial extension in those directions. This is a loss of roughly 50% from those sections of the canopy, and a loss of roughly 25% to 30% of the overall canopy biomass. The DB 2024 arborist report notes an expected loss of some 15% of the existing canopy (assumedly referring to a 15% loss of the total canopy biomass as a whole), though it is not clear if the DB report is also accounting for loss of canopy due to pruning to clear airspace related to an unknown width “construction corridor” between the tree #10 protection zone fencing, and the proposed two balconies that will extend toward the tree. Construction corridor airspace clearance typically requires full clearance to unlimited height, in order to allow for use of lift machines to perform exterior finishing work such as window installations, balconies, painting, etc. In WLCA’s experience, the width of a construction corridor can range anywhere from 5 feet to 20 feet in horizontal width, depending on the types of machinery required to complete the exterior finish work. In some cases, a construction elevator is required to be installed along the exterior of a new building, which may require up to 20 feet horizontal width. The DB report notes there will be significant pruning involved during the airspace clearance work, including a 17 inch diameter stem, an 8 inch diameter stem, and a dozen or so stems ranging from 1 to 6 inches diameter each. Again, this appears to only account for pruning to clear the new proposed building and balconies, but is assumedly not accounting for any construction corridor width airspace clearance tree pruning that may require an additional 5 to 20 feet in horizontal width to be completely cleared to unlimited vertical elevation (not verified). • Roots: Expected subgrade work will encroach to within the City of Palo Alto “10 times diameter” tree protection zone on the north side of tree, inside which special methods/materials/monitoring is required for site construction work. Extent of root zone compromised by the various elements of proposed work (garage wall excavation using vertical shoring, landscape decking, landscape irrigation, landscape plant and tree installation, etc. is expected to be moderate to severe, depending on actual cut depths and depending on whether machinery and personnel are allowed to enter into the TPZ and compact the root zone in the north area of TPZ. Note that the actual extent of roots may or may not be 2x to 3x the tree canopy dripline radius distance northward from trunk (e.g. 90 feet to 135 feet radius), and is currently obscured by hardscape and not able to be verified in terms of lateral distance of growth. The RB ground penetrating radar report root maps suggest that this is the case. See the 2022 RB report root map pages reproduced below in this WLCA report body for reference. Critical Root Zone (i.e. “CRZ”) in terms of structural root plate retention during work on a single side of a tree, is typically recommended as a so-called “tree protection zone” (TPZ) per 2016 BMP booklet “Managing Trees During Construction, 2nd Edition” of at least 6x, 8x, or 10x2 the diameter as a lateral offset from edge of mainstem, which in the case of tree #10, calculates to roughly 24 feet, 32 feet, or 40 feet radius, depending on which standard is used. Per the BMP book, coast live oak has a good tolerance of construction damage, but as a mature specimen, the TPZ multiplication factor that is most appropriate for use for tree #10 is either the 8x or the 10x factor (i.e. a TPZ radius of 32 feet radius, or 40 feet). 2 The applicant’s sheet L4.2 does indicate that the standard City-required tree protection zone (TPZ) is 10x trunk diameter, which equates to 41 feet offset radius, per the DB report. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 128  Packet Pg. 206 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 5 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Cumulative Impact vs. Root or Canopy Impact Alone Note that in the case of the 660 University project, the severe extent of clearance pruning creates a cumulative impact in terms of loss of tree condition rating, such that the combined root zone impact plus tree live canopy loss impact is relatively severe, even though the majority of the work would occur north of the so-called “Tree Protection Zone” of 32 feet offset radius (see WLCA markup showing hard construction related impact to 30 feet offset radius from trunk edge, which is slightly within a TPZ of 8x diameter offset). The DB report does not address cumulative impacts, and instead considers “roots” and “canopy” to be separate and distinct from one another, with a +/- 15% loss expected to each of roots and canopy per the DB report. In WLCA’s experience, construction related impacts to roots and canopy are neither separate nor distinct, and should instead be added together as a combined cumulative impact to the tree, bringing the actual impact to somewhere in the range of 30% to 40% or greater “cumulative impact”, which is “severe”.3 TPZ Radius / Multiple Distances Cited It is not clear why the DB 2024 arborist report continues to reference various different tree protection zone (TPZ) offset radius distances out from the trunk edge of oak #10. The actual required TPZ per City of Palo Alto, established in the City tree technical manual, is 10x diameter offset from mainstem, which equates to +/- 41 feet offset radius from mainstem edge of oak #10. However, per the DB 2024 report, the project as proposed per current plan iterations provides only some 30 feet offset from oak #10 mainstem as a horizontal separation between the tree mainstem edge and the new building footprint plus garage, and only a 20 foot radius protection offset from tree mainstem edge for limit of “ground disturbances” beneath the existing asphalt surfacing materials. This multi-tier TPZ setup will not be in compliance with City of Palo Alto’s TPZ standards, unless very significant tree impact mitigation measures are adhered to with robust arborist site monitoring throughout the entire planned project buildout from start to finish, for all work that occurs within zero to 41 feet offset radius from the oak #10 mainstem edge. Note also that the proposed terrace/garden element of the project does not comply with even the shortest of the three (3) TPZ radii (i.e. the 20 foot offset radius TPZ), given that the proposed terrace will encroach to within just a few feet of the oak #10 mainstem edge, violating even this minimal 20 foot TPZ offset. Soil Compaction within the Critical Root Zone (CRZ) / Tree Protection Zone (TPZ) Note that proposed driving of machinery, foot traffic, extensive landscape footing development, and extensive planting and (possibly also) extensive irrigation pipe trenching are expected to occur within the CRZ/TPZ of 32 feet radius from trunk edge of tree #10. Consulting Arborists will typically specify use of robust “ground protection” in these cases, covering the ground with a thick mat of geotextile overlaid with 6 or more inches of wood chips, and finally covered with steel trench plates or full sheets of exterior grade plywood strapped together with steel strap plates to create a soil buffer. But given that there is planned intense landscaping and decking, etc. to be developed in the area between the garage retaining wall and the south property line abutted up against the 517 Byron lot, WLCA expects that it would be virtually impossible for the developer to actually implement use of robust ground protection and maintain it for any length of time, without causing a major problem in terms of ground logistics (staging, storage, movement of tools and materials, performance of landscape related development between 517 3 This form of cumulative tree impact analysis was used by WLCA during contract consulting work for Barrie D. Coate and Associates of Saratoga, CA, under direction from firm Staff. Barrie D. Coate and Associates was considered at that time to be the preeminent arboriculture consulting firm in the Bay Area, and cumulative tree impacts were routinely determined in this manner. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 129  Packet Pg. 207 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 6 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Byron and the underground parking garage wall, etc.). Therefore, it is expected that soil compaction of a high degree will likely occur in the north section of the tree #10 root zone, within the CRZ/TPZ offset radius, causing additional reduction in overall tree health and structural condition as soil oxygen pore space is compacted and root zone root growing conditions end up suffering as a result of loss of oxygen pore spaces within the tree root growth section of the soil profile (i.e. mainly the uppermost two feet of the soil profile, but potentially down to 4 or 5 feet or more below soil surface grade elevation in native Palo Alto area historical riparian cobble type soils). From a read of the RB ground penetrating radar report, one might think that the root system of the tree is only growing lateral woody roots at great depth (the report maps roots at highest density at distances some 5 to 7 feet below grade). However, trees do have extensively branches root systems with fine absorbing roots 1/32 inch to 1/16 inch diameter each, for example, which would assumedly not show up on the GPR root maps. The fact that the existing asphaltic surface parking lot over which the GPR testing was performed is considered a fill soil pad of great depth above the original tree #10 root system grade elevations, this does not mean that woody roots and/or fine absorbing roots are only present at great depth. In WLCA’s 27 years of consulting experience, the layer of older baserock base section just beneath older parking lot asphalt (especially very old parking lots from the early to mid 20th century) is a layer with conditions favorable to tree root extension and expansion growth in general. WLCA assumes that the root system of oak #10 extends up into the uppermost elevation of the soil profile, just beneath the asphaltic layer, where soil compaction is lowest, and oxygenation is highest. • TRAQ Risk: The removal of +/-25% to 30% of the overall canopy biomass of tree #10 for airspace clearance as noted above, will cause southward lopsidedness of the currently-symmetrical canopy tree specimen of extremely large spread radius (45 feet radius), resulting in increased load forces acting on the north side (“tension” side) of the root system. The root system will have been compromised to an unknown degree during site work (underground parking garage wall excavation, building foundation footing excavation, landscape development, and possible adjustments to or demolition of the existing brick retaining wall that separates 517 Byron from the proposed 660 University project site. Risk of whole tree failure mode and impact with targets to the south of the mainstem location will be necessarily increased and elevated due to these site plan work activities. Risk of individual stem failure and impact with various ground targets will over time be increased and elevated, due to the required clearance pruning through the north side of the canopy to clear scaffolding, bucket lift machinery, balconies, and the new building exterior wall plus underground parking retaining wall work that requires vertical machinery airspace clearance. Very large diameter pruning cuts will be made to accomplish the work, ranging from a few inches diameter each, to as much as 17 inches diameter or more, on some stems that extend northward into the proposed project airspace area. Pruning cuts of this relatively large diameter will allow for fungal wood decay-causing pathogen entrance into the stems via these open cut wounds, resulting in extensive decay column formation over time that progresses down into the stems from the cut wounds. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 130  Packet Pg. 208 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 7 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture 2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (6/20/2025, 8/08/2025). 1. EXTERIOR: The proposed exterior of the building (solid lines) will be approximately 30 feet west of the subject oak tree mainstem edge per sheet A0.2A. 2. BALCONIES: The proposed edge of two new multi-story balconies (gray dashed line rectangles extending map-downward from the building exterior on this sheet) will be approximately 24 feet and 26 feet west of the subject oak mainstem edge, per sheet A0.2A. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 131  Packet Pg. 209 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 8 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (CONTINUED) 3. CONSTRUCTION CORRIDORS ETC.: An additional minimum 5 horizontal feet of airspace clearance (or possibly far greater) is expected to be required to be able to build the proposed balconies, build other exterior features per plan and maintain a free and clear space around the balconies over time. This means the actual extent of pruning will be to a distance of 17 feet west of the mainstem edge of the subject oak specimen, removing at least 20 or more horizontal feet of the existing live canopy biomass, which is a loss of approximately 54% (or more) of the west quadrant of the canopy. Note that the pruning cuts are likely going to consist of “non-ANSI A300 conforming cuts”, since there are few if any remaining stem forks at which to cut back to at that location of 17 feet west of the mainstem, which means that the cuts will then have to be made using “internodal cuts”, performed at locations between branch forks: a poor pruning technique which is often referred to as shearing, topping, or shaving, hedging, etc. when performed on shrubs. See the WLCA markup at right, showing approximately where these cuts might be performed (shown to non-accurate scale, arrows point to locations that are “roughly” 17 feet west or so of the subject oak mainstem edge). Internodal cuts performed on the subject oak will have a severe negative effect on the tree’s overall health and structure, since relatively large diameter internodal cuts are subject to decay and dieback over time, with pests and pathogens able to enter into the pruning cut faces whereby wood decay progresses downward and into the remaining stem cross sectional area, further reducing tree stability and health (vigor). The canopy will be suddenly susceptible to sunscald/sunburn as sunlight will be able to penetrate deeply into the west side of the canopy once clearance pruning is performed to +/- 17 feet west of the mainstem edge, likely resulting in additional decline/death of remaining residual live wood and foliage in that west quadrant of the canopy. Coast live oaks as a species do tend to response relatively well to pruning and root pruning impacts during construction projects, but this degree of pruning is considered “severe”, even though it will only be impacting a single side of the symmetrical canopy. The City of Palo Alto notes that the expected pruning will be considered to be +/-15% of canopy loss overall for the entire tree canopy. However, it is WLCA’s opinion that the City and the project design team may not have actually considered the requirement that a construction corridor, of minimum 5 feet width (or far greater width) as noted above, will be cleared completely in terms of vertical airspace pruning of tree canopy live wood and foliage, and that the pruning cuts are likely going to be performed as shearing-type cuts at internodal locations, which is equivalent to topping pruning in that the tree’s long term response is going to be a profusion of epicormic shoots growing from near the pruning cut wounds, increased sunscald/sunburn, and long term progression of internal wood decay by fungi species that will progress inward and downward through the remaining stems from the large diameter pruning cut wounds made during project airspace clearance pruning. Also of note is the fact that the remaining canopy will be severely lopsided, and that TRAQ risk of whole tree failure and impact with various high value targets will be increased to some degree (as discussed elsewhere in this letter report per WLCA’s 2023 analysis). Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 132  Packet Pg. 210 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 9 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture 2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (CONTINUED) 4. UNDERGROUND PARKING: Sheet A2.P2 dated 8/08/2025 shows a proposed new underground parking curvilinear access road that will require deep excavation at approximately 29 to 30 horizontal feet offset from the mainstem edge of the subject oak. This position of the curvilinear underground driveway is relatively closer to the tree than shown in previous 2023 plan sheet iterations. See WLCA’s markup at right showing the gray driveway cut (deep excavation) and a vector of 29-30 feet true north of the tree mainstem edge. Note that in this image, the light gray dashed line is NOT the tree canopy dripline, and is instead a 30 foot radius demarcation by the project team on the plan sheet renderings. The actual tree canopy extends at least 37 feet north as indicated on the applicant’s plan sheets, (and extends some 45 feet radius northward per WLCA’s estimation in 2023 using a forestry tape). A tree protection zone of 10x calculates to 10 x 50” = 500 inches = approximately 41 feet radius offset from mainstem edge, for new construction. This means that the proposed underground driveway will encroach to far within the 41 foot protection zone. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 133  Packet Pg. 211 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 10 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture 2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (CONTINUED) OVER-EXCAVATION There may or may not be additional “over-excavation” (industry terminology: “over-ex”) required to be performed beyond the limit of excavation shown in this applicant plan sheet in gray coloration on plan sheet A2.P1 reproduced above on page 9 of this WLCA letter report. This is a subject for further research or discussion. Example: if the proposed retaining wall is to be located at the edge of the shown gray area on sheet A2.P1, then there may be a French drain or other type of drainage corridor that needs to be installed behind the wall, requiring over-excavation of some unknown number of horizontal feet, in order to accommodate a thin diameter or a thick diameter drainage curtain (e.g. thin Mirafi “drain core”, or traditional thick gravel-filled French drain system, etc.) that allows for water to drain vertically downward behind the retaining wall, and into a PVC piped drainage system from which water is pumped out in some manner. The thickness of a drainage area behind an underground parking garage retaining wall may be as thick as 3 feet or more (see image above for an example of how a traditional thick type French drain system appears behind a retaining wall). The “overex” or “over-excavation” required for this item is typically not shown and not understood by laypersons to even exist, until the detailed design set of plans (aka “DD” set of plans) are rendered by a project team of professionals. A 3-foot width French drain system would bring the final excavation cut to within approximately 26-27 feet of the subject oak tree mainstem edge. Use of the more narrow “Miradrain” drainage curtain product, or similar, may reduce this required thickness to as little as 6 inches diameter. During his 27 years of construction project consulting experience, WLCA has worked on Bay Area projects where “over-excavation” was not indicated on rendered plans during the pre-project design stage, resulting in horizontal excavation that extended multiple feet farther than the limits of proposed new underground parking garage retaining wall excavation cuts as shown on birds eye view plan sheets. Nearby trees being protected in place ended up with significant unavoidable root loss due to this oversight by the project engineering teams. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 134  Packet Pg. 212 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 11 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture 2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (CONTINUED) At right is a snippet from Robert Booty arborist report dated 5/23/2022, which is public record as part of the applicant’s background documentation. Mr. Booty used ground penetrating radar (GPR) to determine an approximation of the root extent far below asphalt surface grade elevation, on the side of oak tree #10 facing proposed new building foundation excavation for both the building and underground parking garage retaining walls. Not shown on this image is the curvilinear underground parking garage work which will cut far more root mass than shown by Mr. Booty’s vector black line in the image at right. One of the parking garage roadways below ground is shown in a snippet above on page 8 of this WLCA arborist letter report. From the image at right from Booty arborist report dated 2022, and from the curvilinear below grade parking garage and driveway work shown on page 8 above, we can clearly see that the percentage of the root system to be removed will be very significant: possibly as much as 40-50% of the root system on the northwest side of the tree, not including damage from the proposed terrace/garden buildout area, which is discussed in item #5 below. We should assume from the Booty ground penetrating radar examination of the tree #10 root system that lateral woody roots continue to extend outward in all directions much farther than were recorded by Mr. Booty’s GPR machine, which means that an even greater percentage of the tree #10 root system will be damaged and destroyed during development of the proposed property per plans, since the tree’s structural and vigor life support system literally depends on this woody root system and the fine absorbing root mass attached to it, which is apparently far greater in extent than might have otherwise been known prior to the 2022 arborist report graphic root representations having been provided with scale bars by the applicant’s arborist Robert Booty. Note also that the RB report root maps indicate roots present at varying depths of between +/- 30 inches depth (2.5 feet below parking lot surface grade elevation) and the 7 foot depth limit of the GPR machine setting used by RB for his analysis. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 135  Packet Pg. 213 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 12 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture 2025 WLCA QUICK-LOOK ANALYSIS OF THE MOST CURRENT ITERATIONS OF THE APPLICANT PLAN SHEETS (CONTINUED) TREE PROTECTION ZONE FENCING AND MONITORING BY ARBORISTS: It is not clear to WLCA as to the exact location of the official tree protection zone fencing, with an apparent 41 foot TPZ offset alignment indicated by the City of Palo Alto. Actual distance of construction-related impacts to both root system (soil pore space compaction by machinery driving, etc.) and canopy (pruning for vertical and/or horizontal airspace clearance of building, balconies, and an additional “construction corridor” east of the balconies of unknown required width), will necessarily mean that airspace work and some driving of lift vehicles will be occurring at locations between 17 feet west of mainstem edge and 30 feet west of mainstem edge. Additionally, the terrace/garden construction will occur at between 3 feet west of mainstem edge and 30 feet west of mainstem edge as an end-of-project end-phase landscape element of the design that has yet to be detailed in the proposed plan sheets. The conditions of project approval (COPA), set forth by City of Palo planning division and public works division as legally binding conditions, should ideally include specific wordage that indicates a tiered system of root zone protection (i.e. ground protection) for tree #10, such as: • GROUND PROTECTION: Robust ground protection of 6 to 12 inches thickness for the area between the oak tree mainstem edge and out to 30 feet west of mainstem edge, with frequent arborist consultant on-site monitoring on a weekly or twice-monthly basis to verify compliance by the project build team. See image at right showing this type of protection on a WLCA project in the past in Menlo Park, CA, which was a layer of 6 inches of coarse wood chips overlaid with exterior grade 1.0 inch “actual thickness” (or greater) plywood boards screwed together with steel screw plates. • ZERO IMPACT VS. PARTIAL IMPACT AREAS: If City Urban Forestry is recommending zero impact zone of 20 feet radius, then that area between 0 and 20 feet west of the mainstem will need to be hard-fenced at all times, with no access to the ground, which then sets up a problem for the final landscape buildout portion phase of the project when that protection will be required to be removed to allow for the proposed 735 sq ft terrace/garden element of the project to be built out. • MONITORING BY A PROJECT ARBORIST: The scheduling of project consulting arborist monitoring will potentially need to include daily or weekly on-site monitoring of a much more frequent basis than on a typical construction project, if the oak #10 root system and canopy is to be preserved and protected to the best possible extent on sides facing proposed new site construction work. The project arborist will likely need to be present on site during relatively long periods of the tree canopy pruning work as well as the garage retaining wall excavation work. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 136  Packet Pg. 214 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 13 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Conclusion & Recommendations If the proposed 660 University site plan project were built out as currently proposed per the June and August 2025 planning resubmittal versions of the plan sheets, WLCA expects that tree #10 would experience a relatively severe degree of below-ground live lateral woody root loss, and a relatively severe degree of above-ground live canopy pruning likely at internodal locations randomly dispersed along large diameter stems to within 17 feet of the mainstem edge, which, when combined as a cumulative below-ground and above-ground negative impact, would necessarily result in loss of tree vigor (health) and tree structure to a “severe” degree over the long term. The applicant’s Robert Booty ground penetrating radar report from 2022 substantiates the presence of oak #10 rooting out to distances far greater in radius than shown on the report root map images, suggesting that actual tree root loss caused by proposed construction as currently shown on the 2025 set of plan sheets may be far greater than the +/-15% loss of root system noted in the David Babby consulting arborist report. The tree’s safe and useful life expectancy in its current condition rating of “good” (+/- 62% overall condition rating) may be significantly to severely reduced as a result of site plan project work from (EXISTING: no-construction scenario) 50 to 100 years remaining, to (PROPOSED: post-construction scenario) 10 to 20 years remaining, or less, depending on the tree’s response to very significant project clearance canopy and root pruning as described above in this letter report. It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a “severe” degree as a direct result of proposed site work as currently described on the June and August 2025 sets of plan sheets, resulting in tree #10 potentially falling into a spiral of condition decline from which it cannot recover. Project airspace clearance pruning of large diameter stems at internodal locations along the stems to clear the building, the balconies, and a construction corridor of unverified additional width, is expected to result in increased activity by pest and/or wood decay causing fungi species progressing inward and downward through the cross sectional areas of the stems, starting at the pruning cut wound faces at approximately 17 horizontal feet west of the mainstem edge, potentially causing an increase in risk of stem failure over time, with ever-increasing “fungal load” within the cross sectional areas of remaining cut stems. Due to wood decay-causing fungi colonization of the cross sections of various clearance-pruned stems at the west side of the subject tree as noted above, there would necessarily be a corresponding increase in severity of the TRAQ risk rating(s) in terms of risk of whole tree and/or tree part failure and impact with various static and moving targets with moderate to high occupancy ratings within the target zone and a reasonable time frame such as 12 to 24 months, starting as of the proposed site construction completion date (note that this would need to be assessed at a future time, and is outside the scope of WLCA’s initial pre-project tree impact analysis assignment). The tree is located in the an area known to have high water table elevations and gravelly (gravel-laden) riparian type alluvium soil that tends to support excellent native oak tree root growth in terms of both rooting depth and root lateral extension. RECOMMENDATIONS See WLCA’s partial set of recommendations above on page 12 of this letter report. Note that even if all of the above recommendations indicated on page 12 of this WLCA letter report were to be strictly adhered to by the applicant build team and their team of professional consultants, this will not change the fact that at least +/- 50% or more of the tree’s west side of canopy live biomass will be removed to clear the proposed new building exterior, balconies, and a construction corridor of unknown required width with unlimited vertical clear airspace to the southeast of the balconies. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 137  Packet Pg. 215 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 14 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Digital Images by WLCA 12/13/2023 / Tree #10 Coast live oak (Quercus agrifolia) View looking eastward while standing on 517 Byron. Note the excellent buttress root flaring at the root crown of tree #10 which is considered normal and desirable. View of the relatively wide angle fork attachments between 10 and 15 feet elevation above grade at which the tree #10 codominant mainstems arise. These saddle shaped forms are normal and desirable from a structural stability standpoint. Although it is not “optimal” to have codominant mainstems forking in a tree, the best case scenario would be for all of the forks to exhibit wide saddle-shaped attachments like this tree. It is actually extremely unusual for a coast live oak to exhibit saddle-shaped forks at every Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 138  Packet Pg. 216 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 15 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of subject oak #10 looking northward from 517 Byron. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 139  Packet Pg. 217 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 16 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of oak #10 lower 50% of canopy/mainstem architecture, with the adjoining asphalt parking lot area west of 517 Byron visible at left half of the image. The root system is assumed to be extended through most or all adjoining lots surrounding 517 Byron (not verified), as is assumed to reach as much as 2x to 3x the 45 foot canopy radius (again, not verified, but very possible, per WLCA’s past experience with older oaks in Palo Alto and Menlo Park area, especially if Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 140  Packet Pg. 218 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 17 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Per WLCA’s multi-layer mockup created for a valley oak location comparison with groundwater depths and soil types, the tree #10 location has a 25 foot depth groundwater table, and nearby Palo Alto study-noted red dots which indicate very large older valley oak specimens surveyed in the past and included on internet maps for reference. The Qoa soil type at the 660 University site is defined as “older alluvium” (hence the “oa” designation): a Pleistocene soil of gravels, sand, and silt that is unconsolidated to consolidated, interspersed with alluvial materials from stream action. See next page of this report for the United States Geological Survey legend pertaining to this soil unit, clipped from the Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 141  Packet Pg. 219 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 18 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Above was excerpted from the USGS Quadrangle (soil unit map) which includes the City of Palo Alto area. Assumptions and Limiting Conditions Any legal description provided to the consultant/appraiser is assumed to be correct. Any titles and ownership to any property are assumed to be good and marketable. No responsibility is assumed for matters legal in character. Any and all property is appraised and evaluated as through free and clean, under responsible ownership and competent management. It is assumed that any property is not in violation of any applicable codes, ordinance, statutes, or other government regulations. Care has been taken to obtain all information from reliable sources. All data has been verified insofar as possible; however, the consultant/appraiser can neither guarantee nor be responsible for the accuracy of information provided by others. The consultant/appraiser shall not be required to give testimony or to attend court by reason of this report unless subsequent contractual arrangements are made, including payment of an additional fee for such services as described in the fee schedule and contract of engagement. Unless required by law otherwise, the possession of this report or a copy thereof does not imply right of publication or use for any other purpose by any other than the person to whom it is addressed, without the prior expressed written or verbal consent of the consultant/appraiser. Unless required by law otherwise, neither all nor any part of the contents of this report, nor copy thereof, shall be conveyed by anyone, including the client, to the public through advertising, public relations, news, sales, or other media, without the prior expressed conclusions, identity of the consultant/appraiser, or any reference to any professional society or institute or to any initiated designation conferred upon the consultant/appraiser as stated in his qualifications. This report and any values expressed herein represent the opinion of the consultant/appraiser, and the consultant’s/appraiser’s fee is in no way contingent upon the reporting of a specified value, a stipulated result, the occurrence of a subsequent event, nor upon any finding to be reported. Sketches, drawings, and photographs in this report, being intended for visual aids, are not necessarily to scale and should not be construed as engineering or architectural reports or surveys unless expressed otherwise. The reproduction of any information generated by engineers, architects, or other consultants on any sketches, drawings, or photographs is for the express purpose of coordination and ease of reference only. Inclusion of said information on any Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 142  Packet Pg. 220 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 19 of 19 Site Address: 660 University, Palo Alto, CA Iteration: 09/25/2025 Walter Levison  2025 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture drawings or other documents does not constitute a representation by Walter Levison to the sufficiency or accuracy of said information. Unless expressed otherwise: • information contained in this report covers only those items that were examined and reflects the conditions of those items at the time of inspection; and • the inspection is limited to ground-based visual examination of accessible items without climbing, dissection, excavation, probing, or coring. • There is no warranty or guarantee, expressed or implied, that problems or deficiencies of the plants or property in question may not arise in the future. Loss or alteration of any part of this report invalidates the entire report. Arborist Disclosure Statement: Arborists are tree specialists who use their education, knowledge, training, and experience to examine trees, recommend measures to enhance the beauty and health of trees, and attempt to reduce the risk of living near trees. Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice. Arborists cannot detect every condition that could possibly lead to the structural failure of a tree. Tree are living organisms that fail in ways we do not fully understand. Conditions are often hidden within trees and below ground. Arborist cannot guarantee that a tree will be healthy or safe under all circumstances, or for a specified period of time. Likewise, remedial treatments, like any medicine, cannot be guaranteed. Treatment, pruning, and removal of trees may involve considerations beyond the scope of the arborist’s services such as property boundaries, property ownership, site lines, disputes between neighbors, and other issues. Arborists cannot take such considerations into account unless complete and accurate information is disclosed to the arborist. An arborist should then be expected to reasonably rely upon the completeness and accuracy of the information provided. Trees can be managed, but they cannot be controlled. To live near trees is to accept some degree of risk. The only way to eliminate all risk associated with trees is to eliminate the trees. Certification I hereby certify that all the statements of fact in this report are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. Signature of Consultant DIGITAL BADGES: ISA CERTIFIED ARBORIST CREDENTIAL: https://certificates.isa-arbor.com/f1918723-df46-48cc-ace2-c12625530fec#gs.v54om6 (Renewed through June, 2026) ISA TREE RISK ASSESSMENT QUALIFIED (TRAQ): https://certificates.isa-arbor.com/d180515f-ab75-440b-9c66-106005e3cf10?record_view=true#gs.hpb30w (Renewed through March, 2028) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 143  Packet Pg. 221 of 517  660 University Project Ream – Protect the Coast Live Oak October 3, 2025 A"achment B Selected pages from Robert Booty’s GRP Scan May 23, 2022 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 144  Packet Pg. 222 of 517  . Arborist OnSite® Horticultural Consulting, Inc. ISA Certified Arborist Report Submitted To: Rincon Consultants, Inc. 449 15th Street, Suite 303 Oakland, California 94612 Project Location: 660 University Avenue Palo Alto, California Submitted By: Robert Booty, Registered Member # 487 ISA Qualified Tree Risk Assessor The American Society of Consulting Arborists ISA Certified Arborist WC-4286 May 23, 2022 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 145  Packet Pg. 223 of 517  Copied from page 10 of the report. Adjusted so the “y” scale is the same as the “x” scale. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 146  Packet Pg. 224 of 517  660 University Project Ream – Protect the Coast Live Oak October 3, 2025 A"achment C Mathema0cal Calcula0ons of Circle Segments Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 147  Packet Pg. 225 of 517  Page 1 of 4 Calcula&ons Related to a Circle Segment Christopher Ream October 3, 2025 When a straight line is drawn across a circle, the two shapes produced are “segments” of that circle, a major segment and the smaller minor segment. I am dealing today only with the minor segment, the segment which is a semicircle or smaller. If you know the radius of the circle and the height of the segment, you can find the segment area from the formula below. where: r is the radius of the circle of which the segment is a part. h is the height of the segment. Note: The result of the cos-1 func2on in the formula is in radians. The foregoing was copied off the web at hKps://www.mathopenref.com/segmentareaht.html This same website as a very easy to use calculator which I use to enter the radius (r = 45) and the height (“h”), and it produces the Area. And then if I already know the Area and want to find the height (“h”), I can again enter r=45 and then make mulSple entries for height (“h”) unSl the calculator gives me the same Area which I already know. I used this technique to arrive at all the numbers in the table on page 5 of my October 3, 2025 letter “Protect the Coast Live Oak” and here is what I did. Area of a Circular Segment given its heightDefinition: The number of square units it takes to fill a segment of a circleTry this Drag one of the orange dot that defines an endpoint of the segment. Adjust thesegment height. Note the number of square units it takes to fill it and the calculation. If you know the radius of the circle and the height of the segment, you can find the segment area from the formula below. The result will vary from zero when the height is zero, to the full area of the circle when the height is equal to the diameter. where: r is the radius of the circle of which the segment is a part. h is the height of the segment. Note: The result of the cos-1 function in the formula is in radians. Another method If you know the central angle of the segment (the angle subtended by the segment at the center of the circle) you can use the method Area of a circular segment given the central angle. Applications Area =42 cos−1 4−3.04 −(4−3.0)√2·4·3.0−3.02 =17.2 area =r2 cos−1 r−h r −(r−h)√2rh−h2 r = 4 5 ’ h The area of the circle cut off is a “segment.” Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 148  Packet Pg. 226 of 517  Page 2 of 4 Start with the entries for the South side of the Tree, the semicircle of canopy facing south towards The Hamilton. 25% Agreement There will have been no cuYng back of the canopy on this side of the Tree, so the “Area of the remaining canopy” is the area of the untouched semicircle, by the simple formula A = 0.5 x ∏r2 = 0.5 x ∏ x 45 x 45 = 3,181. As with a seesaw, or a crowbar, or any other kind of lever, you mulSple the weight applied by the length of the lever from the fulcrum. In our case, the weight of the remaining canopy is a direct funcSon of the area of the remaining canopy, and that weight can be considered applied at the center of the remaining canopy. The center of the remaining canopy is where the area of canopy outboard of that spot is equal to the area inboard. To find the “Distance from the center of the remaining canopy to tree trunk,” I needed to find what value of “h” will give me a segment area equal to 0.5 x 3181 = 1,590.5, one half of the “Area of the remaining canopy.” I used the calculator on the website at hKps://www.mathopenref.com/segmentareaht.html; entered r = 45, and tried mulSple entries for “h” unSl I got 1,590.5 for the Area. I did it and got “h” = 26.82. This was the distance from the perimeter of the circle to the “center” of the remaining canopy; but I wanted the distance from the “center” to the tree trunk, so I took the radius (“r”) of 45 and subtracted the “h” of 26.82 to give me 18.18 as the length of the Lever. Now to get the Unbalanced Tipping Force, I mulSplied remaining canopy of 3,181 by the Lever of 18.18, and got 59,803. Cutback to give balconies clearance Since no canopy is to be removed on the South side of the Tree, the numbers for the Cutback are the same as those for the 25% Agreement. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 149  Packet Pg. 227 of 517  Page 3 of 4 Move on to the entries for the North side of the Tree, the semicircle of canopy facing north towards Applicant’s proposed building. This will be a liKle more complicated 25% Agreement Both arborists esSmate that 25% of the enSre canopy will be sliced off, but all of the removal is going to be from the North half of the canopy. Simple math tells you that 25% of the whole will be 50% of the North semicircle. The North semicircle is the same size as the South semicircle, or 3,181, and 50% of that is 1,590.5, and with that 1,590.5 removed, the remaining canopy is 1,590.5. Similar to the South side, I now needed to find the center of the remaining canopy, from where half of the remaining canopy, 0.5 x 1590.5 = 795.25, would be inboard and the other half, 795.25 would be outboard. SSll dealing with circle segments, I wanted to visualize a new segment that would account for both the outboard half of the remaining canopy (795.25) and the 50% to be sliced off (1,590.5) or a total of 2,385.75. (Note that 2,385.75 is 75% of the 3,181 semicircle.) To find that, I looked for the “h” value that, with “r” sSll at 45, would produce an area of 2385.75, and found h = 36.1. As with the South side above, this was the distance from the perimeter of the circle to the “center” of the remaining canopy; but I wanted the distance from the “center” to the tree trunk, so I took the radius (“r”) of 45 and subtracted the “h” of 36.1 to give me 8.9 as the length of the Lever. Now to get the Par=al CounterBalance Force, I mulSplied remaining canopy of 1,590.5 by the Lever of 8.9, and got 14,155. Cutback to give balconies clearance This is again a liKle different because don’t have simple calculaSons of areas, rather we have height of the segment sliced off and needed to use that to find the area of the canopy sliced off and thus the area of the remaining canopy. The radius of the canopy is 45 feet but the face of the proposed building is only 30 feet from the Tree trunk; therefore, Applicant must slice off a segment with an “h” of 15 feet. The face of the proposed building it is going to covered with mulSple balconies sScking out 6 feet beyond that face; therefore, another 6 feet of canopy would have to be sliced off. And finally, Applicant must provide clearance around the balconies so the residents can use them; therefore, another 6 feet of canopy would have to be sliced off. “h” = 15 + 6 + 5 = 26. I went to the online calculator at hKps://www.mathopenref.com/segmentareaht.html, entered r = 45 and h = 26, and got an Area of 1523 for the sliced off canopy. SubtracSng that from the 3,181 area of the semicircle and got 1,658 for the Area of the remaining canopy on the North side (3181 – 1523 = 1,658). Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 150  Packet Pg. 228 of 517  Page 4 of 4 Noted that this area number is a li<le more than the 1,590.5 es?mate of the two arborists. That is likely due to the arborists accoun?ng for some addi?onal pruning required for construc?on which I did not take into account. Similar to the explanaSon above of how I found the “Lever” under the “25% Agreement on the North side, I now needed to find the center of the remaining canopy, from where half of the remaining canopy, 0.5 x 1,658 = 829, would be inboard and the other half, 829 would be outboard. SSll dealing with circle segments, I wanted to visualize a new segment that would account for both the outboard half of the remaining canopy (829) and the 1,523 to be sliced off or a total of 2,352. To find that, I looked for the “h” value that, with “r” sSll at 45, would produce an area of 2352, and found h = 35.7. As with the South side above, this was the distance from the perimeter of the circle to the “center” of the remaining canopy; but I wanted the distance from the “center” to the tree trunk, so I took the radius (“r”) of 45 and subtracted the “h” of 35.7 to give me 9.3 as the length of the Lever. Now to get the Par=al CounterBalance Force, I mulSplied remaining canopy of 1,658 by the Lever of 9.3, and got 15,419. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 151  Packet Pg. 229 of 517  1 Kallas, Emily From:carol.gilbert@icloud.com Sent:Friday, October 3, 2025 2:46 PM To:Kallas, Emily Subject:Slides for me on Oct 8th CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. ! This message could be suspicious  Similar name as someone you've contacted.  This is a personal email address. Mark Safe Report Powered by Mimecast These are the few slides I would like to show when I talk at the Wed., October. 8th Planning and Transportation meeting. Slide 1 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 152  Packet Pg. 230 of 517  2 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 153  Packet Pg. 231 of 517  3 Slide 2 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 154  Packet Pg. 232 of 517  4 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 155  Packet Pg. 233 of 517  5 Slide 3 Carol Gilbert 555 Byron St. Palo Alto, CA 94301 650-323-2862 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 156  Packet Pg. 234 of 517  6 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 157  Packet Pg. 235 of 517  1 Kallas, Emily From:Faith Brigel <faithwb3@yahoo.com> Sent:Tuesday, September 30, 2025 8:13 PM To:Kallas, Emily Subject:Re: Planning and Transportation Committee: 660 University Ave. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hi Emily, Thanks for your informative response. I am sorry that I did not realize that you were at that meeting. I came a few minutes late and so I missed the introductions. And I am sorry it took me this long to get back to you. I have been very busy the past few months. Several months ago after living beside a house for 4 years that was demolished and a large, new 2 story house with a large basement and large ADU constructed; I decided to move out of Palo Alto. The last 4 years have been filled with construction right beside my living quarters: the noise, the dust, the trucks, the constant building and builders there all day yelling to each other, 6 days a week. I had been in that house for 25 years, and I loved it. I had not planned on moving out. But the construction next door, made it impossible for me to have a good quality of life. They started that project in December, 2021. Almost 4 years ago! And they are not near finished. My main objection was that they built their house only about 1.5 feet from the property line. But speaking several times to the City I was told that it is according to code. So realizing that construction will now start all over again with another very large project, right across from my office building is very disconcerting. And again, I feel that no one in the City is showing any consideration for the neighbors. This building will be the most massive building in the area. It will be 6 stories with balconies, and insufficient parking spots. It will totally change the ambiance of this area. I appreciated our first talk when I felt that you had some understanding of my feelings. I wish that this project would go back to 4 stories! I just shared my situation with you for you to maybe understand my feelings a bit more. I assume that the City Council has already addressed this project? Thanks, Faith Faith W. Brigel > On Aug 21, 2025, at 5:23 PM, Kallas, Emily <Emily.Kallas@paloalto.gov> wrote: > > Hi Faith, > I do not know why you think I was not there. I introduced myself, gave the staff presentation, and answered most of the Board members’ questions. > Construction activity is regulated through the City Code consistently for all projects. As such, this project will include a Construction Logistics Plan, reviewed and approved by the Public Works Department as a part of the Building Permit review. The standard condition states: > CONSTRUCTION LOGISTICS PLAN. A construction logistics plan shall be provided addressing all Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 158  Packet Pg. 236 of 517  2 impacts to the public including, at a minimum: work hours, noticing of affected businesses, bus stop relocations, construction signage, dust control, noise control, storm water pollution prevention, job trailer, contractors’ parking, truck routes, staging, concrete pours, crane lifts, scaffolding, materials storage, pedestrian safety, and traffic control. All truck routes shall conform to the City of Palo Alto’s Trucks and Truck Route Ordinance, Chapter 10.48, and the route map. NOTE: Some items/tasks on the logistics plan may require an encroachment permit. > I cannot guarantee that there will never be a temporary road closure at any point during the construction. However, if it does occur, notice will be provided and it will be done following procedures and regulations set by the Public Works Department. Sincerely, > Emily > <image001.png>Emily Kallas, AICP > Senior Planner > Planning and Development Services Department > (650) 617-3125 | emily.kallas@cityofpaloalto.org > www.cityofpaloalto.org > <image002.png> Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped > From: Faith Brigel <faithwb3@yahoo.com> > Sent: Thursday, August 21, 2025 1:17 PM > To: Kallas, Emily <Emily.Kallas@paloalto.gov> > Cc: Council, City <city.council@PaloAlto.gov> > Subject: Re: Planning and Transportation Committee: 660 University Ave. > CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. > > Hello Emily, > I attended the Architectural Review Board meeting this morning re the project at 660 University. I assume that you were not there. I spoke and several other neighbors made comments as well. > There are a couple of other points that I want to add. There were several comments made about guarding the tree that is adjacent to the construction. And that is good- but what about the people, the neighbors such as myself? This construction project is massive. And it will overwhelm my one story building. > I have owned that house across the street for 37 years. And it is more than 120 years old, and it is in good condition- there was no mention of respect or consideration to it as a neighbor. I need to know that this development will not adversely affect my building- both during the construction and once it is complete. > One of the members at the end mentioned that when the construction begins the neighbors should be given notice re closing the street, etc; > > It is absolutely not acceptable that Byron Street be closed for any amount of time due to their construction. This construct will take what? About 4 years?! > I have tenants who work there and have clients there daily. They need to have access to my building in order to do their work. And they need it quiet. > If they cannot enter Byron Street for any amount of time, or if construction trucks block access to my driveway, and if any of my tenants leave that > will effect my income. And the construction company will be responsible. > They need to find ways to contain the construction to their own property. And as I have mentioned before and other people have as well - this building is much too large for the space- and we the neighbors Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 159  Packet Pg. 237 of 517  3 in that area are relying on the Architectural Review Board and the City Council to protect the integrity of Palo Alto, and not to allow construction companies coming in to Palo Alto from other locations and building structures that are way out of proportion to the area as this one is. > > Emily can you pls forward this email to the Architectural Review Board? > > Thanks, > > Faith W. Brigel > > > > On Apr 30, 2025, at 3:46 PM, Kallas, Emily <Emily.Kallas@paloalto.gov> wrote: > > > > Hi Faith, > > > > Thank you for your comments. This agenda item has been cancelled at the request of the applicant. You will receive another notice when it has been rescheduled. > > > > Thanks, > > Emily > > > > > > Emily Kallas, AICP > > Senior Planner > > Planning and Development Services Department > > (650) 617-3125 | emily.kallas@paloalto.gov > > www.paloalto.gov > > > > > > > > Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms & Applications | Planning Applications Mapped > > > > -----Original Message----- > > From: Faith Brigel <faithwb3@yahoo.com> > > Sent: Wednesday, April 30, 2025 1:58 PM > > To: Kallas, Emily <Emily.Kallas@paloalto.gov> > > Subject: Planning and Transportation Committee: 660 University Ave. > > > > CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. > > > > Hello Emily, > > I received a notice that there will be a public hearing tonight at City Hall re the construction project at 660 University Ave. > > Unfortunately, I will not be able to attend. So I am writing this email to you in the hopes that you and the members of this committee will see it. > > I cannot state strongly enough how out of place, and cumbersome this huge building will be on Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 160  Packet Pg. 238 of 517  4 University Ave and Byron Street. > > I have been on Byron St. for thirty years and so I feel that I have some knowledge of that area. > > It will be out of place in that no other buildings in that area are that large, that dense, nor that high. No other buildings are 6 stories high. > > Initially weren’t they describing it as 4 stories, which is still very high? > > I call it cumbersome in that there will be many people living there, and many people working there and most of them will need parking spots. > > And as they explained at one of the meetings though they will have a 2 level underground parking lot- there still will NOT be enough parking sports for all of their people. > > There is very little parking on University Ave, , and rarely are there any available parking spots on Byron Street. Similarly, finding parking on Middlefield is close to impossible. > > This lack of parking for their tenants, and clients or customers will be a serious problem once the construction is complete. I am quite sure that they are not yet aware of this. > > The fact that they are planning to build 6 stories is of a great concern to me. My building at 518 Byron Street is as I have explained a one story, and it has been there for more than 120 years. Having this construction 6 stories high right across the street will effect the light plan. It will be ominous. And it will detrimentally affect the quality of life of my tenants. > > I am hoping and would expect that the City Staff would help protect the Palo Alto community of already established buildings., like mine, from new developments coming in and overwhelming the area. > > > > I hope that you will not just focus on building more houses for Palo Alto, but also protect the character that older, Victorian buildings such as mine offer to our City. > > > > Thank you, > > > > Faith W. Brigel > > > > > > Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 161  Packet Pg. 239 of 517  From:Armer, Jennifer To:Kallas, Emily; Raybould, Claire Cc:Tavera, Samuel Subject:Fw: HAC support for 660 University Ave. Date:Thursday, September 18, 2025 8:18:22 AM Attachments:660 University Ave Letter of Support-7.pdfOutlook-Logo__Desc.pngOutlook-h2w13w1h.png FYI Sincerely, Jennifer JENNIFER ARMER, AICP Assistant Director Planning and Development Services Department (650) 329-2191 | jennifer.armer@paloalto.gov www.paloalto.gov From: Ali Sapirman <ali@housingactioncoalition.org> Sent: Wednesday, September 17, 2025 6:37 PM To: Planning Commission <Planning.Commission@PaloAlto.gov>; Armer, Jennifer <Jennifer.Armer@paloalto.gov> Cc: brandon.yung@hcd.ca.gov <brandon.yung@hcd.ca.gov>; Irvin.Saldana@hcd.ca.gov <Irvin.Saldana@hcd.ca.gov>; Coy, Melinda@HCD <melinda.coy@hcd.ca.gov>; Witt Turner <witt@housingactioncoalition.org>; Brianna Morales <brianna@housingactioncoalition.org> Subject: HAC support for 660 University Ave. CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Commissioners, Staff, and HCD: Please see the attached letter of support on behalf of The Housing Action Coalition. Pleasenote HCD is copied on this email due to the history of delays the project has faced. Feel free toreach out with any questions or concerns. In solidarity, -- Ali Sapirman | Pronouns: They/Them Advocacy & Policy Manager| Housing Action Coalition555 Montgomery St, San Francisco, CA 94111 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 162  Packet Pg. 240 of 517  Cell: (407) 739-8818 | Email: ali@housingactioncoalition.org To opt out of all HAC emails, respond to this email with "unsubscribe all". Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 163  Packet Pg. 241 of 517  September 8, 2025 Dear Commissioners, The Housing Action Coalition is a member-supported nonprofit that advocates for creating more housing for residents of all income levels to help alleviate the Bay Area and California’s housing shortage, displacement, and affordability crisis. Our endorsement committee had the opportunity to review Smith Development’s proposal at 660 University, and we proudly endorsed the project. Smith Development’s proposal would bring 66 much-needed new units to Palo Alto. We were impressed with the project's dedication to affordable housing, with 20 percent of the units for lower-tiered affordable housing, which is high especially considering current economic conditions. By prioritizing affordable housing and urban development, we can create more sustainable and inclusive communities for everyone. In terms of Land Use and Density, the project site's central location with its proximity to essential downtown amenities, including the Caltrain station, and the inclusion of ample bike parking facilities underscore a commitment to promoting environmental sustainability and reducing reliance on automobiles. In terms of parking, our committee would like to see a reduction on the amount of parking provided for the project, and have the project redirect those costs to increasing the overall density of the project. In terms of overall design, we commend the steps Smith Development has taken to preserve the Oak tree on site, and even incorporated it into the design. This project will be critical to support Palo Alto, and the Bay Area’s housing needs. Please move this project forward without delay. Corey Smith, Executive Director Housing Action Coalition (HAC) Ali Sapirman, Advocacy and Policy Manager Housing Action Coalition (HAC) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 164  Packet Pg. 242 of 517  From:Tran, Vickie To:Kallas, Emily; Raybould, Claire Cc:Lait, Jonathan; Armer, Jennifer Subject:FW: 660 University Ave., Palo Alto Date:Monday, August 25, 2025 8:36:23 AM Hi Emily and Claire, Please see below for public comment on 660 University. Vickie -----Original Message-----From: Velasquez, Ingrid <Ingrid.Velasquez@paloalto.gov>Sent: Monday, August 25, 2025 8:23 AMTo: Lait, Jonathan <Jonathan.Lait@paloalto.gov>; Armer, Jennifer <Jennifer.Armer@paloalto.gov>; Tran, Vickie<Vickie.Tran@paloalto.gov>Cc: Nose, Kiely <Kiely.Nose@paloalto.gov>; Gaines, Chantal <Chantal.Gaines@paloalto.gov>; City Mgr<CityMgr@paloalto.gov>Subject: FW: 660 University Ave., Palo Alto Good morning, Forwarding the comment below for awareness. Thanks, Ingrid Ingrid VelásquezAdministrative AssistantOffice of the City Manager(650) 329-2354| Ingrid.Velasquez@PaloAlto.gov www.PaloAlto.gov -----Original Message-----From: Faith Brigel <faithwb3@yahoo.com>Sent: Saturday, August 23, 2025 9:05 PMTo: city.council@cityofpaloalto.gov; Council, City <city.council@PaloAlto.gov>Cc: Faith Brigel <faithwb3@yahoo.com>Subject: 660 University Ave., Palo Alto CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clickingon links. Dear City Council of Palo Alto, Re 660 University Ave. Construction Project I sent an email regarding 660 University Ave, a few days ago, but I would like to express a few more objections tothis project that I hope you will consider. I have great concern that the size and a few other issues related to thisconstruction will detrimentally affect my property, and several of the other neighbors. 1- I understand that the State is mandating that housing be increased in California. But we have several newprojects being considered already, not just 660 University, and several of those other areas do not have as many Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 165  Packet Pg. 243 of 517  serious problems that this one has. There is the 17 story building on Mollie Stones, there is the project just 2 blocks up from 660 University on University Ave, one on San Antonio I believe it is 197 apartments, and I think one on El Camino Real. And probably more will be submitted.2-At the Architectural Board Review Thurs. Aug. 21 several of the members of this Board questioned such issues asthe lack of parking, and the high-level of congested traffic in that area, and other issues. When questioned theresponses that the developer gave were rather disappointing. Such as, when asked about parking and trafficcongestion- he said that they assume that a lot of the residents will not drive cars. But that is an assumption notbased on any facts or analysis! It is very possible on the other hand, that most, or many of the residents will havecars. Public transit is quite scarce in this area, and the train is not close at all to this project.3- This construction was initially submitted for 4 stories. But when they were asked to increase the setback - theysaid fine they will do that but they will increase the height to 6 stories! If 6 stories is allowed this building will bethe highest in that location. It will take of course longer to build, and it will permanently overwhelm, and possiblynegatively affect the light plan of my building that has been there for about 120 years, and other neighbors.4- The traffic in that area is very dense most of the day. The location is at the corner of University Ave., andMiddlefield which is the entrance to the downtown of Palo Alto. The City has not had an official traffic analysisdone. Only the developer of this project had one done. It would be important for the City to hire a neutral party to doone.5-They will only be providing 78 parking spots for the whole building in a 2 level parking garage. This is toaccommodate 70 multi-family residential units, plus 1900 sq. ft of offices, where tenants, and outsiders also will becoming and going and certainly needing parking spaces.6-There are rarely parking spots available on Byron, University or Middlefield, any time of day. And it has beenlike this for the 37 years that I have frequented that area. In fact, on 8/21 right after attending most of the ARBmeeting I went over to my property on 518 Byron Street and there was a car parked blocking my driveway. Whenshe came out of the dentist’s office she said she didn’t realize it was a driveway( it is very clear) and she was in ahurry. I hope this is not a prediction of things to come.7-There has been a great deal of discussion about protecting a tree that would be adjacent to the building. That isvery good. However, I would like equal attention to the neighboring houses. 8- As one of the ARB members expressed -this large building will only have 2 common spots in the front ( onByron Street). With various delivery trucks coming by - that is- Amazon, Door Dash, etc ., there will not be enoughparking spots for them. So will they park in the middle of the street and block it for the neighbors? He suggested thatthis building of this size needs more spots for this type of parking. Very true. But will there be any follow up on thisand other issues mentioned since the vote was 3-2 and passed by the ARB members.9- Apparently, recently the developer has added more balconies to the residential units. He said: “Everybody lovesbalconies.” But what about the neighbors? Since I have been there that area has been dominated by professionals:dentists, attorneys, and therapists: that is, Psychiatrists, Psychologists, and Clinical Social Workers. This location iseast of downtown. Byron is not quite in the downtown area. It is a quieter area. That very large building of officesand residents, and balconies will change the atmosphere.10- It is my understanding that the developers of this project have not built in Palo Alto before. These developersare from San Francisco or Sacramento. Palo Alto is unique. Please help hold onto some of its character.11- Please if no other changes are required, please do not allow 6 stories. They themselves at first submitted 4stories. Pls go back to the 4 stories. It will take less time to build, and it will be less overwhelming for houses suchas mine, which is a beautiful Victorian style that has been there for 120 years. Once this huge construction project isbuilt the developer will leave -but this very tall and massive building will be there forever. It will be permanent. Please show consideration, respect and appreciation for the already established Palo Alto buildings by not voting inthis mammoth structure as it is.I much appreciate your time to read my email and consider my points. Thank you,FaithFaith W. Brigel518 Byron Street Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 166  Packet Pg. 244 of 517  From:Christopher Ream To:Kallas, Emily; Architectural Review Board Subject:660 University- SECOND LETTER other than Tree Date:Monday, August 18, 2025 4:07:42 PM Attachments:Ream - SECOND LETTER - Comments on Other Than Tree - 20250308.pdf Importance:High CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Emily, Attached is my letter “SECOND LETTER – Comments on Other than the Tree”. Please distribute it to the Members of the Architectual Review Board, and to others as may be appropriate, in time for their review before the ARB Meeting this coming Thursday morning. Thank you. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 167  Packet Pg. 245 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com August 18, 2025 Members Architectural Review Board City of Palo Alto, California Via: ARB@PaloAlto.gov Emily.Kallas@PaloAlto.gov Re: ARB Meeting on August 21, 2025 660 University Project SECOND LETTER – Comments on Other than the Tree Board Members, The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all our neighbors. • Balconies over University Avenue • Parking • Parking for Office Size Adjustment ? • No Parking for Fitness Center • Balconies in the Canopy • Setbacks • Daylight Plane Balconies over University Avenue Applicant shows 6-foot to 7-foot setbacks for the above-ground building along University Avenue. There are 36 balconies from the Second Floor to the Sixth Floor sticking out six feet into that “setback” so they come right to the edge of the public sidewalk or within one foot of it. They will have a clear glass railing set 3½ feet off the deck, with a clear glass sheet between the railing and the deck of the balcony. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 168  Packet Pg. 246 of 517  Ream – More Comments re the 660 University Project August 18, 2025 Page 2 of 5 On warm, sunny Friday or weekend afternoons and evenings, there are going to be young people socializing on these balconies. The 3½ foot railing is an inviting place to rest your forearm as you hold a soft drink, a beer or a glass of wine. Geometry dictates that the drink is now another 6 - 12 inches closer to the sidewalk floors below. Many residents in The Hamilton get some exercise by walking around our small block and their walk will pass under these balconies. I frequently see seniors from other parts of “Senior Corner” including this sidewalk as part of their walk. Please don’t drop a glass – you may kill someone. This is a grave, inexcusable, unnecessary danger. Those balconies must be removed. Parking Parking in downtown Palo Alto is a problem the City has been dealing with for years and continues to deal with. There is no parking on either University Avenue or Middlefield Road near the project. The Hamilton is on the short block of Byron between University and Hamilton and sees the parking problem every day. It is a narrow street to start with, but on every workday, every single parking spot on both sides of the street is filled all day long. This narrows the drivable room so that two cars going in opposite directions cannot pass; one must slowly pull into a driveway to make room for the other to pass. Every time a delivery vehicle stops on Byron Street during the day, it clogs and backs up Byron. The project does not provide any short-term parking for delivery vehicles, so Byron is going to get backed up many times a day. Applicant calculates that according to PAMC 18.52.040 a total of 81 parking stalls are required to serve the residents of the 70 residential units and 8 parking stalls to serve the workers in the non- residential office space on the ground floor, for a total of 89 stalls. But then Applicant invokes several arguments to reduce the number of stalls it is required to provide, starting with a 13% reduction claimed by TDM, down to only 69 actual parking stalls. Has the city staff carefully reviewed the TDM Applicant has submitted? Will it actually reduce the need for parking or is it only designed to reduce the daily use of cars: Is it designed to reduce the number of daily automotive commutes a person takes, while that person still owns a car to be used for weekend activity. Even though it may reduce daily congestion, that car still needs a place to park. Bottom Line – Applicant has cleverly eliminated 20 parking stalls (89 – 69 = 20). Those 20 stalls may have been eliminated in the project’s garage, but the cars have not been eliminated and the 20 cars that can’t find an empty stall in the project’s garage will be driving around downtown, commercial and residential, looking for a parking space and causing congestion that the TDM was supposed to reduce. My granddaughters and other family members might not come to visit me because of the inability to park nearby and friends will not want to come over as much as they used to. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 169  Packet Pg. 247 of 517  Ream – More Comments re the 660 University Project August 18, 2025 Page 3 of 5 Parking for Office Size Adjustment ? Applicant has shown only 1,984 ft2 of non-residential office space on the First Floor (see Sheet A2.1) and has calculated that the code requirement for that is the 8 parking stalls I referred to in the above section. Last year, up until Applicant added a Fifth and a Sixth Floor in October 2024, the non-residential office space on the First Floor was 9,115 ft2 which calculated to a code requirement of 37 parking stalls, 29 more stalls than the current plans call for (37–8 = 29). I accept Applicant’s calculation of only 8 parking stalls as the First Floor is configured now. Last Year – 9,115 ft2 Light blue is office space Current – 1,984 ft2 Light blue is office space But, there is a warning flag – Applicant has inserted a notice on Sheet A2.1: ALL INTERIOR DEMISING AND PARTITION WALLS SUBJECT TO CHANGE PRIOR TO PERMIT SUBMITTAL AND APPROVAL If Applicant’s plans get approved, will Applicant then go back to the configuration of the First Floor it had last year and collect a lot of monthly rent on the additional 7,131 ft2 of office space without incurring the obligation for the additional 29 parking stalls? It will be tempting to Applicant. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 170  Packet Pg. 248 of 517  Ream – More Comments re the 660 University Project August 18, 2025 Page 4 of 5 Emily Kallas, the City Planner on this project has informally told me that Applicant could only make minor adjustments not to exceed a total of 100 ft2. If this project is going to be approved, I strongly urge that the City Attorney get a binding written contract that limits Applicant to Ms. Kallas’s understanding of a maximum of 100 ft2 in adjustments. Without such a contract, we might have another 29 cars wandering around in addition to the 20 cars in the prior section above. No Parking for Fitness Center Applicant has said that the 1,829 ft2 Fitness Center on the First Floor will be exclusively for use by tenants in the building (residential and office), and thus no need to calculate any additional parking stalls. So, while the City Attorney is at it, get a written contract affirming that the Fitness Center will remain exclusive to tenants. Balconies in the Canopy The approval of the Architectural Review Board at its December 5, 2024 meeting was subject to several conditions being met. The first condition was “Remove balconies from within the Oak tree canopy.” (This can be found in the Staff Report for the upcoming August 21, 2025 Meeting, Item No. 2. Page 5 of 9.). Applicant has ignored this for its plans show 31 balconies including 5- foot clearance would intrude into the canopy (45-foot radius), and none have been removed. They need to be removed. Setbacks At the April 18, 2024 and again at the December 5, 2024 ARB meetings on this project, there was a lot of discussion about the lack of proper setback along Middlefield Road. Applicant has moved the above grade portion of the building back to form a 25-foot setback along Middlefield as requested, but the underground garage still extends right up to the property line with ZERO setback and a minimal amount of soil fill above the garage structure. (See Sheet A3.3A.) Will the City of Palo Alto be able to make improvements to Middlefield Road in the future with this garage flush up against the road? Not likely. Applicant has offered to provide a small area at the Middlefield/University corner of the property as an “accommodation” if the City were to want to make improvements along Middlefield Road. Any improvement would most likely be to improve travel along Middlefield Road. But Applicant’s offer is only for 27 feet down Middlefield from the corner, leaving 46.5 feet still obstructed by the garage. (See Sheet A1.1A.) Applicant needs to make the offer to the City for the entire length of the property along Middlefield. This brings out the fact that the garage also abuts both University Avenue and Byron Street with zero setbacks. Is this standard and acceptable? Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 171  Packet Pg. 249 of 517  Ream – More Comments re the 660 University Project August 18, 2025 Page 5 of 5 Daylight Plane There is a single family, one-story residence zoned RM-20 at 524 Middlefield Road adjacent to the project. Upon a 1/21/2022 review of Applicant’s initial filing, Samuel Gutierrez advised Applicant of the requirement to observe a 45° daylight plane. Applicant complied, and in the next submission of plans, cut back the portion of the Fourth Floor next to the neighboring house. The Fourth Floor has remained cut back and compliant with the daylight plane in all subsequent plans submitted by Applicant including the current submission; but Applicant has now added two additional stories onto the building raising the height up to 82 feet and disregarded the fact that these additional floors egregiously violate the daylight plane. The following is from Applicant’s submission. I have enhanced it to make the line of the daylight plane and the location of the neighboring house more visible. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Board to require action to correct. Thank you for your consideration, Christopher Ream 3/32"=1'-0" PL PL OFFICE LOBBY SPEED RAMP DOWNTO P2 LEVEL UNIVERSITY AVE. 10'- 0 " 10' - 6 " OFFICE PARKING RESIDENTIAL PARKING STAIRBEYOND 7'-9 " T Y P . 45.0° 55' - 0 "LINE O F D A Y L I G H T P L A N E 3'-6 " 3'-6 " 9'-9 " 13 ' - 6 " 10' - 6 " 14'- 6 " 7'-0 " FEN C E 7'-0 " 9'- 9 " EL. -1'-6" (NAVD 88 EL. 45.5') NEIGHBORINGPROPERTY GRADE P1 LEVEL P2 LEVEL LIFT PIT SECOND FLOOREL. 14'-8" THIRD FLOOR FOURTH FLOOR EL. 24'-5" EL. 34'-2" FIRST FLOOR EL. 1'-2" (NAVD 88 EL. 48.16') BASE FLOOD ELEV. EL. 0'-0" (NAVD 88 EL. 47') 1'-2 " 12 ' - 8 1 / 2 " ± 8'-4 1 / 4 " 7'-6 " M I N . EL. -12'-1 1/8" ± EL. -26'-7 1/8" ± EL. -33'-7 1/8" ± CORR.TYP.9'-9 " 12 ' - 3 " 55' - 5 " 1'-6 " FIFTH FLOOREL. 43'-11" SIXTH FLOOREL. 56'-2" T.O. ROOF SLABEL. 70'-2" 14 ' - 0 " T.O. PARAPET / ELEV. EL. 71'-8" OVERRUN / STAIRS T.O. RAILINGEL. 73'-8"T.O. MECH. SCREENEL. 80'-2" 3'-6 " 6'-6 " MECHANICALSCREEN 54'- 6 " + / - 3'-6 " 2'-2" SHORING/SOLDIER BREAMS 1/32"=1'-0" 3/- UNIVERSITY AVE MID D L E F I E L D R O A D BYR O N S T R E E T 64G CARTCOMPOST64G CARTCOMPOSTRC64G CARTCOMPOST 64G CARTCOMPOST 96G CARTWASTE96G CARTRECYCLING 96G CARTWASTE 96G CARTRECYCLING ARCHITECTSKORTH SUNSERI HAGEY SHEET NUMBER SCALE PROJECT NUMBER SHEET TITLE DATENO. ISSUES AND REVISIONS DESCRIPTION ARCHITECTSKORTH SUNSERI HAGEY 21003 PLANNING SUBMITTAL12.01.22 PLANNING RESUBMITTAL #105.13.22 PLANNING RESUBMITTAL #208.15.22 PLANNING RESUBMITTAL #408.28.23 PLANNING RESUBMITTAL #510.31.23 PLANNING RESUBMITTAL #612.20.23 PLANNING RESUBMITTAL #702.07.24 AD HOC REVISIONS05.02.24 PLANNING RESUBMIITTAL #809.30.24 524 MIDDLEFIELD A3.3B ENHANCEMENT OF VISIBILITY OF LINE OF DAYLIGHT PLANE AND 524 MIDDLEFIELD MADE BY CHRISTOPHER REAM Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 172  Packet Pg. 250 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 173  Packet Pg. 251 of 517  Please let me know if you have trouble opening either. Thank you, K Brown Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 174  Packet Pg. 252 of 517  Kay Brown August 16, 2025 Emily Kallas Senior Planner Planning and Development Dept. City of Palo Alto 250 Hamilton Ave Palo Alto, CA 94301 Dear Ms. Kallas, I’m writing to you, once again, to express my concerns regarding traffic issues which will undoubtedly arise with the slated construction of 660 University. In my letter to you dated March 4, 2025, I outlined a number of already existing dangers on Byron St. as well as the potential for an exponential increase in traffic related accidents that will occur on Byron should 660 be given the go-ahead without a proper EIR traffic safety analysis and an in-depth mitigation plan to address said issues. (Below, I will attach my March 4th letter for reference). As you (inclusive of planning department) must be aware, a thorough traffic EIR analysis must include the potential for both pedestrian and vehicle accidents. Unless, I have missed some interaction at meetings or documentation in follow-up reports, I have not seen (within the constructs of the EIR report) any reference to this aspect of 660’s scheduled demolition and construction project. Nor, have I seen an analysis of how an increase in population and autos might impact the safety of existing residents, patients, church-goers and nursery school attendees. I was made aware at the last planning meeting that a few representatives from the planning commission visited the site one day to get a sense of the traffic situation. One representative stated that the lack of space on the narrow street, did present an issue. However, no mitigating solutions were presented that evening nor later in any documentation. A thorough EIR Traffic Safety Report encompasses multi-day and multi-time observations before an adequate analysis can me generated. Repeating, there is no formal EIR traffic safety analysis that has been completed that I can locate for 660. And, after such report has been submitted, there need be mitigating solutions to address said Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 175  Packet Pg. 253 of 517  hazards. The developer must provide in advance adequate alternatives (mitigating solutions ) for parking during construction. The City of Palo Alto Planning Commission must in good conscience provide adequate mitigating traffic solutions, as well, to address increased population/traffic upon project completion. 1. Again, where will the large construction vehicles park for demolition and building erection? Will they be parking on Byron, University or Middlefield? 2. When completed, where will all the new tenants of 660 park? According to the expected population of 660, 74 parking spaces are required. Yet, there’s a 30% reduction allowed under TDM. Only 52 stalls will be available. Clearly, the excess spaces required will overpopulate parking on Byron, University and adjacent streets. (While the TDM has a lofty ambition to encourage mass transportation, a 22 slot reduction in parking will undoubtedly exacerbate an already precarious narrow street scenario.) 3. Please take into consideration multimodal conflict points with the challenged population that exists in a 2 block radius of 660. There are 3 large elderly communities that surround 660. During the day, pedestrians with walkers, wheelchairs and canes regularly cross University to attend meals and activities at the Methodist Church across Byron from 660. 4. With, the increased residents and office workers at 660, what will be the impact on an already dangerous traffic situation? (Must be included in a formal EIR traffic safety report). And, appropriate mitigation steps need to be outlined by either developer or the City of Palo Alto Planning Commission in advance of a go-ahead for construction. A transportation analysis was completed by Hexagon Transportation, a private consultant corporation hired by the developer. Hexagon addresses safety transiently. Briefly, it states that Byron is a quiet street (ie. No danger factor ). The study does not address the width of the street, the traffic patterns on Byron, University nor the pedestrian population that traverses the streets. A legitimate EIR traffic safety analysis according to California codes) must be completed by a public agency, not a private corporation paid by the developer with a vested interest. Hexagon’s report is primarily an overview of traffic patterns in Santa Clara County. Where is the EIR traffic safety analysis that is required by the State of California? Appreciate your time and attention. Sincerely, Kay Brown Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 176  Packet Pg. 254 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 177  Packet Pg. 255 of 517  Kay Brown March 4, 2025 Emily Kallas Senior Planner Planning and Development Dept. City of Palo Alto 250 Hamilton Ave Palo Alto, CA 94301 Dear Ms. Kallas, I’m writing to express my concerns regarding the intended project slated to be built at 660 University. This large apartment/multi-use facility is scheduled to come before you for determination on March 12, 2025. I would like to familiarize you with the current traffic issues on the 500 block of Byron St. As it stands today, senior residents of 555 Byron as well as nursery school parents, church-goers and dental office patients encounter frequent near-misses entering and exiting their respective parking lots. 1. Currently parallel parking is permitted on both sides of the street, and the narrow residual allotment for 2-way traffic becomes unwieldy with one car needing to pull over to allow on-coming traffic to pass. 2. Byron is utilized frequently as an auto pass-through for traffic wanting to avoid the traffic light at University and Middlefield. Residents and patients in cars must to pull-over and brake to avoid the on-coming traffic. The cars travel swiftly without regard to elderly residents that are with walkers and wheelchairs as they attempt to cross the street. 3. Large commercial vehicles deliver food, linen, packages, etc or service plumbing, electrical, wifi tele-communication issues at the various facilities. When these large trucks park on Byron, the danger factor is exacerbated. It is difficult to see or maneuver safely around the commercial vans, etc. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 178  Packet Pg. 256 of 517  4. There are currently 3 large senior facilities within the 2 block radius. Concern for Emergency Response Vehicles ability to access the streets at all times should be paramount It is my understanding that the developer of 660 University intends to situate the ingress and egress to the underground parking directly on Byron St? With the dense apartment units and office spaces allotted to the new complex, accidents can be anticipated. Also, please consider the situation that will arise during construction of the new complex. At any given time, there will be large construction vehicles needed to demolish existing structures and erect the final facility. Where will they park so as not to worsen an already dangerous situation…on University, on Middlefield? I am under the impression that the developers are anticipating that many of the 660 University dwellers will not own cars and will be utilizing mass transport. At the previous City Council meetings, a study initiated on the developers behalf stated that a majority of the tenants will not be coming and going in automobiles by a computer generated (formulation) pie in the sky scenario? If this is an accurate analysis, I am asking the city of Palo Alto to verify this information and stand by it’s assessment. Thank you for your attention to this matter. Appreciatively, KB Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 179  Packet Pg. 257 of 517  From:Christopher Ream To:Kallas, Emily; Architectural Review Board Subject:660 University - Letter re Tree Date:Monday, August 18, 2025 1:51:14 AM Attachments:Ream Letter re Tree - 20250818 w Attachments.pdf Importance:High Emily, Attached is my letter “Protect the Coast Live Oak”. Please distribute it to the Members of the Architectual Review Board, and to others as may be appropriate, in time for their review before the ARB Meeting this coming Thursday morning. Thank you.  Chris _________________________ Christopher Ream Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 180  Packet Pg. 258 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 181  Packet Pg. 259 of 517  660 University Project Protect the Coast Live Oak August 18, 2025 Page 2 of 3 The Palo Alto Tree Technical Manual, Section 1.36 requires a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. In the most recent Tree Protection Report, Applicant acknowledges this 41-foot TPZ requirement on page 9 of David Babby’s February 4, 2024 Tree Protection Report it filed with its plans; but notwithstanding that, Applicant has gone ahead and arbitrarily drawn a deficient TPZ of only 30 feet on its plans and positioned its proposed building right next to that 30 feet. That is 11 feet less than the protection required by the City of Palo Alto. Notwithstanding Applicant drawing a 30-foot radius circle on its plans, its Tree Protection Report, pages 9 & 10 discloses that Applicant intends to disregard even that fake TPZ by reporting that there will be a 20-foot setback from the Tree’s trunk for any ground disturbance and that applies to any soil compaction, grading, subexcavation, overexcavation, drenching, and drilling/auguring. In other words, if the construction crew is at least 20 feet from the Tree, they are free to rip out as many roots as they like notwithstanding the deadly effect on the Tree. Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment A). But those roots are going to cut off by the garage and ramps at 30 feet and still much closer to the trunk by the 20-foot rule during construction. Canopy The Tree has a beautiful canopy that stretches 45 feet over the site. The TPZ applies to the canopy as well as the root structure, but Applicant has used its fake 30-foot TPZ to bring the exterior wall of the building up to 30 feet from the trunk of the Tree, slicing off 15 feet of canopy. But then there are a large number of balconies sticking out six feet from the exterior wall. First, Applicant will need to slice off another 6 feet of the canopy to make room for those balconies. Then, the building’s residents are not going to tolerate the Tree intruding their balconies, so the Tree will be pruned back to provide a little fresh air to those enjoying the balconies and you can be sure the Applicant will prune the Tree back so that there is at least 5 feet of clearance between those balconies and the Tree. The result – Tree’s beautiful canopy stretching 45 feet over Applicant’s property will be cut back 26 feet or more (15 + 6 + 5) and will now be only 19 feet. It should be noted that you, the Architectural Review Board, held at your December 5, 2024 Meeting that your approval was conditioned upon “Remove balconies from within the Oak tree canopy.” Staff Report for the upcoming August 21, 2025 Meeting, Item No. 2. Page 5 of 9. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 182  Packet Pg. 260 of 517  660 University Project Protect the Coast Live Oak August 18, 2025 Page 3 of 3 Tree Failure It gets worse – Page 4 of the current Tree Protection Report discloses that the canopy “does unfavorably displace limb and branch weight towards the canopy's edges.” This means that the loss of 26 feet of canopy will be the loss of a disproportionate, huge majority of the canopy’s weight on the side of the Tree closest to the proposed building. And what weight there will be remaining on that side of Tree will be centered much closer to the Tree than the canopy weight on opposite side and thus will have much less leverage to counter-balance the full, heavy canopy on the opposite side. There will be a huge force on one side of the Tree. A tree’s roots do more than just feed and water a tree, the roots stabilize the tree and hold it upright. As the weight and leverage of the canopy on the opposite side of the Tree strains to tip it over the next-door dental office at 517 Byron Street and onto The Hamilton, it is the job of the roots to fight back and hold the Tree up. But, these roots are going to be sliced off under where the canopy is going to be cut back and the roots will not be able to do their job after they have been sliced off. The Hamilton has retained an independent arborist to analyze the possible danger to the Tree. After extensive investigation and the preparation of a detailed analysis, it was that arborist’s professional opinion that the Tree’s vigor would be negatively impacted to a severe degree as a direct result of the proposed work at the 660 University site as described on Applicant’s plans, resulting in the Tree falling into a spiral of condition decline from which it cannot recover. Please review the Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023 (See Attachment B). Notwithstanding that this report had been made public to Applicant well almost two years ago, Applicant has done nothing to minimize this serious danger. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy that dental office and badly injure and maybe kill anyone in those offices at the time. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Commission to require action to correct Thank you for your consideration, Christopher Ream Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 183  Packet Pg. 261 of 517  660 University Project Ream – Protect the Coast Live Oak March 4, 2025 A"achment A Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 184  Packet Pg. 262 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 185  Packet Pg. 263 of 517  660 University Project Ream – Protect the Coast Live Oak March 4, 2025 A"achment B Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 186  Packet Pg. 264 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 187  Packet Pg. 265 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 188  Packet Pg. 266 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 189  Packet Pg. 267 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 190  Packet Pg. 268 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 191  Packet Pg. 269 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 192  Packet Pg. 270 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 193  Packet Pg. 271 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 194  Packet Pg. 272 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 195  Packet Pg. 273 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 196  Packet Pg. 274 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 197  Packet Pg. 275 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 198  Packet Pg. 276 of 517  From:Admin To:Architectural Review Board Subject:Re: 660 University Project Date:Sunday, August 17, 2025 3:47:25 PM Attachments:Letter to ARB Aug 17, 2025.pdf Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 199  Packet Pg. 277 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 200  Packet Pg. 278 of 517  From:Kallas, Emily To:Christopher Ream Cc:Gilbert, Carol Subject:Re: 660 University Date:Monday, July 21, 2025 4:28:11 PM Attachments:Outlook-Logo__Desc.pngOutlook-po3batwi.pngOutlook-Logo__Desc.pngOutlook-tkzgy4nh.png Hi Chris, Thank you for letting me know you did not receive my email on July 14th. The revised plans are also available on the project webpage: https://www.paloalto.gov/Departments/Planning-Development-Services/Current- Planning/Projects/660-University-Ave You are correct that the plans have been reuploaded with the changes you identified. They also made changes to how the BMR units are distributed, and minor changes to the Middlefield setback area. We are currently targeting ARB on August 21, PTC on September 24, and Council on October 20 or November 3 depending on agenda availability. Thanks, Emily Emily Kallas, AICP PlannerPlanning and Development Services Department (650) 617-3125 | emily.kallas@cityofpaloalto.orgwww.cityofpaloalto.org Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms &Applications | Planning Applications Mapped From: Kallas, Emily <Emily.Kallas@paloalto.gov> Sent: Monday, July 21, 2025 4:18 PM To: Christopher Ream <chrisshop@reamlaw.com> Cc: Gilbert, Carol <carol.gilbert@comcast.net> Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 201  Packet Pg. 279 of 517  Subject: Re: 660 University Hi Chris, Yes, we discussed this on July 14th. Please let me know if you did not receive my email that day. That information is correct. Thanks, Emily Emily Kallas, AICPPlannerPlanning and Development Services Department(650) 617-3125 | emily.kallas@cityofpaloalto.orgwww.cityofpaloalto.org Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms &Applications | Planning Applications Mapped From: Christopher Ream <chrisshop@reamlaw.com> Sent: Monday, July 21, 2025 4:16 PM To: Kallas, Emily <Emily.Kallas@paloalto.gov> Cc: Gilbert, Carol <carol.gilbert@comcast.net> Subject: 660 University Emily, Please give me an update on the status of the 660 University Project. It is my understanding that the developer is moving forward with its original application 21PLN-00341. Two new sets of plans and supporting documents were filed on 6/23/2025, C12_660 University Ave_PLAN1.pdf, C12_660 University Ave_PLAN2.pdf, and C12_660 University Ave_DOCS.pdf. My brief review of these plans reveals a major change: The top floor (sixth) is no longer office space but has been changed to 12 new residential units, and the total number of residential units has increased from 66 to 70. I am assuming that these new plans and documents supersede the prior filings. Am I correct in my understanding? Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 202  Packet Pg. 280 of 517  Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 chrisshop@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 203  Packet Pg. 281 of 517  From:Faith Brigel To:Kallas, Emily Subject:Planning and Transportation Committee: 660 University Ave. Date:Wednesday, April 30, 2025 1:58:05 PM CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hello Emily, I received a notice that there will be a public hearing tonight at City Hall re the construction project at 660 University Ave. Unfortunately, I will not be able to attend. So I am writing this email to you in the hopes that you and the members of this committee will see it. I cannot state strongly enough how out of place, and cumbersome this huge building will be on University Ave and Byron Street. I have been on Byron St. for thirty years and so I feel that I have some knowledge of that area. It will be out of place in that no other buildings in that area are that large, that dense, nor that high. No other buildings are 6 stories high. Initially weren’t they describing it as 4 stories, which is still very high? I call it cumbersome in that there will be many people living there, and many people working there and most of them will need parking spots. And as they explained at one of the meetings though they will have a 2 level underground parking lot- there still will NOT be enough parking sports for all of their people. There is very little parking on University Ave, , and rarely are there any available parking spots on Byron Street. Similarly, finding parking on Middlefield is close to impossible. This lack of parking for their tenants, and clients or customers will be a serious problem once the construction is complete. I am quite sure that they are not yet aware of this. The fact that they are planning to build 6 stories is of a great concern to me. My building at 518 Byron Street is as I have explained a one story, and it has been there for more than 120 years. Having this construction 6 stories high right across the street will effect the light plan. It will be ominous. And it will detrimentally affect the quality of life of my tenants. I am hoping and would expect that the City Staff would help protect the Palo Alto community of already established buildings., like mine, from new developments coming in and overwhelming the area. I hope that you will not just focus on building more houses for Palo Alto, but also protect the character that older, Victorian buildings such as mine offer to our City. Thank you, Faith W. Brigel Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 204  Packet Pg. 282 of 517  From:Faith Brigel To:Planning Commission Cc:Kallas, Emily Subject:Re: The 511 Byron St., 660 University Ave. 680 University Ave., 500 Middlefield Ave.Complex Date:Friday, March 14, 2025 6:35:17 PM Attachments:image001.pngATT00001.txtimage002.pngATT00002.txt CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hello Panning Commission,I do not know if you got the email that I sent to you on March 12 right before the meeting. I am sorry that it was so late. I read some of what happened in the meeting and I would like to make a few comments. Firstly, I realize that these developers initially submitted their plans for this project in 2021.And I think that there may be the concern that since it has been such a long time- you should be more empathicto them, and just approve it. I would like to make the point that had their initial draft been different it may have gonethrough much faster and more smoothly. By different I mean more in line with the other buildings in this area. From the first draft thisbuilding has been mammoth, massive, and very out of character with this neighborhood. For several reasons this construction is wrong for that location. All the changes that they havemade over the past few years have not brought it down in scale or size. In fact, it has gotten larger! When they were told that they need more setback- they said fine we will just addanother story- so it went from four stories up to six stories! And so due to their own insistence that it remain massive in size - this process has lingered. And they have taken up your time. Secondly, I read that at least one of you believe that the final decision that was made at your meeting was wrong. And that you should have approved their current design.I want to say that you did the right thing. I am thrilled that their design was not approved. It is so wrong. I was fearing that only once it is built will you see how wrong it is. And by then ofcourse it is too late. Thirdly, to mention several of the reasons why it is wrong: 1- It will be huge, gigantic, massive and totally out of scale with the neighbor’s buildings. There are NO 6 story buildings here. The highest is 4 stories. 2- That intersection of University and Middlefield is the gateway to downtown Palo Alto, and it is always congested. To accept this current design will add more congestion and traffic than it can bear. It will be a constant nightmare. 3- At one of the meetings the developer himself stated that they will have a two level parkinggarage in their new basement. But he added, there will NOT be enough parking spots for them. There will be 66 apartments. And only 78 spaces. What about the parking needs of theiroffices? That is not near enough what they will need. So where will they park? They will not be able to park on Byron Street which is a small, narrow street and as I wrote 3/12 it is alwaysfull. Rarely are there available spots. There will be very few spots on University, and very few on Middlefield. So this will become a serious and ongoing problem. 4- This area mostly consists of office buildings with professionals, attorneys, dentists, and therapists. Aside from the traffic, it is a quiet area. Allowing this gigantic construction with 66 studio apartments that will have balconies, plus offices will effect the ambiance negatively. We have no restaurants, nor bars in our area. It is quiet. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 205  Packet Pg. 283 of 517  5- By allowing this development company to build a 6 story, complex sets a precedent forothers to build that high in this area. A bad decision. 6- Personally, I have owned the small, one-story, beautiful, well maintained, 120 year oldVictorian building across the street. This massive development will totally overshadow my building, which will negatively affect the quality of living of my tenants. One tenant hasalready told me that she might move out. And I think it might affect my daylight plane. 7- I understand that due to some contract not being signed by Palo Alto the developers cannow build at their own discretion. But it seems that these developers realize the benefits of trying to get the Planning Commission and the City Council’s approval. But still this is not areason to approve such a phenomenally mammoth building. Pease continue to use your discretion, and integrity as you did at that last meeting, and do not let a developer destroy what has been a tasteful, professional area just for their own greed. Thank you for your consideration. I would be happy to meet any of you on Byron Street to discuss this further. I have spent a lotof time on Byron since 1987, which is 38 years. Best regards, Faith Faith W. Brigel518 Byron St. > On Mar 12, 2025, at 5:35 PM, Faith Brigel <faithwb3@yahoo.com> wrote: > > > >> Dear Planning Commission, >> I am not able to get to the meeting tonight. And I was not able to write any sooner. >> I hope that you see this email prior to the meeting. I have attended a couple of the other meetings on the construction on University Ave. and Byron. I own the building across thestreet. It is a single story Victorian house. I have been there since 1987. >> The construction submitted that is being discussed is much too large for this area. And Iunderstand that now they are asking for it to be six stories. This is much too tall for this area. No other buildings here are that high. There is also a lot of traffic at that corner. The 2 levelunderground parking will not be large enough for their needs. So their parking needs will spill out onto Byron that is already completely taken every day, all day, except maybe Sunday.>> Please consider the quality of life that will be detrimentally affected by the neighbors by allowing that project to be so massive. Please have them scale it back to a more moderate size.>> Thank you for your consideration. >> >> Faith W. Brigel >> >>> On Mar 6, 2025, at 2:01 PM, Kallas, Emily <Emily.Kallas@cityofpaloalto.org> wrote: >>> >>> Hello, >>> You are receiving this email because you have expressed interest in the Planned HomeZoning (PHZ) project proposed at 511 Byron St, 660 University Ave, and 680 University Ave/500 Middlefield Rd (aka 660 University). This project. is being presented to the Planningand Transportation Commission on March 12, 2025 at 6pm. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 206  Packet Pg. 284 of 517  >>> The agenda, staff report, and attachments are available here:>>> https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16498 >>> The project plans, Draft EIR, Final EIR, and other project documents are available here:>>> https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Current- Planning/Projects/660-University-Ave>>> If you have any comments, please email them to Planning.Commission@CityofPaloAlto.org. There will also be the opportunity for publiccomments during the hearing. If you have any questions about the project you would like assistance with prior to the hearing, please email me at emily.kallas@cityofpaloalto.org.>>> Thanks, and see you next week, >>> Emily Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 207  Packet Pg. 285 of 517  From:slevy@ccsce.com To:Planning Commission Cc:Kallas, Emily Subject:660 University Date:Monday, March 10, 2025 4:23:11 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. ! Dear Commissioners, Please add your comments and forward to the City Council. This application is now in its 4th year of review. They deserve a decision by council. I attended all the ARB hearings in which opponents made their objections after which the ARB approved the project. The applicant has worked hard to meet concerns while preserving feasibility and choosing a compliant not builder's remedy application. This to my knowledge is the only housing proposal downtown of any significant size. Also it brings with it BMR units that the applicant was able to weight toward lower income residents. Housing downtown is a major city goal in our HE and approval of this project will be a promising start and\ bring the many benefits of downtown living to residents (I am one), to local businesses and to the environment. I look forward to seeing this application approved and see the new housing in myneighborhood. Stephen Levy This message could be suspicious The sender's email address couldn't be verified. Mark Safe Report Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 208  Packet Pg. 286 of 517  1 Kallas, Emily From:Preparata, Franco <franco_preparata@brown.edu> Sent:Wednesday, March 5, 2025 8:25 AM To:Planning Commission Cc:Lily.lim-tsao@cityofpaloalto.org; Kallas, Emily Subject:660 University Ave CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Byrne Chang (Chair)  Allen Akin (Vice Chair)  Doria Summa (Commissioner)  Bart Hechtman (Commissioner)  Carolyn Templeton (Commissioner)      Dear Honorable City Commissioners:    As residents of The Hamilton, the 55+ retirement community located next to this proposed site, this proposed project is  deeply concerning for us.    The increased density of a 6‐story building would substantially alter what is currently a quiet and safe street; It would  not only change the character of this neighborhood block but it would also create a hazard for many of The Hamilton's  residents. As elderly pedestrians, increased congestion is a significant safety issue. This is particularly the case given that  the vehicular entry to the proposed building’s parking garage would be on Byron Street, next to The Hamilton’s  entrance.    Additionally, Byron Street is a narrow street. As it stands, two cars cannot pass one another on the street. The setback of  the proposed building on the Byron street side would need to be comparable to the setback of The Hamilton complex in  order to permit the safe parking of firetrucks or other emergency vehicles.    We urge you to seriously reconsider the project.    Franco P. and Rosa Maria Preparata  ‐‐   Franco Preparata  An Wang Professor of Computer Science, Emeritus  Brown University  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 209  Packet Pg. 287 of 517  1 Kallas, Emily From:Christopher Ream <ream@reamlaw.com> Sent:Wednesday, March 5, 2025 2:31 AM To:Kallas, Emily Subject:660 University - SECOND letter Attachments:Ream Letter re Other Than Tree - 20250305.pdf Importance:High CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Emily,    Please find attached a SECOND letter from me regarding other concerns with the 660 University project.  This  is in addtion to the letter concerning the Tree which I had just sent to you.  Please include include this SECOND letter as well in the packet for the March 12 PTC hearing.   Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1‐650‐424‐0821 ream@reamlaw.com      Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 210  Packet Pg. 288 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com March 5, 2025 Commissioners Planning and Transportation Commission City of Palo Alto, California Via: Emily.Foley@CityofPaloAlto.org Re: 660 University Project SECOND LETTER – More Comments Commissioners, The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all of our neighbors. Parking Parking in downtown Palo Alto is a problem the City has been dealing with for years and continues to deal with. There is no parking on either University Avenue or Middlefield Road near the project. The Hamilton is on the short block of Byron between University and Hamilton and sees the parking problem every day. It is a narrow street to start with, but on every workday, every single parking spot on both sides of the street is filled all day long. This narrows the drivable room so that two cars going in opposite directions cannot pass; one has to slowly pull into a driveway to make room for the other to pass. Every time a delivery vehicle stops on Byron Street during the day, it clogs and backs up Byron. The project does not provide short-term parking for delivery vehicles, so Byron is going to get backed up many times a day. Applicant calculates that according to PAMC 18.52.040 a total of 111 parking stalls are required to serve the residents of the 66 residential units and the workers in all the office space. But then Applicant invokes several arguments to reduce the number of stalls it has to provide, starting with a 30% reduction claimed by TDM, down to only 69 actual parking stalls. I have seen 20% reductions claimed for TDM, but never 30%. Is Applicant’s claim of 30% proper? Has the city staff carefully reviewed the TDM Applicant has submitted? Will it actually reduce the need for parking or is it only designed to reduce the daily use of cars: Is it designed to reduce the number of daily automotive commutes a person takes, while that person still owns a car to be used for weekend activity. Even though it may reduce daily congestion, that car still needs a place to park. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 211  Packet Pg. 289 of 517  Ream – More Comments re the 660 University Project November 26, 2024 Page 2 of 4 Bottom Line – Applicant has cleverly eliminated 42 parking stalls (111 – 69 = 42). Those 42 stalls may have been eliminated, but the cars have not been eliminated, and the 42 cars that can’t find an empty stall in the project’s garage will be driving around downtown, commercial and residential, looking for a parking space and causing congestion that the TDM was supposed to reduce. My granddaughter and other family members may not come to visit me because of the inability to park nearby; friends will not want to come over as much as they used to. Setbacks At the April 18, 2024 ARB meeting on this project, there was a lot of discussion about the lack of proper setback along Middlefield Road. Applicant has moved the above grade portion of the building back to form a 24’ setback along Middlefield as requested, but the underground garage extends right up to the property line with ZERO setback and a minimal amount of soil fill above the garage structure. (See Sheet A3.3A.) Will the City of Palo Alto be able to make improvements to Middlefield Road in the future with this garage flush up against the road? This brings out the fact that the garage also abuts both University Avenue and Byron Street with zero setbacks. Is this standard and acceptable? Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 212  Packet Pg. 290 of 517  Ream – More Comments re the 660 University Project November 26, 2024 Page 3 of 4 Daylight Plane There is a single family, one-story residence zoned RM-20 at 524 Middlefield Road, adjacent to the project. Upon a 1/21/2022 review of the initial filing by Applicant, Samuel Gutierrez advised Applicant of the requirement to observe a 45° daylight plane. Applicant complied, and in the next submission of plans, cut back the portion of the fourth floor next to the neighboring house. The fourth floor has remained cut back and compliant with the daylight plane in all subsequent plans submitted by Applicant including the current submission; but Applicant has now added two additional stories onto the building raising the height up to 82 feet, and disregarded the fact that these additional floors egregiously violate the daylight plane. The following is from Applicant’s submission. I have enhanced it to make the line of the daylight plane and the location of the neighboring house more visible. Balconies in the Canopy The approval of the Architectural Review Board at its December 5, 2024 meeting was subject to several conditions being met. The first condition was “Remove balconies from within the Oak tree canopy.” (This can be found at the top of the fifth page of the document filed on 3/3/2025 under the name “C11_660 University Ave_DOCS_Revised for PTC.pdf”). Applicant’s plans show 24 balconies would intrude into the canopy (45-foot radius), and none have been removed. 3/32"=1'-0" PL PL OFFICE LOBBY SPEED RAMP DOWNTO P2 LEVEL UNIVERSITY AVE. 10 ' - 0 " 10' - 6 " OFFICE PARKING RESIDENTIAL PARKING STAIRBEYOND 7'-9 " T Y P . 45.0° 55 ' - 0 " LINE O F D A Y L I G H T P L A N E 3'-6 " 3'-6 " 9'-9 " 13 ' - 6 " 10' - 6 " 14 ' - 6 " 7'-0 " FE N C E 7'-0 " 9'-9 " EL. -1'-6" (NAVD 88 EL. 45.5') NEIGHBORINGPROPERTY GRADE P1 LEVEL P2 LEVEL LIFT PIT SECOND FLOOREL. 14'-8" THIRD FLOOR FOURTH FLOOR EL. 24'-5" EL. 34'-2" FIRST FLOOR EL. 1'-2" (NAVD 88 EL. 48.16') BASE FLOOD ELEV. EL. 0'-0" (NAVD 88 EL. 47') 1'-2 " 12' - 8 1 / 2 " ± 8'- 4 1 / 4 " 7'- 6 " M I N . EL. -12'-1 1/8" ± EL. -26'-7 1/8" ± EL. -33'-7 1/8" ± CORR.TYP.9'-9 " 12 ' - 3 " 55 ' - 5 " 1'-6 " FIFTH FLOOREL. 43'-11" SIXTH FLOOREL. 56'-2" T.O. ROOF SLABEL. 70'-2" 14' - 0 " T.O. PARAPET / ELEV. EL. 71'-8" OVERRUN / STAIRS T.O. RAILINGEL. 73'-8"T.O. MECH. SCREENEL. 80'-2" 3'-6 " 6'-6 " MECHANICALSCREEN 54' - 6 " + / - 3'-6 " 2'-2" SHORING/SOLDIER BREAMS 1/32"=1'-0" 3/- UNIVERSITY AVE MID D L E F I E L D R O A D BY R O N S T R E E T 64G CARTCOMPOST64G CARTCOMPOSTRC64G CARTCOMPOST 64G CARTCOMPOST 96G CARTWASTE96G CARTRECYCLING 96G CARTWASTE 96G CARTRECYCLING ARCHITECTSKORTH SUNSERI HAGEY SHEET NUMBER SCALE PROJECT NUMBER SHEET TITLE DATENO. ISSUES AND REVISIONS DESCRIPTION ARCHITECTSKORTH SUNSERI HAGEY 21003 PLANNING SUBMITTAL12.01.22 PLANNING RESUBMITTAL #105.13.22 PLANNING RESUBMITTAL #208.15.22 PLANNING RESUBMITTAL #408.28.23 PLANNING RESUBMITTAL #510.31.23 PLANNING RESUBMITTAL #612.20.23 PLANNING RESUBMITTAL #702.07.24 AD HOC REVISIONS05.02.24 PLANNING RESUBMIITTAL #809.30.24 524 MIDDLEFIELD A3.3B ENHANCEMENT OF VISIBILITY OF LINE OF DAYLIGHT PLANE AND 524 MIDDLEFIELD MADE BY CHRISTOPHER REAM Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 213  Packet Pg. 291 of 517  Ream – More Comments re the 660 University Project November 26, 2024 Page 4 of 4 Balconies over University Avenue Applicant shows six to seven foot setback for the above-ground building along University Avenue. There are 29 balconies from the second to the fifth floor sticking out six feet into that “setback” so they come right to the edge of the public sidewalk or within one foot of it. They will have a clear glass railing set 3½ feet off the deck, with a clear glass sheet between the railing and the deck of the balcony. The majority of these balconies are part of small studio apartments. On warm, sunny Friday or weekend afternoons, there are going to be young people socializing on these balconies. The 3½ foot railing is an inviting place to rest your forearm as you hold a soft drink, a beer or a glass of wine. Geometry dictates that the drink is now another 6 -12 inches closer to the sidewalk floors below. Many residents in The Hamilton get some exercise by walking around our small block and their walk will pass under these balconies. I frequently see seniors from other parts of “Senior Corner” including this sidewalk as part of their walk. Please don’t drop a glass – you may kill someone. Those balconies need to be removed. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Board to require action to correct. Thank you for your consideration, Christopher Ream Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 214  Packet Pg. 292 of 517  1 Kallas, Emily From:Christopher Ream <ream@reamlaw.com> Sent:Wednesday, March 5, 2025 2:26 AM To:Kallas, Emily Subject:660 University - Letter t for PTC hearing Attachments:Ream Letter re Tree - 20250304.pdf Importance:High CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Emily,    Please find attached a letter from me regarding the Tree next to the 660 University Project, together with two  attachments. Please include this in the packet being prepared for the hearing on March 12.   Thank you.  Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1‐650‐424‐0821 ream@reamlaw.com      Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 215  Packet Pg. 293 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com March 4, 2025 Commissioners Planning and Transportation Commission City of Palo Alto, California Via: Emily.Foley@CityofPaloAlto.org Re: 660 University Project Protect the Coast Live Oak Commissioners, My wife Anne and I have been Palo Alto residents for more than 53 years and have been residents of The Hamilton for the past six years. The Hamilton is a senior living (55+) condominium development which shares the small block with the proposed development at 660 University Avenue. The Board of Directors of the Hamilton Homeowners Association (“HHA”), with the support of its residents, has resolved to push for revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block. David Babby, Applicant’s arborist, reports the Tree’s trunk is 50 inches in diameter and its mostly uniform canopy stretches out 90 feet in diameter and is approximately 60 feet high. The Tree abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is much larger. The Tree is several hundred years old and is deemed a protected tree by the City of Palo Alto. The Tree brings shade and joy to us and everyone else on the block. Applicant’s proposal to build a large building close to the Tree will put it in grave danger, and we need to protect it. TPZ – Tree Protection Zone The Palo Alto Tree Technical Manual requires a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Applicant acknowledges this 41-foot TPZ requirement in the Tree Protection Report it has filed with its plans, but then it has arbitrarily drawn a TPZ of only 30 feet on its plans and positions this building right next to that 30 feet. That is 11 feet less than required by the City of Palo Alto. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 216  Packet Pg. 294 of 517  660 University Project Protect the Coast Live Oak March 4, 2025 Page 2 of 3 Notwithstanding Applicant drawing a 30-foot radius circle on its plans, its Tree Protection Report discloses that Applicant intends to disregard even that fake TPZ by reporting that there will be a 20-foot setback from the Tree’s trunk for any ground disturbance and that applies to any soil compaction, grading, subexcavation, overexcavation, drenching, and drilling/auguring. In other words, if the construction crew is at least 20 feet from the Tree, they are free to rip out as many roots as they like notwithstanding the deadly effect on the Tree. Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment A). But those roots are going to cut off by the garage and ramps at 30 feet and much closer to the trunk by the 20-foot rule during construction. Canopy The Tree has a beautiful canopy that stretches 45 feet over the site. The TPZ applies to the canopy as well as the root structure, but Applicant has used its fake 30-foot TPZ to bring the exterior wall of the building up to 30 feet from the trunk of the Tree, slicing off 15 feet of canopy. But then there are a large number of balconies sticking out six feet from the exterior wall. Applicant will need to slice off another 6 feet of the canopy to make room for those balconies. The building’s residents are not going to tolerate the Tree intruding their balconies, so the Tree will be pruned back to provide a little fresh air to those enjoying the balconies and you can be sure the Applicant will prune the Tree back so that there is at least 5 feet of clearance between those balconies and the Tree. The Tree’s beautiful canopy stretching 45 feet over Applicant’s property will be cut back 26 feet or more (15 + 6 + 5) and will now be only 19 feet. Tree Failure A tree’s roots do more than just feed and water a tree, the roots stabilize the tree and hold it upright. These roots are going to be sliced off under where the canopy is going to be cut back. As the weight and leverage of the canopy on the opposite side of the Tree strains to tip it over the dental office and onto The Hamilton, it is the job of the roots to fight back and hold the Tree up. But the roots will not be able to do that after they have been sliced off. The Hamilton retained an independent arborist to analyze the possible danger to the Tree. After extensive investigation and the preparation of a detailed analysis, it was that arborist’s professional opinion that the Tree’s vigor would be negatively impacted to a severe degree as a Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 217  Packet Pg. 295 of 517  660 University Project Protect the Coast Live Oak March 4, 2025 Page 3 of 3 direct result of the proposed work at the 660 University site as described on Applicant’s plans, resulting in the Tree falling into a spiral of condition decline from which it cannot recover. Please review the Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023 (See Attachment B). Notwithstanding that this report had been made public to Applicant over a year ago, Applicant has done nothing to minimize this serious danger. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy the dental offices and badly injure and maybe kill anyone in those offices at the time. Conclusion The Hamilton community strongly opposes this application for excessive development on our small block and urges the Commission to require action to correct As David Hirsch so succinctly stated on December 1, 2022 at the first Architectural Review Board Meeting to consider this application: “This is too much building in too small of a space.” Thank you for your consideration, Christopher Ream Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 218  Packet Pg. 296 of 517  660 University Project Ream – Protect the Coast Live Oak March 4, 2025 A"achment A Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 219  Packet Pg. 297 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 220  Packet Pg. 298 of 517  660 University Project Ream – Protect the Coast Live Oak March 4, 2025 A"achment B Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 221  Packet Pg. 299 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 1 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Date: 12/18/2023 Impact Analysis of Proposed 660 University, Palo Alto Site Plan Project Work on One (1) Off-Site Coast Live Oak (Quercus agrifolia) Specimen (Project Tree #10, Palo Alto City Tree Tag #1572) at 517 Byron Palo Alto, CA Mr. Chris Ream, President The Hamilton Homeowners Association 555 Byron Palo Alto, CA ream@reamlaw.com Dear Mr. Ream, The following written letter report is the single deliverable prepared by Walter Levison, Consulting Arborist (WLCA) per your request as an association with members residing at The Hamilton, in close proximity to the proposed multi-story 660 University project. Background and Assignment The proposed private development project stated above proposes to demolish various existing office buildings and parking lot areas, and build an underground parking garage, with residential and commercial office facility directly over the garage footprint. WLCA’s assignment was to determine whether the site work as currently proposed per the set of plan sheets (dated October 2023) would cause severe or otherwise irreversible injury to the subject oak specimen to such as degree that it would be expected to fall into a spiral of decline from which it could not recover, as a direct result of the site work. WLCA visited the site on 12/13/2023 to archive digital images, create a tree map markup showing actual site-verified canopy dimensions (rough approx.), and confirm existing site conditions. The project encompasses three lots, 660 University, 680 University, and 511 Byron. An adjacent lot at 517 Byron just south of the proposed work area exhibits a relatively very large “veteran tree” coast live oak (Quercus agrifolia) referenced by David L. Babby, author of the Tree Protection Report filed by the developer, as tree #10 (City tag #1572), a specimen in good overall condition (62% out of 100% possible) as visually assessed by WLCA, with a canopy spread that is equal to the largest coast live oak specimens ever assessed in the author’s entire 25 year professional consulting career (see digital images below in this report showing the 90 foot diameter canopy). WLCA reviewed the private development proposed plan sheets dated 10/31/2023 (planning resubmittal #5) which were downloaded from the City of Palo Alto website, and an arborist report by David Babby dated 11/19/2021, which does not actually contain any site plan sheets (Mr. Babby used a topographic survey sheet for his site tree map markup). Multiple marked-up tree location maps, color-coded by WLCA, show expected construction-related impacts in relation to the tree #10 existing canopy dripline and in relation to the standard tree protection zone (TPZ) of 10 x diameter as an offset radius from mainstem edge. These markups are attached to the end of this letter report for reference (view document using Adobe Pro, Adobe CS, or other paid form of Adobe Acrobat, to maintain the visibility of the color-coded markups). Digital images archived by WLCA in December 2023 are also included in this report for reference of pre-project conditions. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 222  Packet Pg. 300 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 2 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Basic Data Diameter: 50 inches, per Babby report. Spread: Approximately 90 feet total diameter, per David Babby report and WLCA. Health (Vigor): 70% per Babby, 80% per WLCA. Structure: 40% per Babby, 50% per WLCA. Overall Condition Rating: 50% (fair) per Babby, 62% (good) per WLCA. Live Twig Density and Live Foliar Density: Good. Additional Tree Information per WLCA’s Visual Tree Assessment (VTA) 12/13/2023 and Research Foliage hangs down to 15 to 25 feet above grade at 45 feet radius north of mainstem edge. Multiple mainstems exhibit wide angle saddle shaped (i.e.”normal”) attachment forks between 10 and 15 feet elevation above grade. These stems are somewhat upward oriented. Buttress root flares at root crown appear normal, though root system extent and condition are essentially unknowable due to hardscape presence over a large percentage of actual root zone. It is hypothesized that the actual extent of root zone is at least 2x to 3x the 45 foot canopy radius in terms of lateral distance in most directions out from trunk1, based on both Arboriculture 4th Edition (2004), and on WLCA’s past 25 years of construction site consulting experience with coast live oak specimens on older sites with older less-compacted root zone conditions, where historical building foundations and parking lot baserock base sections were constructed to far less strict standards than modern engineer specifications. There may be extensive rooting occurring out through various private lots that adjoin the 517 Byron lot on which tree #10 stands, with lateral woody roots extending from tree #10 underneath various retaining wall footings and building footings, out to underneath existing asphalt parking lot surfacing, etc. Per USGS local quadrangle soils map, tree #10 is growing in the “Qoa” unit, which is defined as an older alluvium (oa): a gravelly riparian soil that is derived from stream associated movements, and typically contains smooth rocky material that drains relatively well, and is excellent for development of deep, elongated native oak tree root systems (based on WLCA’s professional experience and research). This Palo Alto site probably has one of the best soils in the entire Bay Area in terms of allowing for fast growth of native oaks. See the digital images section of this report for an overlay map created by WLCA using various online sources and the USGS soil map shows how groundwater at this location is relatively high in elevation (25 foot groundwater contour), and shows existing roads, historical streams, and red dot plots where a past survey by others indicated locations of extremely old native valley oak specimens for reference. What this all means is that the proposed project site has very good growing conditions for native oaks with a high groundwater table elevation contour and gravelly alluvium soil associated with historical waterways which drains relatively quickly and may also exhibit relatively good aeration related to the larger material components of the soil. 1 Per Harris et. al. 2004. Arboriculture 4th Edition. Prentice Hall. Upper Saddle River, New Jersey, USA. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 223  Packet Pg. 301 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 3 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Expected Tree Root Zone and Canopy Impact Analysis / Based on October 2023 Set of Proposed Plan Sheets • Canopy: Expect 20 to 30% of canopy live wood and foliage to be removed to clear southward-extended balcony construction, garage vertical wall construction, foundation footing construction for main building structure, vertical exterior walls along the south side of the residential structure, and an additional +/- 10 feet of horizontal width required to be totally cleared up to roof peak elevations as a “construction corridor” airspace for exterior work, scaffold erection, and bucket lift machinery use (based on WLCA’s past projects to date, which required between 6 feet and 15 feet of horizontal clearance as construction corridors around building exterior walls, between soil surface grade and the roof peaks). Note that the curvilinear section of garage entry ramp, although it is below grade elevation, may actually require tall vertical machinery clearance directly above the proposed wall cut locations, resulting in further clearance pruning of the tree #10 northwest corner of canopy (not verified). This information is based on past projects overseen by WLCA involving underground parking garage retaining wall construction in the Bay Area. Total expected canopy loss will likely result in a remnant canopy with 20 to 25 feet of north, northeast, and northwest extension from mainstem base, whereas existing canopy is +/- 45 feet radial extension in those directions. Refer to the attached WLCA tree map markup for a graphic representation of the various impacts indicated as color-coded lines. • Roots: Expected subgrade work will encroach to within the City of Palo Alto “10 times diameter” tree protection zone on the north side of tree, inside which special methods/materials/monitoring is required for site construction work. Extent of root zone compromised by the various elements of proposed work (garage wall excavation using vertical shoring, landscape decking, landscape irrigation, landscape plant and tree installation, etc. is expected to be moderate to severe, depending on actual cut depths and depending on whether machinery and personnel are allowed to enter into the TPZ and compact the root zone in the north area of TPZ. Note that the actual extent of roots may or may not be 2x to 3x the tree canopy dripline radius distance northward from trunk, and is currently obscured by hardscape and not able to be verified in terms of lateral distance of growth. Critical Root Zone (i.e. “CRZ”) or “Tree Protection Zone”, in terms of structural root plate, lateral woody roots, and absorbing root mass retention during work on one or more sides of a tree, is ten times the diameter of trunk (10 x 50 inch diameter as noted in the David Babby report). Therefore, it is WLCA’s understanding that the required TPZ work offset radius for tree #10 is approximately 10 x 50 inches = 41.6 feet radius2), unless site work at offset distances less than 10 x diameter is specifically authorized by City Urban Forestry Staff. Note that in the case of the 660 University project, the severe extent of clearance pruning creates a cumulative impact in terms of loss of tree condition, such that the combined root zone and canopy impacts are relatively severe or extremely severe (see attached WLCA markups showing deep excavation work impacts, for example, expected to within 30 feet offset from trunk, which is far less than the 41.6 foot official TPZ offset). 2 Reference the developer’s Tree Disclosure Statement, which notes that the official TPZ is 10 x diameter of trunk, per City of Palo Alto Tree Technical Manual (TTM) standards. Blue link to full TTM below shows up erroneously as a hyperlink to “Appendix A”, but is actually the full TTM document: APPENDIX A (cityofpaloalto.org) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 224  Packet Pg. 302 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 4 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Note also that there is no guarantee that site work will be performed by the developer in a manner consistent with specific conditions of project approval as set forth by Palo Alto Urban Forestry Staff, even if those special conditions were mandated by the City. There is no way for an arborist monitoring site work, for instance, to be on site during every stage of the work. The arborist monitor, if retained to inspect site work near to tree #10 during the development phase of the project, would only be able to visibly inspect the site once a month or so, leaving him/her with a limited snapshot of what below-ground impacts occurred in relation to the tree #10 root zone. Soil Compaction within the CRZ/TPZ: Note that proposed driving of machinery, foot traffic, extensive landscape footing development, and extensive planting and (possibly also) extensive irrigation pipe trenching are expected to occur within the CRZ/TPZ of 41.6 feet radius from trunk edge of tree #10. Consulting Arborists will typically specify use of robust “ground protection” in these cases, covering the ground with a thick mat of geotextile overlaid with 6 or more inches of wood chips, and finally covered with steel trench plates or full sheets of exterior grade plywood strapped together with steel strap plates to create a soil buffer. But given that there is planned intense landscaping and decking, etc. to be developed in the area between the garage retaining wall and the south property line abutted up against the 517 Byron lot, WLCA expects that it would be virtually impossible for the developer to actually implement use of robust ground protection and maintain it for any length of time, without causing a major problem in terms of ground logistics (staging, storage, movement of tools and materials, performance of landscape related development between 517 Byron and the underground parking garage wall, etc.). Therefore, it is expected that soil compaction of a high degree will likely occur in the north section of the tree #10 root zone, within the CRZ/TPZ offset radius, causing additional reduction in overall tree health and structural condition as soil oxygen pore space is compacted and root zone root growing conditions end up suffering as a result of loss of oxygen pore spaces within the tree root growth section of the soil profile (i.e. mainly the uppermost two feet of the soil profile, but potentially down to 4 or 5 feet or more below soil surface grade elevation in native Palo Alto area historical riparian cobble type soils). • TRAQ Risk: The removal of 20% to 30% of the canopy of tree #10 for clearance as noted above, will cause southward lopsidedness of the currently-symmetrical canopy tree specimen of extremely large spread radius (45 feet radius), resulting in increased load forces acting on the north side (“tension” side) of the root system. The root system will have been compromised to an unknown degree during site work (underground parking garage wall excavation, landscape development, and possible adjustments to or demolition of the existing brick retaining wall that separates 517 Byron from the proposed 660 University project site. Risk of whole tree failure mode and impact with targets to the south of the mainstem location will be necessarily increased and elevated due to these site plan work activities. Risk of stem failure and impact with various ground targets will over time be increased and elevated, due to the required clearance pruning through the north side of the canopy to clear scaffolding, bucket lift machinery, balconies, and the new building exterior wall plus underground parking retaining wall work that requires vertical machinery airspace clearance. Very large diameter pruning cuts will be made to accomplish the work, ranging from a few inches diameter each, up to 17 or more inches diameter each3, on some stems that extend northward into the proposed project airspace area. Pruning cuts of this relatively large diameter will allow for fungal wood decay-causing pathogen entrance into the stems via these open cut wounds, resulting in extensive decay column formation over time that progresses down into the stems from the cut wounds. 3 David Babby’s arborist report notes that a 14” and a 17” diameter stem will require pruning. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 225  Packet Pg. 303 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 5 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture • Heritage Tree Designation in City of Palo Alto There are currently +/- eight (8) trees listed on the City heritage tree list maintained by the City. Per the following information, trees are apparently not required to meet any specific “approval criteria” in terms of species, size, condition, or other relevant parameters, to be selected as formal heritage tree specimens in City of Palo Alto, other than that the trees are native oak species or redwoods located on private property: (Excerpt from a City Staff Report Online): “In 1996, Council enacted the Tree Preservation Ordinance, Chapter 8.10 of the Palo Alto Municipal Code, to preserve and maintain specified native oaks, redwoods, and heritage trees on private property, and to protect them from disfigurement or removal, except in certain circumstances. Section 8.10.090 of the ordinance allows persons to nominate a tree on their property forheritage tree status. After Council approval of such designation, the tree is added to the heritage tree listing, which includes specific location, overall size, and canopy spread. The list is maintained by the Department of Public Works and available to the public on the City’s Urban Forestry website. Once designated, a heritage tree is protected by the provisions of the Tree Preservation and Management Regulations, unless removed from the heritage tree list by subsequent Council action at the request of the property owner.” Per the above information, protected size tree #10 (City tree tag #1572) appears to be an excellent candidate for inclusion in the City’s heritage tree designation program which protects native oaks on private properties. It is a specimen in good overall condition, with exceptional size in terms of both mainstem diameter (est. 50 inches), and canopy spread (90 feet total diameter), with good vigor, good buttress root flares, and good saddle-shaped wide angle forks of mainstem attachment. • David Babby Report 11/19/2021 Page 6 Per page 6 of the developer’s arborist report by David Babby, tree #10 exhibits a “high” rating in terms of suitability for preservation (see below excerpt from page 6 of Babby report): Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 226  Packet Pg. 304 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 6 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Conclusion If the proposed 660 University site plan project were built out as currently proposed per the 10/31/2023 planning resubmittal #5 versions of the plan sheets, WLCA expects that tree #10 would experience relatively moderate to severe root loss, and relatively severe pruning, which combined as a cumulative below-ground and above-ground negative impact would necessarily result in loss of vigor (health) and structure to a severe degree. The tree’s safe and useful life expectancy in its current condition rating of “good” (+/- 62% overall condition rating) may be reduced as a result of site plan project work from (EXISTING: no-construction scenario) 50 to 100 years remaining, to (PROPOSED: post-construction scenario) 10 to 20 years remaining, or less, depending on the tree’s response to very significant project clearance canopy and root pruning as described above in this letter report. It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover. There would also necessarily be a corresponding elevation of the TRAQ risk rating in terms of risk of whole tree and/or tree part failure and impact with various static and moving targets with moderate to high occupancy ratings within the target zone and a reasonable time frame such as 12 to 24 months, starting as of the proposed site construction completion date (this would need to be assessed at a future time, and is outside the scope of WLCA’s initial pre-project assignment). The tree is located in the an area known to have high water table elevations and gravelly (gravel-laden) riparian type alluvium soil that tends to support excellent native oak tree root growth in terms of both rooting depth and root lateral extension. It is highly recommended that this exceptionally large native oak specimen in good overall condition be designated by the City Council as a City of Palo Alto Heritage Tree on private land, and formally added to the list maintained by the City on their official website, with the added tree protection guarantees that this tree special protection status includes (tree specimens are typically nominated for such designation by the owner of the property on which the tree stands). Refer also to David Babby’s arborist report dated 11/19/202, page 6, which notes that tree #10 is rated as “high” suitability for preservation, appearing healthy and structurally stable per his assessment, presenting “good potential for contributing long-term to the site”. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 227  Packet Pg. 305 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 7 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Digital Images by WLCA 12/13/2023 / Tree #10 Coast live oak (Quercus agrifolia) View looking eastward while standing on 517 Byron. Note the excellent buttress root flaring at the root crown of tree #10 which is considered normal and desirable. View of the relatively wide angle fork attachments between 10 and 15 feet elevation above grade at which the tree #10 codominant mainstems arise. These saddle shaped forms are normal and desirable from a structural stability standpoint. Although it is not “optimal” to have codominant mainstems forking in a tree, the best case scenario would be for all of the forks to exhibit wide saddle-shaped attachments like this tree. It is actually extremely unusual for a coast live oak to exhibit saddle-shaped forks at every Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 228  Packet Pg. 306 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 8 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of subject oak #10 looking northward from 517 Byron. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 229  Packet Pg. 307 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 9 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of oak #10 lower 50% of canopy/mainstem architecture, with the adjoining asphalt parking lot area west of 517 Byron visible at left half of the image. The root system is assumed to be extended through most or all adjoining lots surrounding 517 Byron (not verified), as is assumed to reach as much as 2x to 3x the 45 foot canopy radius (again, not verified, but very possible, per WLCA’s past experience with older oaks in Palo Alto and Menlo Park area, especially if Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 230  Packet Pg. 308 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 10 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Per WLCA’s multi-layer mockup created for a valley oak location comparison with groundwater depths and soil types, the tree #10 location has a 25 foot depth groundwater table, and nearby Palo Alto study-noted red dots which indicate very large older valley oak specimens surveyed in the past and included on internet maps for reference. The Qoa soil type at the 660 University site is defined as “older alluvium” (hence the “oa” designation): a Pleistocene soil of gravels, sand, and silt that is unconsolidated to consolidated, interspersed with alluvial materials from stream action. See next page of this report for the United States Geological Survey legend pertaining to this soil unit, clipped from the Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 231  Packet Pg. 309 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 11 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Above was excerpted from the USGS Quadrangle (soil unit map) which includes the City of Palo Alto area. Assumptions and Limiting Conditions Any legal description provided to the consultant/appraiser is assumed to be correct. Any titles and ownership to any property are assumed to be good and marketable. No responsibility is assumed for matters legal in character. Any and all property is appraised and evaluated as through free and clean, under responsible ownership and competent management. It is assumed that any property is not in violation of any applicable codes, ordinance, statutes, or other government regulations. Care has been taken to obtain all information from reliable sources. All data has been verified insofar as possible; however, the consultant/appraiser can neither guarantee nor be responsible for the accuracy of information provided by others. The consultant/appraiser shall not be required to give testimony or to attend court by reason of this report unless subsequent contractual arrangements are made, including payment of an additional fee for such services as described in the fee schedule and contract of engagement. Unless required by law otherwise, the possession of this report or a copy thereof does not imply right of publication or use for any other purpose by any other than the person to whom it is addressed, without the prior expressed written or verbal consent of the consultant/appraiser. Unless required by law otherwise, neither all nor any part of the contents of this report, nor copy thereof, shall be conveyed by anyone, including the client, to the public through advertising, public relations, news, sales, or other media, without the prior expressed conclusions, identity of the consultant/appraiser, or any reference to any professional society or institute or to any initiated designation conferred upon the consultant/appraiser as stated in his qualifications. This report and any values expressed herein represent the opinion of the consultant/appraiser, and the consultant’s/appraiser’s fee is in no way contingent upon the reporting of a specified value, a stipulated result, the occurrence of a subsequent event, nor upon any finding to be reported. Sketches, drawings, and photographs in this report, being intended for visual aids, are not necessarily to scale and should not be construed as engineering or architectural reports or surveys unless expressed otherwise. The reproduction of any information generated by engineers, architects, or other consultants on any sketches, drawings, or photographs is for the express purpose of coordination and ease of reference only. Inclusion of said information on any Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 232  Packet Pg. 310 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 12 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture drawings or other documents does not constitute a representation by Walter Levison to the sufficiency or accuracy of said information. Unless expressed otherwise: • information contained in this report covers only those items that were examined and reflects the conditions of those items at the time of inspection; and • the inspection is limited to ground-based visual examination of accessible items without climbing, dissection, excavation, probing, or coring. • There is no warranty or guarantee, expressed or implied, that problems or deficiencies of the plants or property in question may not arise in the future. Loss or alteration of any part of this report invalidates the entire report. Arborist Disclosure Statement: Arborists are tree specialists who use their education, knowledge, training, and experience to examine trees, recommend measures to enhance the beauty and health of trees, and attempt to reduce the risk of living near trees. Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice. Arborists cannot detect every condition that could possibly lead to the structural failure of a tree. Tree are living organisms that fail in ways we do not fully understand. Conditions are often hidden within trees and below ground. Arborist cannot guarantee that a tree will be healthy or safe under all circumstances, or for a specified period of time. Likewise, remedial treatments, like any medicine, cannot be guaranteed. Treatment, pruning, and removal of trees may involve considerations beyond the scope of the arborist’s services such as property boundaries, property ownership, site lines, disputes between neighbors, and other issues. Arborists cannot take such considerations into account unless complete and accurate information is disclosed to the arborist. An arborist should then be expected to reasonably rely upon the completeness and accuracy of the information provided. Trees can be managed, but they cannot be controlled. To live near trees is to accept some degree of risk. The only way to eliminate all risk associated with trees is to eliminate the trees. Certification I hereby certify that all the statements of fact in this report are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. Signature of Consultant DIGITAL BADGES: ISA CERTIFIED ARBORIST CREDENTIAL: https://certificates.isa-arbor.com/f1918723-df46-48cc-ace2-c12625530fec#gs.v54om6 (Renewed through June, 2026) ISA TREE RISK ASSESSMENT QUALIFIED (TRAQ): https://certificates.isa-arbor.com/d180515f-ab75-440b-9c66-106005e3cf10?record_view=true#gs.hpb30w (Renewed through March, 2028) Attached: Tree Map Markups by WLCA 12/18/2023 (View Using Adobe or Adobe CS in Order to Allow for Full Visibility of the Markups Created Using Adobe Pro Software). Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 233  Packet Pg. 311 of 517  1 Kallas, Emily From:Kay Brown <kayb49@sbcglobal.net> Sent:Tuesday, March 4, 2025 9:59 AM To:Kallas, Emily Subject:21 PLN-00341/660 University Ave Attachments:City of Palo Alto Letter to Planning.pages CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Kay Brown 555 Byron St Apt 101 Palo Alto, CA 94301 kayb49@sbcglobal.net 650-269-1985   March 4, 2025    Emily Kallas   Senior Planner  Planning and Development Dept.  City of Palo Alto  250 Hamilton Ave Palo Alto, CA 94301  Re:  660 University/21 PLN‐00341    Dear Ms. Kallas,     I’m writing to express my concerns regarding the intended project slated to be built at 660 University. This large  apartment/multi‐use facility is scheduled to come before you for determination on March 12, 2025.  I would like to  familiarize you with the current traffic issues on the 500 block of Byron St.    As it stands today, senior residents of 555 Byron as well as nursery school parents, church goers and dental office patients  encounter frequent near‐misses entering and exiting their respective parking lots.    1. Currently parallel parking is permitted on both sides of the street, and the narrow residual allotment for 2‐way  traffic becomes unwieldy with one car needing to pull over to allow on‐coming traffic to pass.    2. Byron is utilized by random drivers as pass‐through wanting to avoid the traffic light at University and  Middlefield. Residents and patients in cars must to pull‐over and brake to avoid the on‐coming traffic. The cars  travel swiftly without regard to elderly residents that are with walkers and wheelchairs as they attempt to cross  the street.  3. Large commercial vehicles  deliver food, linen, packages, etc or service plumbing, electrical, wifi tele‐ communication issues at the various facilities. When these large trucks park on Byron, the danger factor is  exacerbated. It is difficult to see or maneuver safely around the commercial vans, etc.   4. There are currently 3 large senior facilities within the 2 block radius.  Concern for Emergency Response Vehicles  ability to access the streets at all times should be paramount.  And, keep in mind that the majority of the  population in this vicinity is elderly (ie. walkers, wheelchairs, and slow physically impaired amblers). Residents  of Lytton Gardens regularly come for lunch at the church on foot with assisted devices. They traverse both Byron  and University.  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 234  Packet Pg. 312 of 517  2   It is my understanding that the developer of 660 University intends to situate the ingress and egress to the underground  parking directly on Byron St? With the dense apartment units and office spaces anticipated in the new complex, accidents  can be anticipated.    Also, please consider the situation that will arise during construction of the new complex.  At any given time, there will  be large construction vehicles needed to demolish existing structures and erect the final facility. Where will the  construction vehicles park so as not to worsen an already dangerous situation…on University, on Middlefield?     I am under the impression that the developers are anticipating that many of the 660 University dwellers will not own cars  and will be utilizing mass transport.  At the previous City Council meetings, a study initiated on the developers behalf  stated that a majority of the tenants will not be coming and going in automobiles by a computer generated (formulation)  pie in the sky scenario?  If this is an accurate analysis, I am asking the city of Palo Alto to verify this information and  stand by it’s assessment.    Thank you for your attention to this matter.    Appreciatively,  Kay Brown  Letter Attached:    Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 235  Packet Pg. 313 of 517  1 Kallas, Emily From:Leroy Barnes <ltbarnes@gmail.com> Sent:Tuesday, March 4, 2025 12:56 PM To:Kallas, Emily Subject:660 University Avenue CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.    To the Palo Alto Planning and Transportation Committee    I am a resident of what is known as “seniors corner”, at University and Hamilton in Palo Alto.   Lytton Gardens, the  Webster, and the Hamilton together house hundreds of elderly Palo Alto citizens at this corner.   The addition of about  88 new cars in this small area would result from building the proposed 660 University high rise, assuming one car for  each living unit.   Slow‐walking citizens with poor eyesight and impaired hearing walk on Byron St., University, and  Webster all day, every day.    One of the cars belonging to the proposed building will surely run over one or more of our  citizens within months or years of its completion.   Help us live a long life by rejecting this proposal.    In addition, aesthetically, the building is a poor fit for downtown Palo Alto.    Since it would be built on University at the  east entrance to downtown, they might as well put up a sign that says, “Welcome to Downtown Palo Alto.   We’re trying  to look like Redwood City.”      This building may some day serve a great purpose to Palo Alto, but not in the proposed location.    We energetically  request that you deny the proposal as it has been presented.    Leroy Barnes  555 Byron Street Resident    Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 236  Packet Pg. 314 of 517  1 Kallas, Emily From:Leroy Barnes <ltbarnes@gmail.com> Sent:Tuesday, March 4, 2025 12:54 PM To:Kallas, Emily Subject:660 University CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on  links.      Palo Alto Planning and Transportation Commission:    We respect the developer’s desire to add housing units to the Byron/University/Middlefield neighborhood.    However,  we are confident that the completion of this project will be an irreversible mistake that mars Palo Alto’s downtown  skyline and endangers hundred of senior citizens who live and walk in this three block area.       The traffic congestion that would result from this development would suffocate Byron Street between University and  Hamilton, a street on which delivery trucks, moving trucks, ambulances and parents dropping off preschool children at  First School all compete for space on the single two‐way lane between cars parked on both sides of the street.   The  additional cars that would belong to the residents of 660 University would overwhelm this area.      Please reject the proposed location for this development.   We support additional housing in Palo Alto, but are confident  that this would be a disaster that would be forever blamed on the members of your Commission.      Thank you.     Linda Chin  555 Byron Street Resident    Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 237  Packet Pg. 315 of 517  1 Kallas, Emily From:Admin <carol.gilbert@comcast.net> Sent:Tuesday, March 4, 2025 12:45 PM To:Transportation; Planning Commission Cc:Kallas, Emily; Gilbert, Carol Subject:660 University Ave. CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    To: Planning and Transportation Commission March 4, 2025 Subject: 660 University The building proposed at 660 University will create a dangerous situation for those of us who live or do business on the 500 block of Byron between University and Hamilton. Lund Development proposes to create 60+ living units plus a floor of office space. The proposal only provides for 78 parking stalls. There are no parking spaces surrounding that building on University or Middlefield, so that only leaves Byron or other nearby streets with 2-hour limited parking available to those occupants, a traffic nightmare. This photograph shows Byron on a delivery-impacted day. Imagine adding the truck, auto, emergency, and garbage truck traffic for the occupancy that will be added. As an area of senior residences with pedestrians on walkers and canes and frequent Paramedic vehicles needed, I wish to propose that you strongly consider reconfiguring the length o 500 Byron St. so that all cars, rescue vehicles, pedestrians, and trash removal can safely turn onto or cross or exit our street. At the forthcoming meeting on March 12, I wish to propose this reconfiguration: Sincerely, Carol Gilbert 555 Byron St. #209 Palo Alto, CA 94301 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 238  Packet Pg. 316 of 517  From:Austin Traver To:Kallas, Emily Subject:Neighbor, Opposed to 680 University Avenue Date:Friday, December 6, 2024 7:03:43 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Hello Emily, My name is Austin, I own a home on Fulton St in downtown Palo Alto. I noticed that a developer has proposed to construct a massive building right next to my little condo. https://www.cityofpaloalto.org/Departments/Planning-Development-Services/Current-Planning/Projects/680-University-Avenue I live one building away, in a 10-unit complex. Our condo is already pretty cramped as it is, in terms of parking spaces, density, etc., This project seems like it will be very disruptive to the character of the nearby neighborhoodcommunity. Can you help me understand how I, as a resident of Palo Alto, can participate in our city’s decision on whether to allow this to go forward? I want my voice to be heard by myrepresentatives. Sincerely, Austin Traver Sent from my iPhone Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 239  Packet Pg. 317 of 517  1 Kallas, Emily From:Yingxi Chen <ychenarch@gmail.com> Sent:Thursday, December 5, 2024 8:26 PM To:Kallas, Emily Subject:660 University Ave- Structure Feasibility for Future Transportation Improvements CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.    Hi Emily,  I would like to share some additional thoughts regarding the special setbacks for the 660 University Ave project  following today's ARB meeting.  One of the key reasons for establishing these special setbacks is to accommodate future transportation improvements,  which may include bike lanes, street parking/loading zones, left‐turn lanes, and other enhancements. Given the rapid  growth of the city, with over 6,000 new units planned, Middlefield Road will inevitably face increased traffic congestion  and safety concerns. At some point, the road will require modifications to address these challenges.  The design team for 660 University Ave has made significant efforts to meet the required 24‐foot setback, but it would  be shortsighted if, years down the line, we discover that these necessary roadway improvements cannot be  implemented due to potential structural issues with underground parking.  In fact, the applicant could benefit from these future improvements. For instance, if the street is widened to allow for  street parking, it could help alleviate parking issues. Similarly, the expanded roadway could provide space for a loading  zone or designated trash collection area, preventing disruptions to traffic flow while meeting the building’s operational  needs.  I understand that further studies, surveys, and community engagement will be conducted before any changes are made.  However, buildings are permanent commitments, and their design will shape the city for decades. The ongoing wave of  new housing projects means that transportation infrastructure improvements will need to keep pace with growth. I urge  the applicant to consider the structural feasibility of accommodating these future transportation needs in their design,  in addition to provisions for landscaping and utilities.  Thank you for your consideration of these points, and I hope you have a wonderful holiday season.  Sincerely,  Yingxi    Yingxi Chen, AIA  Y. Chen Architect  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 240  Packet Pg. 318 of 517  From:slevy@ccsce.com To:Architectural Review Board Cc:Kallas, Emily; Lait, Jonathan Subject:660 Univeristy project Date:Saturday, November 30, 2024 10:57:53 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Chair Rosenberg and committee members, I hope you are having a joyful Thanksgiving holiday. Please move this application forward with your comments and any remaining concerns. As the housing project on this site enters its fourth year of review, I believe the applicant and community deserve a hearing before the city council and timely decision. My comments below are as a DTN resident and economist with experience in housingeconomics and more than a dozen HCD advisory committee member meetings. As I alwaysclarify before you, I have no expertise as an architect or arborist and will not comment onthese issues. 1) I believe this is the only housing proposal of any significant size in DTN, an area identified as important for additional housing in our Housing Element and by you in previous meetings. 2) As with 3265 and 3150 ECR, this current application is the result of collaboration between the applicant and staff to respond to ARB comments and concerns while preserving the financial feasibility of the application. I have been pleased by the recognition and appreciation by ARB members of these twin objectives. As with 3265, the applicant has responded to concerns by adding height and other configuration changes. And, as the chair noted at the last meeting, the alternative to successful resolution of issuescould be no project or in this case a builder's remedy application that the applicant hasshelved for now in favor of this smaller project. 3) The applicant is proposing a large majority (10) of the 14 BMR units for low income residents including 6 for very and extremely low income residents. I am pleased the applicant i able to co this in the context of a feasible proposal. 4) This site has additional benefits as it will allow some/many trips to be done without driving and the residents will make a small but positive addition as customers for DTN businesses. I look forward to hearing council's review asap as we begin the process of adding housing in appropriate DTN locations. Stephen Levy Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 241  Packet Pg. 319 of 517  From:Greg Welch To:Architectural Review Board; Kallas, Emily Cc:Ann Lewnes Subject:Public Feedback on the proposed project "660 University Ave" project [21PLN-00341] Date:Wednesday, December 4, 2024 7:58:11 PM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. My wife and I are writing as we will be unable to attend the ARB meeting at 8:30am on 12-5-24 due to work conflicts. We own a unit on the north side, third floor of the Hamilton building ( at 555 Byron St.) just to the south of the proposed project. My house-bound, elderlymother-in-law occupies the unit and the sunlight through her windows and on her balcony represent most of her experience of the outdoors. We are very concerned that the proposedproject could cut off all direct sunlight and require her to have to draw her blinds to have any sort of privacy. 1) the six-story height suggests a size and mass completely out of keeping withthe surrounding neighborhood 2) at that height, the project threatens to loom over and literally overshadow the buildingsaround it. 3) Throughout Palo Alto, building standards preserve privacy by preventing neighbors frombuilding structures that look down into backyards, or directly into windows in existing structures. How will that be accomplished on this project? Greg WelchAnn Lewnes 560 Center DrivePalo Alto, CA Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 242  Packet Pg. 320 of 517  December 3,2024 Dear Committee Members, The Housing Action Coalition is a member-supported nonprofit that advocates for creating more housing for residents of all income levels to help alleviate the Bay Area and California’s housing shortage,displacement,and affordability crisis. Our endorsement committee had the opportunity to review Smith Development’s proposal at 660 University,and we proudly endorsed the project. Smith Development’s proposal would bring 66 much-needed new units to Palo Alto.We were impressed with the project's dedication to affordable housing,with 20 percent of the units for lower-tiered affordable housing,which is high especially considering current economic conditions.By prioritizing affordable housing and urban development,we can create more sustainable and inclusive communities for everyone. In terms of Land Use and Density,the project site's central location with its proximity to essential downtown amenities,including the Caltrain station,and the inclusion of ample bike parking facilities underscore a commitment to promoting environmental sustainability and reducing reliance on automobiles.In terms of parking,our committee would like to see a reduction on the amount of parking provided for the project,and have the project redirect those costs to increasing the overall density of the project.In terms of overall design,we commend the steps Smith Development has taken to preserve the Oak tree on site,and even incorporated it into the design. This project will be critical to support Palo Alto,and the Bay Area’s housing needs.Please move this project forward without delay. Corey Smith,Executive Director Housing Action Coalition (HAC) Ali Sapirman,Advocacy and Policy Manager Housing Action Coalition (HAC) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 243  Packet Pg. 321 of 517              !" #$"!%&'()*+,$$!-"*"./ 3345645758 6938 :;,!+" >!),!- ?"( #"@'+,&A%*"./EJKL MNOKP QRKSKTOUMV WRQN QXULKVM QW UJM QRSOTKYOUKQTZ [M \OXUKQXL QW Q]MTUL OTV \PK\^KTS QT PKT^LZcadb _`ab cadb ebffghhgbijkhlnkgdgio db jpqkjhh fr jidsthg`hdgu htqqbkd vbk dsj qkbqbhjw sbthgio qkbxjud `d yyzkhgdr c|j gi wbnidbni _`ab cadb} ~sgh qkbxjud ngaa j ` dkjfjiwbth `hhjd db dsj ubffttk kjogbi `h ` nsbaj}wwgdgbi bv yy tigdh db dsj `kj` gh ` j`ubi bv sbqj gi `wwkjhhgio _`ab cadb€h qkjhhgiogio hsbkd`oj} ~sj qkbxjud€h qkbpgfgdr db wbnidbni `fjigdgjhl giuatwgio e`adk`gi hd`dgbis m ab|j `iw kgwj w`gar‚ `iw `fqaj gƒj q`kƒgiol f`ƒjh dsj qkbxjud `i `ddk`udg|j qa`uj db qkbfbdgio ji|gkbifjid`a hthd`gi`gagdr}b|jkl m `f q`kdguta`kar gfqkjhhjw r dsj qkbxjud€h ubffgdfjid db giuathg|gdr} …jddgio `hgwid bv dsj tigdh vbk abnjk‡dgjkjw `vvbkw`aj sbthgio hsbnu`hjh ` wjwgu`dgbi db qkb|gwgiokdtigdgjh vbk giwg|gwt`ah vkbf wg|jkhj hbugbjubibfgu `uƒokbtiwh db dskg|j gi dsj ubffgh hb gfqbkd`id} ˆr qkgbkgdg‰gio `vvbkw`aj sbthgio `iw tk`i wj|jabqfjidl nj u`i ukj` hthd`gi`aj `iw giuathg|j ubfftigdgjh vbk j|jkrbij} md gh ijujhh`kr vbk _`ab cadb db jpgio bqdgbih `iw `uubffbw`dj dsj ijjwh bv ` okbngio qbqta`dgbi `iw m tkoj rbt db d`ƒji r htqqbkdgio dsgh qkbxjud ngds ib vtkdsjk wja`r} vbkn`kw db ngdijhhgio dsj hsbkd djkf `iw abio djkf qbhgdg|j gfq`udh ds`d dsgh qkbxjud ng bi _`ab cadb `iw dsj htkkbtiwgio ubfftigdr} ~s`iƒ rbt} ebtadjkkbi}i}ubtadjkŠof`ga}ubf bio Žkg|j cq`kdfjid z ‘bhjl e`agvbkig` ’‹ Œy Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 244  Packet Pg. 322 of 517             ! 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"''()*(+*+, '*-./ 0153& 657 8&39 !&3:5;<&&3="@ A 5 !A 5?&&5;<&&3="B C&5@ DE&4&E !DE&4&EC&5F5;G&03="KPQR STUQV WXQYQZU[S\ ]XWT W^[RQ\S W] [PS WXYUZQ_U[QWZ` aS bU^[QW^R W] WcSZ[R UZ\ bVQbdQZY WZ VQZdR`kh lmnfopfhq gor smttkuuff tftpfhnvz ghf jg{koq g |my}z~ jgo€nqk{koq jm~krgy {f ujkn gxx~ksgukmo }mhƒghr ƒkuj ymzh smttfoun gor goy hftgkokoq smosfhon znkoq xhm|fsu mo ujkn nkuf foufhn kun }mzhuj yfgh m} hf{kfƒv w pf~kf{f ujf gxx~ksgou guy rfnfh{f g jfghkoq pf}mhf ujf skuy smzosk~ gor uktf~y rfsknkmo foun pf~mƒ ghf gn g e† hfnkrfou gor fsmomtknu ƒkuj f‡xfhkfosf ko jmznkoq fsmom g rmˆfo ‰ie gr{knmhy smttkuuff tftpfh tffukoqn „n w g~ƒgyn s~ghk}y pf}mhf y‡xfhuknf gn go ghsjkufsu mh ghpmhknu gor ƒk~~ omu smttfou mo ujfnf knnzfn f ujkn kn ujf mo~y jmznkoq xhmxmng~ m} goy nkqok}ksgou nkˆf ko e†v go ghfg krfouk}kf }mh grrkukmog~ jmznkoq ko mzh ‰mznkoq Œ~ftfou gor py ymz ko xhf{kmzn tffukoqn Ž gor ŽŠ ‘ Œilv ujkn szhhfou gxx~ksgukmo kn ujf hfnz~u m} sm~~gpmhgukmo pfuƒffgor nug}} um hfnxmor um „l’ smttfoun gor smosfhon ƒjk~f xhfnfh{koq ujf }kogoskg m} ujf gxx~ksgukmo w jg{f pffo x~fgnfr py ujf hfsmqokukmo gor gxxhfskgukmo py „l m} ujfnf uƒko mp|fsuk{fn v ujf gxx~ksgou jgn hfnxmorfr um smosfhon py grrkoq jfkqju gor mujfh smo}kqzhf sjgkh omufr gu ujf ~gnu tffukoqv ujf g~ufhoguk{f um nzssfnn}z~ hfnm~zukmo m} knnzf|fsu mh ko ujkn sgnf g pzk~rfh“n hftfry gxx~ksgukmo ujgu ujf gxx~ksgou jgn njf~{fr }mjkn ntg~~fh xhm|fsu x~ksgou kn xhmxmnkoq g ~ghqf tg|mhkuy ”Š‘‹ m} ujf Š• ’…l zokun }mh ~mƒ kosmtf hfnkr }mh {fhy gor f‡uhftf~y ~mƒ kosmtf hfnkrfoun w gt x~fgnfr ujf gxx~ksgou k gp~f uf‡u m} g }fgnkp~f xhmxmng~ uf jgn grrkukmog~ pfof}kun gn ku ƒk~~ g~~mƒ nmtf–tgoy uhkxn um pf rmof ƒkujmzu rhk{koun ƒk~~ tg€f g ntg~~ pzu xmnkuk{f grrkukmo gn sznumtfhn }mh e† pznkofnnfn ghr um jfghkoq smzosk~“n hf{kfƒ gngx gn ƒf pfqko ujf xhmsfnn m} grrkoq jmznkoq k Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 246  Packet Pg. 324 of 517          !"# $% & '()%(* +,%-%-.)*/01%2-314 89:8:9;9< =>88 &?2B3(% CBD2B) E%(* +%(F/32G.,%%-(04%,2(1%7 +%2/AJ270%3273%227-(04K &GJ% (7 +%GJ%/J12A*BDB,1B7-314K 6BDGDG/33J3B-314A1B7J L8M ?EN6,,( Q( L89-;8-9<N-,*.K &%3A & OO; P72D 6,,( R17J-,*.KV[\] ^_`\a bc\d\e`f^g hcb_ bif]\g^ bh f[^ bcd`e\j`f\bek l^ m`if\bi] bh bn^ef] `eg ma\mo\ed be a\eo]k% & '()%(*rJ J,,( BB( .( AB OO; P72DB(J2G &DB7B ?2sB* PJB $(t&CE %0B7*%N %7* %JJ32%B* &%3A1B7 &q )A23A 273*BJ DB( 8;; ,%0BJ . ,(J .( AB ,(tB3- Š~† ‚Š’“Œ’”– Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 247  Packet Pg. 325 of 517  December 1, 2024 SUBJECT: Agenda Item #3 - 660 University Avenue Mixed-Use Project Dear Chair Rosenberg and Board Members, We urge quick action on the proposed mixed-use project at 660 University Avenue. The project has been positively modified based on previous Architectural Review Board comments. We are excited to see an additional floor has been added to the project for a total of 66 residential units as part of this mixed-use project We support this project because it is walking distance to downtown businesses, retail, and services . It is 0.6 mile from Caltrain and adjacent to major transit stops, thus reducing residents' climate emissions because they can drive less. In furtherance of our affordable housing goals, the project will provide 66 homes and 20% will be affordable (where normally 15% is required). We hear often from tenants in Palo Alto that there is not enough bike parking in their multi-family developments. This is especially true as more residents are adopting e-bikes and cargo bikes. We are excited to see accessible and plentiful bicycle parking being provided as part of the project – a huge bonus to future residents and office tenants. The proposed vehicle parking ratio is adequate based on recent development trends and given the project’s location near transit and retail. This modest 66-unit project has been through a long (but sadly typical) PHZ process since 2021, including an exhaustive Environmental Impact Report that is normally reserved for significantly larger projects. Please provide substantive comments so that the project can move towards approval. Palo Alto Forward has been working to strengthen community support for housing projects to end our housing crisis and strengthen our city. As such, we have included 100 pages of support letters written by residents on behalf of this project. Thank you for your service to our community! Amie Ashton Executive Director, and on behalf of the Board of Palo Alto Forward ATTACHMENT A: 100 Pages of Public Comment Comments Supporting the Project Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 248  Packet Pg. 326 of 517  ATTACHMENT A: 100 Pages of Public Comments Supporting the Project (link) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 249  Packet Pg. 327 of 517           ! "#$%!&'()%*% +, -. 123232425 6718 90'!  <!='!> ? + " *$'%@A, -. ( "%&$&)';+!=!A)!(,).D ?%+ E)'; "*%+$&)';+!=!A)!(,).;)!( FG2H I?J &'% 9=! L M((!+ N)! O('(- P)A'(,+QDUZ[\ ]^_[` ab[c[d_e]f gba^ ahe\[f] ag eZ] abc_d[i_e[adj k] l_he[ah\ ag am]de\ _df l`[ln[dc ad `[dn\j(-p;!+  !&A(+!(! @ ;! ? +q& )!!'(- ( r!!)*! s;,{ |}~|€‰‰Š…‹‚Œ Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 250  Packet Pg. 328 of 517  2261 Market Street STE 10416 San Francisco, CA 94114 hello@yimbylaw.org 12/02/2024 City of Palo Alto Architectural Review Board 250 Hamilton Ave Palo Alto, CA 94301 arb@CityofPaloAlto.org Via Email Re: 660 University Avenue Proposal Dear Palo Alto Architectural Review Board, YIMBY Law is a 501(c)3 non-profit corporation, whose mission is to increase the accessibility and affordability of housing in California. YIMBY Law sues municipalities when they fail to comply with state housing laws, including the Housing Accountability Act (HAA). As you know, the City Council has an obligation to abide by all relevant state housing laws when evaluating the above captioned proposal, including the HAA. Should the City fail to follow the law, YIMBY Law will not hesitate to file suit to ensure that the law is enforced. This proposal consists of a mixed-use development with 66 units and a top-floor office and two levels of below-ground parking. The proposal was submitted under Palo Alto’s Planned Home Zoning community plan in an area zoned for multi-family residential use. Though it requests zoning changes, this proposal is compliant with the City’s General Plan. Under California Government Code § 65589.5 in cases where the general plan and zoning ordinance do not match, a project is only required to comply with the general plan. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 251  Packet Pg. 329 of 517  2261 Market Street STE 10416 San Francisco, CA 94114 hello@yimbylaw.org (j)...(4) For purposes of this section, a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the project site is inconsistent with the general plan. If the local agency has complied with paragraph (2), the local agency may require the proposed housing development project to comply with the objective standards and criteria of the zoning which is consistent with the general plan, however, the standards and criteria shall be applied to facilitate and accommodate development at the density allowed on the site by the general plan and proposed by the proposed housing development project. In the case of this particular project, the zoning ordinance has a more restrictive density limit than the general plan and no density minimum. The general plan on the other hand requires a minimum density for new development in this area that is not present in the zoning ordinance. Applied to this project state law clearly mandates that the project comply with the city’s general plan in cases where the zoning ordinance differs. This includes all objective general plan standards or criteria, including the density minimum. This is all noted in the staff report for this project, which accurately describes the proper application of state law, regarding unit count, to this project. Therefore, you must approve the application, or else make findings to the effect that the proposed project would have an adverse impact on public health and safety, as described above. Should the City fail to comply with the law, YIMBY Law will not hesitate to take legal action to ensure that the law is enforced. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 252  Packet Pg. 330 of 517  2261 Market Street STE 10416 San Francisco, CA 94114 hello@yimbylaw.org I am signing this letter both in my capacity as the Executive Director of YIMBY Law, and as a resident of California who is affected by the shortage of housing in our state. Sincerely, Sonja Trauss Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 253  Packet Pg. 331 of 517           !" #$%& '#$%&(  !)*%&+,  (-./ 345454647 897: ;1%>*-  ?>@%>A B -C ' -D)*%&+,  (-./ 1>!! .>EEEEEB-%.> '+ %=ADG)& =(*$/&" I>*>$D>- 3" 4647 :943 J1%& '#$%&(  !)*%&+,  (-./.> '+ %=ADG)& =(*$/ O2%@>-!%& ;@>( ,-M>* E  $ !!%@>=%! >$ % -%.%2 >C +-$ !%C> + => -. 2%R %2( B> * %! + ,>2%2.  2 %2!(> 2%*> -> => ;-*=%>*-  ?>@%>A B -C $>>%2. 2 I>*>$D>- T" =  A% C%!* !D$%>C +- NN6 O2%@>-!%& ;@>2>( + => ! > =  C & 2C ! P * 22 >2C( SA>@>-" P = @> !-2. +>>%2.! D A-%%2. & ! &- >$ % CC->!! %! => 2& 2> 2 => * -C =  A ! !>2  $& * 2 ,! +-A -C %  => ;-*=%>*-  ?>@%>A B -C A= A% D> *2C*%2. =  A=>2 =%! ,-M>* A ! +%-! !D$%>C =>& A>-> C>!*-%D%2. % ! 7 !-& D%C%2C =  =>& 2>>C>C  A A%C>- !>D * =>& ! %C =  =>& *C C =  DD%C % T !-%>!( ;2C 2A -> C%2. =%! 2%*> P !>> =  =>& -> %2 + * ->U>!%2. D%C%2.! %2 =  -> -> 2>" A - =->> !-%>!( Q2> -> T - N !-%>!( P = @>!! => !->> +- G6 &> -!( P %! 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C!,/!0 D'+ %'E*./)F(-'12JOPQ RSTPU VWPXPYTZR[ \WVS V]ZQP[R V\ ZOR VWXTYP^TZPVY_ `R aT]ZPV]Q V\ VbRYZQ TY[ aUPacPYX VY UPYcQ_hfig defg hfig jgkklmmlgnopmqsplilnt ig ouvpomm kw mxvvgpi ygp izo vpgvgmo{ zgxmlnt vpg|o}i ei ~~ €nl opmliw h o lnigsn defg hfig‚ hm e ƒ„woep defg hfig poml{oniq r …oflo o e vpg|o}i mx}z em izlm lm …gizmmepw en{ slff …o e ipokon{gxm emmoi ig gxp }gkkxnliw en{ ig izo potlgnef zgxmlnteto‚yos kxfil„yeklfw zgxmlnt vpg|o}im toi …xlfi noep szopo izow epo mgpofw noo{o{q ln izoigsn }gpo‚ ‡zo e{{lilgn gy ~~„xnlim sliz lkko{leio vpgulkliw ig ekonlilom en{ sefˆlntn}o ig izo jefipeln lm izo pltzi sew ig vpgkgio mxmielne…fo en{ pomlfloni {o ofgvkoni‚t eml{o ƒ vop}oni gy izo xnlim ygp fgsop„ilopo{ eyygp{e…fo zgxmlnt lm e sof}gkolikoni ig mipontizonlnt defg hfigŠm mg}lgo}gngkl} {l opmliw en{ o‹xliw‚ ri lm no}ommepwhfig ig ouven{ zgxmlnt gvilgnm en{ e}}gkkg{eio izo noo{m gy e tpgslnt vgvxfeilgn ewgx ig mxvvgpi en{ evvpg o izlm vpg|o}i sliz ng yxpizop {ofew‚ ygpsep{ ig moolnt izlm vpg|o}i …xlfi en{ kgpo flˆo li ln izo noep yxixpo‚ defg hfig noo{m k zgxmlnt en{ kgpo {onmliw ln evvpgvpleiofw vfenno{ epoem gy izo jliw‚ ‡zenˆ wgx‚pofwqm ‰xzm ‰xzmwmxz tkelf‚}gkhfigq jeflygpnle Ž ~ Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 264  Packet Pg. 342 of 517  1 660 University Avenue Development Issues An Executive Summary for ARB Meeting December 5, 2024 Need to consider the following: 1. Inadequacy of 78 stalls for 66 units plus businesses. 2. How brochures and passes get people out of their cars. 3. If we don’t know compliance for 2 years, there is no going back. 4. Insist on two-year data from previous TDM Specialists, Inc. to prove effectiveness. 5. History of This Project Nearby residents of the proposed 660 University development have been opposed to several aspects of the development and have made our objections known to every city committee that held a hearing. It started with shoe-horning in too much building on too small a property which was 4 stories tall with 70 units and size remains an issue. October 25, 2021 Council held a prescreening to review a conceptual plan for the proposed project on October 25, 2021. The formal PHZ application was submitted on December 21, 2021. Following staff’s initial review and subsequent resubmittal, the PTC reviewed the project on November 16, 2022 and recommended that the project be forward to the ARB for review in accordance with the PC rezoning process. December 1, 2022 The ARB reviewed the same plan set on December 1, 2022. Since this time, the applicant made significant modifications to the project, including changing the parking garage driveway entry from Middlefield Road to Byron Street, as well as removing residential uses from the ground floor to meet FEMA flood zone requirements and address ARB comments related to privacy for ground floor units. This submittal was received on September 1, 2023, ten months after the last public hearing. The plans have been further refined over three rounds of staff review in the last seven months to address various staff comments. Key comments from Board members and the applicant’s response to those comments are summarized in the Exhibit file found separately. Dec. 1, 2022 ARB Meeting A previous Architecture Review Board hearing listened to our objections and sent Smith Development away to make some amendments that would be more suitable for your board and nearby residents on Dec. 1, 2022. Key comments from Board members and the applicant’s response to those comments were summarized. Only change was drive-way moved to Byron St. all others were left alone. You can see Exhibit results separately. April 18, 2024 ARB Meeting Further recommendations by 3 Board members were adjustments be made to the plans. 1. Remove extended balconies from units B1, B1, and A2 from Historic Oak tree. 2. 6 foot screening on 4th floor roof deck to reduce noise and maintain privacy. 3. Inadequate parking remained an issue. 4. Consider the Draft Environmental Impact Report The purpose of this report is to restate the comments made by the Board and detail the applicant’s response to those comments. The analysis section below builds upon the information contained in the earlier report and has been modified to reflect recent project changes. Following the ARB’s recommendation, the project will return to the Planning and Transportation Commission (PTC) for a formal recommendation of a Planned Community Ordinance. Both of these recommendations will be forwarded to Council for a final decision. At that point the number of units was 63. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 265  Packet Pg. 343 of 517  2 Builder’s Remedy May 2024 6 stories and initially 110 units. The revised application that Smith Development submitted last month for its planned project 660 University Ave. calls for a six-story building with office space on the lowest and highest floors and then 66 apartments in between. The proposal is just the latest iteration of a downtown project that has already gone through multiple revisions since Smith first applied in 2021 under the “planned home zoning” process, which allows residential builders to negotiate with the city over zoning exemptions. The four-story project that the company had previously proposed was narrowly approved by the Architectural Review Board in April. While both the builder’s remedy and the PHZ applications are currently on file, the applicant has requested that the City place the Builder’s Remedy application on hold while the City continues to process the PHZ application November 26, 2024 ARB Meeting re: TDM Plan The Transportation Demand Management (TDM) plan includes measures and programs to achieve a reduction in single-occupancy vehicle trips to the site by a minimum of 45%. New residents will have to sign an acknowledgment that they are aware there is a goal to reduce commuter trips and maximize use of all other sources. This is not a legal pledge. The TDM plan includes an annual monitoring plan to document their traffic. The first data will not be known until 2 years hence. In summary, a TDM plan sounds great, but it only works for Smith Development who will make too few parking places available for residents. With no adjacent streets permitting parking and limited parking on Byron, do you really think this will work? In TDM’s own words, “We have a proven track record of getting employees out of their cars. As projects are built and occupied, TDM Specialists can develop the, outreach, and campaigns necessary to implement and manage employee Commute Programs or parking management programs. The initial start-up, implementation, and ongoing management of the Commute Program are designed to meet employee benefits for businesses.” It is incumbent on this board to request some proven results that TDM has been able to achieve after two years before making any decision on this project. Exhibit Follows which shows various ARB directions with applicant’s responses. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 266  Packet Pg. 344 of 517  3 Exhibit File Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 267  Packet Pg. 345 of 517  From:Kathleen Rotow To:Kallas, Emily Subject:Re: 660 University Draft EIR - Now Circulating Date:Wednesday, April 3, 2024 11:52:55 AM Attachments:image001.png image002.png Thanks Emily. I'm glad the review concluded that the Byron Ave entry and exit for thisproject made more sense than further slowing down Middlefield and University. It also keeps some of the inevitable noise from this project from disturbing the senior project across thestreet on University. On Wed, Apr 3, 2024 at 8:28 AM Kallas, Emily <Emily.Kallas@cityofpaloalto.org> wrote: Hi Kathleen, After the initial ARB review, the driveway was relocated to the Byron frontage, to reducepotential conflict on Middlefield. Thanks, Emily Emily Kallas, AICP Planner Planning and Development Services Department (650) 617-3125 | emily.kallas@cityofpaloalto.org www.cityofpaloalto.org Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms &Applications | Planning Applications Mapped Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 268  Packet Pg. 346 of 517  From: Kathleen Rotow <kathleenrotow@gmail.com> Sent: Wednesday, April 3, 2024 4:46 AMTo: Kallas, Emily <Emily.Kallas@cityofpaloalto.org>Subject: Re: 660 University Draft EIR - Now Circulating CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Good Morning Emily, I have an initial question that you may be able to answer quickly. Given that I live withintwo blocks from the project on University Avenue, one of my concerns is the amount of additional traffic this project will generate on an already very congested corner. Probableadditional traffic backups on both University Ave and Middlefield Ave. Will the entry and exits for parking be on University or Middlefield? Will there be any left turn entry into theparking for the project while heading west on University? Thank you, Kathleen Rotow Sent from my iPhone On Apr 2, 2024, at 5:58 PM, Kallas, Emily <Emily.Kallas@cityofpaloalto.org>wrote:  Good afternoon, This e-mail is to inform you that the Draft EIR for the 660 University project is now available here on our Planning Department website. The Notice ofAvailability is attached and has further information regarding the proposed project. The comment period for the Draft EIR begins today, Tuesday, April2nd and will end on May 17, 2024. This e-mail is being provided to you because you are a neighboring jurisdiction, your agency has expressed aninterest in the proposed project or because your agency may have an interest in the proposed project, or because you have been requested to be contactedregarding any project within the City of Palo Alto’s jurisdiction. Please feel free to contact me if you have any questions or to send comments. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 269  Packet Pg. 347 of 517  Regards, Emily <image001.png>Emily Kallas, AICP Planner Planning and Development Services Department (650) 617-3125 | emily.kallas@cityofpaloalto.org www.cityofpaloalto.org <image002.png> Parcel Report | Palo Alto Zoning Code | Online Permitting System | PlanningForms & Applications | Planning Applications Mapped <660_University_NOA signed.pdf> Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 270  Packet Pg. 348 of 517  From:Christopher Ream To:Kallas, Emily Subject:660 University Project Date:Wednesday, April 10, 2024 3:38:35 PM Importance:High CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Emily, Chris Ream here, the President of the Hamilton Homeowners Association. I intend to prepare a letter to the Architectural Review Board outlining The Hamilton’s objections to the planned project at 660 University, and I also intend to attend and comment at the ARB Hearing new week on April 18. I have done a quick review of the Draft EIR. The Draft EIR addresses many of the points I had previously brought up to the ARB along with some new points, including in particular, the danger of killing Tree #10 (the protected coastal oak) and the alternative of adding a fifth above-ground story to the building, and the alternative of eliminating the second floor of the underground garage. These are not shown in the developer’s current plans, but are obviously issues that need to be addressed at some point. My question is: Would it be proper for me to address in my letter to the ARB and at the Hearing points raised in the Draft EIR but not yet appearing in the developer’s plans. I will call you to have a brief discussion on this. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 271  Packet Pg. 349 of 517  From:Mimi and Eric Carlson To:Christopher Ream; Kallas, Emily Subject:Re: 660 University Project Date:Thursday, April 11, 2024 11:02:35 AM You don't often get email from mimianderic@hotmail.com. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Chris et al. Please note that the proposed project will create a traffic nightmare, espesciallly if the entrance is on Byron.- which is effectively a one wao street during the day. Eric Carlson From: Christopher Ream <ream@reamlaw.com> Sent: Wednesday, April 10, 2024 3:38 PM To: Kallas, Emily <Emily.Kallas@cityofpaloalto.org> Subject: 660 University Project Emily, Chris Ream here, the President of the Hamilton Homeowners Association. I intend to prepare a letter to the Architectural Review Board outlining The Hamilton’s objections to the planned project at 660 University, and I also intend to attend and comment at the ARB Hearing new week on April 18. I have done a quick review of the Draft EIR. The Draft EIR addresses many of the points I had previously brought up to the ARB along with some new points, including in particular, the danger of killing Tree #10 (the protected coastal oak) and the alternative of adding a fifth above-ground story to the building, and the alternative of eliminating the second floor of the underground garage. These are not shown in the developer’s current plans, but are obviously issues that need to be addressed at some point. My question is: Would it be proper for me to address in my letter to the ARB and at the Hearing points raised in the Draft EIR but not yet appearing in the developer’s plans. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 272  Packet Pg. 350 of 517  I will call you to have a brief discussion on this. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 273  Packet Pg. 351 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com April 16, 2024 Via email: Emily.Kallas@CityofPaloAlto.org Re: 660 University Project Architectural Review Board Hearing on April 18, 2024 Draft EIR April 2024 Comments re Protection of the Coast Live Oak Tree Dear Emily, Please consider the comments in this letter as you continue to work on the Draft EIR for the 660 University Project and pass on these comments to members of the Architectural Review Board and to others where appropriate. There is an Attachment A and an Attachment B to this letter. The Hamilton is a senior living (55+) condominium development with 36 residential units and the average age of the residents in The Hamilton is mid-80’s. The Hamilton shares the same small block with the proposed development at 660 University Avenue. Lytton Gardens, Webster House and Webster House Health Center are within a block and directly across the street from the proposed development. Channing House is two blocks away. Because of this concentration of elderly citizens, the area is frequently referred to as “Senior Corner.” I am Christopher Ream. My wife Anne and I have been Palo Alto residents for 53 years and have been residents of The Hamilton for the past five years. The Hamilton community strongly opposes the proposed development at 660 University, and the Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its members/residents, has resolved to fight against the proposed development. I am the President of the HHA and am personally committed to significantly revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block and is listed as Tree #10 on Applicant’s plans. Applicant’s arborist reports that the Tree’s trunk is 50 inches in diameter and its limbs stretch out 90 feet in diameter “in a mostly balanced canopy.” The Tree abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is larger than that. The Tree brings shade and joy to us and everyone else on the block. The Tree is several hundred Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 274  Packet Pg. 352 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 2 of 4 years old and is deemed a Protected Heritage Tree by the City of Palo Alto. Applicant’s arborist rates the Tree “High” for suitability for preservation. This proposed project puts this beautiful Tree in grave danger: “It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover.” Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023, p.6 Please see Attachment A to this letter for the full Impact Analysis by Walter Levison Consulting Arborist. Tree Protection Zone Applicant’s plans recite that the City’s Tree Technical Manual (TTM) ¶1.36 specifies a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Another rule is that the TPZ should be equal to the foliage, so here that would be a radius of 45 feet based upon the arborist’s report of a 90-foot canopy spread. I am not an arborist, but I am told that one common rule of thumb is that a tree’s roots are one and a half to three times wider than the canopy. For the Tree’s 45-foot limbs, that would be 67 to 135 feet of roots out under the parking lot where the new building would go. Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment B.) Applicant has drawn a TPZ of only 30 feet on its plans and has the new building right next to and touching that 30 feet. That is 11 to 15 feet less than required. And the 30 feet is just what the building is supposed to look like – you don’t have to be an experienced contractor to know that there will be plenty of damaging construction work done on the exterior side of the two-story underground garage walls, and that will be much closer than 30 feet to the Tree. Robert Booty’s report points out that the roots are going to be sliced off at his scan of 31 feet. (See Attachment B.) Now, look up at the 2nd, 3rd and 4th floors, there are residential units with balconies sticking out 6 feet into the TPZ. Applicant’s arborist admits that pruning will be required, including a 17-inch limb. The Tree has to be pruned back to clear those balconies. Then be realistic: Applicant is going to prune the Tree even further back so that there is at least 5 feet of clearance between those balconies and the Tree. We are now cutting the Tree back to only 19 feet of foliage left. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 275  Packet Pg. 353 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 3 of 4 If 660 University is allowed to be built as now proposed, the Tree’s canopy will be severed on one side, disrupting the Tree’s balance, potentially allowing strong gravitational forces to push the Tree over. In addition, the roots needed to hold the Tree back from tipping over will have been cut and lost their gripping force. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy the dental offices at 517 Byron, and badly injure and maybe kill anyone in those offices at the time. The neighborhood will lose this beautiful tree. The privacy of the seniors in the sixteen apartments in The Hamilton on that side of our development will be exposed to the 36 units with balconies on our side of the 660 University building as well as the noisy crowds on the roof top party deck. Security The Staff Report for the Architectural Review Board Hearing to be held April 18, 2024 reported that the Urban Forestry Section has requested that any building permit be conditioned upon the Applicant obtaining an appraisal of the replacement value of the Tree and posting security for that amount. What does that mean in this situation? It will be completely impossible to replace the Tree, thus how can anyone come up with a replacement value. And, if the Tree “dies” within three years of the completion of the project, then the money from the security will go into the Forestry Fund to plant trees elsewhere. So much for the owner of 517 Byron and thus the person who was the owner of the Tree and the one most damaged by its death. This might make sense if the permit was conditioned upon obtain an appraisal value using the Trunk Formula Method (TTM 6.45B) rather than the Replacement Cost Method (TTM 6.45A). Solution At the Architectural Review Board hearing in December 2022, everyone, including the Applicant’s architect and its landscaper actively agreed that the Tree had to be protected; but the Applicant did not suggest that a 41-45 foot TPZ should be observed. No, their answer was that they knew of a tree in Mountain View that has so far survived a small TPZ (although they did not say how long it has survived). One tree surviving for an unknown time is not a valid argument to ignore the universally accepted rule of a TPZ equal to 10 times the trunk’s diameter or the extent of the canopy. The only solution here to save this Protected Heritage Tree is that the proper 41-foot TPZ must be imposed and complied by both the proposed building and its construction. This is not an unfair burden on the Applicant: They have known all along that their 30-foot TPZ was in violation of TTM regulations, and that the building could not be constructed without violating even that reduced TPZ because of the necessity to have construction closer to the Tree than that artificial 30 feet. The first time they showed a TPZ on their plans was their C3 filing on October 6, 2022 when they showed a TPZ with a radius of 29’11-½” (strange number for a TPZ). C3_660 University Ave_PLAN1.pdf, p.24. This was later updated to the 30 feet we see now. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 276  Packet Pg. 354 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 4 of 4 Applicant’s arborist David L. Babby discusses the size of the TPZ in §5.3 of his Tree Protection Report, 660 University Avenue, February 7, 2024: “The CPA's Tree Protection Zone (TPZ) standard is a radial distance from the trunk equal to 10 times its diameter, which for oak #10, identifies a TPZ of 41 feet from the trunk. The proposed project establishes the TPZ to be 30 feet from the trunk, which equates to a multiplier of 7 times the trunk diameter (and 11 feet inside).” He then goes on to say that the small 30-foot TPZ only applies to the finished building and garage, and sets up an even smaller, undisclosed zone where all sorts of construction work can tear up the ground and destroy the Tree’s roots: “The architectural design substantially conforms to my recommendations provided in January 2021, which stipulates a minimum 30-foot setback from the oak's trunk to construct the future building and parking garage, and a minimum setback of 20 feet from the trunk for all ground disturbance beneath the existing asphalt surface. “Roots The 20-foot setback from #10's trunk for ground disturbance applies to any soil compaction, grading, subexcavation, overexcavation, trenching, drilling/auguring, storm drains, swales, etc.” In other words, once you are 20 feet or more from the Tree, you can go at it, tear up the ground and destroy the Tree’s roots anyway and as much as you want. It appears to me that the Applicant didn’t have a thought when they started about Palo Alto’s desire to protect its beautiful Heritage Trees. They just saw some land, put together plans to fill that land with rental opportunities, and moved forward. When they discovered that Palo Alto wanted to protect the Tree, they drew a TPZ to accommodate their plans, rather than drawing their plans to accommodate the Tree. As Chair David Hirsch so succinctly stated at the December, 2022 Architectural Review Board Hearing on this project: “This is too much building in too small of a space.” Thank you for your consideration, Christopher Ream Christopher Ream Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 277  Packet Pg. 355 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 278  Packet Pg. 356 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 1 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Date: 12/18/2023 Impact Analysis of Proposed 660 University, Palo Alto Site Plan Project Work on One (1) Off-Site Coast Live Oak (Quercus agrifolia) Specimen (Project Tree #10, Palo Alto City Tree Tag #1572) at 517 Byron Palo Alto, CA Mr. Chris Ream, President The Hamilton Homeowners Association 555 Byron Palo Alto, CA ream@reamlaw.com Dear Mr. Ream, The following written letter report is the single deliverable prepared by Walter Levison, Consulting Arborist (WLCA) per your request as an association with members residing at The Hamilton, in close proximity to the proposed multi-story 660 University project. Background and Assignment The proposed private development project stated above proposes to demolish various existing office buildings and parking lot areas, and build an underground parking garage, with residential and commercial office facility directly over the garage footprint. WLCA’s assignment was to determine whether the site work as currently proposed per the set of plan sheets (dated October 2023) would cause severe or otherwise irreversible injury to the subject oak specimen to such as degree that it would be expected to fall into a spiral of decline from which it could not recover, as a direct result of the site work. WLCA visited the site on 12/13/2023 to archive digital images, create a tree map markup showing actual site-verified canopy dimensions (rough approx.), and confirm existing site conditions. The project encompasses three lots, 660 University, 680 University, and 511 Byron. An adjacent lot at 517 Byron just south of the proposed work area exhibits a relatively very large “veteran tree” coast live oak (Quercus agrifolia) referenced by David L. Babby, author of the Tree Protection Report filed by the developer, as tree #10 (City tag #1572), a specimen in good overall condition (62% out of 100% possible) as visually assessed by WLCA, with a canopy spread that is equal to the largest coast live oak specimens ever assessed in the author’s entire 25 year professional consulting career (see digital images below in this report showing the 90 foot diameter canopy). WLCA reviewed the private development proposed plan sheets dated 10/31/2023 (planning resubmittal #5) which were downloaded from the City of Palo Alto website, and an arborist report by David Babby dated 11/19/2021, which does not actually contain any site plan sheets (Mr. Babby used a topographic survey sheet for his site tree map markup). Multiple marked-up tree location maps, color-coded by WLCA, show expected construction-related impacts in relation to the tree #10 existing canopy dripline and in relation to the standard tree protection zone (TPZ) of 10 x diameter as an offset radius from mainstem edge. These markups are attached to the end of this letter report for reference (view document using Adobe Pro, Adobe CS, or other paid form of Adobe Acrobat, to maintain the visibility of the color-coded markups). Digital images archived by WLCA in December 2023 are also included in this report for reference of pre-project conditions. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 279  Packet Pg. 357 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 2 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Basic Data Diameter: 50 inches, per Babby report. Spread: Approximately 90 feet total diameter, per David Babby report and WLCA. Health (Vigor): 70% per Babby, 80% per WLCA. Structure: 40% per Babby, 50% per WLCA. Overall Condition Rating: 50% (fair) per Babby, 62% (good) per WLCA. Live Twig Density and Live Foliar Density: Good. Additional Tree Information per WLCA’s Visual Tree Assessment (VTA) 12/13/2023 and Research Foliage hangs down to 15 to 25 feet above grade at 45 feet radius north of mainstem edge. Multiple mainstems exhibit wide angle saddle shaped (i.e.”normal”) attachment forks between 10 and 15 feet elevation above grade. These stems are somewhat upward oriented. Buttress root flares at root crown appear normal, though root system extent and condition are essentially unknowable due to hardscape presence over a large percentage of actual root zone. It is hypothesized that the actual extent of root zone is at least 2x to 3x the 45 foot canopy radius in terms of lateral distance in most directions out from trunk1, based on both Arboriculture 4th Edition (2004), and on WLCA’s past 25 years of construction site consulting experience with coast live oak specimens on older sites with older less-compacted root zone conditions, where historical building foundations and parking lot baserock base sections were constructed to far less strict standards than modern engineer specifications. There may be extensive rooting occurring out through various private lots that adjoin the 517 Byron lot on which tree #10 stands, with lateral woody roots extending from tree #10 underneath various retaining wall footings and building footings, out to underneath existing asphalt parking lot surfacing, etc. Per USGS local quadrangle soils map, tree #10 is growing in the “Qoa” unit, which is defined as an older alluvium (oa): a gravelly riparian soil that is derived from stream associated movements, and typically contains smooth rocky material that drains relatively well, and is excellent for development of deep, elongated native oak tree root systems (based on WLCA’s professional experience and research). This Palo Alto site probably has one of the best soils in the entire Bay Area in terms of allowing for fast growth of native oaks. See the digital images section of this report for an overlay map created by WLCA using various online sources and the USGS soil map shows how groundwater at this location is relatively high in elevation (25 foot groundwater contour), and shows existing roads, historical streams, and red dot plots where a past survey by others indicated locations of extremely old native valley oak specimens for reference. What this all means is that the proposed project site has very good growing conditions for native oaks with a high groundwater table elevation contour and gravelly alluvium soil associated with historical waterways which drains relatively quickly and may also exhibit relatively good aeration related to the larger material components of the soil. 1 Per Harris et. al. 2004. Arboriculture 4th Edition. Prentice Hall. Upper Saddle River, New Jersey, USA. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 280  Packet Pg. 358 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 3 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Expected Tree Root Zone and Canopy Impact Analysis / Based on October 2023 Set of Proposed Plan Sheets • Canopy: Expect 20 to 30% of canopy live wood and foliage to be removed to clear southward-extended balcony construction, garage vertical wall construction, foundation footing construction for main building structure, vertical exterior walls along the south side of the residential structure, and an additional +/- 10 feet of horizontal width required to be totally cleared up to roof peak elevations as a “construction corridor” airspace for exterior work, scaffold erection, and bucket lift machinery use (based on WLCA’s past projects to date, which required between 6 feet and 15 feet of horizontal clearance as construction corridors around building exterior walls, between soil surface grade and the roof peaks). Note that the curvilinear section of garage entry ramp, although it is below grade elevation, may actually require tall vertical machinery clearance directly above the proposed wall cut locations, resulting in further clearance pruning of the tree #10 northwest corner of canopy (not verified). This information is based on past projects overseen by WLCA involving underground parking garage retaining wall construction in the Bay Area. Total expected canopy loss will likely result in a remnant canopy with 20 to 25 feet of north, northeast, and northwest extension from mainstem base, whereas existing canopy is +/- 45 feet radial extension in those directions. Refer to the attached WLCA tree map markup for a graphic representation of the various impacts indicated as color-coded lines. • Roots: Expected subgrade work will encroach to within the City of Palo Alto “10 times diameter” tree protection zone on the north side of tree, inside which special methods/materials/monitoring is required for site construction work. Extent of root zone compromised by the various elements of proposed work (garage wall excavation using vertical shoring, landscape decking, landscape irrigation, landscape plant and tree installation, etc. is expected to be moderate to severe, depending on actual cut depths and depending on whether machinery and personnel are allowed to enter into the TPZ and compact the root zone in the north area of TPZ. Note that the actual extent of roots may or may not be 2x to 3x the tree canopy dripline radius distance northward from trunk, and is currently obscured by hardscape and not able to be verified in terms of lateral distance of growth. Critical Root Zone (i.e. “CRZ”) or “Tree Protection Zone”, in terms of structural root plate, lateral woody roots, and absorbing root mass retention during work on one or more sides of a tree, is ten times the diameter of trunk (10 x 50 inch diameter as noted in the David Babby report). Therefore, it is WLCA’s understanding that the required TPZ work offset radius for tree #10 is approximately 10 x 50 inches = 41.6 feet radius2), unless site work at offset distances less than 10 x diameter is specifically authorized by City Urban Forestry Staff. Note that in the case of the 660 University project, the severe extent of clearance pruning creates a cumulative impact in terms of loss of tree condition, such that the combined root zone and canopy impacts are relatively severe or extremely severe (see attached WLCA markups showing deep excavation work impacts, for example, expected to within 30 feet offset from trunk, which is far less than the 41.6 foot official TPZ offset). 2 Reference the developer’s Tree Disclosure Statement, which notes that the official TPZ is 10 x diameter of trunk, per City of Palo Alto Tree Technical Manual (TTM) standards. Blue link to full TTM below shows up erroneously as a hyperlink to “Appendix A”, but is actually the full TTM document: APPENDIX A (cityofpaloalto.org) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 281  Packet Pg. 359 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 4 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Note also that there is no guarantee that site work will be performed by the developer in a manner consistent with specific conditions of project approval as set forth by Palo Alto Urban Forestry Staff, even if those special conditions were mandated by the City. There is no way for an arborist monitoring site work, for instance, to be on site during every stage of the work. The arborist monitor, if retained to inspect site work near to tree #10 during the development phase of the project, would only be able to visibly inspect the site once a month or so, leaving him/her with a limited snapshot of what below-ground impacts occurred in relation to the tree #10 root zone. Soil Compaction within the CRZ/TPZ: Note that proposed driving of machinery, foot traffic, extensive landscape footing development, and extensive planting and (possibly also) extensive irrigation pipe trenching are expected to occur within the CRZ/TPZ of 41.6 feet radius from trunk edge of tree #10. Consulting Arborists will typically specify use of robust “ground protection” in these cases, covering the ground with a thick mat of geotextile overlaid with 6 or more inches of wood chips, and finally covered with steel trench plates or full sheets of exterior grade plywood strapped together with steel strap plates to create a soil buffer. But given that there is planned intense landscaping and decking, etc. to be developed in the area between the garage retaining wall and the south property line abutted up against the 517 Byron lot, WLCA expects that it would be virtually impossible for the developer to actually implement use of robust ground protection and maintain it for any length of time, without causing a major problem in terms of ground logistics (staging, storage, movement of tools and materials, performance of landscape related development between 517 Byron and the underground parking garage wall, etc.). Therefore, it is expected that soil compaction of a high degree will likely occur in the north section of the tree #10 root zone, within the CRZ/TPZ offset radius, causing additional reduction in overall tree health and structural condition as soil oxygen pore space is compacted and root zone root growing conditions end up suffering as a result of loss of oxygen pore spaces within the tree root growth section of the soil profile (i.e. mainly the uppermost two feet of the soil profile, but potentially down to 4 or 5 feet or more below soil surface grade elevation in native Palo Alto area historical riparian cobble type soils). • TRAQ Risk: The removal of 20% to 30% of the canopy of tree #10 for clearance as noted above, will cause southward lopsidedness of the currently-symmetrical canopy tree specimen of extremely large spread radius (45 feet radius), resulting in increased load forces acting on the north side (“tension” side) of the root system. The root system will have been compromised to an unknown degree during site work (underground parking garage wall excavation, landscape development, and possible adjustments to or demolition of the existing brick retaining wall that separates 517 Byron from the proposed 660 University project site. Risk of whole tree failure mode and impact with targets to the south of the mainstem location will be necessarily increased and elevated due to these site plan work activities. Risk of stem failure and impact with various ground targets will over time be increased and elevated, due to the required clearance pruning through the north side of the canopy to clear scaffolding, bucket lift machinery, balconies, and the new building exterior wall plus underground parking retaining wall work that requires vertical machinery airspace clearance. Very large diameter pruning cuts will be made to accomplish the work, ranging from a few inches diameter each, up to 17 or more inches diameter each3, on some stems that extend northward into the proposed project airspace area. Pruning cuts of this relatively large diameter will allow for fungal wood decay-causing pathogen entrance into the stems via these open cut wounds, resulting in extensive decay column formation over time that progresses down into the stems from the cut wounds. 3 David Babby’s arborist report notes that a 14” and a 17” diameter stem will require pruning. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 282  Packet Pg. 360 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 5 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture • Heritage Tree Designation in City of Palo Alto There are currently +/- eight (8) trees listed on the City heritage tree list maintained by the City. Per the following information, trees are apparently not required to meet any specific “approval criteria” in terms of species, size, condition, or other relevant parameters, to be selected as formal heritage tree specimens in City of Palo Alto, other than that the trees are native oak species or redwoods located on private property: (Excerpt from a City Staff Report Online): “In 1996, Council enacted the Tree Preservation Ordinance, Chapter 8.10 of the Palo Alto Municipal Code, to preserve and maintain specified native oaks, redwoods, and heritage trees on private property, and to protect them from disfigurement or removal, except in certain circumstances. Section 8.10.090 of the ordinance allows persons to nominate a tree on their property forheritage tree status. After Council approval of such designation, the tree is added to the heritage tree listing, which includes specific location, overall size, and canopy spread. The list is maintained by the Department of Public Works and available to the public on the City’s Urban Forestry website. Once designated, a heritage tree is protected by the provisions of the Tree Preservation and Management Regulations, unless removed from the heritage tree list by subsequent Council action at the request of the property owner.” Per the above information, protected size tree #10 (City tree tag #1572) appears to be an excellent candidate for inclusion in the City’s heritage tree designation program which protects native oaks on private properties. It is a specimen in good overall condition, with exceptional size in terms of both mainstem diameter (est. 50 inches), and canopy spread (90 feet total diameter), with good vigor, good buttress root flares, and good saddle-shaped wide angle forks of mainstem attachment. • David Babby Report 11/19/2021 Page 6 Per page 6 of the developer’s arborist report by David Babby, tree #10 exhibits a “high” rating in terms of suitability for preservation (see below excerpt from page 6 of Babby report): Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 283  Packet Pg. 361 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 6 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Conclusion If the proposed 660 University site plan project were built out as currently proposed per the 10/31/2023 planning resubmittal #5 versions of the plan sheets, WLCA expects that tree #10 would experience relatively moderate to severe root loss, and relatively severe pruning, which combined as a cumulative below-ground and above-ground negative impact would necessarily result in loss of vigor (health) and structure to a severe degree. The tree’s safe and useful life expectancy in its current condition rating of “good” (+/- 62% overall condition rating) may be reduced as a result of site plan project work from (EXISTING: no-construction scenario) 50 to 100 years remaining, to (PROPOSED: post-construction scenario) 10 to 20 years remaining, or less, depending on the tree’s response to very significant project clearance canopy and root pruning as described above in this letter report. It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover. There would also necessarily be a corresponding elevation of the TRAQ risk rating in terms of risk of whole tree and/or tree part failure and impact with various static and moving targets with moderate to high occupancy ratings within the target zone and a reasonable time frame such as 12 to 24 months, starting as of the proposed site construction completion date (this would need to be assessed at a future time, and is outside the scope of WLCA’s initial pre-project assignment). The tree is located in the an area known to have high water table elevations and gravelly (gravel-laden) riparian type alluvium soil that tends to support excellent native oak tree root growth in terms of both rooting depth and root lateral extension. It is highly recommended that this exceptionally large native oak specimen in good overall condition be designated by the City Council as a City of Palo Alto Heritage Tree on private land, and formally added to the list maintained by the City on their official website, with the added tree protection guarantees that this tree special protection status includes (tree specimens are typically nominated for such designation by the owner of the property on which the tree stands). Refer also to David Babby’s arborist report dated 11/19/202, page 6, which notes that tree #10 is rated as “high” suitability for preservation, appearing healthy and structurally stable per his assessment, presenting “good potential for contributing long-term to the site”. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 284  Packet Pg. 362 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 7 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Digital Images by WLCA 12/13/2023 / Tree #10 Coast live oak (Quercus agrifolia) View looking eastward while standing on 517 Byron. Note the excellent buttress root flaring at the root crown of tree #10 which is considered normal and desirable. View of the relatively wide angle fork attachments between 10 and 15 feet elevation above grade at which the tree #10 codominant mainstems arise. These saddle shaped forms are normal and desirable from a structural stability standpoint. Although it is not “optimal” to have codominant mainstems forking in a tree, the best case scenario would be for all of the forks to exhibit wide saddle-shaped attachments like this tree. It is actually extremely unusual for a coast live oak to exhibit saddle-shaped forks at every Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 285  Packet Pg. 363 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 8 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of subject oak #10 looking northward from 517 Byron. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 286  Packet Pg. 364 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 9 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of oak #10 lower 50% of canopy/mainstem architecture, with the adjoining asphalt parking lot area west of 517 Byron visible at left half of the image. The root system is assumed to be extended through most or all adjoining lots surrounding 517 Byron (not verified), as is assumed to reach as much as 2x to 3x the 45 foot canopy radius (again, not verified, but very possible, per WLCA’s past experience with older oaks in Palo Alto and Menlo Park area, especially if Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 287  Packet Pg. 365 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 10 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Per WLCA’s multi-layer mockup created for a valley oak location comparison with groundwater depths and soil types, the tree #10 location has a 25 foot depth groundwater table, and nearby Palo Alto study-noted red dots which indicate very large older valley oak specimens surveyed in the past and included on internet maps for reference. The Qoa soil type at the 660 University site is defined as “older alluvium” (hence the “oa” designation): a Pleistocene soil of gravels, sand, and silt that is unconsolidated to consolidated, interspersed with alluvial materials from stream action. See next page of this report for the United States Geological Survey legend pertaining to this soil unit, clipped from the Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 288  Packet Pg. 366 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 11 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Above was excerpted from the USGS Quadrangle (soil unit map) which includes the City of Palo Alto area. Assumptions and Limiting Conditions Any legal description provided to the consultant/appraiser is assumed to be correct. Any titles and ownership to any property are assumed to be good and marketable. No responsibility is assumed for matters legal in character. Any and all property is appraised and evaluated as through free and clean, under responsible ownership and competent management. It is assumed that any property is not in violation of any applicable codes, ordinance, statutes, or other government regulations. Care has been taken to obtain all information from reliable sources. All data has been verified insofar as possible; however, the consultant/appraiser can neither guarantee nor be responsible for the accuracy of information provided by others. The consultant/appraiser shall not be required to give testimony or to attend court by reason of this report unless subsequent contractual arrangements are made, including payment of an additional fee for such services as described in the fee schedule and contract of engagement. Unless required by law otherwise, the possession of this report or a copy thereof does not imply right of publication or use for any other purpose by any other than the person to whom it is addressed, without the prior expressed written or verbal consent of the consultant/appraiser. Unless required by law otherwise, neither all nor any part of the contents of this report, nor copy thereof, shall be conveyed by anyone, including the client, to the public through advertising, public relations, news, sales, or other media, without the prior expressed conclusions, identity of the consultant/appraiser, or any reference to any professional society or institute or to any initiated designation conferred upon the consultant/appraiser as stated in his qualifications. This report and any values expressed herein represent the opinion of the consultant/appraiser, and the consultant’s/appraiser’s fee is in no way contingent upon the reporting of a specified value, a stipulated result, the occurrence of a subsequent event, nor upon any finding to be reported. Sketches, drawings, and photographs in this report, being intended for visual aids, are not necessarily to scale and should not be construed as engineering or architectural reports or surveys unless expressed otherwise. The reproduction of any information generated by engineers, architects, or other consultants on any sketches, drawings, or photographs is for the express purpose of coordination and ease of reference only. Inclusion of said information on any Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 289  Packet Pg. 367 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 12 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture drawings or other documents does not constitute a representation by Walter Levison to the sufficiency or accuracy of said information. Unless expressed otherwise: • information contained in this report covers only those items that were examined and reflects the conditions of those items at the time of inspection; and • the inspection is limited to ground-based visual examination of accessible items without climbing, dissection, excavation, probing, or coring. • There is no warranty or guarantee, expressed or implied, that problems or deficiencies of the plants or property in question may not arise in the future. Loss or alteration of any part of this report invalidates the entire report. Arborist Disclosure Statement: Arborists are tree specialists who use their education, knowledge, training, and experience to examine trees, recommend measures to enhance the beauty and health of trees, and attempt to reduce the risk of living near trees. Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice. Arborists cannot detect every condition that could possibly lead to the structural failure of a tree. Tree are living organisms that fail in ways we do not fully understand. Conditions are often hidden within trees and below ground. Arborist cannot guarantee that a tree will be healthy or safe under all circumstances, or for a specified period of time. Likewise, remedial treatments, like any medicine, cannot be guaranteed. Treatment, pruning, and removal of trees may involve considerations beyond the scope of the arborist’s services such as property boundaries, property ownership, site lines, disputes between neighbors, and other issues. Arborists cannot take such considerations into account unless complete and accurate information is disclosed to the arborist. An arborist should then be expected to reasonably rely upon the completeness and accuracy of the information provided. Trees can be managed, but they cannot be controlled. To live near trees is to accept some degree of risk. The only way to eliminate all risk associated with trees is to eliminate the trees. Certification I hereby certify that all the statements of fact in this report are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. Signature of Consultant DIGITAL BADGES: ISA CERTIFIED ARBORIST CREDENTIAL: https://certificates.isa-arbor.com/f1918723-df46-48cc-ace2-c12625530fec#gs.v54om6 (Renewed through June, 2026) ISA TREE RISK ASSESSMENT QUALIFIED (TRAQ): https://certificates.isa-arbor.com/d180515f-ab75-440b-9c66-106005e3cf10?record_view=true#gs.hpb30w (Renewed through March, 2028) Attached: Tree Map Markups by WLCA 12/18/2023 (View Using Adobe or Adobe CS in Order to Allow for Full Visibility of the Markups Created Using Adobe Pro Software). Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 290  Packet Pg. 368 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 291  Packet Pg. 369 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 292  Packet Pg. 370 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 A"achment B Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 293  Packet Pg. 371 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 294  Packet Pg. 372 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 295  Packet Pg. 373 of 517  May 8, 2022 660 University Avenue Palo Alto, California. Scan #7 Line scan over parking lot 31 feet away from Oak tree #1572 Asphalt Thickness Root Depth in inches Excavation point for below-ground garage. This involves this whole cross section. All roots will be removed; beginning with the following scans 7-12 May 23, 2023 Root Study Oak Tree #1572 660 University Avenue Palo Alto, California Robert Booty Registered Consulting Arborist 487 ISA Qualified Tree Risk Assessor Copyright 2022 Arborist OnSite Horticultural Consulting, Inc. www.arboristonsite.com 34 Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 296  Packet Pg. 374 of 517  From:Christopher Ream To:Kallas, Emily Subject:660 University, ARB Hearing Date:Wednesday, April 17, 2024 12:27:59 AM Attachments:660 - Ream Letter re Tree - 20240416 w Attachments.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Emily, Please find attached my letter which I wish the Architectural Review Board will have a chance to review before the Hearing Thursday morning. Please share it with each Member and with anyone else for whom you think would be appropriate. Please point out to them that Walter Levison’s Impact Analysis is attached. Thank you. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 297  Packet Pg. 375 of 517  Some people who received this message don't often get email from faithwb3@yahoo.com. Learn why this is important From:Kallas, Emily To:Kallas, Emily Subject:FW: New Construction at 511 Byron Street, and more, Palo Alto Date:Tuesday, May 21, 2024 4:22:00 PM From: Faith Brigel <faithwb3@yahoo.com> Sent: Thursday, April 18, 2024 5:21 PM To: Council, City <city.council@cityofpaloalto.org>; Lythcott-Haims, Julie <Julie.LythcottHaims@CityofPaloAlto.org>; Veenker, Vicki <Vicki.Veenker@CityofPaloAlto.org>; Lauing, Ed <Ed.Lauing@CityofPaloAlto.org>; Kou, Lydia <Lydia.Kou@CityofPaloAlto.org>; Tanaka, Greg <Greg.Tanaka@CityofPaloAlto.org> Cc: Faith Brigel <faithwb3@yahoo.com>; greg.stone@cityofpaloalto.org; Burt, Patrick <Pat.Burt@CityofPaloAlto.org> Subject: New Construction at 511 Byron Street, and more, Palo Alto CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council of City of Palo Alto, This morning I attended an Architectural Review Board meeting to discuss the new construction that is being proposed for 511 Byron Street, 660 University Ave., 680 University Ave., and 500 Middlefield Road. Once all of these buildings will be demolished they will construct an immense four story, mixed usage of many offices and many residential rentals, and a two story basement for parking, though the parking spaces will be much reduced from what is needed. And I assume a lot of water will need to be drained since our water level is shallow. Their presentation talked about several of the other buildings in that area that are large, though not as large as this one: the Hamilton project, Lytton Gardens, The Webster House and there is the 3 story 2 condo on Webster and University Ave. There are already several large buildings in this area. And I think none of them have a two story basement. That intersection is already very congested. And there is rarely any parking on Byron Street. One person opposed to this project this morning stated that constructing this building into that area is like squeezing it into a lot that is much too small. I have owned the single, story Victorian that is more than 100 years old, for almost 40 years. My building was not mentioned this morning. And I will lose some of my daylight plan, which was also not mentioned. Byron Street and University Ave. in Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 298  Packet Pg. 376 of 517  that area has always been a quiet, professional area for the past 40 years. My building has a psychiatrist, and a psychologist. They work in my building because it is quiet. Adding many residential apartments with balconies to those structures will totally change the nature of this area. And I more than likely will lose at least some of my tenants, if not all of them. I understand that the State is requiring more housing. But a very large building with offices and apartments right downtown on University Ave. beside Middlefield is not a good spot for it. There should be some consideration for people like myself who have been in that area for many years- not just the developers who are not concerned that they are overbuilding the downtown area. I ask and hope that you who represent all of us on the City Council and will take into consideration all of us not just the developers. Thank you for your consideration, Faith W. Brigel Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 299  Packet Pg. 377 of 517  From:Mathews, Marley@DOT To:Kallas, Emily Cc:Luo, Yunsheng@DOT Subject:660 University Avenue Mixed-Use Project Caltrans Comment Date:Wednesday, May 8, 2024 1:06:33 PM You don't often get email from marley.mathews@dot.ca.gov. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Hello Emily, Thank you for including Caltrans in this review of the 660 University Avenue Mixed-Use Project DIER. At this time, Caltrans has no comments on the material provided. Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only. Please continue to include Caltrans in discussions regarding this Project to stay informed. We encourage multi-agency collaboration and welcome any potential opportunities. Any future material or correspondence regarding this Project can be submitted to LDR-D4@dot.ca.gov. Thank you, Marley Mathews Transportation Planner (she/her) D4 Caltrans 510-960-0841 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 300  Packet Pg. 378 of 517  From:Gennifer Wehrmeyer To:Kallas, Emily Cc:CPRU-Dropbox; Shree Dharasker Subject:VW File 34811 – Comments on DEIR for 660 University Avenue Mixed-Use Project Date:Friday, May 17, 2024 4:14:49 PM Attachments:image001.png You don't often get email from gwehrmeyer@valleywater.org. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Emily, The Santa Clara Valley Water District (Valley Water) has reviewed Notice of Availability of aDraft Environmental Impact Report (DEIR) for the 660 University Avenue Mixed-Use Project to merge three parcels to construct a four-story mixed-use building at 511 BryonStreet, 660 University Ave, and 680 University Ave/500 Middlefield Rd in Palo Alto, received on April 2, 2024, and has the following comments: 1. Valley Water does not have any right of way or facilities within the project siteboundary; therefore, in accordance with Valley Water’s Water ResourcesProtection Ordinance, a Valley Water encroachment permit will not be requiredfor the project. 2. Valley Water previously commented on the Notice of Preparation (NOP) thatunderground structures should be designed for waterproofing that avoids theneed for permanent dewatering after construction is complete. As stated inSection 10-a, construction will involve excavation up to 38 feet below groundsurface, during which time dewatering will be used. It is unclear if dewatering willoccur after construction. Underground structures should be designed forwaterproofing and permanent dewatering should be avoided once constructionis finished. 3. Valley Water records indicate that no active wells are located on the subjectproperty. While Valley Water has records for most wells located in the County, itis always possible that a well exists that is not in the Valley Water’s records. Ifpreviously unknown wells are found on the subject property during development,they must be properly destroyed under permit from Valley Water or registeredwith Valley Water and protected from damage. For more information, please callthe Valley Water’s Well Ordinance Program Hotline at 408-630-2660. 4. According to the Federal Emergency Management Agency’s (FEMA) FloodInsurance Rate Map (FIRM) 006085C0010H, effective May 18, 2009, the projectsite is within FEMA Flood Zone AH, an area with 1% annual chance of shallowflooding (usually areas of ponding), located between base flood elevations of 46feet and 47 feet. The project is required to follow the flood plain ordinance andnational flood insurance requirements. If you have any questions or need further information, you can reach me at gwehrmeyer@valleywater.org or at (408) 694-2069. Please reference Valley Water File 34811 on further correspondence regarding this project. Thank you, Gennifer Wehrmeyer ASSISTANT ENGINEER, CIVIL Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 301  Packet Pg. 379 of 517  Community Projects Review Unit Watershed Stewardship and Planning Division GWehrmeyer@valleywater.org Tel. (408) 630-2588 Cell. (408) 694-2069 SANTA CLARA VALLEY WATER DISTRICT 5750 Almaden Expressway, San Jose CA 95118 www.valleywater.org Clean Water . Healthy Environment . Flood Protection Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 302  Packet Pg. 380 of 517  From:Kathleen Rotow To:Kallas, Emily Subject:Re: 660 University Draft EIR - Now Circulating Date:Wednesday, April 3, 2024 11:52:55 AM Attachments:image001.png image002.png Thanks Emily. I'm glad the review concluded that the Byron Ave entry and exit for thisproject made more sense than further slowing down Middlefield and University. It also keeps some of the inevitable noise from this project from disturbing the senior project across thestreet on University. On Wed, Apr 3, 2024 at 8:28 AM Kallas, Emily <Emily.Kallas@cityofpaloalto.org> wrote: Hi Kathleen, After the initial ARB review, the driveway was relocated to the Byron frontage, to reducepotential conflict on Middlefield. Thanks, Emily Emily Kallas, AICP Planner Planning and Development Services Department (650) 617-3125 | emily.kallas@cityofpaloalto.org www.cityofpaloalto.org Parcel Report | Palo Alto Zoning Code | Online Permitting System | Planning Forms &Applications | Planning Applications Mapped Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 303  Packet Pg. 381 of 517  From: Kathleen Rotow <kathleenrotow@gmail.com> Sent: Wednesday, April 3, 2024 4:46 AMTo: Kallas, Emily <Emily.Kallas@cityofpaloalto.org>Subject: Re: 660 University Draft EIR - Now Circulating CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Good Morning Emily, I have an initial question that you may be able to answer quickly. Given that I live withintwo blocks from the project on University Avenue, one of my concerns is the amount of additional traffic this project will generate on an already very congested corner. Probableadditional traffic backups on both University Ave and Middlefield Ave. Will the entry and exits for parking be on University or Middlefield? Will there be any left turn entry into theparking for the project while heading west on University? Thank you, Kathleen Rotow Sent from my iPhone On Apr 2, 2024, at 5:58 PM, Kallas, Emily <Emily.Kallas@cityofpaloalto.org>wrote:  Good afternoon, This e-mail is to inform you that the Draft EIR for the 660 University project is now available here on our Planning Department website. The Notice ofAvailability is attached and has further information regarding the proposed project. The comment period for the Draft EIR begins today, Tuesday, April2nd and will end on May 17, 2024. This e-mail is being provided to you because you are a neighboring jurisdiction, your agency has expressed aninterest in the proposed project or because your agency may have an interest in the proposed project, or because you have been requested to be contactedregarding any project within the City of Palo Alto’s jurisdiction. Please feel free to contact me if you have any questions or to send comments. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 304  Packet Pg. 382 of 517  Regards, Emily <image001.png>Emily Kallas, AICP Planner Planning and Development Services Department (650) 617-3125 | emily.kallas@cityofpaloalto.org www.cityofpaloalto.org <image002.png> Parcel Report | Palo Alto Zoning Code | Online Permitting System | PlanningForms & Applications | Planning Applications Mapped <660_University_NOA signed.pdf> Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 305  Packet Pg. 383 of 517  From:Christopher Ream To:Kallas, Emily Subject:660 University Project Date:Wednesday, April 10, 2024 3:38:35 PM Importance:High CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Emily, Chris Ream here, the President of the Hamilton Homeowners Association. I intend to prepare a letter to the Architectural Review Board outlining The Hamilton’s objections to the planned project at 660 University, and I also intend to attend and comment at the ARB Hearing new week on April 18. I have done a quick review of the Draft EIR. The Draft EIR addresses many of the points I had previously brought up to the ARB along with some new points, including in particular, the danger of killing Tree #10 (the protected coastal oak) and the alternative of adding a fifth above-ground story to the building, and the alternative of eliminating the second floor of the underground garage. These are not shown in the developer’s current plans, but are obviously issues that need to be addressed at some point. My question is: Would it be proper for me to address in my letter to the ARB and at the Hearing points raised in the Draft EIR but not yet appearing in the developer’s plans. I will call you to have a brief discussion on this. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 306  Packet Pg. 384 of 517  From:Mimi and Eric Carlson To:Christopher Ream; Kallas, Emily Subject:Re: 660 University Project Date:Thursday, April 11, 2024 11:02:35 AM You don't often get email from mimianderic@hotmail.com. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Chris et al. Please note that the proposed project will create a traffic nightmare, espesciallly if the entrance is on Byron.- which is effectively a one wao street during the day. Eric Carlson From: Christopher Ream <ream@reamlaw.com> Sent: Wednesday, April 10, 2024 3:38 PM To: Kallas, Emily <Emily.Kallas@cityofpaloalto.org> Subject: 660 University Project Emily, Chris Ream here, the President of the Hamilton Homeowners Association. I intend to prepare a letter to the Architectural Review Board outlining The Hamilton’s objections to the planned project at 660 University, and I also intend to attend and comment at the ARB Hearing new week on April 18. I have done a quick review of the Draft EIR. The Draft EIR addresses many of the points I had previously brought up to the ARB along with some new points, including in particular, the danger of killing Tree #10 (the protected coastal oak) and the alternative of adding a fifth above-ground story to the building, and the alternative of eliminating the second floor of the underground garage. These are not shown in the developer’s current plans, but are obviously issues that need to be addressed at some point. My question is: Would it be proper for me to address in my letter to the ARB and at the Hearing points raised in the Draft EIR but not yet appearing in the developer’s plans. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 307  Packet Pg. 385 of 517  I will call you to have a brief discussion on this. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 308  Packet Pg. 386 of 517  THE HAMILTON HOMEOWNERS ASSOCIATION Christopher Ream, President 555 Byron Street Palo Alto, California 94301 Telephone: 1-650-424-0821 Email: ream@reamlaw.com April 16, 2024 Via email: Emily.Kallas@CityofPaloAlto.org Re: 660 University Project Architectural Review Board Hearing on April 18, 2024 Draft EIR April 2024 Comments re Protection of the Coast Live Oak Tree Dear Emily, Please consider the comments in this letter as you continue to work on the Draft EIR for the 660 University Project and pass on these comments to members of the Architectural Review Board and to others where appropriate. There is an Attachment A and an Attachment B to this letter. The Hamilton is a senior living (55+) condominium development with 36 residential units and the average age of the residents in The Hamilton is mid-80’s. The Hamilton shares the same small block with the proposed development at 660 University Avenue. Lytton Gardens, Webster House and Webster House Health Center are within a block and directly across the street from the proposed development. Channing House is two blocks away. Because of this concentration of elderly citizens, the area is frequently referred to as “Senior Corner.” I am Christopher Ream. My wife Anne and I have been Palo Alto residents for 53 years and have been residents of The Hamilton for the past five years. The Hamilton community strongly opposes the proposed development at 660 University, and the Board of Directors of the Hamilton Homeowners Association (the “HHA”), with the support of its members/residents, has resolved to fight against the proposed development. I am the President of the HHA and am personally committed to significantly revising the proposed building that will materially adversely affect us and all of our neighbors. There is a majestic, beautiful Coast Live Oak tree (the “Tree”) in the middle of our block and is listed as Tree #10 on Applicant’s plans. Applicant’s arborist reports that the Tree’s trunk is 50 inches in diameter and its limbs stretch out 90 feet in diameter “in a mostly balanced canopy.” The Tree abuts the back property line of the 660 University project and so its limbs reach out approximately 45 feet over the project’s property, and its root structure is larger than that. The Tree brings shade and joy to us and everyone else on the block. The Tree is several hundred Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 309  Packet Pg. 387 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 2 of 4 years old and is deemed a Protected Heritage Tree by the City of Palo Alto. Applicant’s arborist rates the Tree “High” for suitability for preservation. This proposed project puts this beautiful Tree in grave danger: “It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover.” Walter Levison Consulting Arborist Impact Analysis dated 12/18/2023, p.6 Please see Attachment A to this letter for the full Impact Analysis by Walter Levison Consulting Arborist. Tree Protection Zone Applicant’s plans recite that the City’s Tree Technical Manual (TTM) ¶1.36 specifies a “Tree Protection Zone” (TPZ) for a protected tree with a radius equal to the ten times the trunk’s diameter. For the Tree, that would be 10 x 50” = 500” = 41 feet. Another rule is that the TPZ should be equal to the foliage, so here that would be a radius of 45 feet based upon the arborist’s report of a 90-foot canopy spread. I am not an arborist, but I am told that one common rule of thumb is that a tree’s roots are one and a half to three times wider than the canopy. For the Tree’s 45-foot limbs, that would be 67 to 135 feet of roots out under the parking lot where the new building would go. Robert Booty, arborist retained by Rincon Consultants on behalf of the City, reports that his LIDAR root scan of the existing asphalt parking lot at 600 University Avenue shows that the Tree’s roots are still dense and going out strong at his 51-foot scan, the furthest extent of his investigation. (See Attachment B.) Applicant has drawn a TPZ of only 30 feet on its plans and has the new building right next to and touching that 30 feet. That is 11 to 15 feet less than required. And the 30 feet is just what the building is supposed to look like – you don’t have to be an experienced contractor to know that there will be plenty of damaging construction work done on the exterior side of the two-story underground garage walls, and that will be much closer than 30 feet to the Tree. Robert Booty’s report points out that the roots are going to be sliced off at his scan of 31 feet. (See Attachment B.) Now, look up at the 2nd, 3rd and 4th floors, there are residential units with balconies sticking out 6 feet into the TPZ. Applicant’s arborist admits that pruning will be required, including a 17-inch limb. The Tree has to be pruned back to clear those balconies. Then be realistic: Applicant is going to prune the Tree even further back so that there is at least 5 feet of clearance between those balconies and the Tree. We are now cutting the Tree back to only 19 feet of foliage left. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 310  Packet Pg. 388 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 3 of 4 If 660 University is allowed to be built as now proposed, the Tree’s canopy will be severed on one side, disrupting the Tree’s balance, potentially allowing strong gravitational forces to push the Tree over. In addition, the roots needed to hold the Tree back from tipping over will have been cut and lost their gripping force. How soon will the Tree topple over and crash into The Hamilton and others. It would destroy the dental offices at 517 Byron, and badly injure and maybe kill anyone in those offices at the time. The neighborhood will lose this beautiful tree. The privacy of the seniors in the sixteen apartments in The Hamilton on that side of our development will be exposed to the 36 units with balconies on our side of the 660 University building as well as the noisy crowds on the roof top party deck. Security The Staff Report for the Architectural Review Board Hearing to be held April 18, 2024 reported that the Urban Forestry Section has requested that any building permit be conditioned upon the Applicant obtaining an appraisal of the replacement value of the Tree and posting security for that amount. What does that mean in this situation? It will be completely impossible to replace the Tree, thus how can anyone come up with a replacement value. And, if the Tree “dies” within three years of the completion of the project, then the money from the security will go into the Forestry Fund to plant trees elsewhere. So much for the owner of 517 Byron and thus the person who was the owner of the Tree and the one most damaged by its death. This might make sense if the permit was conditioned upon obtain an appraisal value using the Trunk Formula Method (TTM 6.45B) rather than the Replacement Cost Method (TTM 6.45A). Solution At the Architectural Review Board hearing in December 2022, everyone, including the Applicant’s architect and its landscaper actively agreed that the Tree had to be protected; but the Applicant did not suggest that a 41-45 foot TPZ should be observed. No, their answer was that they knew of a tree in Mountain View that has so far survived a small TPZ (although they did not say how long it has survived). One tree surviving for an unknown time is not a valid argument to ignore the universally accepted rule of a TPZ equal to 10 times the trunk’s diameter or the extent of the canopy. The only solution here to save this Protected Heritage Tree is that the proper 41-foot TPZ must be imposed and complied by both the proposed building and its construction. This is not an unfair burden on the Applicant: They have known all along that their 30-foot TPZ was in violation of TTM regulations, and that the building could not be constructed without violating even that reduced TPZ because of the necessity to have construction closer to the Tree than that artificial 30 feet. The first time they showed a TPZ on their plans was their C3 filing on October 6, 2022 when they showed a TPZ with a radius of 29’11-½” (strange number for a TPZ). C3_660 University Ave_PLAN1.pdf, p.24. This was later updated to the 30 feet we see now. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 311  Packet Pg. 389 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 Page 4 of 4 Applicant’s arborist David L. Babby discusses the size of the TPZ in §5.3 of his Tree Protection Report, 660 University Avenue, February 7, 2024: “The CPA's Tree Protection Zone (TPZ) standard is a radial distance from the trunk equal to 10 times its diameter, which for oak #10, identifies a TPZ of 41 feet from the trunk. The proposed project establishes the TPZ to be 30 feet from the trunk, which equates to a multiplier of 7 times the trunk diameter (and 11 feet inside).” He then goes on to say that the small 30-foot TPZ only applies to the finished building and garage, and sets up an even smaller, undisclosed zone where all sorts of construction work can tear up the ground and destroy the Tree’s roots: “The architectural design substantially conforms to my recommendations provided in January 2021, which stipulates a minimum 30-foot setback from the oak's trunk to construct the future building and parking garage, and a minimum setback of 20 feet from the trunk for all ground disturbance beneath the existing asphalt surface. “Roots The 20-foot setback from #10's trunk for ground disturbance applies to any soil compaction, grading, subexcavation, overexcavation, trenching, drilling/auguring, storm drains, swales, etc.” In other words, once you are 20 feet or more from the Tree, you can go at it, tear up the ground and destroy the Tree’s roots anyway and as much as you want. It appears to me that the Applicant didn’t have a thought when they started about Palo Alto’s desire to protect its beautiful Heritage Trees. They just saw some land, put together plans to fill that land with rental opportunities, and moved forward. When they discovered that Palo Alto wanted to protect the Tree, they drew a TPZ to accommodate their plans, rather than drawing their plans to accommodate the Tree. As Chair David Hirsch so succinctly stated at the December, 2022 Architectural Review Board Hearing on this project: “This is too much building in too small of a space.” Thank you for your consideration, Christopher Ream Christopher Ream Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 312  Packet Pg. 390 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 313  Packet Pg. 391 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 1 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Date: 12/18/2023 Impact Analysis of Proposed 660 University, Palo Alto Site Plan Project Work on One (1) Off-Site Coast Live Oak (Quercus agrifolia) Specimen (Project Tree #10, Palo Alto City Tree Tag #1572) at 517 Byron Palo Alto, CA Mr. Chris Ream, President The Hamilton Homeowners Association 555 Byron Palo Alto, CA ream@reamlaw.com Dear Mr. Ream, The following written letter report is the single deliverable prepared by Walter Levison, Consulting Arborist (WLCA) per your request as an association with members residing at The Hamilton, in close proximity to the proposed multi-story 660 University project. Background and Assignment The proposed private development project stated above proposes to demolish various existing office buildings and parking lot areas, and build an underground parking garage, with residential and commercial office facility directly over the garage footprint. WLCA’s assignment was to determine whether the site work as currently proposed per the set of plan sheets (dated October 2023) would cause severe or otherwise irreversible injury to the subject oak specimen to such as degree that it would be expected to fall into a spiral of decline from which it could not recover, as a direct result of the site work. WLCA visited the site on 12/13/2023 to archive digital images, create a tree map markup showing actual site-verified canopy dimensions (rough approx.), and confirm existing site conditions. The project encompasses three lots, 660 University, 680 University, and 511 Byron. An adjacent lot at 517 Byron just south of the proposed work area exhibits a relatively very large “veteran tree” coast live oak (Quercus agrifolia) referenced by David L. Babby, author of the Tree Protection Report filed by the developer, as tree #10 (City tag #1572), a specimen in good overall condition (62% out of 100% possible) as visually assessed by WLCA, with a canopy spread that is equal to the largest coast live oak specimens ever assessed in the author’s entire 25 year professional consulting career (see digital images below in this report showing the 90 foot diameter canopy). WLCA reviewed the private development proposed plan sheets dated 10/31/2023 (planning resubmittal #5) which were downloaded from the City of Palo Alto website, and an arborist report by David Babby dated 11/19/2021, which does not actually contain any site plan sheets (Mr. Babby used a topographic survey sheet for his site tree map markup). Multiple marked-up tree location maps, color-coded by WLCA, show expected construction-related impacts in relation to the tree #10 existing canopy dripline and in relation to the standard tree protection zone (TPZ) of 10 x diameter as an offset radius from mainstem edge. These markups are attached to the end of this letter report for reference (view document using Adobe Pro, Adobe CS, or other paid form of Adobe Acrobat, to maintain the visibility of the color-coded markups). Digital images archived by WLCA in December 2023 are also included in this report for reference of pre-project conditions. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 314  Packet Pg. 392 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 2 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Basic Data Diameter: 50 inches, per Babby report. Spread: Approximately 90 feet total diameter, per David Babby report and WLCA. Health (Vigor): 70% per Babby, 80% per WLCA. Structure: 40% per Babby, 50% per WLCA. Overall Condition Rating: 50% (fair) per Babby, 62% (good) per WLCA. Live Twig Density and Live Foliar Density: Good. Additional Tree Information per WLCA’s Visual Tree Assessment (VTA) 12/13/2023 and Research Foliage hangs down to 15 to 25 feet above grade at 45 feet radius north of mainstem edge. Multiple mainstems exhibit wide angle saddle shaped (i.e.”normal”) attachment forks between 10 and 15 feet elevation above grade. These stems are somewhat upward oriented. Buttress root flares at root crown appear normal, though root system extent and condition are essentially unknowable due to hardscape presence over a large percentage of actual root zone. It is hypothesized that the actual extent of root zone is at least 2x to 3x the 45 foot canopy radius in terms of lateral distance in most directions out from trunk1, based on both Arboriculture 4th Edition (2004), and on WLCA’s past 25 years of construction site consulting experience with coast live oak specimens on older sites with older less-compacted root zone conditions, where historical building foundations and parking lot baserock base sections were constructed to far less strict standards than modern engineer specifications. There may be extensive rooting occurring out through various private lots that adjoin the 517 Byron lot on which tree #10 stands, with lateral woody roots extending from tree #10 underneath various retaining wall footings and building footings, out to underneath existing asphalt parking lot surfacing, etc. Per USGS local quadrangle soils map, tree #10 is growing in the “Qoa” unit, which is defined as an older alluvium (oa): a gravelly riparian soil that is derived from stream associated movements, and typically contains smooth rocky material that drains relatively well, and is excellent for development of deep, elongated native oak tree root systems (based on WLCA’s professional experience and research). This Palo Alto site probably has one of the best soils in the entire Bay Area in terms of allowing for fast growth of native oaks. See the digital images section of this report for an overlay map created by WLCA using various online sources and the USGS soil map shows how groundwater at this location is relatively high in elevation (25 foot groundwater contour), and shows existing roads, historical streams, and red dot plots where a past survey by others indicated locations of extremely old native valley oak specimens for reference. What this all means is that the proposed project site has very good growing conditions for native oaks with a high groundwater table elevation contour and gravelly alluvium soil associated with historical waterways which drains relatively quickly and may also exhibit relatively good aeration related to the larger material components of the soil. 1 Per Harris et. al. 2004. Arboriculture 4th Edition. Prentice Hall. Upper Saddle River, New Jersey, USA. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 315  Packet Pg. 393 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 3 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Expected Tree Root Zone and Canopy Impact Analysis / Based on October 2023 Set of Proposed Plan Sheets • Canopy: Expect 20 to 30% of canopy live wood and foliage to be removed to clear southward-extended balcony construction, garage vertical wall construction, foundation footing construction for main building structure, vertical exterior walls along the south side of the residential structure, and an additional +/- 10 feet of horizontal width required to be totally cleared up to roof peak elevations as a “construction corridor” airspace for exterior work, scaffold erection, and bucket lift machinery use (based on WLCA’s past projects to date, which required between 6 feet and 15 feet of horizontal clearance as construction corridors around building exterior walls, between soil surface grade and the roof peaks). Note that the curvilinear section of garage entry ramp, although it is below grade elevation, may actually require tall vertical machinery clearance directly above the proposed wall cut locations, resulting in further clearance pruning of the tree #10 northwest corner of canopy (not verified). This information is based on past projects overseen by WLCA involving underground parking garage retaining wall construction in the Bay Area. Total expected canopy loss will likely result in a remnant canopy with 20 to 25 feet of north, northeast, and northwest extension from mainstem base, whereas existing canopy is +/- 45 feet radial extension in those directions. Refer to the attached WLCA tree map markup for a graphic representation of the various impacts indicated as color-coded lines. • Roots: Expected subgrade work will encroach to within the City of Palo Alto “10 times diameter” tree protection zone on the north side of tree, inside which special methods/materials/monitoring is required for site construction work. Extent of root zone compromised by the various elements of proposed work (garage wall excavation using vertical shoring, landscape decking, landscape irrigation, landscape plant and tree installation, etc. is expected to be moderate to severe, depending on actual cut depths and depending on whether machinery and personnel are allowed to enter into the TPZ and compact the root zone in the north area of TPZ. Note that the actual extent of roots may or may not be 2x to 3x the tree canopy dripline radius distance northward from trunk, and is currently obscured by hardscape and not able to be verified in terms of lateral distance of growth. Critical Root Zone (i.e. “CRZ”) or “Tree Protection Zone”, in terms of structural root plate, lateral woody roots, and absorbing root mass retention during work on one or more sides of a tree, is ten times the diameter of trunk (10 x 50 inch diameter as noted in the David Babby report). Therefore, it is WLCA’s understanding that the required TPZ work offset radius for tree #10 is approximately 10 x 50 inches = 41.6 feet radius2), unless site work at offset distances less than 10 x diameter is specifically authorized by City Urban Forestry Staff. Note that in the case of the 660 University project, the severe extent of clearance pruning creates a cumulative impact in terms of loss of tree condition, such that the combined root zone and canopy impacts are relatively severe or extremely severe (see attached WLCA markups showing deep excavation work impacts, for example, expected to within 30 feet offset from trunk, which is far less than the 41.6 foot official TPZ offset). 2 Reference the developer’s Tree Disclosure Statement, which notes that the official TPZ is 10 x diameter of trunk, per City of Palo Alto Tree Technical Manual (TTM) standards. Blue link to full TTM below shows up erroneously as a hyperlink to “Appendix A”, but is actually the full TTM document: APPENDIX A (cityofpaloalto.org) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 316  Packet Pg. 394 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 4 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Note also that there is no guarantee that site work will be performed by the developer in a manner consistent with specific conditions of project approval as set forth by Palo Alto Urban Forestry Staff, even if those special conditions were mandated by the City. There is no way for an arborist monitoring site work, for instance, to be on site during every stage of the work. The arborist monitor, if retained to inspect site work near to tree #10 during the development phase of the project, would only be able to visibly inspect the site once a month or so, leaving him/her with a limited snapshot of what below-ground impacts occurred in relation to the tree #10 root zone. Soil Compaction within the CRZ/TPZ: Note that proposed driving of machinery, foot traffic, extensive landscape footing development, and extensive planting and (possibly also) extensive irrigation pipe trenching are expected to occur within the CRZ/TPZ of 41.6 feet radius from trunk edge of tree #10. Consulting Arborists will typically specify use of robust “ground protection” in these cases, covering the ground with a thick mat of geotextile overlaid with 6 or more inches of wood chips, and finally covered with steel trench plates or full sheets of exterior grade plywood strapped together with steel strap plates to create a soil buffer. But given that there is planned intense landscaping and decking, etc. to be developed in the area between the garage retaining wall and the south property line abutted up against the 517 Byron lot, WLCA expects that it would be virtually impossible for the developer to actually implement use of robust ground protection and maintain it for any length of time, without causing a major problem in terms of ground logistics (staging, storage, movement of tools and materials, performance of landscape related development between 517 Byron and the underground parking garage wall, etc.). Therefore, it is expected that soil compaction of a high degree will likely occur in the north section of the tree #10 root zone, within the CRZ/TPZ offset radius, causing additional reduction in overall tree health and structural condition as soil oxygen pore space is compacted and root zone root growing conditions end up suffering as a result of loss of oxygen pore spaces within the tree root growth section of the soil profile (i.e. mainly the uppermost two feet of the soil profile, but potentially down to 4 or 5 feet or more below soil surface grade elevation in native Palo Alto area historical riparian cobble type soils). • TRAQ Risk: The removal of 20% to 30% of the canopy of tree #10 for clearance as noted above, will cause southward lopsidedness of the currently-symmetrical canopy tree specimen of extremely large spread radius (45 feet radius), resulting in increased load forces acting on the north side (“tension” side) of the root system. The root system will have been compromised to an unknown degree during site work (underground parking garage wall excavation, landscape development, and possible adjustments to or demolition of the existing brick retaining wall that separates 517 Byron from the proposed 660 University project site. Risk of whole tree failure mode and impact with targets to the south of the mainstem location will be necessarily increased and elevated due to these site plan work activities. Risk of stem failure and impact with various ground targets will over time be increased and elevated, due to the required clearance pruning through the north side of the canopy to clear scaffolding, bucket lift machinery, balconies, and the new building exterior wall plus underground parking retaining wall work that requires vertical machinery airspace clearance. Very large diameter pruning cuts will be made to accomplish the work, ranging from a few inches diameter each, up to 17 or more inches diameter each3, on some stems that extend northward into the proposed project airspace area. Pruning cuts of this relatively large diameter will allow for fungal wood decay-causing pathogen entrance into the stems via these open cut wounds, resulting in extensive decay column formation over time that progresses down into the stems from the cut wounds. 3 David Babby’s arborist report notes that a 14” and a 17” diameter stem will require pruning. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 317  Packet Pg. 395 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 5 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture • Heritage Tree Designation in City of Palo Alto There are currently +/- eight (8) trees listed on the City heritage tree list maintained by the City. Per the following information, trees are apparently not required to meet any specific “approval criteria” in terms of species, size, condition, or other relevant parameters, to be selected as formal heritage tree specimens in City of Palo Alto, other than that the trees are native oak species or redwoods located on private property: (Excerpt from a City Staff Report Online): “In 1996, Council enacted the Tree Preservation Ordinance, Chapter 8.10 of the Palo Alto Municipal Code, to preserve and maintain specified native oaks, redwoods, and heritage trees on private property, and to protect them from disfigurement or removal, except in certain circumstances. Section 8.10.090 of the ordinance allows persons to nominate a tree on their property forheritage tree status. After Council approval of such designation, the tree is added to the heritage tree listing, which includes specific location, overall size, and canopy spread. The list is maintained by the Department of Public Works and available to the public on the City’s Urban Forestry website. Once designated, a heritage tree is protected by the provisions of the Tree Preservation and Management Regulations, unless removed from the heritage tree list by subsequent Council action at the request of the property owner.” Per the above information, protected size tree #10 (City tree tag #1572) appears to be an excellent candidate for inclusion in the City’s heritage tree designation program which protects native oaks on private properties. It is a specimen in good overall condition, with exceptional size in terms of both mainstem diameter (est. 50 inches), and canopy spread (90 feet total diameter), with good vigor, good buttress root flares, and good saddle-shaped wide angle forks of mainstem attachment. • David Babby Report 11/19/2021 Page 6 Per page 6 of the developer’s arborist report by David Babby, tree #10 exhibits a “high” rating in terms of suitability for preservation (see below excerpt from page 6 of Babby report): Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 318  Packet Pg. 396 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 6 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Conclusion If the proposed 660 University site plan project were built out as currently proposed per the 10/31/2023 planning resubmittal #5 versions of the plan sheets, WLCA expects that tree #10 would experience relatively moderate to severe root loss, and relatively severe pruning, which combined as a cumulative below-ground and above-ground negative impact would necessarily result in loss of vigor (health) and structure to a severe degree. The tree’s safe and useful life expectancy in its current condition rating of “good” (+/- 62% overall condition rating) may be reduced as a result of site plan project work from (EXISTING: no-construction scenario) 50 to 100 years remaining, to (PROPOSED: post-construction scenario) 10 to 20 years remaining, or less, depending on the tree’s response to very significant project clearance canopy and root pruning as described above in this letter report. It is WLCA’s professional opinion that the tree’s vigor would be negatively impacted to a severe degree as a direct result of proposed site work as currently described on the 10/31/2023 set of plan sheets, resulting in tree #10 falling into a spiral of condition decline from which it cannot recover. There would also necessarily be a corresponding elevation of the TRAQ risk rating in terms of risk of whole tree and/or tree part failure and impact with various static and moving targets with moderate to high occupancy ratings within the target zone and a reasonable time frame such as 12 to 24 months, starting as of the proposed site construction completion date (this would need to be assessed at a future time, and is outside the scope of WLCA’s initial pre-project assignment). The tree is located in the an area known to have high water table elevations and gravelly (gravel-laden) riparian type alluvium soil that tends to support excellent native oak tree root growth in terms of both rooting depth and root lateral extension. It is highly recommended that this exceptionally large native oak specimen in good overall condition be designated by the City Council as a City of Palo Alto Heritage Tree on private land, and formally added to the list maintained by the City on their official website, with the added tree protection guarantees that this tree special protection status includes (tree specimens are typically nominated for such designation by the owner of the property on which the tree stands). Refer also to David Babby’s arborist report dated 11/19/202, page 6, which notes that tree #10 is rated as “high” suitability for preservation, appearing healthy and structurally stable per his assessment, presenting “good potential for contributing long-term to the site”. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 319  Packet Pg. 397 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 7 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Digital Images by WLCA 12/13/2023 / Tree #10 Coast live oak (Quercus agrifolia) View looking eastward while standing on 517 Byron. Note the excellent buttress root flaring at the root crown of tree #10 which is considered normal and desirable. View of the relatively wide angle fork attachments between 10 and 15 feet elevation above grade at which the tree #10 codominant mainstems arise. These saddle shaped forms are normal and desirable from a structural stability standpoint. Although it is not “optimal” to have codominant mainstems forking in a tree, the best case scenario would be for all of the forks to exhibit wide saddle-shaped attachments like this tree. It is actually extremely unusual for a coast live oak to exhibit saddle-shaped forks at every Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 320  Packet Pg. 398 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 8 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of subject oak #10 looking northward from 517 Byron. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 321  Packet Pg. 399 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 9 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture View of oak #10 lower 50% of canopy/mainstem architecture, with the adjoining asphalt parking lot area west of 517 Byron visible at left half of the image. The root system is assumed to be extended through most or all adjoining lots surrounding 517 Byron (not verified), as is assumed to reach as much as 2x to 3x the 45 foot canopy radius (again, not verified, but very possible, per WLCA’s past experience with older oaks in Palo Alto and Menlo Park area, especially if Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 322  Packet Pg. 400 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 10 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Per WLCA’s multi-layer mockup created for a valley oak location comparison with groundwater depths and soil types, the tree #10 location has a 25 foot depth groundwater table, and nearby Palo Alto study-noted red dots which indicate very large older valley oak specimens surveyed in the past and included on internet maps for reference. The Qoa soil type at the 660 University site is defined as “older alluvium” (hence the “oa” designation): a Pleistocene soil of gravels, sand, and silt that is unconsolidated to consolidated, interspersed with alluvial materials from stream action. See next page of this report for the United States Geological Survey legend pertaining to this soil unit, clipped from the Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 323  Packet Pg. 401 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 11 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture Above was excerpted from the USGS Quadrangle (soil unit map) which includes the City of Palo Alto area. Assumptions and Limiting Conditions Any legal description provided to the consultant/appraiser is assumed to be correct. Any titles and ownership to any property are assumed to be good and marketable. No responsibility is assumed for matters legal in character. Any and all property is appraised and evaluated as through free and clean, under responsible ownership and competent management. It is assumed that any property is not in violation of any applicable codes, ordinance, statutes, or other government regulations. Care has been taken to obtain all information from reliable sources. All data has been verified insofar as possible; however, the consultant/appraiser can neither guarantee nor be responsible for the accuracy of information provided by others. The consultant/appraiser shall not be required to give testimony or to attend court by reason of this report unless subsequent contractual arrangements are made, including payment of an additional fee for such services as described in the fee schedule and contract of engagement. Unless required by law otherwise, the possession of this report or a copy thereof does not imply right of publication or use for any other purpose by any other than the person to whom it is addressed, without the prior expressed written or verbal consent of the consultant/appraiser. Unless required by law otherwise, neither all nor any part of the contents of this report, nor copy thereof, shall be conveyed by anyone, including the client, to the public through advertising, public relations, news, sales, or other media, without the prior expressed conclusions, identity of the consultant/appraiser, or any reference to any professional society or institute or to any initiated designation conferred upon the consultant/appraiser as stated in his qualifications. This report and any values expressed herein represent the opinion of the consultant/appraiser, and the consultant’s/appraiser’s fee is in no way contingent upon the reporting of a specified value, a stipulated result, the occurrence of a subsequent event, nor upon any finding to be reported. Sketches, drawings, and photographs in this report, being intended for visual aids, are not necessarily to scale and should not be construed as engineering or architectural reports or surveys unless expressed otherwise. The reproduction of any information generated by engineers, architects, or other consultants on any sketches, drawings, or photographs is for the express purpose of coordination and ease of reference only. Inclusion of said information on any Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 324  Packet Pg. 402 of 517  ISA Tree Risk Assessment Qualified Cell (415) 203-0990 ISA Certified Arborist #WE-3172A Email walterslevisonjr@yahoo.com 12 of 12 Site Address: 660 University, Palo Alto, CA Iteration: 12/18/2023 Walter Levison  2023 All Rights Reserved Registered Member, American Society of Consulting Arborists and Life Member of the International Society of Arboriculture drawings or other documents does not constitute a representation by Walter Levison to the sufficiency or accuracy of said information. Unless expressed otherwise: • information contained in this report covers only those items that were examined and reflects the conditions of those items at the time of inspection; and • the inspection is limited to ground-based visual examination of accessible items without climbing, dissection, excavation, probing, or coring. • There is no warranty or guarantee, expressed or implied, that problems or deficiencies of the plants or property in question may not arise in the future. Loss or alteration of any part of this report invalidates the entire report. Arborist Disclosure Statement: Arborists are tree specialists who use their education, knowledge, training, and experience to examine trees, recommend measures to enhance the beauty and health of trees, and attempt to reduce the risk of living near trees. Clients may choose to accept or disregard the recommendations of the arborist, or to seek additional advice. Arborists cannot detect every condition that could possibly lead to the structural failure of a tree. Tree are living organisms that fail in ways we do not fully understand. Conditions are often hidden within trees and below ground. Arborist cannot guarantee that a tree will be healthy or safe under all circumstances, or for a specified period of time. Likewise, remedial treatments, like any medicine, cannot be guaranteed. Treatment, pruning, and removal of trees may involve considerations beyond the scope of the arborist’s services such as property boundaries, property ownership, site lines, disputes between neighbors, and other issues. Arborists cannot take such considerations into account unless complete and accurate information is disclosed to the arborist. An arborist should then be expected to reasonably rely upon the completeness and accuracy of the information provided. Trees can be managed, but they cannot be controlled. To live near trees is to accept some degree of risk. The only way to eliminate all risk associated with trees is to eliminate the trees. Certification I hereby certify that all the statements of fact in this report are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. Signature of Consultant DIGITAL BADGES: ISA CERTIFIED ARBORIST CREDENTIAL: https://certificates.isa-arbor.com/f1918723-df46-48cc-ace2-c12625530fec#gs.v54om6 (Renewed through June, 2026) ISA TREE RISK ASSESSMENT QUALIFIED (TRAQ): https://certificates.isa-arbor.com/d180515f-ab75-440b-9c66-106005e3cf10?record_view=true#gs.hpb30w (Renewed through March, 2028) Attached: Tree Map Markups by WLCA 12/18/2023 (View Using Adobe or Adobe CS in Order to Allow for Full Visibility of the Markups Created Using Adobe Pro Software). Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 325  Packet Pg. 403 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 326  Packet Pg. 404 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 327  Packet Pg. 405 of 517  660 University Project Ream Comments re Protection of the Coast Live Oak Tree April 16, 2024 A"achment B Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 328  Packet Pg. 406 of 517  Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 329  Packet Pg. 407 of 517  Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 330  Packet Pg. 408 of 517  May 8, 2022 660 University Avenue Palo Alto, California. Scan #7 Line scan over parking lot 31 feet away from Oak tree #1572 Asphalt Thickness Root Depth in inches Excavation point for below-ground garage. This involves this whole cross section. All roots will be removed; beginning with the following scans 7-12 May 23, 2023 Root Study Oak Tree #1572 660 University Avenue Palo Alto, California Robert Booty Registered Consulting Arborist 487 ISA Qualified Tree Risk Assessor Copyright 2022 Arborist OnSite Horticultural Consulting, Inc. www.arboristonsite.com 34 Item 6Attachment H - PublicComments       Item 6: Staff Report Pg. 331  Packet Pg. 409 of 517  From:Christopher Ream To:Kallas, Emily Subject:660 University, ARB Hearing Date:Wednesday, April 17, 2024 12:27:59 AM Attachments:660 - Ream Letter re Tree - 20240416 w Attachments.pdf CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Emily, Please find attached my letter which I wish the Architectural Review Board will have a chance to review before the Hearing Thursday morning. Please share it with each Member and with anyone else for whom you think would be appropriate. Please point out to them that Walter Levison’s Impact Analysis is attached. Thank you. Chris _________________________ Christopher Ream 555 Byron Street, #409 Palo Alto, CA 94301 1-650-424-0821 ream@reamlaw.com Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 332  Packet Pg. 410 of 517  Some people who received this message don't often get email from faithwb3@yahoo.com. Learn why this is important From:Kallas, Emily To:Kallas, Emily Subject:FW: New Construction at 511 Byron Street, and more, Palo Alto Date:Tuesday, May 21, 2024 4:22:00 PM From: Faith Brigel <faithwb3@yahoo.com> Sent: Thursday, April 18, 2024 5:21 PM To: Council, City <city.council@cityofpaloalto.org>; Lythcott-Haims, Julie <Julie.LythcottHaims@CityofPaloAlto.org>; Veenker, Vicki <Vicki.Veenker@CityofPaloAlto.org>; Lauing, Ed <Ed.Lauing@CityofPaloAlto.org>; Kou, Lydia <Lydia.Kou@CityofPaloAlto.org>; Tanaka, Greg <Greg.Tanaka@CityofPaloAlto.org> Cc: Faith Brigel <faithwb3@yahoo.com>; greg.stone@cityofpaloalto.org; Burt, Patrick <Pat.Burt@CityofPaloAlto.org> Subject: New Construction at 511 Byron Street, and more, Palo Alto CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City Council of City of Palo Alto, This morning I attended an Architectural Review Board meeting to discuss the new construction that is being proposed for 511 Byron Street, 660 University Ave., 680 University Ave., and 500 Middlefield Road. Once all of these buildings will be demolished they will construct an immense four story, mixed usage of many offices and many residential rentals, and a two story basement for parking, though the parking spaces will be much reduced from what is needed. And I assume a lot of water will need to be drained since our water level is shallow. Their presentation talked about several of the other buildings in that area that are large, though not as large as this one: the Hamilton project, Lytton Gardens, The Webster House and there is the 3 story 2 condo on Webster and University Ave. There are already several large buildings in this area. And I think none of them have a two story basement. That intersection is already very congested. And there is rarely any parking on Byron Street. One person opposed to this project this morning stated that constructing this building into that area is like squeezing it into a lot that is much too small. I have owned the single, story Victorian that is more than 100 years old, for almost 40 years. My building was not mentioned this morning. And I will lose some of my daylight plan, which was also not mentioned. Byron Street and University Ave. in Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 333  Packet Pg. 411 of 517  that area has always been a quiet, professional area for the past 40 years. My building has a psychiatrist, and a psychologist. They work in my building because it is quiet. Adding many residential apartments with balconies to those structures will totally change the nature of this area. And I more than likely will lose at least some of my tenants, if not all of them. I understand that the State is requiring more housing. But a very large building with offices and apartments right downtown on University Ave. beside Middlefield is not a good spot for it. There should be some consideration for people like myself who have been in that area for many years- not just the developers who are not concerned that they are overbuilding the downtown area. I ask and hope that you who represent all of us on the City Council and will take into consideration all of us not just the developers. Thank you for your consideration, Faith W. Brigel Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 334  Packet Pg. 412 of 517  From:Mathews, Marley@DOT To:Kallas, Emily Cc:Luo, Yunsheng@DOT Subject:660 University Avenue Mixed-Use Project Caltrans Comment Date:Wednesday, May 8, 2024 1:06:33 PM You don't often get email from marley.mathews@dot.ca.gov. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Hello Emily, Thank you for including Caltrans in this review of the 660 University Avenue Mixed-Use Project DIER. At this time, Caltrans has no comments on the material provided. Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only. Please continue to include Caltrans in discussions regarding this Project to stay informed. We encourage multi-agency collaboration and welcome any potential opportunities. Any future material or correspondence regarding this Project can be submitted to LDR-D4@dot.ca.gov. Thank you, Marley Mathews Transportation Planner (she/her) D4 Caltrans 510-960-0841 Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 335  Packet Pg. 413 of 517  From:Gennifer Wehrmeyer To:Kallas, Emily Cc:CPRU-Dropbox; Shree Dharasker Subject:VW File 34811 – Comments on DEIR for 660 University Avenue Mixed-Use Project Date:Friday, May 17, 2024 4:14:49 PM Attachments:image001.png You don't often get email from gwehrmeyer@valleywater.org. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear Emily, The Santa Clara Valley Water District (Valley Water) has reviewed Notice of Availability of aDraft Environmental Impact Report (DEIR) for the 660 University Avenue Mixed-Use Project to merge three parcels to construct a four-story mixed-use building at 511 BryonStreet, 660 University Ave, and 680 University Ave/500 Middlefield Rd in Palo Alto, received on April 2, 2024, and has the following comments: 1. Valley Water does not have any right of way or facilities within the project siteboundary; therefore, in accordance with Valley Water’s Water ResourcesProtection Ordinance, a Valley Water encroachment permit will not be requiredfor the project. 2. Valley Water previously commented on the Notice of Preparation (NOP) thatunderground structures should be designed for waterproofing that avoids theneed for permanent dewatering after construction is complete. As stated inSection 10-a, construction will involve excavation up to 38 feet below groundsurface, during which time dewatering will be used. It is unclear if dewatering willoccur after construction. Underground structures should be designed forwaterproofing and permanent dewatering should be avoided once constructionis finished. 3. Valley Water records indicate that no active wells are located on the subjectproperty. While Valley Water has records for most wells located in the County, itis always possible that a well exists that is not in the Valley Water’s records. Ifpreviously unknown wells are found on the subject property during development,they must be properly destroyed under permit from Valley Water or registeredwith Valley Water and protected from damage. For more information, please callthe Valley Water’s Well Ordinance Program Hotline at 408-630-2660. 4. According to the Federal Emergency Management Agency’s (FEMA) FloodInsurance Rate Map (FIRM) 006085C0010H, effective May 18, 2009, the projectsite is within FEMA Flood Zone AH, an area with 1% annual chance of shallowflooding (usually areas of ponding), located between base flood elevations of 46feet and 47 feet. The project is required to follow the flood plain ordinance andnational flood insurance requirements. If you have any questions or need further information, you can reach me at gwehrmeyer@valleywater.org or at (408) 694-2069. Please reference Valley Water File 34811 on further correspondence regarding this project. Thank you, Gennifer Wehrmeyer ASSISTANT ENGINEER, CIVIL Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 336  Packet Pg. 414 of 517  Community Projects Review Unit Watershed Stewardship and Planning Division GWehrmeyer@valleywater.org Tel. (408) 630-2588 Cell. (408) 694-2069 SANTA CLARA VALLEY WATER DISTRICT 5750 Almaden Expressway, San Jose CA 95118 www.valleywater.org Clean Water . Healthy Environment . Flood Protection Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 337  Packet Pg. 415 of 517  You don't often get email from kathleenrotow@gmail.com. Learn why this is important From:Foley, EmilyTo:Klicheva, Madina Subject:FW: 660 University Ave Date:Wednesday, November 16, 2022 8:56:46 AMAttachments:image001.pngimage002.pngimage004.pngimage005.pngimage006.pngimage007.pngimage008.png Emily Foley, AICP Planner Planning and Development Services Department (650) 617-3125 | emily.foley@cityofpaloalto.org www.cityofpaloalto.org NEW Parcel Report | Palo Alto Municipal Code | Online Permitting System | Planning Forms & Handouts | Planning Applications Mapped The City of Palo Alto is doing its part to reduce the spread of COVID-19. We have successfully transitioned most of our employees to a remote workenvironment. We remain available to you via email, phone, and virtual meetings during our normal business hours. From: Kathleen Rotow <kathleenrotow@gmail.com> Sent: Tuesday, November 8, 2022 1:43 PM To: Foley, Emily <Emily.Foley@CityofPaloAlto.org> Subject: 660 University Ave CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. I am the owner of 789 University Ave and have feedback regarding The Notice of Preparation for the 660 University proposed project. I have several concerns about this project. I am opposed to rezoning from Low Density Multiple Family Residence (RM-20) to high density Planned Community (PC). It is inappropriate in the proposed location given the foreseeable increase in traffic, noise and pollution. All of the aforementioned will negatively affect public safety and quality of life for nearby residents. As we are all aware, this expansive project is directly across the street from an elderly senior living facility that necessarily includes a population that cannot respond to the public safety, pollution, traffic and noise issues in the same manner as other populations. On the other side of the proposed project, there is another senior living development. Additionally, many residential homes are located in close proximity and the increased traffic, pollution and noise would be prohibitive for the residential nature of the area. This project is clearly adjacent to low density residential and senior living facilities. It would dramatically change the character of the area and should not be approved. It is my understanding that this development is trying to squeeze approximately 65 dwellings onto an area zoned for up to 20 dwellings per acre. In addition, it includes office space that is comparable to the total square footage on the site as it stands currently. You would be allowing an increase from the current 9,216 square feet to 42,189 square feet. This increase does not adhere to the current zoning parameters or to the nature of the area. This project should not be approved. As the city is aware, the Middlefield/University intersection is already heavily congested with traffic and the noise currently generated is unacceptable. This large scale project will exacerbate an already busy and dangerous intersection and increase the noise level for area residents, including many seniors. Maybe the city should consider asking the developers to move the project next to one of their homes. I'm sure they would like the increase in traffic, noise and pollution not to mention the public safety issues it will generate. This project should be implemented elsewhere. This is the wrong project, in the wrong place and the wrong size. Respectfully, Kathleen Rotow P.S. The link provided for The Notice of Preparation is inaccurate. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 338  Packet Pg. 416 of 517  From:Foley, EmilyTo:Klicheva, Madina Subject:FW: 660 University Project comments Date:Wednesday, November 16, 2022 8:56:39 AMAttachments:image001.pngimage002.pngimage004.pngimage005.pngimage006.pngimage007.pngimage008.png Emily Foley, AICP Planner Planning and Development Services Department (650) 617-3125 | emily.foley@cityofpaloalto.org www.cityofpaloalto.org NEW Parcel Report | Palo Alto Municipal Code | Online Permitting System | Planning Forms & Handouts | Planning Applications Mapped The City of Palo Alto is doing its part to reduce the spread of COVID-19. We have successfully transitioned most of our employees to a remote workenvironment. We remain available to you via email, phone, and virtual meetings during our normal business hours. From: Alan Brauer, M.D. <drbrauer@totalcare.org> Sent: Saturday, November 5, 2022 6:52 PM To: Foley, Emily <Emily.Foley@CityofPaloAlto.org> Subject: 660 University Project comments CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links. Hi Emily, As we are located directly across the street from the proposed 660 University project, we are concerned about 2 main issues:: 1. What are the noise mitigation measures that will be required? Our building is occupied primarily by mental health professional who engage in psychotherapy. This requires a quiet environment and we are concerned about intrusions into the ability of our professionals to conduct therapy sessions. 2. What measures will be required to permit unrestricted access to our driveway on Byron? 3. Additionally, should this project receive final approval, can you provide any time frame for the possible start of any demolition? Thanks for your attention to this important matter. Alan & Donna Brauer Owners, 630 University Ave., Palo Alto Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 339  Packet Pg. 417 of 517  From:Janet L. Billups To:Planning Commission Cc:Foley, Emily; Lait, Jonathan; Stump, Molly; Christopher Ream; Leigh F. Prince Subject:Opposition to Project Proposed at 660 University Avenue Date:Tuesday, November 15, 2022 11:38:07 AM Attachments:Letter to PTC re 660 University 11.15.22.pdf Some people who received this message don't often get email from jlb@jsmf.com. Learn why this is important CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links. Dear City of Palo Alto Planning Commission, The attached letter, submitted by Leigh Prince, on behalf of the Homeowner’s Association for The Hamilton, a continuing care retirement community for seniors located at 555 Byron Street, expresses opposition to the project proposed at 660 University Avenue. The Hamilton encourages the Planning Commission to consider several of the alternatives outlined in the letter. Kind regards, Janet Billups, Legal Assistant to Leigh F. Prince, Esq. Jorgenson, Siegel, McClure & Flegel LLP 1100 Alma Street, Ste. 210 Menlo Park, CA 94025 Ph. 650-324-9300 jlb@jsmf.com CONFIDENTIALITY NOTICE: This e-mail and any attachments are for the sole use of the intended recipients and contain information that may be confidential or legally privileged. If you have received this e-mail in error, please notify the sender by reply e-mail and delete the message. Any disclosure, copying, distribution, or use of this communication by someone other than the intended recipient is prohibited. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 340  Packet Pg. 418 of 517  WILLIAM L. McCLURE JOHN L. FLEGEL DAN K. SIEGEL JENNIFER H. FRIEDMAN MINDIE S. ROMANOWSKY LEIGH F. PRINCE DAVID L. ACH GREGORY K. KLINGSPORN NICOLAS A. FLEGEL KRISTINA A. FENTON CARA E. SILVER KIMBERLY J. BRUMMER CAMAS J. STEINMETZ PHILIP S. SOUSA ____________ BRITTNEY L. STANDLEY CHRISTIAN D. PETRANGELO JOSEPH H. FELDMAN JORGENSON, SI EGEL, McCLURE & F LEGEL, LLP ATTORNEYS AT LAW 1100 ALMA STREET, SUITE 210 MENLO PARK, CALIFORNIA 94025-3392 (650) 3 24-9300 FACSI MILE (650) 324-0227 www.jsmf.com November 15, 2022 OF COUNSEL KENT MITCHELL ____________ RETIRED JOHN D. JORGENSON MARGARET A. SLOAN DIANE S. GREENBERG ____________ DECEASED MARVIN S. SIEGEL (1936 - 2012) JOHN R.COSGROVE (1932 - 2017) Sent Via Email: Planning.Commission@CityofPaloAlto.org Planning and Transportation Commission City of Palo Alto Palo Alto City Hall 250 Hamilton Avenue Palo Alto, CA 94301 Re: Opposition to Project Proposed at 660 University Avenue Dear Honorable Members of the Planning and Transportation Commission, This letter is written on behalf of the Homeowner’s Association for The Hamilton, a continuing care retirement community for seniors with 36 units located at 555 Byron Street. The Hamilton is adjacent to the proposed mixed-use project which would consist of 65 residential units and 9,115 square feet of office (“Project”) at 660 University Avenue (“Property”). The residents of The Hamilton, whose average age is in the mid-80s, will be significantly impacted by the proposed Project. In addition, the Project will impact a number of other senior communities in this “Senior Corner” of Palo Alto, including Lytton Gardens and Webster House (and Channing House). Rather than proposing something compatible with the “Senior Corner,” the Project proposes a density and intensity far in excess of any surrounding development and in excess of what is allowed by the current residential zoning or the City’s Comprehensive Plan. This letter will highlight concerns with the merits of the Project as well as environmental impacts, and should be considered a comment letter on the Notice of Preparation. The Hamilton is concerned about impacts to transportation, air quality, noise, parking, pedestrian safety, land use/planning and the loss of a significant tree presented by Project with its unprecedented density and intensity. The Hamilton requests that the Planning and Transportation Commission (“PTC”) recommend that the Project be reduced to be more consistent with the existing residential zoning and compatible with the surrounding senior communities. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 341  Packet Pg. 419 of 517  Planning and Transportation Commission Re: Opposition to Project Proposed at 660 University Avenue November 15, 2022 Page 2 Density Significantly Exceeds that Allowed by the Zoning or the Comprehensive Plan. The Project proposes 65 units (47 studios, 12 one-bedroom and 6 two-bedroom units). Although this is a reduction of five units from the preliminary proposal reviewed by the City Council during the Planned Home Zoning (“PHZ”) pre-screening, this is still significantly above the density allowed by the Property’s RM-20 multifamily zoning. The maximum number of units allowed by the zoning would be 10 units. Thus, the Project is proposing six and a half times the maximum allowable zoning density. Furthermore, the Project also far exceeds the allowable residential density identified in the City’s Comprehensive Plan. The Comprehensive Plan would allow a density of 40 units per acre. On this approximately half-acre site, the maximum Comprehensive Plan density would be 20 units. Thus, the Project is proposing 45 units more (or more than three times the density) anticipated by the highest density identified for the Property in the City’s Comprehensive Plan. With 65 units on approximately one-half acre, the Project density is approximately 126 units per acre for this multifamily residential area. The highest density identified in the Housing Element for any property is 81.25 units per acre for general manufacturing and research, office and limited manufacturing zones. Thus, the proposed Project density is one and one-half times the highest density identified anywhere in the City in the draft Housing Element. This is also far in excess of other planned communities in this area. The Hamilton is located on approximately 1.18 acres and has 36 units for a density of is 33 units per acre. Thus, the proposed Project is well over three times more dense than the neighboring development. Because by any measure this Project is proposed at an unreasonably high density, The Hamilton encourages the PTC to recommend the Project’s density be significantly reduced. Inadequate Public Benefit Provided in Exchange for Increased Density. The Project does not provide a substantial public benefit adequate to justify the significant increase in density. The Project proposes to provide 20 percent affordable housing units (four very-low, four low and five moderate income units) consistent with the City Council direction on the minimum affordability necessary to support a rezoning to PHZ. However, given the significant increase in density, this is a woefully inadequate public benefit. To put it into perspective, a project that proposes 20 percent low-income units would be entitled to a 35 percent density bonus under state density bonus law (Government Code Section 65915). With a maximum Comprehensive Plan density of 20 units, a 35 percent density bonus would result in a 27-unit project.1 In fact, the highest density bonus a project can receive using state density bonus law is 50 percent, which would allow a 30-unit project. Thus, although the PHZ does not require strict adherence to state law, it is important to note that if approved the City would be allowing a far greater density increase than mandated by state law in exchange for far less affordable housing. 1 Strict compliance with the state density bonus law would result in a density bonus of less than 35 percent. State law generally requires one income category be selected to determine the density bonus; however, many jurisdictions as a policy matter will count units at lower affordability toward the higher category. With four very-low income units, the density bonus percentage would be 20 percent which would be a total project of 24 units. Four low income units would not quality the Project for a density bonus. If the four very-low income were counted toward the low income category, with eight low income units, the Project would quality for a 23 percent density bonus. This would allow a 25-unit project. With five moderate income units, the Project would not qualify for a density bonus. If the four very-low and four low income units were counted toward the moderate income category, the Project would qualify for a 15 percent density bonus. This would allow a 23-unit project. Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 342  Packet Pg. 420 of 517  Planning and Transportation Commission Re: Opposition to Project Proposed at 660 University Avenue November 15, 2022 Page 3 Giving away this increased density also does not provide the City significant progress toward meeting its Regional Housing Need Allocation (“RHNA”) for the current Housing Element cycle. The City needs to plan for 1,556 very-low income units, 896 low income units and 1,013 moderate income units. For more than triple the allowable density, the City obtains only four very-low income units (0.2% of the need), four low income units (0.4% of the need) and five moderate units (0.4% of the need). Understanding that the City needs to plan to develop housing to meet its RHNA goals, the City should not “throw the baby out with the bath water.” Increased housing density should be approved within reasonable limits and certainly not so far in excess of that allowed by the zoning or the Comprehensive Plan, even with state law mandates layered on top. Approving this Project as proposed would unfairly put the burden on the seniors living at The Hamilton to allow the City as a whole to make negligible progress toward its RHNA goals. Therefore, The Hamilton encourages the PTC to recommend the density of this Project be substantially reduced. Office Use Adds Intensity Without Benefit. Not only does the Project far exceed the residential density, it also includes office. The Project proposes 9,115 square feet of general office. Office is not a permitted or conditional use in the RM-20 multifamily residential zoning district. Office uses are inconsistent with the City’s Comprehensive Plan for this residential area. Further, general office is a departure from the existing non-conforming medical office. While medical office might serve the “Senior Corner,” general office does not. Instead, general office uses would add intensity and traffic congestion and create additional housing need without benefiting the surrounding community. Thus, The Hamilton urges the PTC to recommend removal of the office use from this Project. In addition, the City should prepare a housing needs assessment (“HNA”), including consideration of the multiplier effect, as part of the environmental impact report. A HNA would help the City to understand how many employees will occupy the office space and the housing demand that will be generated by those workers. This is especially important in an era where office space per worker is declining, and the number of employees may be higher than anticipated (the average tech worker uses less than 250 square feet of office space). Finally, the office vacancy rate in Palo Alto is currently at approximately 14 percent indicating there is no need for the development of office in this location where it is neither permitted, nor beneficial.2 Thus, The Hamilton urges the PTC to recommend office be removed from this Project. Transportation Impacts Potentially Significant. The environmental impact report and the City in its deliberation regarding the merits of this Project should carefully consider the impact of the additional trips generated by the residential units and office use. The multifamily residential zoning anticipated 20 units per acre and no office. The Comprehensive Plan anticipated a maximum of 40 units per acre and no office. The intensity of this Project with approximately 126 units per acre and office will far exceed the transportation impacts presented in any environmental review for existing planning documents. The transportation impact analysis and environmental impact report should not focus only on the impact during peak commute hours, but should consider the impact throughout the day. Such an analysis is important in this “Senior Corner” because many residents are home throughout the 2 https://www.nmrk.com/storage-nmrk/uploads/fields/pdf-market-reports/1Q22-SPeninsula-Office-Market_2022-05-31-174425_nzty.pdf Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 343  Packet Pg. 421 of 517  Planning and Transportation Commission Re: Opposition to Project Proposed at 660 University Avenue November 15, 2022 Page 4 day. The Hamilton is concerned that the additional traffic generated by the Project will impact their ability not only to drive, but also to walk safely in the neighborhood. One related issue that should be studied in the transportation impact analysis and environmental impact report is the design of the Project’s entry/exit for the garage onto Middlefield Road. The garage entry/exit is close to the traffic light at University Avenue and may cause significant queuing, which will likely lead to traffic jams on Middlefield Road. This congestion will lead people to try to bypass the traffic by cutting down Byron Street. Byron Street is narrow, and the fully utilized parking on either side makes it impossible for two moving cars to pass each other safely. Thus, cut through traffic down Byron Street should be analyzed. This is in addition to analyzing the impacts to University Avenue and Middlefield Road that are main arteries in Palo Alto. Finally, the transportation impact analysis and environmental impact report should carefully consider the impacts on parking. The Project is proposing 82 spaces, which is 28 spaces less than the 110 spaces required. One of the two levels of parking proposes stackers, which can be difficult to operate and maintain. With inadequate and complicated parking, it is reasonable to conclude that many residents, workers and visitors will park off the Property. Consideration of the Project should include parking impacts such as additional miles travelled in search of parking and parking intrusion into surrounding areas. Air Quality Impacts Should Be Carefully Analyzed. Closely related to the transportation impacts, are the potential air quality impacts. As noted, this is an area referred to as “Senior Corner.” Seniors are sensitive receptors who are at a heightened risk of negative health outcomes due to exposure to air pollution. The environmental impact report should include a health risk assessment and mitigate the Project to avoid negative health impacts to this sensitive community. Tree Preservation is of Substantial Importance. There is a beautiful Coastal Live Oak tree with a trunk diameter of 50 inches growing just over the property line. The canopy stretches approximately 45 feet over the Project site. It provides beauty and shade for the entire block and likely habitat for biological resources such as nesting birds. Careful consideration needs to be given to ensuring that this tree is adequately protected and survives and is in good health after the redevelopment of the Property to minimize the impact of the Project on aesthetics and biological resources. A professional arborist should consider not only the roots, but to how much of the canopy may need to be cut to allow the Project and how this can be limited to avoid impacting the environment. Other Considerations Impacting Aesthetics, Land Use and Planning. The setbacks on all streets and sidewalks proposed by the Project are greatly reduced from required setbacks. The required setback along Middlefield is a minimum of 24 feet. The required setback along University Avenue and Byron Street are both 16 feet. The Project would reduce each of these setbacks down to only 10 feet. These setbacks impact the pedestrian experience and may impact safety. These potential impacts should be considered. The residential portion of the building is 50 feet tall and it is higher for mechanical and elevator equipment. This exceeds the height allowed in the multifamily zoning district. Plans for the Project reveal that a majority of the rooftop will be opened up as a social gathering common area with multiple barbeques, lounges, tables and chairs, including a TV mounted on one of the walls. The Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 344  Packet Pg. 422 of 517  Planning and Transportation Commission Re: Opposition to Project Proposed at 660 University Avenue November 15, 2022 Page 5 aesthetic impacts of the height of the building, any noise impacts from rooftop activities or mechanical equipment should be considered. Alternatives to Consider. The Hamilton encourages the environmental impact report to consider a number of alternatives to the proposed Project. One alternative that could considered is a project that complies with the current zoning and Comprehensive Plan, including density, uses, setbacks, height, etc. This alternative could include additional density based on state density bonus law. Even with the additional density allowed by state law, such a project would likely be more responsible to its context and compatible with adjacent development. Another alternative would be a senior project with low income senior housing. Not only is there a need for senior housing and low income senior housing in Palo Alto, such a project may also have reduced impacts (e.g. seniors drive less). The Hamilton urges the PTC to consider either of these alternatives as preferable to the proposed Project. The Hamilton thanks you for your time and attention to this matter and strongly encourages the PTC not to support moving this Project forward as proposed. The Project should be consistent with or a modest modification to the existing multifamily residential standards, should not include office and should consider providing senior housing. Sincerely, Leigh Prince Leigh F. Prince Cc: Emily Foley, Planner (Emily.Foley@CityofPaloAlto.org) Jonathan Lait, Planning Director (Jonathan.Lait@CityofPaloAlto.org) Molly Stump, City Attorney (Molly.Stump@cityofpaloalto.org) Christopher Ream, President, The Hamilton HOA (ream@reamlaw.com) Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 345  Packet Pg. 423 of 517  From:Aram James To:Binder, Andrew; Tony Dixon; KEVIN JENSEN; Jeff Rosen; Sean Allen; Filseth, Eric (Internal);mike.wasserman@bos.sccgov.org; Foley, Michael; Afanasiev, Alex; Lee, Craig; Council, City; PlanningCommission; GRP-City Council; Bains, Paul; Winter Dellenbach; Shikada, Ed; Gennady Sheyner; Jay Boyarsky;Joe Simitian; Supervisor Otto Lee; Supervisor Susan Ellenberg Subject:minor-traffic-stops-plummet-in-months-after-lapd-policy-change? Date:Monday, November 14, 2022 11:31:11 AM CAUTION: This email originated from outside of the organization. Be cautiousof opening attachments and clicking on links.But why is PAPD Chief Andrew Binder unwilling to stop racially loaded pretextstops? and adopt a program similar to the LAPD ? See Binder’s answer onpretext stops- to Weekly reporter Gennady Sheyner in his Battling Bias inPolicing piece dated Nov 4, 2022 ( see below the latines piece below) https://www.latimes.com/california/story/2022-11-14/minor-traffic-stops-plummet-in-months-after-lapd-policy-change?_amp=true https://www.paloaltoonline.com/news/2022/11/04/battling-bias-in-law-enforcement-what-data-reveals-about-the-palo-alto-police?utm_source=express-2022-11-04&utm_medium=email&utm_campaign=express Item 6 Attachment H - Public Comments        Item 6: Staff Report Pg. 346  Packet Pg. 424 of 517  If you need assistance reviewing the above documents, please contact the Project Planner or call the Planner-on- Duty at 650-617-3117 or email planner@cityofpaloalto.org Attachment D Project Plans In order to reduce paper consumption, a limited number of hard copy project plans are provided to Board members for their review. The same plans are available to the public, at all hours of the day, via the following online resources. Directions to review project plans, TDM plan, and environmental documents, including the Draft and Final EIR online: 1. Go to: bit.ly/PApendingprojects 2. Scroll down to find “660 University” and click the address link 3. On this project-specific webpage you will find a link to the project plans and other important information Direct Link to Project Webpage: https://www.cityofpaloalto.org/News-Articles/Planning-and-Development-Services/660- University-Avenue Item 6 Attachment I - Project Plans and Environmental Review Documents        Item 6: Staff Report Pg. 347  Packet Pg. 425 of 517  City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Transportation Meeting Date: November 10, 2025 Report #:2509-5227 TITLE Approval of the Four-Quadrant Gate System as the preferred Quiet Zone Implementation Measure at the Churchill, Meadow, and Charleston Rail Crossings as Recommended by the Rail Committee; CEQA status - categorically exempt. RECOMMENDATION The Rail Committee and staff recommend approving the Four-Quadrant Gate System as the Quiet Zone implementation Measure at the Churchill Avenue, Meadow Drive, and Charleston Road Rail Crossings for Quiet Zones along the Caltrain Corridor in Palo Alto. EXECUTIVE SUMMARY Implementation of Quiet Zones was identified as a Council Priority for Palo Alto in March 2024. To this end, City staff completed a Quiet Zone Study to evaluate rail crossings at Churchill Avenue, E. Meadow Drive, and Charleston Road in accordance with Federal Railroad Administration (FRA) regulations. Rail Committee then considered initial findings on August 20, 2024 and directed staff to explore two options: Implementing a four-quadrant gate system in order be eligible for a Quiet Zone; and Installation of a wayside horns system. In accordance with state law, diagnostic and follow up meetings were held on these options with representatives from the FRA, California Public Utilities Commission (CPUC), and Caltrain. A public engagement meeting was also held to gather feedback from community members. Community members expressed strong support for implementing Quiet Zones through the installation of Four-Quadrant Gate Systems. The current estimated cost for implementing wayside horns at the three locations is approximately $1.5 million, while the four-quadrant gate system at the three locations is approximately $4.1-5.6 million. The project will likely require funding through a combination of the City’s Capital Improvement Program funds and Measure K Business Tax revenue for either of the proposed alternatives. On September 16, 2025, Rail Committee unanimously recommended the Four Quadrant Gate System for implementation of a Quiet Zone along the Caltrain corridor at the existing at-grade Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 1  Packet Pg. 426 of 517  rail crossings in Palo Alto at Churchill Avenue, E. Meadow Drive, and Charleston Road, and that this be agendized as an action item for the full City Council. This measure is intended as an interim improvement until permanent grade separations are constructed. Accordingly, staff is seeking approval to proceed with the installation of Four-Quadrant Gate Systems as the safety enhancement required to implement Quiet Zones at these crossings. BACKGROUND & ANALYSIS Palo Alto has four at-grade crossing locations with 104 daily Caltrain services in addition to unscheduled Union Pacific freight services. At each of these locations, Federal regulations require that locomotive horns produce sounds from 96 to 110 decibels for at-grade crossings and that trains begin sounding these horns 15–20 seconds before entering public rail grade crossings, and no more than one-quarter mile in advance. These train horns create noise impacts in neighborhoods surrounding railroad crossings in Palo Alto. The extent and severity of noise impacts is affected by a range of factors including horn noise level and character, ambient noise levels, and prevailing winds. In September 2024, the Peninsula Joint Powers Board (JPB) completed a multi-decade project to electrify Caltrain operations. Following electrification, Caltrain and Cities along the Peninsula noted an increase in noise complaints related to Caltrain horns, which had initially been set toward the high end of the legal limit. In November 2024, Caltrain adjusted horn noise levels to the low end of the legal range. The City of Palo Alto (City) has received several requests for consideration of a Quiet Zone (QZ) at crossings along the Caltrain Corridor. As part of the Palo Alto Council Priority process, implementation of quiet zones has been identified as a Council Priority consistent with the goals of Public Safety, Wellness and Belonging. For this reason, on March 4, 2024, City Council approved an agreement with Kimley Horn and Associates for performing a Quiet Zone Study (Staff Report 2311-2269)1. As the first phase of the quiet zone project, the City of Palo Alto in collaboration with the City of Menlo Park conducted a QZ study for establishing a quiet zone at the Palo Alto Avenue/Alma Street crossing. The design of the improvements required for implementation of QZ at Palo Alto Avenue was completed in early 2025 and associated improvements are currently under construction. After the project is constructed, the City will be eligible to apply to the FRA for establishment of a quiet zone in which train horns do not need to be sounded under normal circumstances. Gate bells would still sound and emergency train horns use would be under the discretion of the train engineer. The City is now undertaking the second phase of the quiet zone project for the remaining three 1 City Council Meeting, March 4, 2024; Consent Item SR# 2311-2269 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=82717 Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 2  Packet Pg. 427 of 517  at-grade crossings of Churchill Avenue, E. Meadow Drive, and Charleston Road. Quiet zone improvements at these locations will serve as an interim measure to mitigate noise impacts before planned Grade Separations are constructed at these crossings. The Federal Railroad Administration (FRA) Title 49 regulations establish safety requirements for local agencies that wish to mitigate train horn noise impacts by establishing Quiet Zones. The regulations require agencies to complete a quiet zone study to evaluate the Quiet Zone Risk Index (QZRI) and assess Supplemental Safety Measures (SSM) needed to make a crossing eligible for a quiet zone. In total, FRA lists fourteen recognized SSMs. Based on street geometry and nearby signal operations, the only feasible SSM identified for the three crossing locations under consideration in Palo Alto was a four-quadrant gate system. After completing the initial review of the existing conditions and analysis of the crossings. Staff presented various options for consideration of QZ to the Rail Committee on August 20, 2024 (Staff Report 2405-3805).3 At this meeting, Rail Committee selected two alternatives to advance to concept development: Option 1: Implementing a Four-Quadrant Gate System at Each Crossing to bring the QZRI below the existing Risk Index With Horns (RIWH) and qualify the crossings as quiet zones. This also satisfies the QZ implementation methodology of providing an approved SSM at each crossing within the quiet zone. Option 2: Implementing Wayside Horns, which would not qualify the crossings as quiet zones, but would reduce and localize noise impacts. Wayside horns are allowed to be installed at crossings that are already equipped with flashing lights and automatic gates. The horns must sound in the same sequence and at the same decibel level as train horns, and may be placed on the warning device, or installed on a separate post, and oriented to face the roadway and oncoming traffic. Based on feedback from the Rail Committee, initial concepts for the two options above were prepared and discussed with CPUC, FRA and Caltrain staff at a pre-diagnostic and field diagnostic meeting held on October 22, 2024. The initial conceptual plans were then revised to incorporate feedback from diagnostic meetings. City staff also conducted a public outreach meeting to seek feedback and comments on April 16, 2025. A total of 17 attendees participated in the community meeting. In addition, staff received several emails and phone calls. Residents generally supported Quiet Zones efforts, particularly full establishment of a Quiet Zone using the four-quadrant gate system. One resident, however, opposed the quiet zone concept citing potential safety concerns resulting from the “no horns” condition. Many residents viewed wayside horns as an insufficient measure for addressing project goals. 3 Rail Committee, August 20, 2024; Action item SR# 2405-3805 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=53093 Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 3  Packet Pg. 428 of 517  In addition to community input, the project consultant team undertook case study reviews from across the country, which suggest potentially lower operational and maintenance concerns associated with quadrant gates relative to wayside horns. This difference may be due to the higher prevalence of quadrant gates and correspondingly lower number of suppliers and technical support available for wayside horns. In some cases where wayside horns have been installed, local agencies have subsequently chosen to remove the horns due to ongoing maintenance issues and the time it takes to repair a faulty wayside horn system. In addition, some local agencies noted that railroad engineers continued to use locomotive horns even after wayside horns were in operation. Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 4  Packet Pg. 429 of 517  to require approximately 36 to 42 months. This represents a shorter timeframe compared to the estimated 42 to 60 months for installation of the Four Quadrant Gate System. After considering a range of factors—including safety factors, construction costs, ongoing maintenance needs and technical support, regulatory compliance, community feedback and risk the Rail Committee on September 16, 2025 (Staff Report # 2507-4951)5 unanimously selected the Four Quadrant Gate System for implementation of Quiet Zone along Caltrain corridor at the existing at-grade rail crossings in Palo Alto at Churchill Avenue, E. Meadow Drive, and Charleston Road as interim improvements until grade separations are constructed. In light of the potential shorter timeframe for wayside horn implementation and significance of this decision, the Committee also recommended the full City Council discuss this as an action item. Accordingly, subject to City Council concurrence, staff is seeking approval to proceed with the installation of Four-Quadrant Gate Systems as the safety enhancement required to implement Quiet Zones at these crossings. More recent discussion with Caltrain indicated a higher cost to implement Four Quadrant Gate Systems at these three crossings and has estimated the cost to be in the range of $5.0 to 5.6 million for Four Quadrant Gates Systems that include Caltrain project management and oversight. Additionally, it was noted that if Caltrain proceeds with both the design and construction phases, utilizing on-call consultants and contractors could lead to greater efficiencies with respect to the implementation of improvements—potentially reducing the implementation timeline for the four-quadrant gate systems to 36 months. FISCAL/RESOURCE IMPACT The Quiet Zone Study is currently funded in the Transportation and Parking Improvements capital project (PL-12000). Funding for the study of $178,559 was included in the FY 2026 Adopted Capital Budget for PL-12000. Depending upon the City Council direction additional funding for the implementation will be subject to Council appropriation in future years as part of the annual budget process. Based on the Council direction for the recommended Quite Zone implementation, staff will return to Council to request appropriation of Measure K Business Tax revenue that was set aside by the Council for Transportation Safety projects for design and construction of improvements. STAKEHOLDER ENGAGEMENT Stakeholder engagement on this issue has included a community meeting on April 16, 2024, Rail Committee meetings on August 20, 2024 and September 16, 2025, and a diagnostic meeting with various stakeholders representing FRA, CPUC, and Caltrain on October 22, 2024. Outreach for the community meeting included mailers to all residents within 1000’ radius of the 5 Rail Committee, August 20, 2024; Action item SR# 2507-4951 https://recordsportal.paloalto.gov/Weblink/DocView.aspx?id=53113 Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 5  Packet Pg. 430 of 517  crossings vicinity. Outreach for the Rail Committee meetings included noticing in the City’s Transportation newsletter and email blasts through the City Clerk’s meeting notification system. Notices for all of these public meetings also included publishing on City calendar. ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item 7 Item 7 Staff Report        Item 7: Staff Report Pg. 6  Packet Pg. 431 of 517  Quiet Zone Implementation Study Prepared for: City of Palo Alto 250 Hamilton Avenue Palo Alto, CA 94301 Prepared by: Kimley-Horn and Associates, Inc. 10 S. Almaden Boulevard Suite 1250 San Jose, CA 95113 Prepared on: June 26, 2025 This document, together with the concepts and designs presented herein, as an instrument of service, is intended only for the specific purpose and client for which it was prepared. Reuse of and improper reliance on this document without written authorization and adaptation by Kimley-Horn and Associates, Inc., shall be without liability to Kimley-Horn and Associates., Inc. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 7  Packet Pg. 432 of 517  Page 2 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 CITY OF PALO ALTO QUIET ZONE STUDY TABLE OF CONTENTS Background ............................................................................................................................................. 3 Scope of Work ......................................................................................................................................... 3 Document Review and Initial Data Collection........................................................................................ 3 Quiet Zone Analysis ................................................................................................................................ 5 SSM at Each Crossing ......................................................................................................................... 6 SSM at Some Crossings (QZRI Less Than RIWH) ............................................................................... 6 No SSM (QZRI Less Than NSRT) ........................................................................................................ 6 Quiet Zone Alternative – Wayside Horns (WSH) ...................................................................................... 7 Wayside Horns Case Study – Flagstaff, AZ .......................................................................................... 7 Prevalence of Wayside Horns .............................................................................................................. 8 Quiet Zone Evaluation ............................................................................................................................. 8 Conceptual Design .................................................................................................................................. 9 Field Diagnostic Meetings ...................................................................................................................... 10 Cost Estimates ...................................................................................................................................... 10 Outreach and Coordination .................................................................................................................... 10 Recommendations ................................................................................................................................. 11 Next Steps............................................................................................................................................. 11 Final Design ....................................................................................................................................... 11 Permitting .......................................................................................................................................... 12 Funding ............................................................................................................................................. 12 Construction....................................................................................................................................... 12 Quiet Zone Certification...................................................................................................................... 12 Continued Outreach ........................................................................................................................... 13 List of Appendices Appendix A Full Quiet Zone Analysis Appendix B Conceptual Designs Appendix C Field Diagnostic Meeting Minutes Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 8  Packet Pg. 433 of 517  Page 3 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 BACKGROUND There are four at-grade vehicular railroad crossings within the City of Palo Alto, all along the Caltrain corridor, whose right of way is owned by the Peninsula Corridor Joint Powers Board (PCJPB). Per Federal Railroad Administration (FRA) requirements, locomotive engineers are required to sound their horns upon approach to at-grade crossings in a four-blast sequence, beginning either 20 seconds or ¼- mile upstream of the at-grade crossing. In Palo Alto, these four vehicular at-grade crossings span over 3.5 miles – meaning that for each train passing through this city, the train horns sound sixteen times (excluding any train horns sounded on approach to the Caltrain stations within the City). With Caltrain being a transit agency boasting robust service, trains pass through Palo Alto quite frequently; Union Pacific Railroad (UPRR) also maintains trackage rights, allowing them to use this corridor for freight operations. These train movements, and the required horn soundings, result in significant noise pollution and quality of life degradation for nearby residents and businesses. For the reasons listed above, the City Palo Alto (subsequently referred to as “City”) has undertaken a study to determine the feasibility of implementing a quiet zone along this railroad corridor. SCOPE OF WORK The work accomplished under this study included analysis, conceptual designs, field diagnostic meetings, and public outreach for the four at-grade crossings. The crossings located in the City of Palo Alto are shown in Table 1 below. Table 1: Crossings located in the City of Palo Alto Crossing DOT#Crossing Roadway Name 754992N Palo Alto Avenue 754998E Churchill Avenue 755010S East Meadow Drive 755011Y Charleston Road Source: FRA Office of Safety Analysis (https://safetydata.fra.dot.gov/officeofsafety/publicsite/crossing/crossing.aspx) The northernmost at-grade crossing in Palo Alto (Palo Alto Avenue) was evaluated in a previous quiet zone implementation study, which was then followed by a final design phase. The Palo Alto Avenue crossing is approaching the construction phase for its set of quiet zone improvements, which is comprised of a raised median on both sides of the tracks. Any improvements to the remaining crossings in the City would then append the quiet zone at Palo Alto Avenue. The purpose of this study is to determine the recommended set of improvements at the remaining three crossings in the City – Churchill Avenue, East Meadow Drive, and Charleston Road. Kimley-Horn performed the necessary analysis prescribed by the FRA, prepared draft conceptual designs of the improvements to each of the three remaining at-grade crossings within the scope, scheduled and attended diagnostic field meetings with stakeholders, and assisted the City in public outreach efforts. DOCUMENT REVIEW AND INITIAL DATA COLLECTION Kimley-Horn staff performed an initial site visit to evaluate the existing conditions of the grade crossings and assessed both the opportunities and constraints for the potential improvements. This investigation Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 9  Packet Pg. 434 of 517  Page 4 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 involved taking photographs and discussing the site conditions internally and evaluating potential improvements. Kimley-Horn staff also reviewed available documents from the FRA, including existing U.S. DOT Inventory Forms and historical incident reports. The inventory reports detail the existing conditions of the crossing, and include vital information about the roadway infrastructure, railroad infrastructure, crossing geometry, railroad organization information, train information (including daily counts and timetable speeds), and general location information. The incident reports include collision details and provide insight into historic events at each crossing, including what, if any, safety measures were implemented at that time. The incident reports allowed Kimley-Horn staff to directly compare the data for each crossing and identify major safety differences among the crossings. Since 2015, there have been 26 incidents along this three-crossing section of the corridor. Table 2 shows a breakdown of the incidents, including the year of the incident and a summary of the incident. Table 2: Incidents at Each Crossing from 2015 to present Crossing DOT# Crossing Roadway Name Date of Incident Type of Incident Injury/Fatality 754998E Churchill Avenue 4/16/2023 Person Fatality 9/09/2022 Vehicle (unoccupied)None reported 5/10/2021 Vehicle (occupied)None reported 1/21/2021 Person Fatality (intentional) 11/15/2019 Vehicle (unoccupied)None reported 8/03/2018 Vehicle (occupied)None reported 10/16/2017 Vehicle (unoccupied)None Reported 6/15/2017 Vehicle (unoccupied)None Reported 5/22/2017 Vehicle (occupied)None reported 755010S East Meadow Drive 2/20/2024 Person Fatality 1/26/2024 Person Fatality 7/06/2023 Person Fatality 7/23/2022 Person Fatality (intentional) 1/19/2017 Vehicle (occupied)None reported Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 10  Packet Pg. 435 of 517  Page 5 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 10/16/2016 Vehicle (unoccupied)None reported 9/19/2016 Vehicle (occupied)Injury 9/13/2015 Vehicle (occupied)None reported 755011Y Charleston Road 1/23/2024 Vehicle (unoccupied)None reported 12/02/2021 Vehicle (unoccupied)None reported 10/26/2021 Person Fatality (intentional) 8/16/2019 Vehicle (unoccupied)None reported 3/25/2018 Vehicle (unoccupied)None reported 2/12/2018 Vehicle (unoccupied)None reported 10/05/2017 Vehicle (unoccupied)None reported 12/23/2016 Vehicle (occupied)Fatality (intentional) 1/25/2015 Person Fatality (intentional) Source: FRA Office of Safety Analysis (https://safetydata.fra.dot.gov/officeofsafety/publicsite/crossing/crossing.aspx) The City collected traffic volumes in April 2023 at each crossing to determine the mode share for vehicles, bicycles, and pedestrians. See Table 3 for a summary of the traffic counts collected. In 2025, Caltrain operates 104 Caltrain commuter trains per day across these crossings. Of note, Caltrain may adjust service frequency in the future to meet customer demand. Based on Caltrain’s 10-Year Strategic Financial Plan as of December 2024, the assumed weekday trains per day (TPD) will increase to 116 TPD in 2029 and to 128 TPD in 2031. Table 3: Summary of daily total traffic volumes at study locations Crossing DOT# Crossing Roadway Name Pedestrian Count Bicycle Count Vehicle Count WB EB WB EB WB EB 754998E Churchill Avenue 105 9 298 187 1,162 4,622 755010S East Meadow Drive 58 5 224 370 3,028 3,716 755011Y Charleston Road 77 1 186 224 4,416 5,768 Source: Traffic Counts provided by the City of Palo Alto QUIET ZONE ANALYSIS There are multiple ways a section of railroad corridor can achieve quiet zone status, which are outlined below. These include the installation of Supplemental Safety Measures (SSM) at all crossings, a partial implementation of SSMs across the crossings, and in rare cases, demonstrating that the existing risk index qualifies for a quiet zone. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 11  Packet Pg. 436 of 517  Page 6 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 SSM AT EACH CROSSING The first method is to provide a Supplemental Safety Measure (SSM) at each crossing within the quiet zone. SSMs are defined by the FRA in 49 Code of Federal Regulations Appendix A to Part 222. It includes options such as “four-quadrant” (or “exit”) gates, non-traversable medians, one-way streets with entry gates, and temporary or full crossing closure. Table 4, below, shows the full list of 14 SSMs accepted by the FRA. Table 4: SSM Codes and Definitions SSM Code SSM Definition 1 Temporary Closure of a Public Highway-Rail Grade Crossing 2 Permanent Closure of a Public Highway-Rail Grade Crossing 3 Grade Separation of a Public Highway-Rail Grade Crossing 4 Four-Quadrant Gates Upgrade from Two Quadrant gates, No Vehicle Presence Detection 5 Four-Quadrant Gates Upgrade from Two Quadrant Gates, with medians and no Vehicle Presence Detection 6 Four-Quadrant Gates Upgrade from Two Quadrant gates, with Vehicle Presence Detection 7 Four-Quadrant Gates Upgrade from Two Quadrant gates, with medians and Vehicle Presence Detection 8 Four-Quadrant Gates New Installation, No Vehicle Presence Detection 9 Four-Quadrant Gates New Installation with medians and no Vehicle Presence Detection 10 Four-Quadrant Gates New Installation with Vehicle Presence Detection 11 Four-Quadrant Gates New Installation with medians and Vehicle Presence Detection 12 Mountable medians with Reflective Traffic Channelization Devices 13 Non-Traversable Curb Medians with or without Channelization Devices 14 One-Way Streets with Gates Source: FRA Quiet Zone Calculator (https://safetydata.fra.dot.gov/quiet/ssm.aspx) SSM AT SOME CROSSINGS (QZRI LESS THAN RIWH) The second method to qualify for a quiet zone is a partial establishment of SSMs at one or more crossings within the proposed quiet zone such that the Quiet Zone Risk Index (QZRI) is reduced to a level at or below the Risk Index With Horns (RIWH). The RIWH is the risk associated with all crossings included in the specified quiet zone when train horns are sounded per FRA requirements. Under this method of quiet zone qualification, SSMs may not be required at all crossings. The quiet zone rule defines a rate of effectiveness for each SSM to formulaically assign risk reductions to each crossing. NO SSM (QZRI LESS THAN NSRT) The third and final method by which a quiet zone can be achieved is if the Quiet Zone Risk Index (QZRI) along the section of corridor is at or below the Nationwide Significant Risk Threshold (NSRT). The NSRT is defined as the average of the risk indexes for all grade crossings in the country where train horns sound. As of May 2025, the NSRT is currently equal to 15,488.00. Because the NSRT is representative of all grade crossings in the country, it includes grade crossings which may have undergone safety improvements and may have implemented the full range of crossing improvements or implemented significantly impactful SSMs or ASMs, like one-way streets or partial closure. If the QZRI with no Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 12  Packet Pg. 437 of 517  Page 7 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 improvements is at or below the NSRT, the specified crossings would automatically qualify for a quiet zone. Alternatively, if SSMs are implemented along the section of corridor such that the QZRI is at or below the NSRT, the corridor would then qualify as a quiet zone. This method exposes the quiet zone to risk in the event the NSRT, which is evaluated yearly by the FRA, drops below the quiet zone QZRI, which would invalidate the quiet zone status. However, this corridor does not qualify for a quiet zone in its current state, unless crossing closures are considered. Crossing closures were not determined to be in the best interest of the community. Therefore, the NSRT method was not considered for the study. QUIET ZONE ALTERNATIVE – WAYSIDE HORNS (WSH) An alternative to a quiet zone, but one that still promotes noise reduction, would be the installation of wayside horns. Wayside horns are fixed audible warning devices, which are physically present at the crossing. The wayside horn is required to sound at the same frequency, decibel level, and duration as a traditional train horn. The noise reduction stemming from a wayside horn is due to the fixed nature of the horn. Where the noise distribution of a traditional train horn moves as the train moves, the wayside horn stays fixed at the crossing, with the horn itself directed at the stop line for oncoming motorists. The result is a reduction in noise for those that are not directly adjacent to the crossing. It should be noted that for those directly adjacent to or at the crossing, the result is that the full volume of all four sounds of the horn can be heard. While a wayside horn is not a quiet zone measure, it is evaluated as a one-for-one replacement of the train horn. The requirements for installation of a wayside horn are noted in Appendix E to Part 222 of the Code of Federal Regulations – Requirements for Wayside Horns. As noted in Appendix E to Part 222, wayside horns must provide a minimum sound level of 92 dB(A) – maximum 110 dB(A) – when measured 100’ from the centerline of the nearest track. The horn system is required to sound a minimum of 15 seconds prior to the train’s arrival at the crossing. WAYSIDE HORNS CASE STUDY – FLAGSTAFF, AZ Kimley-Horn reached out to internal partners nationwide to gather information surrounding wayside horns. The most recent example evaluated was a 2010 WSH installation in Flagstaff, Arizona. In this location, Fanning Drive (Crossing DOT# 025129Y) and Steves Boulevard (Crossing DOT# 025099J), have implemented wayside horns. These crossings see about 100 to 120 trains per day (TPD) operating at a maximum authorized speed of 55mph. The TPD is similar to Caltrain’s current 104 TPD. These two crossings are part of a larger quiet zone project with three other crossings. The other crossings do not use wayside horns. Instead, they have implemented other SSMs such as median upgrades or conversion to a one-way street. Of note, the city has fielded continuous complaints from residents since their installation in 2010. There has also been community feedback noting equity issues that arise from certain parts of the city receiving what the community refers to as a “true” quiet compared to a wayside horn implementation with the same frequency of train horns sounding in a localized area. The City of Flagstaff installed wayside horns manufactured by Railroads Controls Limited (RCL), which was acquired by Wabtec Corporation in 2015. The sound level of the wayside horns is recertified every two years using a sound meter purchased by the City – this recertification involves ensuring the wayside horns sound at the required decibel levels as prescribed in Appendix E to Part 222 of the Code of Federal Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 13  Packet Pg. 438 of 517  Page 8 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 Regulations. The City also noted that obtaining replacement parts has been challenging, as the original company no longer exists. Due to the factors of community feedback, lack of ongoing technical support, and cumbersome recertification, the City of Flagstaff is seeking funding to replace the wayside horns with a four quadrant gate system at both the Fanning Drive and Steves Boulevard crossings. PREVALENCE OF WAYSIDE HORNS Wayside horns are not considered quiet zone crossings on their own, but may be listed as quiet zone crossings if they are included as part of a larger quiet zone. Because the City of Palo Alto is working toward a quiet zone on Palo Alto Avenue / Alma Street, the crossings at Churchill Ave, E Meadow Dr, and Charleston Rd could be appended to this existing quiet zone. Kimley-Horn also evaluated the usage of wayside horns on a nationwide basis. Kimley-Horn used data published by the FRA on April 30, 2025, and found that there are 5,757 crossings listed as having either a partial or full/24-hour quiet zone. Of these 5,757 quiet zone crossings in the FRA Crossing Inventory Dataset, 76 crossings, or 1.3% of crossings, have wayside horns. There are a total of 672 crossings with wayside horns, though as noted, only 76, or 10%, of wayside horn crossings are part of larger quiet zones. implement SSMs or wayside horns. Figure 1: Diagram comparing total quiet zone crossings and quiet zone crossings with wayside horns Source: FRA Office of Safety Analysis (https://safetydata.fra.dot.gov/officeofsafety/publicsite/crossing/crossing.aspx) QUIET ZONE EVALUATION Kimley-Horn used the FRA Quiet Zone calculator, an online tool provided by the FRA, to determine what upgrades would generate quiet zone approval. Based on the existing conditions at each crossing, Kimley- Horn staff determined the Supplemental Safety Measure treatment most applicable for these three locations to be four-quadrant gates with vehicle presence detection. Wayside Horns Crossings, 76, 1% Quiet Zone Crossings, 5757, 99% Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 14  Packet Pg. 439 of 517  Page 9 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 As noted in Table 4, there are 14 total SSMs accepted by the FRA. Full closure of the crossings was not evaluated as the implications for equity and access would likely exceed the cost for implementation of SSMs and temporary closure during peak periods would likewise be impractical. Conversion of roadways from two-way to one-way traffic is another SSM that was not considered as part of this study due to the impracticality of converting residential roadways into one-way streets; similar concerns for equity and access arise when evaluating one-way traffic. All three crossings are less than 60’ from an adjacent roadway (Alma Street); because of this proximity, installation of mountable or non-traversable medians would not qualify as an SSM. Four quadrant gates become the only available option; since all three crossings are currently equipped with gates, it would be an upgrade from the existing two-quadrant system. A four-quadrant gate system prohibits vehicles from driving around gates in the down position and moving onto the tracks during a train event. The gates on the departure side of the crossing have a delayed lowering compared to the entry gates to ensure no vehicles are on the tracks and at risk of fouling the tracks. It should be noted that vehicle presence detection is required at all crossings implementing a four- quadrant gate system in California per California Public Utilities Commission (CPUC) General Order No. 75-D. Because of this, if a vehicle is detected in the trackway during gate activation, the exit gates would also remain in the “up” position and would not descend until the vehicle clears the trackway. See Figure 1 for an example graphic of a four-quadrant gate system as depicted by the California High Speed Rail Authority (CAHSRA). Source: https://hsr.ca.gov/about/safety/quad-gates/ Wayside horns are not in the Quiet Zone Calculator but are viewed as a direct replacement to SSMs. If wayside horns are applied at each of the three crossings, the quiet zone would qualify through the first listed option for quiet zones – installing SSMs at every crossing. CONCEPTUAL DESIGN Kimley-Horn staff prepared conceptual design plans for each of the three at-grade crossings to provide a complete evaluation of the impacts and potential needs for upgrades at each crossing. Kimley-Horn evaluated the four-quadrant gate alternative, as well as wayside horns. See Appendix B for the finalized conceptual layouts. Figure 2: Four-quadrant gates Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 15  Packet Pg. 440 of 517  Page 10 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 FIELD DIAGNOSTIC MEETINGS A preliminary field diagnostic meeting was performed in October of 2024 to evaluate the proposed improvements with relevant stakeholders to determine if the quiet zone is feasible. This field diagnostic included staff from the City, Kimley-Horn, Caltrain, CPUC, and FRA. While UPRR has trackage rights to operate on the corridor, they were not included in the diagnostic meeting. The draft conceptual designs for SMM installation were provided to all invited to the field diagnostic meeting to allow for review ahead of the meeting. During the field diagnostic meeting, small design revisions were noted by stakeholders, and the conceptual layouts were then updated accordingly. Kimley-Horn drafted field review minutes following the diagnostic meetings and sent them to stakeholders for review and input. The meeting minutes then incorporated City and stakeholder feedback and were finalized. See Appendix C for the Field Diagnostic Meeting Minutes. COST ESTIMATES Kimley-Horn staff drafted cost estimates for each crossing. These estimates detail approximate infrastructure costs, as well as expected project delivery costs associated with the completion of the project. Construction costs were derived from the following sources: · Bid results from recent at-grade rail improvement projects in Northern CA. · Caltrans Unit Price Database. · Project research on wayside horn implementation, adjusted for inflation and geographic location. Table 5 shows the rough order of magnitude costs determined by crossing for each of the three crossings in the study area. Table 5: Rough Order of Magnitude Costs for Each Crossing Crossing DOT#Crossing Roadway Name Four-Quad Gate Cost Wayside Horn Cost 754998E Churchill Avenue $1,200,000 $500,000 755010S Meadow Drive $1,670,000 $500,000 755011Y Charleston Road $1,220,000 $500,000 Source: Kimley-Horn prepared the Rough Order of Magnitude cost estimate. It should be noted that these order of magnitude estimates include a contingency factor, provisions for engineering design and permitting, escalation, and a Caltrain signal design allowance. For the four-quad gate cost, a new signal cabinet at each location has also been included. This is often required by railroads when there are changes to the signaling infrastructure. The wayside horn cost does not include this line item, though it should be noted that the need for a new signal cabinet may be a possibility and could increase the cost at each crossing by approximately $400,000. OUTREACH AND COORDINATION The Caltrain corridor is located adjacent to existing residences, schools, and businesses. Due to its proximity to residents and the fact these improvements hinge on safety considerations, this project required public outreach and coordination. The Kimley-horn team developed presentations for use at Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 16  Packet Pg. 441 of 517  Page 11 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 various City Council, subcommittee, and public meetings, as well as attended and presented at these meetings. Kimley-Horn presented to the Palo Alto Rail Committee in August of 2024, and to the public in April of 2025. At these meetings, Kimley-Horn fielded questions from the public and supported the City in highlighting the importance of a Quiet Zone for this area. In these presentations, Kimley-Horn touched on the background of a quiet zone, the process by which a quiet zone can be achieved (including a rough timeline for implementation), what this quiet zone would entail in terms of infrastructure upgrades, and the next steps for the City to implement a quiet zone. A recording of the public meeting for the project will be made available at https://www.paloalto.gov/Departments/Transportation/Transportation-Projects/Quiet-Zone- Studies/Churchill-Avenue-Meadow-Drive-Charleston-Road-Crossings. RECOMMENDATIONS Kimley-Horn recommends the City of Palo Alto implement a quiet zone by installing a four-quadrant gate system at each of the three crossings. While the capital costs associated with a four-quadrant gate system are higher than that of wayside horns, the impact to the community will be more significant. Wayside horns do reduce the noise level for a majority of residents along the corridor, but there will still be train horn blasts sounded for all residents directly adjacent to the crossings themselves, which does not provide the same benefit to the entire surrounding community as would a four-quadrant gate system. The general community feedback received was in support of a four-quadrant gate system, and viewed wayside horns as a half measure. Additionally, Kimley-Horn’s case study research showed low implementation of wayside horns across the country, with a correspondingly low amount of suppliers and technical support. Additionally, the FRA and CPUC noted that the Caltrain corridor sees a significant level of train incidents, given its high speed and high volume. Providing the four-quadrant gate system would provide a physical barrier to entry to reduce the potential of gate go-arounds, thereby actively providing a safety enhancement and reducing the ability for crossing users to enter the trackway during a train event. NEXT STEPS Following the conclusion of this quiet zone study, the City may begin preparing for the implementation of a quiet zone. For this to occur, the City must still undergo several necessary steps, including developing final engineering plans, acquiring necessary permits, securing funding, undergoing construction, and certifying the quiet zone with necessary agencies. FINAL DESIGN After securing board approval to pursue the remaining work for a quiet zone, the City would need to develop Request for Proposals (RFP) for engineering firms to submit a proposal to perform the engineering work associated with the design of the crossing(s). Typically, the engineering consultant would submit plans, specifications, and estimates (PS&E) to the City and all stakeholder agencies at various levels of design completion, adding additional detail and information through each submittal. Comprehensive demolition, civil improvements, signage and striping, grading and drainage, lighting/traffic signal (if necessary) plans, along with traffic control plans and Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 17  Packet Pg. 442 of 517  Page 12 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 construction phasing plans would all be required at the culmination of the final 100% plan set. The plans will be circulated for comment by multiple stakeholders, including the City, Caltrain and CPUC. PERMITTING Alongside the final design process, the engineering consultant may support the City with the permitting process. CPUC General Order 88-B (GO 88-B) is a permit required for any modifications to an existing rail crossing. Obtaining approval for this permit is paramount to the modification of any grade crossing, as it ensures the plans provided meet CPUC criteria and acts as government approval for safety upgrades. Caltrain would likely require the City to obtain an encroachment permit for any work performed in the right of way owned by the PCJPB. In addition to obtaining permits through CPUC, there may need to be an agreement between the City and PCJPB/Caltrain outlining possible cost sharing for design, construction and maintenance. Environmental clearance would be required through CEQA; the level of environmental documentation required would be a function of the various resources impacted. If federal funding is secured, the crossings would also need to be cleared through NEPA. FUNDING The City would also need to secure funding to support the design and construction associated with the quiet zone. Funding sources exist through federal, state, regional, and local levels, and the engineering consultant may be able to support the City with grant applications for some of these funding opportunities. On the federal level, the FRA offers the Consolidated Rail Infrastructure and Safety Improvements (CRISI) Grant, which is a program funding projects to improve safety, efficiency, and reliability of intercity passenger and freight rail. Municipalities in California have also been successful at obtaining funding through various state grants; the City could, in conjunction with local and state representatives, investigate and lobby for additional funding. The City may also pursue funding through the Palo Alto Transportation Management Association (PATMA). CONSTRUCTION For the improvements to be constructed, the City should hire a firm familiar with performing construction work in and around railroad right-of-way. Depending on PCJPB/Caltrain regulations at the time of construction, construction crews may be required to be trained by Caltrain staff for safety while working near electrified tracks, or Caltrain themselves may install the railroad devices such as automatic gates or wayside horns. The engineering consultant may be tasked with providing construction support to the City, in the form of field visits and general oversight during the construction phase. QUIET ZONE CERTIFICATION The City would be required to file the Notice of Intent (NOI) and Notice of Establishment (NOE) for the quiet zone. The NOI can be submitted prior to construction, and requires a minimum 60-day comment period for all parties in the service list. The NOE should be filed after construction, and requires a similar 60-day comment period. After the NOE is approved by the FRA, the quiet zone can be certified and the “No Train Horn” plaques can be visible to motorists. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 18  Packet Pg. 443 of 517  Page 13 Kimley-Horn.com 10 Almaden Boulevard, Suite 1250, San Jose, CA 95113 669-800-4130 For wayside horns, the notice required is a minimum of 21 days prior to when the wayside horn shall be operational. CONTINUED OUTREACH Throughout the final design and construction phases, the engineering consultant should continue to attend public outreach meetings and hearings to support the City. A post-construction meeting will likely be held with the same attendees as the initial diagnostic meeting to secure final approval of the quiet zone. MAINTENANCE OF CROSSINGS At-grade crossings require ongoing maintenance to ensure the warning devices and systems are operating appropriately. The level of maintenance required depends on the crossing and its features. Per CPUC General Order (GO) 72-D, the railroad owner/operator is responsible for the maintenance of the crossing area measuring 2’ outside the rails of each track, and between sets of tracks (if there are multiple tracks less than 15’ apart). Caltrain also maintains train-activated warning devices for each crossing. Additionally, Caltrain is financially responsible for the maintenance of the gates, and does not currently have cost sharing agreements with local agencies. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 19  Packet Pg. 444 of 517  Page A-1 APPENDIX A Full Quiet Zone Analysis Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 20  Packet Pg. 445 of 517  Palo Alto Quiet Zone 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Mountable medians with Reflective Traffic Channelization Devices Non-Traversable Curb Medians with or without Channelization Devices One-Way Streets with Gates Four-Quadrant Gates Upgrade from Two Quadrant gates, with Vehicle Presence Detection Four-Quadrant Gates Upgrade from Two Quadrant gates, with medians and Vehicle Presence Detection Four-Quadrant Gates New Installation, No Vehicle Presence Detection Four-Quadrant Gates New Installation with medians and no Vehicle Presence Detection Four-Quadrant Gates New Installation with Vehicle Presence Detection Four-Quadrant Gates New Installation with medians and Vehicle Presence Detection Four-Quadrant Gates Upgrade from Two Quadrant gates, with medians and no Vehicle Presence Detection Supplemental Safety Measure (SSM) Codes Temporary Closure of a Public Highway-Rail Grade Crossing Permanent Closure of a Public Highway-Rail Grade Crossing Grade Separation of a Public Highway-Rail Grade Crossing Four-Quadrant Gates Upgrade from Two Quadrant gates, No Vehicle Presence Detection Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 21  Packet Pg. 446 of 517  Palo Alto Quiet Zone Existing SSM SSM Risk SSM Risk Δrisk Palo Alto Ave 0 0 102,853.18 13 20,570.64 -82282.54 Churchill 0 0 588,964.84 6 135,461.91 -453502.93 E Meadow 0 0 295,736.94 6 68,019.50 -227717.44 Charleston 0 0 426,060.47 6 97,993.91 -328066.56 Total 353403.86 80511.49 SSM Risk SSM Risk SSM Risk SSM Risk Palo Alto Ave 13 20570.64 13 20570.64 13 20570.64 13 20570.64 Churchill 0 588964.84 6 135461.91 0 588964.84 0 588964.84 E Meadow 0 295736.94 0 295736.94 6 68019.5 0 295736.94 Charleston 0 426060.47 0 426060.47 0 426060.47 6 97993.91 Total 332833.22 219457.49 275903.86 250816.58 SSM Risk SSM Risk SSM Risk Palo Alto Ave 13 20570.64 13 20570.64 13 20570.64 Churchill 6 135461.91 6 135461.91 0 588964.84 E Meadow 6 68019.5 0 295736.94 6 68019.5 Charleston 0 426060.47 6 97993.91 6 97993.91 Total 162528.13 137440.85 193887.22 UPGRADE TWO CROSSINGS ONLY QZ does not qualify UPGRADE ONE CROSSING ONLY RISK INDEX WITH HORN: 211872.82 DO NOTHING ALTERNATIVE ADD SSM TO ALL CROSSINGS QZ qualifies The following scenarios were analyzed using the FRA Quiet Zone calculator. The Supplemental Safety Measure (SSM) codes are listed below; the full description of SSMs are presented in page 1 of this appendix. To be eligible for a quiet zone, the total risk associated with the zone of interest cannot exceed the risk index with horn (RIWH). For this zone, the RIWH is 211872.82 These calculations are performed under the assumption that the Palo Alto Avenue crossing is to be upgraded in all cases. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 22  Packet Pg. 447 of 517  Page B-1 APPENDIX B Conceptual Designs Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 23  Packet Pg. 448 of 517  NOR T H W10-1 R R W10-2 TRACKS 2 W48(CA) W10-9P TRAIN HORN NO Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 24  Packet Pg. 449 of 517  NOR T H W10-1 R R W10-2 TRACKS 2 W48(CA) W10-9P TRAIN HORN NO R8-8 DO NOTSTOP ON TRACKS Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 25  Packet Pg. 450 of 517  March 2023 NOR T H CHARLESTON RD AT-GRADE CROSSING Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 26  Packet Pg. 451 of 517  10 . 0 ' 10 . 0 ' 18.0' 12.0' NOR T H Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 27  Packet Pg. 452 of 517  10 . 0 ' 10 . 0 ' 13.0' 26.0' NOR T H Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 28  Packet Pg. 453 of 517  10 . 0 ' 10 . 0 ' 12.0' 12.0' NOR T H Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 29  Packet Pg. 454 of 517  Page C-1 APPENDIX C Field Diagnostic Meeting Minutes Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 30  Packet Pg. 455 of 517  Pre-Diagnostic Meeting Palo Alto, CA – Multiple Crossings October 22nd, 2024 Meeting Attendees: Name Agency/Company Email Ripon Bhatia City of Palo Alto Ripon.Bhatia@CityofPaloAlto.org Ade Sogbesan CPUC Eyitejumade.Sogbesan@cpuc.ca.gov Eric Walker FRA eric.s.walker@dot.gov Lou Tolentino Caltrain TolentinoL@caltrain.com Rick Bartholomew Caltrain BartholomewR@caltrain.com Janet Wang JPB/Caltrain WangJ@caltrain.com Amanda Zerbe TASI/Caltrain azerbe@tasi.com Fred Sandoval TASI/Caltrain fsandoval@tasi.com Shawn Lima JPB/Caltrain LimaS@caltrain.com Blake Silkwood Design/ Kimley-Horn Blake.Silkwood@kimley-horn.com Taylor Brown Design/ Kimley-Horn Taylor.Brown@kimley-horn.com Definitions: • Diagnostic Team: Pursuant to CAMUTCD 8A.01.05a, the diagnostic team needs to include at a minimum, representatives of the highway agency or authority with jurisdiction over the roadway, the railroad with responsibility of the track and signals, and the California Public Utilities Commission with statutory authority over grade crossings. • CPUC Standard No 9: An automatic gate arm used in combination with a Standard No. 8. The gate mechanism may be mounted on the Standard 8 mast or separately on an adjacent pedestal. The automatic gate shall be designed to fail in the down position. A Crossbuck sign shall be installed on the mast. • CPUC Standard No. 8: An automatic flashing light signal assembly which, by alternately flashing red lights facing each approach, provides a warning of an approaching train. A Crossbuck sign shall be installed on the mast. • CPUC Standard No. 8-A: A Standard 8 with additional flashing signals over the roadway on a cantilever arm. • CPUC Standard No. 9-A: A Standard 9 with additional flashing light signals over the roadway on a cantilever arm. • CPUC Standard No. 9-E: A Standard 9 installed on the departure side of the at-grade crossing (also known as an exit gate) in addition to the typical approach side of the at-grade crossing (also known as an entrance gate). • Highway Safety Improvement Act (23 U.S.C. § 407) • Roadway diet: The narrowing of the roadway and moving vehicle gates to improve visibility of the flashing lights. • AADT: Annual Average Daily Traffic • ADT: Average Daily Traffic Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 31  Packet Pg. 456 of 517  • CAMUTCD: California Manual on Uniform Traffic Control Devices • CPUC: California Public Utilities Commission • FRA: Federal Railroad Administration • RRTCD: Railroad Traffic Control Devices. • RIRO: Right-in Right-Out. Meeting minutes: Introductions and Meeting Logistics: • Draft notes to be provided within two weeks of meeting for Stakeholder review. Stakeholder comments to be returned within 2 weeks of receipt of notes. • The team reviewed the purpose and definition of a Diagnostic and the Diagnostic Team (CA MUTCD Sections 8A.01, 8A.02 and Code of the Federal Regulations. o “A diagnostic team, consisting of knowledgeable representatives of parties of interest in a highway-rail or highway-LRT grade crossing, using crossing safety management principles, evaluates conditions at a grade crossing to make determinations or recommendations concerning safety needs at the grade crossing. The diagnostic team needs to, at a minimum, include representatives of the highway agency or authority with jurisdiction over the roadway, the railroad or LRT agency with responsibility for the track and signals, and the California Public Utilities Commission (CPUC), which is the state regulatory agency with statutory authority over grade crossings. The removal, reduction, addition, or change in the type of warning devices at each public grade crossing, or publicly- used private grade crossing (as determined by CPUC or a court competent jurisdiction), must be authorized by CPUC. This includes any changes that can affect interconnections with adjacent traffic signals, or any other modification that may impact the safety of the grade crossing. Refer to Public Utilities Code Sections 1201 through 1205, 7537, 99152 and CPUC General Orders 75 and 88, as amended.” • The FRA shared the District 7 statement. Crossing Data Review: Churchill Meadow Charleston AADT (year) 8,146 (2021) 6,762 (2021) 12,931 (2021) % trucks 51% 54% 49% Speed limit (MPH) 25 25 25 Train Counts (year) 108 (2023) 108 (2023) 108 (2023) Max Train speed (MPH) 79 79 79 Incident History (since 2015) 2023: Pedestrian fatality 2022: Unoccupied vehicle 2021: Occupied vehicle; no injuries reported 2024: Pedestrian fatality 2024: Pedestrian fatality 2023: Pedestrian fatality 2022: Pedestrian fatality 2017: Occupied vehicle; 2024: Occupied vehicle, no injuries reported 2021: Unoccupied vehicle 2021: Pedestrian fatality Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 32  Packet Pg. 457 of 517  2021: Pedestrian fatality 2019: Unoccupied vehicle 2018: Occupied vehicle; no injuries reported 2017: Unoccupied vehicle 2017: Unoccupied vehicle 2017: Occupied vehicle; no injuries reported no injuries reported 2016: Unoccupied vehicle 2016: Occupied vehicle; 1 injury reported 2015: Occupied vehicle, no injuries reported 2019: Unoccupied vehicle 2018: Unoccupied vehicle 2018: Unoccupied vehicle 2017: Unoccupied vehicle 2016: Occupied vehicle, fatality reported 2015: Pedestrian fatality Crossing Improvements – Basis of Design • Feasibility of Wayside Horns (WSH) o The City would like to discuss the potential use of WSH as an interim measure or as an alternative to a four-quadrant gate system. • Caltrain does not currently have wayside horns on the corridor. o Installation of WSH does not preclude train operators from sounding their horn any situation where the train operators feels it is warranted. • Caltrain noted that any roadway work or construction on the corridor would require train operators to sound their horns regardless of quiet zone status or installation of WSH. o Caltrain noted this would not decrease the noise experienced by those in the vicinity of the crossing. • Consultant team agreed, but pointed out that the spread of noise from a moving train horn is larger than a WSH, since the WSH would be a static object. o Caltrain noted installation of a WSH would still require an encroachment permit. Caltrain would want to see how a WSH integrates with their current systems. o Caltrain noted that a WSH may need an indicator light to alert train operators whether the WSH is operating or not. o City requests Consultant team show an optional WSH alternative. o The FRA noted that from 2017-2024, there have been 21 strikes across these crossings. If WSH are installed, what stops people from being hit? • The City and Caltrain are undergoing trespass fencing enhancements through a separate project. • Churchill Avenue o Refresh pavement markings and upgrade warning signage to be compliant with 11th Edition MUTCD. ▪ Inclusion of W10-9P signs (NO TRAIN HORN) to all W10-1 posts. o Section 130 improvements are under construction. This includes upgrading warning devices and installation of a pre-signal. o Due to location of pre-signal foundation on 100% plans, exit gate is shown as located downstream of mast arm. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 33  Packet Pg. 458 of 517  ▪ CPUC and FRA noted they would need to bring this configuration to their larger teams for confirmation that this is acceptable. o The City noted that their constituents may not be supportive of the pedestrian gate in the SW quadrant being shortened, given the high volume of pedestrians and bicyclists in the area. City may request the pedestrian infrastructure being pushed down the corridor further in order to accommodate the exit gate. o Caltrain asked the City if there has been any consideration for restricting trucks, at least for the southbound direction? Caltrain noted there have been several instances of broken gates and the SB entry gate being struck by vehicles making the right turn from Alma Street to Churchill Avenue. ▪ City noted restricting Caltrans Legal Design Vehicle may not be possible due to CVC regulations. As part of the project, we can review the existing truck routes and appropriate signage can be installed for truck turning restrictions. ▪ Consultant team will evaluate turning templates at this intersection and present the results to the diagnostic team. • CPUC noted the truck turning templates may be requested for any future GO 88-B applications. • Meadow Drive o Refresh pavement markings and upgrade warning signage to be compliant with 11th Edition MUTCD. ▪ Inclusion of W10-9P signs (NO TRAIN HORN) to all W10-1 posts. o Caltrain noted the concepts say “Meadow Drive”. The roadway is listed as “East Meadow Drive” in inventory forms. Consultant team to update concepts to reflect correct roadway name. o Caltrain noted that the handrailing could be brought closer to the tracks, rather than terminating at the beginning of the tactile warning strip. The Consultant team terminated the railing further from the track due to the proximity to the gates and counterweights. Caltrain noted that they are not concerned with the location of the counterweight and the fencing, as the counterweight is only active during a train event. ▪ Consultant team to modify handrailing to terminate 15’ from centerline of nearest track. • Charleston Road o Refresh pavement markings and upgrade warning signage to be compliant with 11th Edition MUTCD. ▪ Inclusion of W10-9P signs (NO TRAIN HORN) to all W10-1 posts. o Charleston Road was recently obligated Section 130 funds for a similar scope of work as Churchill Avenue. The City has selected a consultant for the design phase. ▪ Note that Section 130 will not fund Quiet Zone improvements, but will allow for spatial provisions for future quiet zone improvements. o Due to the Section 130 project likely advancing prior to any Quiet Zone improvements, much of the infrastructure upgrades are assumed to be part of the Section 130 program. o Caltrain noted the gates at this crossing (and the others) will likely need to be articulated due to needing to maintain clearances to the OCS. ▪ If the height of the gate tip when upright is longer than 22’, the gates will need to be articulated. ▪ This is due to NFPA 70E. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 34  Packet Pg. 459 of 517  Field Diagnostic Meeting - Palo Alto, California October 22nd, 2024 Field Meeting Attendees: Name Agency/Company Email Ripon Bhatia City of Palo Alto Ripon.Bhatia@CityofPaloAlto.org Ade Sogbesan CPUC Eyitejumade.Sogbesan@cpuc.ca.gov Eric Walker FRA eric.s.walker@dot.gov Lou Tolentino Caltrain TolentinoL@caltrain.com Rick Bartholomew Caltrain BartholomewR@caltrain.com Janet Wang JPB/Caltrain WangJ@caltrain.com Amanda Zerbe TASI/Caltrain azerbe@tasi.com Fred Sandoval TASI/Caltrain fsandoval@tasi.com Shawn Lima JPB/Caltrain LimaS@caltrain.com Blake Silkwood Design/ Kimley-Horn Blake.Silkwood@kimley-horn.com Taylor Brown Design/ Kimley-Horn Taylor.Brown@kimley-horn.com Existing Conditions/General Crossing comments: Preliminary Discussion/Existing Conditions: • The Diagnostic Team noted that all crossing signage and pavement markings should consider the current MUTCD. o W10-1 sign for all crossings should be 36”. o W48(CA) sign showing number of tracks at the crossing should be provided at the W10-1s. o Pavement marking should be refreshed if they are either faded or missing. o “CAUTION” signs are nonstandard and should be removed wherever present. • Existing vegetation should be removed or trimmed if obscuring visibility of the crossing traffic control devices as on-going maintenance items. • Caltrain noted the need for Vehicle Presence Detection (VPD) with exit gates. • During construction, a contractor shall maintain an ADA pathway. • When construction activities are near a school, the contractor should be mindful to schedule work activities during times when there will likely not be students present. o It has been suggested to begin work after the school day begins, and end work before the school day ends. Crossings included in Diagnostic Meeting Crossing Roadway Name DOT# Roadway Authority Railroad Owner / Primary Operator Churchill Avenue 754998E City of Palo Alto JPB/Caltrain East Meadow Drive 755010S City of Palo Alto JPB/Caltrain Charleston Road 755011Y City of Palo Alto JPB/Caltrain Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 35  Packet Pg. 460 of 517  Diagnostic Team Review and Recommendations by Location: Crossing Location: Churchill Avenue, DOT 754998E, on October 22, 2024 at 10:00am. General Crossing Comments: • Caltrain noted construction activities from the Section 130 project have created tripping hazards in two quadrants. Caltrain requests the City coordinate with the Section 130 contractor as soon as possible to have the trip/fall hazards remedied. • Existing entry gates are not articulated. This is due to vehicle strikes breaking the gates. Non- articulated gates were all that was readily available. Articulated gates to be reinstalled once Caltrain receives them. Location 1: • Quiet Zone project does not propose any improvements to this quadrant. • CPUC noted the “CAUTION” signs affixed to the W10-1/W48(CA) sign post is nonstandard and should be removed as an immediate action item. Immediate action items: 1. City to trim vegetation blocking visibility of flashing light pairs and existing W10-1/W48(CA) signage. 2. City to remove nonstandard “CAUTION” signs affixed to the W10-1/W48(CA) sign post. Location 2: • The pre-signal foundation has been poured, and it placed further north of the tracks than shown Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 36  Packet Pg. 461 of 517  on the approved construction drawings. Based on visual observations, it appears the exit gate can be placed between the tracks and the pre-signal mast arm and still remain parallel to the entry gate. o The Consultant team will evaluate the photographs taken in the field and show the pre- signal mast arm as placed as it does in the field. Consultant team will update exit gate location accordingly. Immediate action items: 1. City to coordinate with Section 130 contractor to remedy trip/fall hazard in this quadrant. Location 3: • Quiet Zone project does not propose any improvements to this quadrant. • Caltrain noted an additional trip hazard in this location. Immediate action items: 1. City to coordinate with Section 130 contractor to remedy trip/fall hazard in this quadrant. Location 4: • Caltrain noted the exit gates could employ square weights (rather than oblong) to reduce the length of the counterweight. Square weights would reduce the length of counterweight from 4.5’ to approximately 3’. • From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team. • CPUC noted the existing curb is not 6” in height. CPUC recommended the curb lines be reconstructed to a 6” height. Immediate action items: N/A Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 37  Packet Pg. 462 of 517  Diagnostic Team Review and Recommendations by Location: Crossing Location: East Meadow Drive, DOT 755010S, on October 22, 2024 at 11:00am. General Crossing Comments: • Diagnostic Team noted the existing pedestrian gates in Locations 1 and 3 require upgrades to have flashing light pairs. Location 1: • Quiet Zone project proposes to reconfigure sidewalk to relocate the pedestrian gate arm to 15’ from near track centerline. o Diagnostic Team noted that existing sidewalk infrastructure could likely be maintained. • Existing pedestrian gate to be upgraded in place to include flashing light pairs and a bell. • CPUC inquired as to how the pedestrian gate flashers will be visible to oncoming pedestrians, given the sidewalk angle, vegetation, and other existing infrastructure. o Consultant team noted the front-facing flashers could be angled toward the sidewalk approach to be more visible for pedestrians. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 38  Packet Pg. 463 of 517  • Diagnostic Team noticed existing vegetation obstructs the visibility of the W10-1/W48(CA) sign post. o CPUC noted the “CAUTION” signs affixed to the W10-1/W48(CA) sign post is nonstandard and should be removed as an immediate action item. • FRA noted the existing limit line is not placed 8’ from the nearest RRTCD, and should be shown as relocated. o Consultant team to revise design. Immediate action items: 1. City to trim vegetation blocking visibility of flashing light pairs and existing W10-1/W48(CA) signage. 2. City to remove nonstandard “CAUTION” signs affixed to the W10-1/W48(CA) sign post. Location 2: • Quiet Zone proposes sidewalk reconfiguration to accommodate exit gate. • From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team. • Caltrain indicated gate arm foundations to be installed in a material that is easily removable for maintenance purposes. A 1’ buffer surrounding the visible foundation, backfilled with pea gravel or equivalent, is preferred to allow for access to maintain the equipment. This is particularly important for the exit gates due to needing island radar. Immediate action items: N/A Location 3: • Quiet Zone proposes to upgrade existing pedestrian gate to include flashers. • CPUC inquired into the ability to provide a 2’ wide median between the railroad tracks and the Alma Street intersection. o Consultant team to evaluate turning templates with a school bus for right- and left-turns from Alma Street onto East Meadow Drive. Immediate action items: N/A Location 4: • From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team. Immediate action items: N/A Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 39  Packet Pg. 464 of 517  Diagnostic Team Review and Recommendations by Location: Crossing Location: Charleston Road, DOT 755011Y, on October 22, 2024 at 12:00pm. General Crossing Comments: • N/A Location 1: • Quiet Zone proposes to replace the pedestrian gate device to include flashers. o Upon further discussion, this will be removed from the Quiet Zone scope and coordinated through the Section 130 project. The Section 130 project has funding and will likely be constructed prior to Quiet Zone improvements. In the interest of pedestrian safety, having these gates be replaced through Section 130 accelerates the timeline of installation. • Diagnostic Team witnessed vehicles obeying the R10-6 (“STOP HERE ON RED”) signage, then advancing through the crossing and stopping in the hashed area downstream of the tracks. This was primarily observed for vehicles making a northbound right turn onto Alma. o Diagnostic Team recommended installation of a static R13-A (“NO RIGHT ON RED”) sign below the R10-6 sign to deter vehicles from queueing downstream of the tracks. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 40  Packet Pg. 465 of 517  • CPUC noted the “CAUTION” signs affixed to the W10-1/W48(CA) sign post is nonstandard and should be removed as an immediate action item. • CPUC also noted the W10-1 sign is placed in close proximity to a tree, such that the tree appears to be growing around the sign face. City to remedy. Immediate action items: 1. City to remove nonstandard “CAUTION” signs affixed to the W10-1/W48(CA) sign post. 2. City to remedy W10-1 sign face with tree growing around it. Location 2: • Quiet Zone proposes to install an exit gate and realign handrailing, allowing for provisions for a pre-signal mast arm foundation (which will be installed through the Section 130 project). • CPUC recommended the City remove the speed limit sign affixed to the existing traffic signal mast arm, and replace with a R13-A sign. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 41  Packet Pg. 466 of 517  • Caltrain noted the existing “STOP HERE” pavement markings on the sidewalk approach appear to be fading. Caltrain will coordinate with their maintenance groups and have the marking refreshed. Immediate action items: N/A Location 3: • Quiet Zone proposes to upgrade existing pedestrian gate to include flashers. o Upon further discussion, this will be removed from the Quiet Zone scope and coordinated through the Section 130 project. The Section 130 project has funding and will likely be constructed prior to Quiet Zone improvements. In the interest of pedestrian safety, having these gates be replaced through Section 130 accelerates the timeline of installation. • Caltrain noticed the existing power pole appears to not have sufficient backfill to create a level surface. While this area is channelized and there should be no pedestrians, it still is a trip/fall hazard and should be remedied. o Caltrain to coordinate with the City and PG&E on responsibility to perform this work. Immediate action items: 1. Caltrain to coordinate with City and PG&E to have the trip/fall hazard remedied. Location 4: • From visual observation, it appears the exit gate could be placed such that the detectable warning surface and pedestrian gates do not require relocation. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 42  Packet Pg. 467 of 517  o Consultant team to evaluate if this is feasible and provide updated design to Diagnostic Team. • Existing W10-/W48(CA) sign and post to be removed from this quadrant. Sign faces EB motorists and is nonstandard. Immediate action items: 1. City to remove W10-1/W48(CA) on north side of roadway facing EB motorists. Item 7 Attachment A - Palo Alto Quiet Zone Report        Item 7: Staff Report Pg. 43  Packet Pg. 468 of 517  7 1 1 2 City Council Staff Report From: City Manager Report Type: ACTION ITEMS Lead Department: Planning and Development Services Meeting Date: November 10, 2025 Report #:2504-4532 TITLE REINTRODUCED FIRST READING: Adoption of an Ordinance Updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to Adopt New Outdoor Lighting Regulations; CEQA Status — Exempt pursuant to CEQA Guidelines Section 15308 (Actions for Protection of the Environment) RECOMMENDATION Staff recommend the City Council adopt the Draft Ordinance updating Palo Alto Municipal Code (PAMC) Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28, and Section 18.40.230 of Title 18 (Zoning) to adopt new outdoor lighting regulations. EXECUTIVE SUMMARY The draft Lighting Ordinance (Attachment A) implements part of one of the City Council’s priorities (No. 18, Council consideration of an ordinance implementing Bird Safe Glass & Wildlife Light Pollution Protections standards) and is consistent with Comprehensive Plan policies (including Policies N-1.9, N-3.3, and N-7.5). The draft ordinance, which has been modified based on City Council direction on April 7, 2025, aims to reduce light pollution and align with Dark Sky principles in order to increase the health and well-being of Palo Alto residents, protect wildlife and natural ecosystems, and reduce light pollution. The City Council’s direction at the April hearing aligned with the Planning and Transportation Commission (PTC) recommendations from October 2024, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness, which may help reduce the number of complaints and reliance on code enforcement. In addition, the City Council requested that requirements be included for already- installed existing lighting to comply with the new lighting standards after a set time period. Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 1  Packet Pg. 469 of 517  7 1 1 2 The City does not have sufficient resources to proactively enforce the ordinance; staff will respond to egregious violations as capacity allows and will rely on outreach and community- based compliance measures to support implementation. BACKGROUND 1 The organization publishes guidance for communities seeking to achieve a “dark sky” and decrease light pollution. The framework focuses on principles, which have been incorporated into the proposed ordinance: 1 Link to the DarkSky International Website: https://darksky.org/who-we-are/advocates Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 2  Packet Pg. 470 of 517  7 1 1 2 4. Controlled: Use light only when it is needed. Use controls such as timers or motion detectors to ensure that light is available when it is needed, dimmed when possible, and turned off when not needed. 5. Warm-colored: Use warmer color lights where possible. Limit the amount of shorter wavelength (blue-violet) light to the least amount needed. Previous City Council Discussion On April 7, 2025,3 staff presented its recommendation for the Lighting Ordinance update, which differed from the Planning and Transportation Commission’s recommendation of October 30, 2024. Staff clarified that its recommendations primarily centered around concerns regarding impacts on enforcement and implementation once adopted. After deliberation, the City Council directed staff to return with several modifications, including requiring that new standards apply to replacement of existing lighting; allowing additional exceptions; and increasing efforts to raise awareness. These modifications aligned with most of the PTC recommendations and included requirements to be applied to all existing lighting, similar to the City of Brisbane. The City Council motion and staff analysis is provided below. ANALYSIS On April 7, 2025, the City Council directed staff to revise the draft ordinance for greater consistency with the recommendations made by the Planning and Transportation Commission in October 2024. The City Council’s motion items are italicized below, and staff descriptions on how each was incorporated into the draft ordinance follow each element of the motion: MOTION: A. Ensure protections in the existing code are not eroded for existing outdoor lighting in all zoning districts. a. Retain the Requirements and Guidelines that the current municipal code provides to riparian ecosystems section 18.40.140. No revisions needed as the updated ordinance provides equivalent or greater protection from light pollution compared to the existing outdoor lighting requirements. Additionally, the existing provisions and requirements in PAMC 18.40.140 will remain until the Stream Corridor Protection Ordinance Update is adopted. B. Require this ordinance apply to all new or replacement outdoor lighting consistent with the Planning and Transportation Commission (PTC) motion of October 30th to include: 3 Link to the City Council agenda for the public hearing on April 7, 2025 (Item #17): https://cityofpaloalto.primegov.com/Portal/Meeting?meetingTemplateId=16024 Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 3  Packet Pg. 471 of 517  7 1 1 2 a. Installation of new outdoor lighting, replacement of existing outdoor lighting fixtures, or changing the lighting type or system; Incorporated in Section 18.40.250(c). The language from the motion was added to the applicability section. b. for replacement lighting fixtures on buildings and structures, develop a hardship exception provision that would consider technical feasibility or financial burden to only apply to replacements on existing buildings and structures; and Incorporated in Section 18.40.250(j)(2). An exception can be requested if implementation of the lighting requirements more than doubles the cost of the project. c. any existing nonconforming lighting after 10 years for residential and 5 years for nonresidential shall remain extinguished until brought into compliance with this ordinance. Incorporated in Section 18.40.250(l). The deadline for existing lighting to comply with the new requirements is five years from the effective date of the ordinance for nonresidential zoning districts, and 10 years for residential and mixed-use zoning districts. Any existing lighting that has not been brought into compliance with the Code by these deadlines must remain extinguished (off) until it meets the new lighting standards. C. Existing luminaires that have the technical capacity to be adjusted to comply with the ordinance without a need to change the fixture should comply within two (2) years of the effective date of the ordinance (i.e: fixtures that have existing dimmers, adjustable directionality, timers, Correlated Color Temperature adjusters, motion sensors, etc.). Incorporated in Section 18.40.250(l)(2). The deadline for existing lighting to comply through use of existing features is two years from the ordinance's effective date. That lighting will be required to meet the new standards, with the exception of the shielding requirements. D. Amend Section (4)(A) to include specific application of the curfew to all new, replacement, and existing outdoor luminaires. a. Citywide and Holiday lighting curfew of midnight. Incorporated in Sections 18.40.250(d)(4) and 18.40.250(e)(4). The lighting curfew provision was revised to extend the turn-off time of all outdoor lighting to 12:00 Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 4  Packet Pg. 472 of 517  7 1 1 2 a.m. Additionally, the seasonal lighting exception language was revised to explicitly state when such lighting is subject to extinguishment. E. Implement the October 30th PTC motion regarding light trespass to change the light trespass from 0.5 to 0.1 foot candles at every reference throughout the ordinance. Incorporated throughout the ordinance. F. Incorporate into Section 1.B. Findings and Declarations, and Section 2 (a) Purpose, the Five Principles for Responsible Outdoor Lighting. One of the sections should include the full language of the principles. Incorporated (Section 1B of the ordinance, and Section 18.40.250(a)(1)). G. Develop an exception for special security concerns. An exemption has been incorporated in the draft ordinance (Section 18.40.250(d)(7)) to address this direction, however without use of “special security concerns.” See below for further discussion of the specific approach presented. H. Staff to return with recommendations on compliance mechanisms that would reduce the need for code enforcement – such as self-certification under business licenses, education through Utilities inserts, and potential adoption of a tool similar to Brisbane’s Good Neighbor Letter. Potential measures are explained below for the City Council consideration, along with the pros and cons for each measure. Exception for Special Security Concerns During the April hearing, the City Council heard concerns from a community member about how the proposed new lighting standards might impact security, especially in their neighborhood along Edgewood Drive. A speaker noted that less or limited lighting could worsen existing security concerns for property owners in the neighborhood. In response, the City Council asked staff to look into allowing an exception for properties with heightened security concerns. Staff worked with the City’s Police Department and reviewed crime information from the past year for areas near the San Francisquito Creek. While the information showed that crimes and calls for service do occur in this area, they were not significantly higher in the specific residential neighborhood mentioned compared to other areas of the City. The Police Department also confirmed that the City currently does not have any areas identified as having Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 5  Packet Pg. 473 of 517  7 1 1 2 special concerns due to high crime rates, and there are not areas in Palo Alto that they would characterize as “high crime.” While crime data do not support the designation of specific areas as high security risk zones, staff recognize some residents may have heightened perceptions of safety concerns based on local conditions or experiences. Neighbor Letter Template: A letter template modeled on tools used by the City of Brisbane and DarkSky International could allow residents to inform neighbors about the ordinance and encourage voluntary compliance. While this may reduce initial complaints to the City, it relies on voluntary action and may lead to disputes or unprioritized reports. Educational Materials: Staff will develop outreach materials, including online content, printed handouts, and utility bill inserts, to raise awareness about the new requirements. This approach aims to reduce inadvertent non-compliance through public education but has no direct enforcement effect and depends on public engagement. Affidavit Letter: Staff considered requiring applicants and property owners to sign an affidavit acknowledging awareness of the lighting requirements during the permit process. However, this approach would duplicate information already reviewed as part Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 6  Packet Pg. 474 of 517  7 1 1 2 of plan review and introduce additional regulatory steps to the permitting process, and is therefore not recommended. POLICY IMPLICATIONS FISCAL/RESOURCE IMPACT STAKEHOLDER ENGAGEMENT Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 7  Packet Pg. 475 of 517  7 1 1 2 Valley Audubon Society and Sierra Club Loma Prieta Chapter to solicit their input on the proposed ordinances. Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 8  Packet Pg. 476 of 517  7 1 1 2 ENVIRONMENTAL REVIEW ATTACHMENTS APPROVED BY: Item 8 Item 8 Staff Report        Item 8: Staff Report Pg. 9  Packet Pg. 477 of 517  *** NOT YET APPROVED *** 1 0160151_20250821_ay16 Ordinance No. _____ Ordinance of the Council of the City of Palo Alto Repealing and Replacing Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) and Amending Chapters 18.10, 18.12, 18.28 and Section 18.40.230 of Title 18 (Zoning) of the Palo Alto Municipal Code to Adopt New Outdoor Lighting Regulations The Council of the City of Palo Alto ORDAINS as follows: SECTION 1. Findings and Declarations. The City Council finds and declares as follows: A. The term “dark sky” generally refers to achievement of significant reduc on in light pollu on so that the sky returns or becomes closer to its natural nigh me darkness. B. Adhering to Dark Sky principles, which promote responsible outdoor ligh ng prac ces, can significantly reduce light pollu on and mi gate its harmful effects. These principles emphasize using light only if it is needed, direc ng so that it falls only where it is needed, having ligh ng only when it is necessary and no brighter than necessary, and using warmer lights. C. On January 29, 2024, the City Council selected four City Council priori es, one of which is the Climate Change & Natural Environment – Protec on & Adapta on, and included an objec ve to “approve a bird safe glass and wildlife light pollu on protec ons ordinance.” D. On February 14, 2024, and July 18, 2024, the Architectural Review Board conducted study sessions and provided feedback on the concepts of the DarkSky regula ons and dra ordinance. E. On August 14, 2024, the Planning and Transporta on Commission reviewed the dra ordinance, provided feedback and recommended that staff return with more informa on, con nuing the hearing to a date uncertain. F. On October 30, 2024, the Planning and Transporta on Commission recommended that City Council adopt the ordinance. G. The ordinance aligns with Dark Sky principles and is intended to reduce light pollu on at night, protec ng wildlife and suppor ng a sustainable and resilient community. SECTION 2. Section 18.40.250 (Lighting) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is repealed in its entirety and replaced with a new Section 18.40.250 (Lighting) to read as follows: 18.40.250 Lighting (a) Purpose. The intent of this section is to establish exterior lighting standards to reduce light pollution. Exterior lighting of parking areas, pathways, and common open spaces, including fixtures on building facades and free-standing lighting should aim to: Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 10  Packet Pg. 478 of 517  *** NOT YET APPROVED *** 2 0160151_20250821_ay16 (1) Reduce light pollution and its adverse effects on the environment, wildlife habitat, and human health through implementing Dark Sky Principles of responsible outdoor lighting that are useful, targeted, low level, controlled, and warm colored; (2) Minimize the visual impacts of lighting on abutting or nearby properties and from adjacent roadways; (3) Provide safe and secure access on a site and adjacent pedestrian routes; (4) Achieve maximum energy efficiency; and (5) Complement the architectural design of the project. (b) Definitions. For purposes of this chapter, the following words and phrases are defined as follows: (1) “Correlated Color Temperature” or “Color Temperature” means a specification of the color appearance of the light emitted by a light source, measured in Kelvin (K). Warmer color temperatures are a lower number, and cooler color temperatures are a higher number. (2) “Fully Shielded” means a luminaire constructed and installed in such a manner that all light emitted, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction from any part of the luminaire, is projected below the horizontal plane extending from the bottom of the lamp. (3) “Glare” means light entering the eye directly from a luminaire or indirectly from reflective surfaces that causes visual discomfort or reduced visibility to a person. (4) “Lamp” means, in generic terms, a source light, often called a “bulb” or “tube.” Examples include incandescent, fluorescent, high-intensity discharge (HID) lamps, and low-pressure sodium (LPS) lamps, as well as light-emitting diode (LED) modules and arrays. (5) “Light pollution” means the material adverse effect of artificial light, including, but not limited to, glare, light trespass, sky glow, energy waste, compromised safety and security, and impacts on the nocturnal environment, including light sources that are left on when they no longer serve a useful function. (6) “Lumen” means the common unit of measure used to quantify the amount of visible light produced by a lamp or emitted from a luminaire (as distinct from “Watt,” a measure of power consumption). (7) “Luminaire” means outdoor illuminating devices, lamps, and similar devices, including solar powered lights, and all parts used to distribute the light and/or protect the lamp, permanently installed or portable. (8) “Seasonal ligh ng” means ligh ng installed and operated in connec on with holidays or tradi ons within the me period specified in Sec on 18.40.250(d)(4). String Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 11  Packet Pg. 479 of 517  *** NOT YET APPROVED *** 3 0160151_20250821_ay16 ligh ng used outside these periods is not considered seasonal ligh ng and shall be subject to requirements in Sec on 18.40.250(f)(6). (9) “String lighting” means light sources connected by free-strung wires or inside of tubing resulting in several or many points of light. (c) Applicability. Except as otherwise provided in subsections (d) and (e)(4)(A) below, the outdoor lighting standards and guidelines set forth in this Section shall apply to the following projects: (1) All newly constructed structures and buildings; or (2) Structures or buildings proposing a Substantial Remodel, as defined in Section 16.14.070; or (3) If a building permit is required: New installation of outdoor luminaires, replacement of existing outdoor luminaires, or modifications to the lighting type or system. (4) All existing outdoor light fixtures installed prior to the effective date of this ordinance shall conform to the provisions of this ordinance according to the compliance schedule set forth in Section 18.40.250(l). (d) Exemptions. The following types of lighting are exempt from the lighting requirements of the section: (1) Illuminated street numbers; (2) Temporary construction or lighting for emergency personnel; (3) Lighting authorized by a special event, special or temporary use permit; (4) Seasonal lighting, subject to extinguishment at 12:00 a.m., during the period of October 15 through January 15 of each year; (5) Lighting for Airport Operations. Nothing in this section shall be interpreted to restrict, limit, or otherwise regulate lighting that, in the reasonable judgment of the Airport Manager, is prudent or necessary for airport operations, airport safety, or air navigation in connection with operations at the Palo Alto Municipal Airport; or (6) Lighting for Emergency Shelters. Lighting for emergency shelters shall be subject to PAMC 18.14.060. (7) Single family residential sites adjacent to San Francisquito Creek and fronting on Edgewood Drive if the portion of the site subject to a permanent easement in favor of the Santa Clara Valley Water District (or its successor in interest) for flood control purposes is reconfigured after January 1, 2002. These sites shall be subject to the requirements under Section 18.40.250(e)(4)(A). (e) Lighting Standards. (1) Shielding Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 12  Packet Pg. 480 of 517  *** NOT YET APPROVED *** 4 0160151_20250821_ay16 (A) All outdoor lighting shall be fully shielded and directed to avoid light trespass. No lighting shall trespass more than 0.1-foot candle as measured at the property line. (B) Exceptions for shielding requirements shall be applied to the following types of lighting: (i) Low voltage landscape uplighting used to illuminate fountains, shrubbery, trees, and walkways, outdoor art or public monuments provided that they use no more than a 10-watt incandescent bulb or LED equivalent or emit no more than 150 lumens. These luminaires may not direct light towards the public right-of-way; (ii) Sidewalk-facing ligh ng for zero lot line developments, provided the luminaires are motion-activated and automatically extinguish within five minutes without further activation; or (iii) String lighting pursuant to Section 18.40.250(f)(5). (2) Parking Lot Lighting Height. (A) Exterior lighting fixtures shall be mounted less than or equal to 15 feet from grade to top of fixture in parking lots in residential development and 20 feet in parking lots with commercial and mixed-use development. (3) Illumination Level and Color Temperature (A) All light sources shall have a correlated color temperature of 2,700 Kelvin or less. (B) The maximum outdoor light intensity on a site shall not exceed an average value of 5 foot-candles. (4) Lighting Control. (A) Lighting Curfew. Unlike other provisions in this section, the Lighting Curfew shall apply to all outdoor luminaires for new and existing buildings and structures, unless otherwise approved. All outdoor lighting shall be fully extinguished or be motion sensor operated by 12:00 a.m., two hours after the close of business, or when people are no longer present in exterior areas, whichever is later. (B) All lighting activated by motion sensor shall be set up to extinguish after no more than five minutes without further activation. (C) All lighting shall be automatically extinguished using a control device or system when there is sufficient daylight available, except for lighting under canopies or lighting for tunnels, parking garages, or garage entrances. (D) Exceptions for Lighting Control. Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 13  Packet Pg. 481 of 517  *** NOT YET APPROVED *** 5 0160151_20250821_ay16 (i) Any lighting at building entrances, parking areas, walkways, and driveways area; (ii) Outdoor pathway lights that emit 25 lumens or less; or (iii) Lighting that illuminates a pedestrian pathway (examples include bollard, in-place step, or building mounted), provided that such lighting is a maximum height of four (4) feet above the pathway and fully shielded. (f) Special Purpose Lighting. The standards in this section shall prevail over any conflicting standard in subsection (e). (1) Low Density Residential Lighting. In addition to the lighting standards in the section, the following lighting requirements shall be applicable to projects in R-1, R-2, RE, RMD, NV- R1, or NV-R2. (A) When abutting any residential use, no spillover of lighting to adjacent properties shall be allowed. (B) A maximum of 1,260 lumens shall be allowed for each fully shielded outdoor lighting. No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting. (C) Skylights shall limit illuminance and glare during night hours. Glare shall be mitigated through the use of translucent glass, shading systems, and interior light placement. Skylights shall not use white glass. (D) Height for Recreational and Security Lighting. Free-standing lighting shall be a maximum of twelve feet (12’) in height for those that were installed on or after March 11, 1991. (2) Athletic Facilities Lighting. Outdoor athletic facilities shall conform to the following standards: (A) Field lighting is provided exclusively for illumination of the surface of play and viewing stands, and adjacent proximity areas for public safety. (B) Illumination levels shall be adjustable based on the task (e.g., active play vs. field maintenance). (C) Off-site impacts of the lighting will be limited to the greatest practical extent possible. (D) Lights shall be extinguished by 10:30 p.m. except when the facilities are being used for active play and maintenance before or after permitted events, and the lights are equipped with a timer. (E) Timers that automatically extinguish lights shall be installed to prevent lights being left on accidentally overnight. Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 14  Packet Pg. 482 of 517  *** NOT YET APPROVED *** 6 0160151_20250821_ay16 (3) Automobile Service Station Lighting (A) Lighting fixtures in the ceiling of canopies shall be fully recessed or mounted directly to the underside of the canopy. All luminaires shall be located so that no lighting is directed towards the adjoining property or public rights-of-way. (B) Luminaires are not permitted on top of the canopy fascia. (C) The maximum light intensity under the canopy shall not exceed an average foot- candle of 12.5, when measured at finished grade. (D) No free-standing lighting shall be higher than 15 feet above finished grade. (E) The canopy fascia shall not be illuminated. (4) Outdoor Space Above Ground Floor. These requirements apply to all outdoor spaces located above ground level, including, but not limited to, roo op gardens, roo op restaurants or bars, balconies, and decks. (A) Any lighting shall be shielded from public views and any luminaires shall be fully shielded and no uplighting shall be permitted. (B) Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m. or as permitted pursuant to Section 18.40.250(e)(4)(D) (C) No light trespass shall be allowed more than 0.1 foot-candle as measured beyond the perimeter of the roof deck or other outdoor space above the ground floor. (5) String Lighting. (A) String lighting color temperature shall not exceed 2,700 Kelvin and no individual lamp that is part of a string lighting installation shall exceed a rating of 42 lumens. No string lighting shall be blinking, flashing, or chasing. (B) For commercial and mixed-use areas, string lighting shall be limited to designated outside dining or display areas or common open space (i.e. courtyard or patio). (6) Parklets. Lighting for any parklets shall comply with the lighting standards established in the Permanent Parklet Program. (g) Prohibited Lighting. The following types of lighting are prohibited except when used by emergency service personnel during an emergency: (1) Outdoor lighting that blinks, flashes, or rotates; or (2) Searchlights, aerial lasers, or spotlights. (h) Lighting for Signs. See Chapter 16.20 for lighting requirements for signs. (i) Additional Provisions and Conflict Precedence. Lighting required by the Building Code, Fire Code, or state or federal law shall additionally comply with the requirements of this section, Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 15  Packet Pg. 483 of 517  *** NOT YET APPROVED *** 7 0160151_20250821_ay16 unless these requirements necessarily conflict with the aforementioned Codes and laws. In the event of a conflict, the standards in the applicable Codes and laws shall prevail. (j) Hardship Exceptions. The Director may grant an exception from the requirements in Section 18.40.250, if a project applicant provides evidence demonstrating one of the following hardships: (1) Implementation of the lighting requirements in this ordinance would impair the historical integrity and character-defining features of the building and create an adverse impact to the building’s historical, architectural, and cultural significance; or (2) Implementation of the lighting requirements in this ordinance would more than double the cost of the project. This exception shall apply only for replacement of existing outdoor luminaires or changing the lighting type or system that requires a building permit. (k) Public Facilities. Public Facilities, including City-owned and operated facilities, shall comply with the outdoor lighting standards of this Section to the extent feasible. The Director may grant adjustments to any applicable lighting standards for such facilities if the adjustment is necessary for the efficient operation, maintenance, or safety of the facility, or to ensure public safety and security; and is consistent with the overall intent and purpose of this Section. A written request for an adjustment, including supporting documentation, shall be submitted and shall be reviewed according to the applicable review procedures in PAMC Section 18.77 associated with the proposed development. (l) Existing Nonconforming Lighting. (1) Within two years of [the effective date of this ordinance]: Where existing outdoor luminaires have the ability to adjust (through existing dimmers, directional adjustability, timers, etc.), the requirements under Section 18.40.140(e), except for the shielding requirements under the subsection 18.40.140(e)(1), shall apply. (2) For all existing outdoor luminaires, the requirements under Section 18.40.140(e) shall apply within the following timeframes from [the effective date of this ordinance]: (A) Residential and Mixed Use Zoning Districts: Within ten years. (B) Nonresidential Zoning Districts: Within five years. (3) Any nonconforming lighting still in place after the compliance deadline shall remain extinguished at all times until they are brought into compliance. SECTION 3. Subsection (e) of Section 18.40.230 (Rooftop Gardens) of Chapter 18.40 (General Standards and Exceptions) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (e) Any lighting shall be shielded from public views and have full cutoff fixtures that cast downward-facing light, or consist of low-level string lights; no up-lighting is permitted. Lights shall be dimmable to control glare and placed on timers to turn off after 10:00 p.m. Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 16  Packet Pg. 484 of 517  *** NOT YET APPROVED *** 8 0160151_20250821_ay16 Photometric diagrams must be submitted by the applicant to ensure there are no spillover impacts into windows or openings of adjacent properties.For lighting requirements, refer to Section 18.40.250. SECTION 4. Subsection (g) of Section 18.10.040 (Development Standards) of Chapter 18.10 (Low Density Residential (RE, R-2 and RMD) Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (g) Lighting in R-2 District In the R-2 district, recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free- standing recreational and security lighting installed on or later than March 11, 1991, shall be restricted to twelve feet (12') in height. For lighting requirements, refer to Section 18.40.250. SECTION 5. Subsection (k) of Section 18.12.040 (Site Development Standards) of Chapter 18.12 (R-1 Single-Family Residential District) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (k) Lighting Recreational and security lighting shall be permitted only so long as the lighting is shielded so that the direct light does not extend beyond the property where it is located. Free-standing recreational and security lighting installed on or later than March 11, 1991 shall be restricted to twelve feet (12') in height. Direct light from outdoor fixtures shall only fall on the walls, eaves, and yard areas of the site on which it is located. Outdoor fixtures shall have lens covers or reflectors that direct the light away from the neighboring properties. For lighting requirements, refer to Section 18.40.250. SECTION 6. Subsection (n) of Section 18.28.270 (Additional OS District Regulations) of Chapter 18.28 (Special Purpose Districts) of Title 18 (Zoning) of the Palo Alto Municipal Code is amended to read as follows (additions underlined; deletions struck-through): (n) Light and Glare Exterior lighting should be low-intensity and shielded from view so it is not directly visible from off-site. The light emitted from skylights shall be minimal during the night hours. Utilizing treatments such as translucent glass, shading systems, and interior light placement can reduce the night glare. Skylights shall not use white glass. For lighting requirements, refer to Section 18.40.250. SECTION 7. If any section, subsection, clause or phrase of this Ordinance is for any reason held to be invalid, such decision shall not affect the validity of the remaining portion or sections of the Ordinance. The Council hereby declares that it should have adopted the Ordinance and each section, subsection, sentence, clause or phrase thereof irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid. Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 17  Packet Pg. 485 of 517  *** NOT YET APPROVED *** 9 0160151_20250821_ay16 SECTION 8. The Council finds that this project is exempt from the provisions of the California Environmental Quality Act (“CEQA”), pursuant to Section 15061 of the CEQA Guidelines, because it can be seen with certainty that there is no possibility that the ordinance will have a significant effect on the environment and Section 15308, as an action by a regulatory agency to protect the environment. SECTION 9. This ordinance shall be effective on the thirty-first day following its adoption. SECTION 10. This Ordinance shall not apply to any project application deemed complete prior to the effective date of this Ordinance. INTRODUCED: PASSED: AYES: NOES: ABSENT: ABSTENTIONS: NOT PARTICIPATING: ATTEST: ____________________________                     ____________________________ City Clerk                                                             Mayor APPROVED AS TO FORM:                                    APPROVED: ____________________________                     ____________________________ Assistant City Attorney                                    City Manager                                                                             ____________________________                                                                    Director of Planning & Development Services Item 8 Attachment A - Draft Ordinance Updating Lighting Standards (PAMC Section 18.40.250)        Item 8: Staff Report Pg. 18  Packet Pg. 486 of 517  Have you heard? The City of Brisbane passed a “Dark Sky Ordinance” that regulates outdoor lighting. You may not be aware of this, but your lights are: too bright shining in our window interfering with our sleep ________________ ________________ Please consider: directing your lights downward shielding the lamp using a lower wattage bulb using a “warmer” color temperature using motion sensor and/or timer ________________ I would be willing to help with the cost and/or implementation of changes. In addition to helping us out, these actions can help bring you into compliance with the City’s ordinance, reduce light pollution, and improve the environment. Thanks so much for your time and understanding! - your concerned neighbor Learn more at brisbaneca.org/darksky Adapted by OSEC from darksky.org/resources/what-is-light-pollution/light-pollution-solutions/lighting/my-neighbors-lighting/ Dear Neighbor... Shielding reduces glare that can be dangerous and unsafe. Glare can be blinding and create harsh shadows where “bad guys” can hide. Shielded lighting provides real security, not just the illusion of security, which I think we both want for our families and friends. There are several other ways to improve lighting, save money, and still be safe. One is using motion sensors, which alert you if someone is in your yard after dark and have the added benefit of reducing your electric bills by keeping the lights off when they’re not needed. Timers are another way to save money because these devices turn off your lights when they’re not needed, for example, when you retire for the night. Item 8 Attachment B - Examples of Educational Materials and Template Neighbor Letters        Item 8: Staff Report Pg. 19  Packet Pg. 487 of 517  [Date] Dear [insert neighbor’s name], I’m your neighbor [insert your name] at [address], and I would love to talk with you about good outdoor lighting. I notice that you have installed outdoor lights on your property, and I applaud your desire to help improve our neighborhood. You may not have realized that some of your lights are a bit too bright and shine in [pick areas as they apply: our bedroom window, the backyard, into our house etc.] and interfere with our [sleep, hobbies, view of the sky, etc.]. I don’t wish to tell you what to do with your home, but I’m hoping we can openly discuss this and come to a compromise that fulfills and respects everyone’s needs. Please understand I’m not asking you to remove the lights, but perhaps make subtle changes that will work for everyone. One idea would be redirecting the light by shielding the fixtures so that they are even more effective. Unshielded lamps create dangerous glare — this glare causes harsh shadows which can blind you to real, hidden hazards such as unwanted visitors (see pictures below). On the other hand, shielded lighting provides real security (not just the illusion of security) which I think we both want for our homes. As an extra benefit, shielding a lamp usually involves a lower wattage bulb, which would be a money-saver on your electric bill. There are several other ways to improve lighting, save money, and still be safe. One is using motion sensors, which alert you if someone is in your yard after dark, and also reduce your electric bills by keeping the lights off when not needed. Timers are another way to save money, since they can automatically turn off your outdoor lights when you go to bed. Thank you so much for your time and understanding! I would love to talk with you about how I can help, and how lighting changes can benefit your safety, budget, and the night sky. Sincerely, [your name] [contact info] Item 8 Attachment B - Examples of Educational Materials and Template Neighbor Letters        Item 8: Staff Report Pg. 20  Packet Pg. 488 of 517  Item 8 Attachment B - Examples of Educational Materials and Template Neighbor Letters        Item 8: Staff Report Pg. 21  Packet Pg. 489 of 517  Shielded lights protect the night. Item 8 Attachment B - Examples of Educational Materials and Template Neighbor Letters        Item 8: Staff Report Pg. 22  Packet Pg. 490 of 517  Protect the night Preserving and restoring the natural nighttime environment is more urgent than ever. Light pollution continues to grow at an alarming rate, harming our health, damaging the environment, and diminishing our view of the stars. DarkSky International has a plan to save the night, but we need your help. The stars are disappearing Join the movement and help save the night DarkSky is a global community working together to save the night. Sign-up today for DarkSky e-news updates to learn more. DarkSky International is a U.S.-based 501(c)(3) nonprofit that supports a global community and movement dedicated to preserving and protecting the natural nighttime environment. DarkSky International 5049 East Broadway Blvd #105 Tucson AZ 85711 USA www.DarkSky.org +1-520-293-3198 Light pollution isreversible! Unlike other forms of pollution, light pollution is a problem with solutions that are easy to implement. These solutions deliver immediate and lasting results. SUCCESS STORY In 2018, the City of Tucson, Arizona, U.S.A. (population 500,000) upgraded its streetlights. By doing so, it saved $2.2 million per year in energy costs and reduced light pollution by 7%. WE’RE MAKING AN IMPACT 1,000+ More than 1,000 DarkSky Approved lighting fixtures are available on the market. 2,000+ DarkSky supports more than 2,000 volunteer Advocates in 49 countries. 70+ DarkSky supports more than 70 chapters in 24 countries. 200+ More than 200 International Dark Sky Places have been certified, protecting over 160,000 sq km of dark places around the globe. Photo credit: Bin Chen Item 8 Attachment B - Examples of Educational Materials and Template Neighbor Letters        Item 8: Staff Report Pg. 23  Packet Pg. 491 of 517  Light pollution... What is light pollution? Light pollution is the human-made alteration of outdoor light levels from those occurring naturally. When we over-light, fail to use timers and sensors, or use the wrong color of light, we negatively affect many parts of our world. Destroys critical wildlife habitat Plants and animals depend on Earth’s daily light and dark cycle to govern life-sustaining behaviors. Research shows that artificial light at night has adverse and even deadly effects on many species. Wastes energy and money Most outdoor lighting is wasted. This energy waste increases greenhouse gas emissions contributing to climate change and wastes billions of dollars each year. Harms human health Studies indicate that artificial light at night negatively affects human health by increasing our risks for obesity, sleep disorders, depression, diabetes, breast cancer, and more. Decreases safety and security There is no clear scientific evidence that increased outdoor lighting deters crime. In fact, glare from unshielded streetlights can decrease personal safety, contributing to both crime and accidents. Robs us of our night sky heritage Our ancestors experienced a night sky that inspired science, religion, philosophy, art, and literature. Now, millions of children across the globe will never know the wonder of seeing the Milky Way. Inhibits scientific research Satellites in low Earth orbit create visible trails in the night sky, inhibiting astronomical research and jeopardizing NASA’s early warning system for asteroid collisions. What can I do? DarkSky’s Five Principles for Responsible Outdoor Lighting can help you make smart choices to reduce light pollution. Do your lights protect the night? All light should have a clear purpose. Use lights only when and where they are needed. Shield and aim your light so it only falls downward and where it is useful. Lights should be no brighter than necessary to save money and reduce glare. Lights should only be on when needed. Use timers and motions sensors. Warm-colored light causes less skyglow. Use amber-toned lights whenever possible. Is it useful? Is it targeted? Is it low-level? Is it controlled? Is it warm-colored? Visit darksky.org to learn more about the importance of the night and what you can do to reduce light pollution around your home and community. Learn more Learn more about light pollution Item 8 Attachment B - Examples of Educational Materials and Template Neighbor Letters        Item 8: Staff Report Pg. 24  Packet Pg. 492 of 517  1441 Edgewood Dr Palo Alto, CA 94301 April 26, 2025 Kelly Cha Senior Planner Planning and Development Services 250 Hamilton Avenue, Fifth Floor Palo Alto, CA 94301 RE: Outdoor Lighting Update (“Dark Sky”) Dear Ms. Cha: I shared in my prior letters to you and city staff (“Staff”), the Planning & Transportation Committee (“PTC”), and the City Council for the City of Palo Alto (“City Council”) my opposition to the proposed lighting ordinance currently under consideration. I watched with great sadness the City Council on April 7, 2025 pass a motion to incorporate even more egregious conditions into the poorly drafted outdoor lighting ordinance, particularly the expansion to cover any existing light after 10 years. As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following:  Deep security concerns. Residents of Edgewood Dr have a valid and deep concern about safety and security given the frequent and repeated crime we and our property face, the growing unhoused population living immediately adjacent in the San Francisquito Creek (“Creek”) combined with the City’s unwillingness or inability to address the growing issue, and our immediate proximity to East Palo and the spillover impact of frequent crime. The most obvious remedy is to exempt houses on this street from the ordinance or significant portions of the ordinance. While I appreciate Staff’s concern with defining a “high crime” neighborhood, it is vital that the City Council’s direction to address those with “special security concerns” provides adequate relief for homeowners abutting the Creek to install and operate sufficient lighting to protect ourselves. I am terrified of the safety issues my wife and young daughter will face returning to a dark house, trying to take out the trash through a dark backyard, as they are forced to navigate an unlit pool, or are unable to see criminals accessing our yard. Through expensive renovations we can mitigate some of the safety issues caused by this poor ordinance, some of the most severe will remain. Fear for our safety and security is heightened when combined with the other ordinances also under consideration – imagine being forced to no longer allowed have adequate outdoor lighting, no longer allowed to maintain a fence separating you from criminals and unhoused population, and then having to cover your windows in dots so you cannot even see the criminals concealed in the darkness with unfettered access to your backyard. These ordinances, individually and collectively, greatly compromise our safety and security. Please understand these fears are very real for us; we have even started to look at buying firearms and obtaining conceal and carry permits just so we can come home at night! Item 8 Attachment C - Public Comments received after the City Council hearing on April 7, 2025        Item 8: Staff Report Pg. 25  Packet Pg. 493 of 517  - 2 -  Cost to comply exception / legal challenges and taking claim. With the expansion to cover all existing fixtures, the City must add an exception for properties that would incur excess cost to comply. After years of planning and building, I recently completed construction of my brand new home which I previously expected to be our family’s “forever” home. The preliminary estimate to comply with the new draft code as written requires that I destroy approximately $90,000 of lighting (and fan) materials and spend approximately $210,000 in new materials and labor. (This is just for the fixtures and related costs. The systems upgrades described later add further to this loss.) In 10 years, this would represent approximately $350,000 or more of expense (based on forecasted inflation rates). I can only imagine how much worse that will get with most of these fixtures and luminaires manufactured overseas. Imposing such extraordinary costs on homeowners is patently unfair. Would you want to have to work for 1-2 years just to comply with a new ordinance passed by the city? While my costs may be greater than some others, the cost to completely replace exterior lights for homeowners across Palo Alto is likely to be extremely high and grossly underestimated by City Council. Do we really want to pass this cost to so many homeowners? Do we really want to produce this much waste? A hardship exemption for only a temporary period of time, or requiring proof of financial distress, is wholly insufficient to remedy this loss. A cost to comply exemption is needed. Absent such an exception, it is paramount Staff and the City Attorney advise the City Council that passing such an ordinance leaves the city liable for a takings claim. While it is not my preference, please understand that passing an ordinance with a present value cost to me of $210,000 leaves me with no recourse but to challenge of the ordinance’s validity in court and assert a takings claim against the City for the entirety of this loss.  Shielding standard for non-confirming lighting after 10 years. The overwhelming majority of the costs noted above arise from the shielding requirement applied to non-conforming lights after 10 years. One of the primary stated objectives of the ordinance is to reduce light pollution and minimize visual impact to neighbors. If the 10 year restriction is included in the next draft ordinance, I strongly recommend and beg to allow non-shielded lights so long as their lux output (as measured at the property border) satisfies the light trespass requirements (previously 0.5 lux but now proposed to be 0.1 lux). Like many homeowners, this would mean I would not be required to replace every fixture and could instead replace the luminaire and/or use dimming to bring existing fixtures into compliance. While this would not completely solve glare, this would meet the primary objectives of the ordinance with far reduced cost to homeowners. Moreover, this would further benefit the community since many fixtures would then have the “technical capacity” to comply under the 2 year window rather than waiting the full 10 years.  Lighting output measurement lumens vs lux. Most of the restrictions in the proposed ordinance 18.40.250 are written with regard to “lumens” of output. The original draft ordinance applied to new construction or new luminaires. As such, “lumens” was chosen presumably to make it easier for buyers to select luminaires with said rated lumens output (and for Staff to validate those specs during Planning). Now that the code will extend to existing luminaires, it is vital the code also express the limits in lux. It is my understanding that measuring lumen must be performed in a laboratory. I am told it is not practical to measure lumen output of an existing luminaire in the field. The could would therefore set a standard that could not be objectively measured by code enforcement either. Moreover, lumen is often the theoretical maximum which Item 8 Attachment C - Public Comments received after the City Council hearing on April 7, 2025        Item 8: Staff Report Pg. 26  Packet Pg. 494 of 517  - 3 - is reduced by the quality of the actual luminaire, the power system, distance, and other factors. One important benefit of expressing output in lux is that it will also allow lighting designers to construct systems with dimmed lights. Most lighting systems are better served running well below 100% of maximum output to extend the lifetime of transformers and luminaires, therefore reducing cost and waste. Most importantly, it will fixtures with luminaires that cannot comply by lumen to comply through dimming. For example, I have two outdoor fan with a down light, adjustable color that can be made to work at 2700K or less, but with lumen that is too high. The manufacturer does not make a down light that meets the lumen requirements. The light, however, is dimmable and could remain if a lux threshold were established.  Conflict in 18.40.250(f)(1)(B) with 18.40.250(e)(1). The draft ordinance 18.40.250(f)(1)(B) states that “No more than 420 lumens shall be allowed for permitted non-shielded outdoor lighting.” The drafting suggests the intent of this section is to allow non-shielded low voltage outdoor lights so long as the luminaire is less than or equal to 420 lumens. Section 18.250(f)(1) also states that low density outdoor residential lights are subject both to that constraint and all others. Section 18.40.250(e)(1)(B) states that all lights must be fully shielded unless it is low voltage up-lights with no more than 150 lumen. This presents a conflict that must be resolved. In the context of this ordinance, the 420 lumens output is most appropriate limit.  Exemptions for front porch. The draft ordinance 18.40.250(d) provides a list of exemptions, including for illuminated street numbers. This exemption presumably recognizes the legitimate public safety need for first responders to locate a property in the event of an emergency. I would contend that providing safety lighting at a property’s front door is a similar legitimate public safety need. Lighting at a home’s primary ingress and egress is of importance to guests, first responders, and others. For most properties, it is impractical to install motion sensors on a front porch. Given this ordinance is being applied to an urban center, lighting the front porch should be exempted, at least with regard to curfew.  Outdoor security light output. The outdoor security lighting output proposed in 18.40.250(f)(2)(D) is limited to 1,600 lumens. First, this is grossly inadequate for security light output over large areas. The result would force homeowners to install multiple security lights, which is both expensive and likely to be worse for light pollution (not to mention potentially more false positives). Instead, this section for outdoor security lights should be limited only to lux light trespass only as already provided in 18.40.250(f)(2)(C). Therefore, sub-paragraph (D) should be removed. It is worth nothing this change would greatly aid Edgewood residents with a legitimate safety need.  Outdoor security light programmability. The draft code 18.40.250(f)(2)(A) requires outdoor lights to be “fully programmable.” It is entirely unclear from the code, common knowledge, or from consulting experts as to what “fully programmable” means with respect to an outdoor security light. This statement should be removed. Item 8 Attachment C - Public Comments received after the City Council hearing on April 7, 2025        Item 8: Staff Report Pg. 27  Packet Pg. 495 of 517  - 4 -  Outdoor kitchen lighting. The draft code 18.40.250(e)(3)(A) requires all outdoor lights to be 2,700K or less. Lighting professionals routinely recommend 3,000K for kitchens for safety. As with others, my brand new construction followed the lighting professionals’ recommendation and installed 3,000K luminaires in down lights at the outdoor kitchen (with all other outdoor lights of 2,700K). To promote safety, and in consideration that these are not decorative lights but instead task lights for preparing food, it would be reasonable to allow 3,000K luminaires in such down lights when they illuminate an outdoor kitchen.  Control light sensor. The draft code 18.40.250(e)(4)(C) requires lighting control systems to have a light sensor. As noted elsewhere, I recently built a new home. The residence includes a whole-house lighting control system from a well-known manufacturer. The professional lighting designers hired for the project all systematically recommended against a light sensor on the roof for the whole house system given their poor sensitivity and likelihood of failure. They instead all universally recommended time-based automation. In fact, the most common light sensor from the manufacturer used was discontinued years ago because they are so infrequently installed in today’s lighting control systems. The draft code already provides for time-based extinguishing of lights. Therefore, the only practical purpose of this provision is with regard to when lights are allowed to turn on. I therefore recommend adding a time-based alternative to a light sensor. Again, as a practical example, it will cost me approximately $25,000 to add a light sensor to the lighting control system (if I am unable to find the discontinued part, otherwise the cost will likely be over $1m to replace the entire lighting system), whereas it is a simple program change to set the lights to not come on until after a specific time of morning. As noted at the start, I strongly oppose the current ordinance requested by the City Council. I am even more concerned about the cumulative impact of these ordinances: lighting update, bird design standard, and stream protection. Taken together, they effectively condemn my new home as unlivable while incurring massive costs. The foregoing analysis offers several areas where this specific proposed lighting code update could be made substantially less burdensome without materially impacting the stated objectives. Sincerely, Tom Fountain Item 8 Attachment C - Public Comments received after the City Council hearing on April 7, 2025        Item 8: Staff Report Pg. 28  Packet Pg. 496 of 517  1441 Edgewood Dr Palo Alto, CA 94301 May 4, 2025 Kelly Cha Senior Planner Planning and Development Services 250 Hamilton Avenue, Fifth Floor Palo Alto, CA 94301 RE: Outdoor Lighting Update (“Dark Sky”) Dear Ms. Cha: I am writing as a follow-up to my letter of April 26, 2025 regarding the City of Palo Alto’s (the “City”) proposed lighting update. As shared previously, I strongly oppose the proposed ordinance and was deeply disturbed by the direction of the City Council on April 7, 2025. I spent my weekend attempting to apply the proposed ordinance to each of the outdoor luminaires and lamps on my property. As Staff prepares a new draft ordinance responsive to the City Council’s motion, I ask Staff to consider the following recommendations in addition to those shared previously:  Measuring light output and promoting hex filters. The draft ordinance currently expresses lamp output limits in lumen. As noted in my prior letter, once extended to existing lamps, it is vital to instead measure the foot-candles (or lux) at the property border or express these limits as the maximum measured output in foot-candles at a specific distance. I also noted previously the importance of allowing field measurements to encourage dimming. This would significantly reduce the cost to property owners since existing lamping is often dimmable. With or without either of these improvements to the draft code, please also consider allowing lighting designers to account for hexagonal cell louver filters (sometimes called “honeycomb” filters). Such filters significantly reduce glare and typically reduced effective light output by 20- 25% even though, by definition, the lamp’s lumen output is unchanged. Limiting output to a measured foot-candle value would account for filters without further change. If limits remain only in the lamp’s manufacturer-specified lumen, consider instead limiting output to the product of the lamp’s lumen times the effective light output if filtered. Alternatively, the lumen could be expressed both with and without a filter. For example, the low-voltage lighting might be limited to 150 lumen without a filter and 200 lumen when a hexagonal cell louver filter is installed. As a result, some property owners could install filters in existing luminaires and lamps rather than having to replace the entire luminaire and/or lamp. Taking hex filters into account would reduce the cost to comply with this proposed ordinance while simultaneously reducing glare and better achieving the stated objectives of the ordinance.  Clarify low-voltage shield exception in 18.40.250(e)(1)(B)(i). The draft ordinance section 18.40.250(e)(1)(B)(i) is intended to provide an exception for unshielded low-voltage lighting. The current draft states this exception applies only to “low voltage landscape uplighting” (underlined for emphasis). Limiting this exception to only “uplighting” is confusing and Item 8 Attachment C - Public Comments received after the City Council hearing on April 7, 2025        Item 8: Staff Report Pg. 29  Packet Pg. 497 of 517  - 2 - unnecessary. Presumably “uplighting” means anything that is not “Fully Shielded” but that is ambiguous from the context. Moreover, lighting designers should be encouraged, not discouraged, from using low voltage downlights even if they fail to fully satisfy the “Fully Shielded” definition. Consider as an example the FX Luminaire LED Wall Light (h ps://www.fxl.com/product/wall-and-step-lights/designer/mo). Only one faceplate, the one identified as WW, qualifies as “Fully Shielded,” none would be easily identifiable as “uplighting,” yet all should be in the scope intended by the low-voltage shield exception. Striking the word “uplighting” resolves this drafting issue.  Correct fully shielded security lighting in 18.40.250(f)(2)(B). The draft ordinance 18.40.250(f)(2) is intended to allow outdoor security lighting that meets certain standards. Section 18.40.250(f)(2)(B) establishes a height standard. The statement also requires that luminaire be “fully shielded”. Based on the definition of “Fully Shielded” provided in this draft ordinance, effectively no security light could comply. Compliance would require the light be installed such that lamps point straight down. Any projection “forward” of the luminaire would result in the lamp breaking the required plane extending from the bottom of said lamp. The requirement that these lights be “fully shielded” should be removed from this ordinance. If the intent of this phrase is to encourage security lights be aimed in a downward direction, then it should say so rather than reference “fully shielded” which has a specific definition.  Address security perimeter lighting in 18.40.250(f)(2)(C). City Council directed Staff to replace all references to 0.5 foot-candle of spillover with 0.1 foot-candle of spillover. This change, even if applied elsewhere, should not be applied to this section. A limitation of 0.1 foot- candle effectively eliminates the use of security lighting near a fence. Even if aimed down, reflected light off other surfaces will exceed this threshold. It is untenable to have security lighting so limited where it is needed to illuminate an area near a fence.  Correct typo shielding exception in 18.40.250(e)(1)(iii). Section 18.40.250(e)(1)(iii) provides an exemption for string lights and erroneously refers to 18.40.250(f)(5). It should instead refer to 18.40.250(f)(6). Thank you for your continued work to craft an ordinance that does not create such negative impact to city residents. Sincerely, Tom Fountain Item 8 Attachment C - Public Comments received after the City Council hearing on April 7, 2025        Item 8: Staff Report Pg. 30  Packet Pg. 498 of 517  City Council Staff Report From: City Manager Report Type: INFORMATION REPORTS Lead Department: City Manager Meeting Date: November 10, 2025 Report #:2509-5175 TITLE Independent Police Auditor's (IPA) Report of Review of Investigations Between December 2024 and May 2025 and Police Department Use of Force Report for the Same Period BACKGROUND AND ANALYSIS Since 2006, Palo Alto has utilized an Independent Police Auditor (IPA) to conduct secondary review of certain investigations of uniformed Police Department personnel and provide related services. Since the inception of the independent police auditing program, the City has contracted with the Office of Independent Review (OIR Group), to provide these services. The following report transmits the Independent Police Auditor (IPA) Report on Investigations Completed as of May 31, 2025. For reference, the prior IPA report was published April 21, 2025 as an Informational Item1. The Police Department’s website lists all past Independent Police Auditor Reports, here2. Attachment A contains the current IPA report for investigations completed as of May 2025. Per Council direction, the Police Department also shares use of force information through a report provided alongside each IPA report, included here as Attachment B and covers the time period of December – May 2025. The Police Department’s responses to the IPA report recommendations are included here as Attachment C. Consistent with standing practice, this report is issued as informational for the Council and the public. In light of heavy Council agendas through the end of the year and the straightforward contents of this report, staff has not scheduled a study session with OIR Group at this time. Should Council members wish to schedule a study session in early 2026, please advise the City Manager. 1 Independent Police Auditor's (IPA) Report of Review of Investigations as of November 2024 and Police Department Use of Force Report for July - November 2024 https://cityofpaloalto.primegov.com/portal/item/?meetingItemId=85a7fb9e-a7ed-45eb-a6ae-2b02ade31e02 2 Palo Alto Police Department Accountability Webpage: https://www.cityofpaloalto.org/Departments/Police/Accountability Independent Police Auditor Reports Webpage: https://www.cityofpaloalto.org/Departments/Police/Accountability/Independent-Police-Auditor Item A Item A Staff Report        Item A: Staff Report Pg. 1  Packet Pg. 499 of 517  Process to File a Complaint to the IPA The public can find more information about filing a complaint through the link here: www.cityofpaloalto.org/Departments/Police/Accountability/Employee-Complaint Complaints may also be directed to the Independent Police Auditor as follows: Contact: Mike Gennaco Phone: (323) 821-0586 Email: Michael.gennaco@oirgroup.com Or mail to: OIR Group 1443 E. Washington Blvd., #234 Pasadena, CA 91104 FISCAL/RESOURCE IMPACT The OIR Group is already contracted with the City and this report did not incur any additional expenses. ENVIRONMENTAL REVIEW The City’s Independent Police Auditor activities are not a project under section 15378(b)(25) of the California Environmental Quality Act Guidelines (administrative activities that will not result in direct or indirect physical changes in the environment). ATTACHMENTS Attachment A: Independent Police Auditor's Report - Review of Investigations as of May 2025 Attachment B: Police Department Use of Force Report for December 2024 – May 31, 2025 Attachment C: Police Department Responses to IPA Report, October 2025 APPROVED BY: Ed Shikada, City Manager Item A Item A Staff Report        Item A: Staff Report Pg. 2  Packet Pg. 500 of 517  1 INDEPENDENT POLICE AUDITORS’ REPORT Review of Investigations Completed as of 5-31-25 Presented to the Honorable City Council City of Palo Alto 2025 Prepared by: Michael Gennaco and Stephen Connolly Independent Police Auditors for the City of Palo Alto Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 3  Packet Pg. 501 of 517  2 Introduction This Report is one of the shortest in our tenure as the oversight entity of the Palo Alto Police Department (PAPD). On a twice-yearly basis, our responsibility is to review and write about cases completed by PAPD management across specifically delineated categories. That "workload" is accordingly driven by timing and by PAPD activity, both in the field and in the agency's own review processes. This installment covers the first six months of 2025. It includes discussion of one misconduct allegation (initiated by the Department itself to address potential violations of its vehicle pursuit policy), one use of force (in which a less-lethal weapon was used to facilitate the detention of a suicidal woman with a knife), and three incidents involving "pointed firearms" (all of which were found to be justified and consistent with training). We found ourselves in basis alignment with the Department's resolution of each of these matters. As in the past, we also offer related recommendations that are meant to enhance future operational effectiveness. Variations in the number and complexity of cases during a specific period are familiar to us from our years in Palo Alto (as well as our work in other jurisdictions). Though this is one of the smaller groupings, the limited number of public complaints of misconduct (here zero) and criteria-matching force incidents is in fact consistent with PAPD's recent history. And the tracking of pointed firearm events continues to become sharper as the process evolves with time. Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 4  Packet Pg. 502 of 517  3 Internal Complaint Investigation Case 1: Factual Overview PAPD received a report of a strong-arm robbery of a postal carrier that resulted in the taking of her cell phone. Several officers responded to a nearby city in response to tracking indications as to the phone's location. While in that city, the subject officer engaged in a pursuit of a vehicle that appeared to be fleeing from an officer affiliated with the neighboring jurisdiction. That pursuit ended without apprehension of the suspect. But when the subject officer observed the same car upon returning to Palo Alto; it fled again and left behind a passenger whom the officer detained. The subject officer then attempted to join the subsequent pursuit when the driver sped away. Eventually, the subject was successfully detained by other PAPD units. PAPD Investigation When reviewing the pursuit documentation, PAPD became concerned that the subject officer may have violated the Department’s vehicle pursuit policy. Accordingly, PAPD management self-initiated an investigation into those concerns. PAPD's subsequent assessment of the incident was thorough, and included an evaluation of vehicle speeds, body-worn and in-car video cameras, police reports, and statements from the subject officer. The investigation revealed that during the second pursuit, the subject officer drove left of the concrete median with oncoming vehicles present on several occasions, drove through intersections against the light, and reached speeds of 91 miles per hour in a 45 miles per hour zone. PAPD determined that the officer committed four sustained violations of the Department’s vehicle pursuit policy: Initial Pursuit 1. Failure to notify the supervisor of the pursuit or its justification. 2. Failure to broadcast any information advising that he was in pursuit. Second Pursuit 3. Joining the pursuit without supervisor authorization. Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 5  Packet Pg. 503 of 517  4 4. Driving without regard for public safety. IPA Review IPA reviewed all of the investigative materials developed during PAPD’s investigation and concurred with the findings of PAPD. The investigation and subsequent analysis were rigorous. Vehicle pursuits are among the most dangerous of law enforcement activities, creating a risk not only to participating officers and the subjects being pursued but also to uninvolved motorists and pedestrians. As a result, police agencies have established detailed policies that are intended to balance those risks against the interest in apprehending those that flee. The evidence was clear in this case that the subject officer did not consider the limitations and requirements set out in policy when engaged in either pursuit. To PAPD’s credit, it also recognized the misconduct and appropriately found the officer in violation of Departmental expectations as set out by policy. Use of Force Cases Case 1: Use of Less Lethal Munition on Suicidal Person Factual Overview PAPD was called to a location in which others had observed a female with a knife apparently trying to hurt herself by using the knife on her lower arms and wrists. Officers arrived on scene and one officer took the role of crisis negotiator. The negotiating officer attempted to get her to drop the knife as other members of the response team were assigned roles of less lethal and lethal cover. After several minutes of unsuccessful negotiation, the female began walking in the direction of the PAPD response team, still holding the knife. Responding PAPD personnel’s tactical deployment options were limited because the woman was on a narrow pathway. At that time, the negotiating officer yelled at the female to drop the knife and the less lethal operator yelled “Sage.”1 The less lethal operator then delivered one round that struck the female in the abdomen and caused her to go to the ground. The response team then advanced on the female and was able to successfully dislodge the knife from her and take her into custody. She was handcuffed and admitted to the 1 The term “Sage” refers to the model of less lethal munition that was deployed; it fires a heavy rubber projectile. Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 6  Packet Pg. 504 of 517  5 hospital for treatment of her self-inflicted wounds as well as the abdominal bruise caused by the less lethal munition. At the hospital, the female said that her intent had been to end her life, and that she had hoped that the on-scene officers would kill her. Supervisory Review of Force PAPD’s robust supervisory review found that the use of the less lethal munition was consistent with the Department’s use of force policy. It noted that when the female began to advance on the officers still holding the knife, she presented a threat that justified the use of force. To the Department’s credit, the secondary reviewer agreed with the assessment that a supervisor and officer who were on scene when the force occurred should have submitted supplemental reports to document their actions and observations of the incident. More significantly and creditably, PAPD’s leadership crafted an intervention whereby the two who did not write a supplemental report receive training on Department expectations of documentation when a serious force incident occurs. IPA Review IPA reviewed the police report, body worn camera footage, and the supervisory review and concurred that the use of force was consistent with PAPD’s use of force policy. IPA also observed the multiple requests of the negotiator to drop the knife and to engage with the female. Once the female began to walk toward the arrest team, those commands became more forceful and the less lethal operator yelled “I’m going to Sage you.”2 Yet none of the commands directed at the female instructed her to stop her forward movement which was the concerning act that provoked the deployment of the less lethal munition. Ideally, instead of repeating the previously ignored instructions of “drop the knife” and yelling “Sage” (which was mostly for the benefit of the arrest team advising of imminent deployment), it would have been helpful for the command of “stop” to also have been directed to the woman.3 2 PAPD policy states that a “verbal warning of the intended use of the device should precede its application, unless it would otherwise endanger the safety of officers or is not practicable due to the circumstances.” 3 PAPD’s internal review concluded that there was technical compliance with the warning policy but noted that no member of the public would be reasonably expected to know what “I’m going to Sage you” means. It noted that subjects should have a chance to understand what a verbal warning is intending to convey, so that they can make a more informed decision if they want to comply with the commands of officers. To PAPD’s credit, the secondary reviewer directed that alternative warning options be developed and then presented to all sworn personnel at a future “Sage” training session. The reviewer noted that if officers were provided in advance with various Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 7  Packet Pg. 505 of 517  6 Moreover, the supervisory review found that two of the body-worn cameras assigned to supervisors did not function during the negotiations and use of force deployment. Fortunately, other officers on scene did capture the incident. But it should be concerning that the two cameras assigned to supervisors did not properly function during the incident. To its credit, PAPD’s internal review agreed and the second level supervisor crafted further instructions to supervisors on ways to ensure that the body worn cameras are timely examined in cases where footage is not captured.4 RECOMMENDATION One: PAPD should evaluate the warnings in any use of force incident to determine whether different warnings might have been effective. RECOMMENDATION Two: PAPD should continue to emphasize to supervisors the need to timely review body-worn cameras when they do not operate as intended to ensure that the operators had undertaken proper testing and maintenance protocols. "Pointed Firearm" Incidents In keeping with a new protocol that is now in its third year, PAPD provided us with review packages for the completed managerial assessments of encounters that involved the pointing of a gun by one or more officers. There were three separate events within this audit period. Below is a summary of the context for the deployments, along with the Department's supervisory assessment of each. 1. Officers conducted a high-risk traffic stop of a male who had violated a restraining order, and whom they knew to have a criminal history. The man eventually stopped but remained barricaded inside the vehicle and refused to surrender. A standoff ensued and options to consider for verbal warnings, they may be more likely to give a warning that more understandably conveys to the subject what may be about to happen. The reviewer concluded that this, in turn, may increase the opportunity for subjects to comply with commands, and for officers to avoid having to use force. PAPD’s secondary reviewer should be commended for identifying the issue and developing a remedial plan designed to improve officer performance. 4 For example, personnel are instructed to “test” their body worn cameras at the beginning of any shift to ensure that they are functioning properly and properly charged. Supervisors reviewing any defective body worn camera deployment were instructed to timely check to see if the operator had undertaken such a test; the ability to do so expires within 60 days of the incident. Moreover, we have been advised that PAPD is in the process of switching out its body-worn camera inventory due to the camera’s age and similar concerns with the performance of the cameras in recent months. Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 8  Packet Pg. 506 of 517  7 lasted for nearly two hours before one of the officers successfully achieved the man's peaceful surrender. During the incident, two different officers who were providing lethal cover pointed their respective weapons at separate points in the process. The (second officer took over for the first, to allow that person to engage in negotiations with the subject.) No issues were identified in the supervisory review; on the contrary, the reviewer found the officers' actions to be effectively controlled, and the actual weapon pointing was quite limited.5 2. Three PAPD officers responded to a call involving a possible commercial burglary in progress. Two subjects were eventually detained in the shrubbery surrounding the property. One surrendered without incident; the other, in a different location, tried to conceal himself. Two officers both pointed their firearms at the man while one gave commands. Then one re-holstered before moving in to handcuff the subject while the other provided cover. The officers' actions were found to be consistent with training and expectations in terms of their weapon use. However, one of the three involved officers (including one of the weapon-pointers) was not wearing a body-worn camera).6 This issue was determined to be an inadvertent mistake related to the spontaneous need for response; it was addressed by the reviewing supervisor. 3. An officer located a vehicle that had been flagged by an alert system in connection with a recent home invasion robbery; after calling for backup and initiating a traffic stop, the officer was notified that the occupants were potentially armed and dangerous. Accordingly, the officer exited the patrol car and pointed a firearm at the driver, who had pulled over without incident. The officer kept the weapon pointed until the arrival of a partner made it safe to approach; the officer was able to determine that the driver was cooperative and not holding a weapon, and accordingly re-holstered. The arrest proceeded without further incident. The supervisor memo pointed out that the officer did not activate a body-worn camera until approximately the one-minute mark of the traffic stop. The officer's explanation revolved around the need to sync a new camera after a battery had died earlier in the 5 We noted that the officers were notably solicitous of the man after securing his cooperation, even offering him water after he had been handcuffed. This was in keeping with the professional demeanor – and language – that we noted in each of these incidents. 6 That officer's relevant actions were at least captured by another officer's recording. Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 9  Packet Pg. 507 of 517  8 shift; the officer initially neglected to remove the camera from the in-car docking station but then remembered and put it on. This issue was addressed and memorialized. IPA Review We agreed with the determination that the officers' respective actions were valid in the context of the different enforcement actions involved. We also found that the review process was effectively robust. Supervisors did a meticulous assessment of camera recordings to identify key passages (which sometimes involved matching a different officer's camera to the actions of a pointing officer). And, interestingly, in at least one case the officers appeared to "err on the side of caution" by acknowledging their weapon points when video evidence was inconclusive as to their direction of aim while providing cover. Expectations about rigorous documentation and thoughtful review seem to be becoming second nature in the agency, which is encouraging to see. Meanwhile, we note a less favorable issue that has come to our attention before. In two of the three cases, at least one of the officers did not have a complete video record of his or her actions. Though the lapses were not overly detrimental in establishing what occurred (primarily due to the presence of other officers), and while both officers had understandable and mitigating explanations for the respective occurrences, we again urge PAPD to continue its emphasis on compliance with camera policy and expectations. Item A Attachment A - PA IPA Report - Review of Investigations as of May 2025        Item A: Staff Report Pg. 10  Packet Pg. 508 of 517  1 | P a g e DATE: OCTOBER 1, 2025 TO: HONORABLE CITY COUNCIL FROM: POLICE CHIEF ANDREW BINDER SUBJECT: USE OF FORCE SUPPLEMENT TO IPA REPORT This memorandum responds to the City Council’s November 2020 direction to provide use of force summary data (which encompasses all use of force incidents in which a “Supervisor’s Report on Use of Force” has been completed by the Police Department) as an attachment to each Independent Police Auditor (IPA) report. Policy Manual §300 (“Use of Force”) requires that all uses of force by Police Department members “be documented promptly, completely, and accurately in an appropriate report.1” The policy also requires that, under certain circumstances, a “Supervisor’s Report on Use of Force” also be completed by the supervisor, and routed for approval through the chain of command up to and including the Police Chief. Most commonly, a “Supervisor’s Report on Use of Force” is completed after an officer uses some form of force that results in a visible or apparent physical injury to a subject or the subject complains of pain or alleges they were injured. Consistent with the IPA’s expanded scope of administrative review established by the City Council in November 2020, the Department forwards the following types of use of force cases to the IPA for review and recommendations: all cases where a subject’s injuries necessitate any treatment beyond minor medical treatment in the field, and all cases where an officer uses a baton, chemical agent, TASER, less lethal projectile, canine, or firearm. The IPA’s scope of administrative review was further-expanded in July 2021 to include cases when a firearm is pointed at a subject. Consistent with the practice established in the May 2023 iteration of this memorandum, the Department is choosing to release the race of the recipient(s) of any force used. This summary covers the period of December 1, 2024 thru May 31, 2025. Use of Force Cases From December 1, 2024 thru May 31, 2025, the Police Department responded to more than 21,000 calls for service and effected more than 600 arrests. During that time, there were 7 cases where force requiring a “Supervisor’s Report on Use of Force” was used, and 2 of which fell within the IPA’s scope of administrative review. The IPA’s review of those 2 cases will appear in a future IPA report. 1 The Palo Alto Police Department Policy Manual is updated quarterly and posted online at https://www.cityofpaloalto.org/Departments/Police/Public-Information-Portal/Police-Policy-Manual. Item A Attachment B - PD Use of Force Report for December 2024 - May 31, 2025        Item A: Staff Report Pg. 11  Packet Pg. 509 of 517  2 | P a g e The current IPA report includes a review of 1 use of force incident, which occurred prior to December 1, 2024. In their review of this incident, the IPA concurred with the Department’s finding that the force used was justified by the circumstances and consistent with policy. The race of the subject upon whom force was used was White. December 2024 thru May 2025 Use of Force Summary Type of Force Number of Cases Status of IPA Review Physical Strength 7 2 cases pending review; 5 outside of scope Chemical Agent 0 TASER 0 Baton 0 Less-Lethal Projectile 0 Canine 0 Firearm 0 Firearm Pointed at Person Cases From December 1, 2024 thru May 31, 2025, officers pointed a firearm at a person on 9 occasions. Three of these cases appear in the current IPA report; the remaining 6 will appear in a future IPA report. The current IPA report includes a review of 3 total incidents during which officers pointed a firearm at a person, each of which occurred between December 1, 2024 and May 31, 2025. In their review of these 3 incidents, the IPA concurred in each case with the Department’s finding that the pointing of the firearm was justified by the circumstances and consistent with policy. In the 3 incidents described in the current IPA report, the race of the subjects at whom a firearm was pointed was Hispanic (2), and Other (1). Item A Attachment B - PD Use of Force Report for December 2024 - May 31, 2025        Item A: Staff Report Pg. 12  Packet Pg. 510 of 517  1 | P a g e DATE: OCTOBER 1, 2025 TO: HONORABLE CITY COUNCIL FROM: POLICE CHIEF ANDREW BINDER SUBJECT: RESPONSE TO IPA RECOMMENDATIONS IN REPORT COVERING INVESTIGATIONS AS OF MAY 31, 2025 RECOMMENDATION #1: PAPD should evaluate the warnings in any use of force incident to determine whether different warnings might have been effective. The Department agrees and, consistent with existing policy, will continue to evaluate the effectiveness of warnings in use of force incidents. RECOMMENDATION #2: PAPD should continue to emphasize to supervisors the need to timely review body-worn cameras when they do not operate as intended to ensure that the operators had undertaken proper testing and maintenance protocols. The Department agrees and, as part of its continued emphasis on this issue, the Department has implemented guidelines designed to expedite supervisor review of incident footage. Item A Attachment C - PD Responses to IPA Report, October 2025        Item A: Staff Report Pg. 13  Packet Pg. 511 of 517  City Council Staff Report From: City Manager Report Type: CONSENT CALENDAR Lead Department: Utilities Meeting Date: November 10, 2025 Report #:2511-5402 TITLE Adopt a Resolution Deferring CPAU Late Fees and Collection Actions for Certain Customers Affected by the Ongoing Federal Government Shutdown; CEQA Status – Not a Project. RECOMMENDATION Staff recommends Council adopt a Resolution that temporarily defers late fees and other collection actions for certain residential customers (Rate Assistance Program (RAP) participants and federal employees) who are anticipated to be in financial hardship due to the federal government shutdown. EXECUTIVE SUMMARY The current federal government shutdown has disrupted the income and benefits of many federal employees and low-income households nationwide. While exact figures of affected residents in Palo Alto are unavailable, we recognize the potential impact on our community and have proactively identified flexible utility billing measures such as partial payment or postponement of utility bill payments, term repayment arrangements, suspension of late fees, and expedited access to CPAU financial assistance programs that will support our affected RAP residential customers and federal employees during the current shutdown. BACKGROUND As of this writing, the federal government financial closure is now the longest continuous federal government lockdown in history. Federal government employees who have been furloughed or dismissed, essential workers who are legally required to work without paychecks, and rate assistance customers who may be impacted due to suspension of other federal benefits programs are facing the financial impacts beyond their control. ANALYSIS In order to help customers who are having difficulty paying their utility bills, CPAU currently administers bill repayment scheduling, as well as residential financial assistance on a routine basis through the RAP and ProjectPLEDGE, a community-funded utility bill grant program. Item AA1 Item AA1 Staff Report        Item AA1: Staff Report Pg. 1  Packet Pg. 512 of 517  However, due to the unique nature of the federal shutdown, staff believes that it would be helpful to create a special program that temporarily defers late charges and collection actions for customers who are likely to be impacted by the shutdown. with respect to utility charges incurred during the shutdown: FISCAL/RESOURCE IMPACT Item AA1 Item AA1 Staff Report        Item AA1: Staff Report Pg. 2  Packet Pg. 513 of 517  STAKEHOLDER ENGAGEMENT ENVIRONMENTAL REVIEW ATTACHMENT: APPROVED BY: Item AA1 Item AA1 Staff Report        Item AA1: Staff Report Pg. 3  Packet Pg. 514 of 517  ATTACHMENT A NOT YET APPROVED 1 027110625 Resolution No. Resolution of the Council of the City of Palo Alto Deferring CPAU Late Fees and Collection Actions for Certain Customers Affected by the Ongoing Federal Government Shutdown R E C I T A L S A. Since October 1, 2025 the Federal Government has been operating without funding appropriations. B. Until appropriations are approved and go into effect, the Federal Government is “shutdown.” C. During the shutdown many payments normally made by the Federal Government have been suspended; these suspended payments include wage payments to federal employees and payments to states that support certain food assistance and other programs. D. It is not clear at this time how long the shutdown will persist. E. Many Palo Alto residents are federal employees or are recipients of assistance that has been disrupted by the shutdown. F. The City’s utility and public work enterprises provide vital services, including electricity, natural gas, water, sewer, stormwater, and refuse services, to the households of these residents. G. As a result of the shutdown-related disruption to household cashflow, many of these households are anticipated to encounter temporary difficulty in paying their bills. H. It is vital to the public health and safety that the City not disrupt public services to those most affected by the shutdown. I. Pursuant to Chapter 12.20.010 of the Palo Alto Municipal Code, the Council of the City of Palo Alto may by resolution adopt rules and regulations governing utility services, fees and charges. J. The City Council desires to defer certain consequences of non-payment of utility bills for residential customers that are most directly affected by the shutdown. The Council of the City of Palo Alto RESOLVES as follows: SECTION 1. During the Shutdown Period and the Recovery Period as it pertains to charges incurred during the Shutdown Period, the City will not, in connection with an Enrolled Account: (i) apply late charges, (ii) take collection actions such as referring an account to a Item AA1 Attachment A - Resolution        Item AA1: Staff Report Pg. 4  Packet Pg. 515 of 517  ATTACHMENT A NOT YET APPROVED 2 027110625 collection agency or bringing civil action, (iii) initiate termination or disconnection of services, (iv) lower the internal credit risk assessment for the accountholder or account, or (v) report non-payment to any external credit reporting agency. SECTION 2. For any accountholder of an Enrolled Account, the Administrator may create a payment plan for the Enrolled Account that requires that the balance unpaid at the end of the Shutdown Period be paid in installments during the Recovery Period. SECTION 3. The Administrator is authorized to promulgate procedures and rules for the administration of this Resolution consistent with the provisions of this Resolution. The Administrator may require that any request made by an accountholder pursuant to this Resolution be made in a manner or in a format required by the Administrator. SECTION 4. For purposes of this Resolution, the following terms have the following meanings: A. “Administrator” means: The Utilities Director or his designee. B. “Enrolled Account” means: Any residential CPAU Account (other than a multifamily account that covers more than one dwelling unit) that either (i) is enrolled in the CPAU Rate Assistance Program or (ii) serves a Federal Employee Dwelling Unit, where the accountholder applies to the City for such treatment, and establishes that a dwelling unit served in connection with the account is a Federal Employee Dwelling Unit, in a manner to be designated by the Administrator. C. “Federal Employee Dwelling Unit” means: A residential dwelling unit at least one of the occupants of which was employed by the United States Government on October 1, 2025. D. “Shutdown Period” means: The period beginning on October 1, 2025 and ending on the day that an appropriations bill funding the federal government becomes law. E. “Recovery Period” means: A 365-day period that begins on the day following the end of the Shutdown Period. // // // Item AA1 Attachment A - Resolution        Item AA1: Staff Report Pg. 5  Packet Pg. 516 of 517  ATTACHMENT A NOT YET APPROVED 3 027110625 SECTION 5. The Council’s adoption of this Resolution and the actions taken herein do not require review under the California Environmental Quality Act because they do not meet the definition of “project” set forth in Public Resources Code Section 21065 nor the CEQA Guidelines, 14 CCR section 15378(b)(5). INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk Mayor APPROVED AS TO FORM: APPROVED: Assistant City Attorney City Manager Director of Utilities Director of Administrative Services Item AA1 Attachment A - Resolution        Item AA1: Staff Report Pg. 6  Packet Pg. 517 of 517