HomeMy WebLinkAboutRESO 102581
Resolution No. 10258
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
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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.
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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
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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
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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
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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
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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-
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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.
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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
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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
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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
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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:
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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.
Docusign Envelope ID: AFD71E67-30F0-4081-B701-BB492C63178A
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
Docusign Envelope ID: AFD71E67-30F0-4081-B701-BB492C63178A
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.
Docusign Envelope ID: AFD71E67-30F0-4081-B701-BB492C63178A
16
APPROVED:
_____________________________
Mayor
APPROVED:
_____________________________
PASSED: NOVEMBER 10, 2025
AYES:
NOES:
ABSENT:
ABSTENTIONS:
ATTEST:
__________________________
City Clerk
APPROVED AS TO FORM:
__________________________
Assistant City Attorney City Manager
_____________________________
Director of Public Works
_____________________________
Director of Planning and
Development Services
BURT, LAUING, LYTHCOTT-HAIMS, RECKDAHL
LU
STONE, VEENKER
Docusign Envelope ID: AFD71E67-30F0-4081-B701-BB492C63178A
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.
Docusign Envelope ID: AFD71E67-30F0-4081-B701-BB492C63178A
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
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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
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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
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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.
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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
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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
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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
Docusign Envelope ID: AFD71E67-30F0-4081-B701-BB492C63178A
Certificate Of Completion
Envelope Id: AFD71E67-30F0-4081-B701-BB492C63178A Status: Completed
Subject: RESO 10258 - Certify 660 University Ave Final EIR, Adopt Mitigation Monitoring and Reporting Program
Source Envelope:
Document Pages: 24 Signatures: 6 Envelope Originator:
Certificate Pages: 2 Initials: 0 Christine Prior
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC-08:00) Pacific Time (US & Canada)
250 Hamilton Ave
Palo Alto , CA 94301
Christine.Prior@PaloAlto.gov
IP Address: 165.225.242.121
Record Tracking
Status: Original
11/12/2025 5:45:43 PM
Holder: Christine Prior
Christine.Prior@PaloAlto.gov
Location: DocuSign
Security Appliance Status: Connected Pool: StateLocal
Storage Appliance Status: Connected Pool: City of Palo Alto Location: Docusign
Signer Events Signature Timestamp
Albert Yang
Albert.Yang@paloalto.gov
Assistant City Attorney
City of Palo Alto
Security Level: Email, Account Authentication
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Signature Adoption: Pre-selected Style
Using IP Address: 136.226.56.82
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Jonathan Lait
Jonathan.Lait@paloalto.gov
Director, Planning and Development Services
City of Palo Alto
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Brad Eggleston
Brad.Eggleston@paloalto.gov
Director of Public Works
City of Palo Alto
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Ed Shikada
Ed.Shikada@paloalto.gov
Ed Shikada
City of Palo Alto
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Ed Lauing
Ed.Lauing@paloalto.gov
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Mahealani Ah Yun
Mahealani.AhYun@paloalto.gov
City Clerk
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